FERC EIS-0205 Kinder Morgan Louisiana Pipeline Project Draft Environmental Impact Statement

Docket No.

CP06-449-000

January 2007
FEDERAL ENERGY REGULATORY COMMISSION

WASHINGTON, D.C. 20426

OFFICE OF ENERGY PROJECTS 

 In Reply Refer To: 

 OEP/DG2E/Gas Branch 2 

 Kinder Morgan Louisiana Pipeline LLC 

 Docket No. CP06-449-000 

 

TO THE PARTY ADDRESSED: 

The staff of the Federal Energy Regulatory Commission (FERC or Commission) 

has prepared a draft Environmental Impact Statement (EIS) on the natural gas pipeline 

facilities proposed by Kinder Morgan Louisiana Pipeline LLC (KMLP) in the abovereferenced docket. 

The draft EIS was prepared to satisfy the requirements of the National 

Environmental Policy Act. The staff concludes that approval of the proposed project 

with the appropriate mitigating measures as recommended, would have limited adverse 

environmental impact. The draft EIS also evaluates alternatives to the proposal, 

including system alternatives, major route alternatives, and route variations, and requests 

comments on them. 

The draft EIS addresses the potential environmental effects of the construction and 

operation of the following facilities in southwest Louisiana: 

• Leg 1 – 132 miles of 42-inch-diameter pipeline beginning within the Sabine 

Pass Liquefied Natural Gas (LNG) Terminal in Cameron Parish and extending 

northward and easterly through Calcasieu, Jefferson Davis, and Acadia 

Parishes until it connects with an existing Columbia Gulf Transmission 

interstate pipeline in Evangeline Parish, Louisiana. 

• Leg 2 – 1.22 miles of 36-inch-diameter pipeline beginning within the Sabine 

Pass LNG Terminal and extending to a point of interconnection with the 

existing Natural Gas Pipeline Company of America pipeline just south of State 

Highway 82 in Cameron Parish, Louisiana. 

• The Florida Gas Transmission (FGT) Lateral – 2.3 miles of 24-inch-diameter 

pipeline extending eastwardly from Leg 1 at approximately milepost 110.60 
Docket No. CP06-449-000 - 2 -

until it connects with the existing FGT Company's Compressor Station No. 7 

near the town of Williams in Acadia Parish, Louisiana. 

• Associated mainline block valves, metering, tie-in, and pigging facilities. 

The purpose of the proposed facilities is to deliver at least 3,395,000 decatherms 

(Dth) per day of regasified natural gas from the Sabine Pass LNG Terminal into the 

national pipeline and underground storage grid. 

Specific Comment Request

In addition to the proposed system and route, the staff has identified and evaluated 

in detail two system alternatives, four major route alternatives, and 15 route variations. 

The staff concludes that the proposed system and route are environmentally least 

damaging, and therefore prefers the proposed system and route. Any route variation 

considered to be an environmental improvement has been incorporated into the proposed 

route. Area residents, local or state governments, intervenors, and other interested parties 

are asked to provide specific comments on our analysis of alternatives. Comments 

should also address any effect on project timing and related cost/benefits. 

Comment Procedures and Public Meetings

Any person wishing to comment on the draft EIS may do so. To ensure 

consideration prior to a Commission decision on the proposal, it is important that we 

receive your comments before the date specified below. Please carefully follow these 

instructions to ensure that your comments are received in time and properly 

recorded:

• Send an original and two copies of your comments to: 

Magalie R. Salas, Secretary 

Federal Energy Regulatory Commission 

888 First Street, N.E., Room 1A 

Washington, DC 20426; 

• Label one copy of your comments for the attention of Gas Branch 2, DG2E; 

• Reference Docket No. CP06-449-000 on the original and both copies; and 

• Mail your comments so that they will be received in Washington, DC on or 

before March 12, 2007.
Docket No. CP06-449-000 - 3 -

Please note that we are continuing to experience delays in mail deliveries from the 

U.S. Postal Service. As a result, we will include all comments that we receive within a 

reasonable time frame in our environmental analysis of this project. However, the 

Commission strongly encourages electronic filing of any comments or interventions 

or protests to this proceeding. For information on electronically filing comments, 

please see Title 18 CFR 385.2001 (a)(1)(iii) and the instructions on the Commission’s 

web site at http://www.ferc.gov under the “Documents and Filings” tab. Under that tab 

you will find the “eFiling” link and the link to the User’s Guide. Before you can submit 

comments you will need to create a free account, which can be created on-line by 

clicking on “Sign-up” under “New User.” You will also be asked to select the type of 

filing you are making. This filing is considered a “Comment on Filing.” Comments 

submitted electronically must be submitted by March 12, 2007. 

We will announce in a future notice, the location and time of three local public 

meetings to receive comments on the draft EIS. These meetings will be posted on the 

Commission’s calendar located at http://www.ferc.gov/EventCalendar/EventsList.aspx

along with other related information. 

After these comments are reviewed, any significant new issues are investigated, 

and modifications are made to the draft EIS, a final EIS will be published and distributed 

by the staff. The final EIS will contain the staff's responses to timely comments filed on 

the draft EIS. 

Comments will be considered by the Commission but will not serve to make the 

commentor a party to the proceeding. Any person seeking to become a party to the 

proceeding must file a motion to intervene pursuant to Rule 214 of the Commission's 

Rules of Practice and Procedures (18 CFR 385.214). 

Anyone may intervene in this proceeding based on this draft EIS. You must file 

your request to intervene as specified above.1

 You do not need intervenor status to 

have your comments considered.

The draft EIS has been placed in the public files of the FERC and is available for 

distribution and public inspection at: 

 

1

Interventions may also be filed electronically via the Internet in lieu of paper. 

See the previous discussion on filing comments electronically. 
Docket No. CP06-449-000 - 4 -

Federal Energy Regulatory Commission 

Public Reference Room 

888 First Street, N.E., Room 2A 

Washington, DC 20426 

(202) 502-8371 

A limited number of copies are available from the Public Reference Room 

identified above. In addition, copies of the draft EIS have been mailed to federal, state 

and local agencies, public interest groups, individuals who have requested the draft EIS, 

newspapers, and parties to this proceeding. 

Additional information about the project is available from the Commission's 

Office of External Affairs, at 1-866-208-FERC (3372) or on the FERC Internet website 

(http://www.ferc.gov). Using the “Documents and Filings” tab, click on the “eLibrary 

link,” and select “General Search.” Enter the project docket number excluding the last 

three digits (i.e., CP06-449) in the “Docket Number” field. Be sure you have selected an 

appropriate date range. For assistance, please contact FERC Online Support at 

FERCOnlineSupport@ferc.gov or toll free at 1-866-208-3676, or for TTY, contact (202) 

502-8659. The eLibrary link on the FERC Internet website also provides access to the 

texts of formal documents issued by the Commission, such as orders, notices, and 

rulemakings. 

In addition, the Commission offers a free service called eSubscription which 

allows you to keep track of all formal issuances and submittals in specific dockets. This 

can reduce the amount of time you spend researching proceedings by automatically 

providing you with notification of these filings, document summaries, and direct links to 

the documents. To register for this service, go to http://www.ferc.gov/docsfiling/esubscription.asp. 

Magalie R. Salas 

 Secretary
TABLE OF CONTENTS 

Kinder Morgan Louisiana Pipeline Project 

Draft Environmental Impact Statement 

Page

TABLE OF CONTENTS .............................................................................................................. i 

LIST OF APPENDICES ............................................................................................................. vi 

LIST OF TABLES ...................................................................................................................... vii 

LIST OF FIGURES .................................................................................................................... ix 

LIST OF ACRONYMS AND TERMS ...................................................................................... xi 

EXECUTIVE SUMMARY .................................................................................................... ES-1 

INTRODUCTION ..................................................................................................................... ES-1

PROJECT BACKGROUND ..................................................................................................... ES-1

PROPOSED ACTION............................................................................................................... ES-1

PUBLIC OUTREACH AND COMMENTS ............................................................................. ES-2

ENVIRONMENTAL IMPACTS............................................................................................... ES-2

ALTERNATIVES CONSIDERED ........................................................................................... ES-4

CONCLUSIONS ....................................................................................................................... ES-4

1.0 INTRODUCTION.......................................................................................................... 1-1 

1.1 PROJECT PURPOSE AND NEED.................................................................................1-2

1.2 PURPOSE AND SCOPE OF THIS STATEMENT ........................................................1-2

1.3 PERMITS, APPROVALS, AND REGULATORY REQUIREMENTS.........................1-3

1.4 PUBLIC REVIEW AND COMMENT............................................................................1-6

1.5 NONJURISDICTIONAL FACILITIES ..........................................................................1-8

2.0 DESCRIPTION OF THE PROPOSED ACTION...................................................... 2-1 

2.1 PROPOSED FACILITIES...............................................................................................2-1 

2.1.1 Pipelines ............................................................................................................2-3 

2.1.2 Aboveground Facilities .....................................................................................2-5 

2.1.3 Ancillary Areas .................................................................................................2-6 

2.2 LAND REQUIREMENTS ..............................................................................................2-7 

2.2.1 Pipeline Rights-of-Way and Extra Workspaces................................................2-7 

2.2.2 Aboveground Facilities ...................................................................................2-10 

2.2.3 Ancillary Areas ...............................................................................................2-10 

2.3 CONSTRUCTION AND RESTORATION PROCEDURES .......................................2-10 

2.3.1 Pipelines ..........................................................................................................2-12 

2.3.1.1 Conventional Upland Construction Methods................................2-12 

2.3.1.2 Wetland Construction Techniques ................................................2-24 

2.3.1.3 Special Pipeline Construction Techniques....................................2-31 

2.3.2 Aboveground Facilities ...................................................................................2-43 

2.3.3 Ancillary Facilities..........................................................................................2-44 

2.4 OPERATION AND MAINTENANCE PROCEDURES..............................................2-44 

2.5 ENVIRONMENTAL COMPLIANCE, INSPECTION, AND MITIGATION 

MONITORING..............................................................................................................2-45 

2.6 SAFETY CONTROLS ..................................................................................................2-46 

2.7 FUTURE PLANS AND ABANDONMENT ................................................................2-47 

 i Table of Contents 
TABLE OF CONTENTS (cont’d) 

Page

 ii Table of Contents 

3.0 ALTERNATIVES.......................................................................................................... 3-1 

3.1 NO ACTION OR POSTPONED ACTION ALTERNATIVE ........................................3-1 

3.2 SYSTEM ALTERNATIVES...........................................................................................3-2 

3.2.1 Use of Existing Pipeline Systems......................................................................3-3 

3.2.2 Use of Proposed Pipeline Systems....................................................................3-3 

3.2.2.1 System Alternative #1 .....................................................................3-4 

3.2.2.2 System Alternative #2 .....................................................................3-7 

3.3 MAJOR ROUTE ALTERNATIVES...............................................................................3-8 

3.3.1 Southern Route Alternative #1........................................................................3-10 

3.3.2 Southern Route Alternative #2........................................................................3-10 

3.3.3 Northern Route Alternative.............................................................................3-12 

3.3.4 Center Route Alternative.................................................................................3-13 

3.4 Route Variations ............................................................................................................3-13 

3.4.1 Blue Buck Point Route Variation (Leg 1 MP 1.1 – MP 7.1) ..........................3-15 

3.4.2 Garrison’s Ridge Route Variation (Leg 1 MP 2.1 – MP 4.6) .........................3-16 

3.4.3 Vinton Drainage Canal Route Variation (Leg 1 MP 31.2 – MP 35.7)............3-16 

3.4.4 Bayou Choupique Route Variation (Leg 1 MP 40.1 – MP 45.2)....................3-17 

3.4.5 Calcasieu River Route Variation (Leg 1 MP 47.8 – MP 52.4) .......................3-18 

3.4.6 Tom Herbert Road Route Variations (Leg 1 MP 57.2 – MP 59.7) .................3-18 

3.4.7 Interstate Highway 10 (I-10) Route Variation (Leg 1 MP 74.9 – 

MP 78.4)..........................................................................................................3-19 

3.4.8 Freeland Road Route Variation (Leg 1 MP 88.6 – MP 89.1) .........................3-20 

3.4.9 Bayou Nezpique Route Variations (Leg 1 MP 95.3 – MP 100.5)...................3-20 

3.4.10 US Highway 190 Route Variation (Leg 1 MP 111.9 – MP 112.5) .................3-20 

3.4.11 South Forty Acre Subdivision Route Variation (Leg 1 MP 114.8 – 

MP 115.7)........................................................................................................3-21 

3.4.12 Old Schoolhouse Road Route Variation (Leg 1 MP 122.0 – MP 123.2) ........3-22 

3.4.13 Perron Road Route Variation (Leg 1 MP 127.6 – MP 129.8).........................3-23 

4.0 ENVIRONMENTAL ANALYSIS................................................................................ 4-1 

4.1 GEOLOGIC RESOURCES.............................................................................................4-1 

4.1.1 Affected Environment.......................................................................................4-1 

4.1.2 Impacts and Mitigation .....................................................................................4-5 

4.2 SOILS ..............................................................................................................................4-9 

4.2.1 Affected Environment.......................................................................................4-9 

4.2.2 Impacts and Mitigation .....................................................................................4-9 

4.2.2.1 Construction Impacts.......................................................................4-9 

4.2.2.2 Operation Impacts .........................................................................4-15 

4.3 WATER RESOURCES .................................................................................................4-16 

4.3.1 Groundwater....................................................................................................4-16 

4.3.1.1 Affected Environment ...................................................................4-16 

4.3.1.2 Impacts and Mitigation..................................................................4-17 

4.3.2 Surface Water..................................................................................................4-19 

4.3.2.1 Affected Environment ...................................................................4-19 

4.3.2.2 Impacts and Mitigation..................................................................4-24 
TABLE OF CONTENTS (cont’d) 

Page

 iii Table of Contents 

4.3.2.3 The Sabine Lake and Calcasieu River Crossings..........................4-26 

4.4 WETLANDS .................................................................................................................4-29 

4.4.1 Affected Environment.....................................................................................4-29 

4.4.2 Impacts and Mitigation ...................................................................................4-38 

4.5 VEGETATION..............................................................................................................4-42 

4.5.1 Affected Environment.....................................................................................4-42 

4.5.2 Impacts and Mitigation ...................................................................................4-43 

4.5.2.1 Primary Impact to Vegetative Cover Types..................................4-43 

4.5.2.2 Exotic/Invasive Plant Species .......................................................4-44 

4.6 WILDLIFE AND AQUATIC RESOURCES................................................................4-46 

4.6.1 Terrestrial Wildlife Resources ........................................................................4-46 

4.6.1.1 Affected Environment ...................................................................4-46 

4.6.1.2 Impacts and Mitigation..................................................................4-49 

4.6.2 Freshwater Aquatic Resources........................................................................4-51 

4.6.2.1 Affected Environment ...................................................................4-51 

4.6.2.2 Impacts and Mitigation..................................................................4-52 

4.6.3 Marine Fishery Resources...............................................................................4-55 

4.6.3.1 Affected Environment ...................................................................4-55 

4.6.3.2 Impacts and Mitigation..................................................................4-57 

4.6.4 Essential Fish Habitat......................................................................................4-58 

4.6.4.1 Affected Federally Managed Species............................................4-59 

4.6.4.2 Impacts and Mitigation..................................................................4-62 

4.6.4.3 Conclusions...................................................................................4-64 

4.7 THREATENED AND ENDANGERED SPECIES.......................................................4-65 

4.7.1 Federally Listed Threatened and Endangered Species....................................4-65 

4.7.2 State-Sensitive Species....................................................................................4-71 

4.7.3 Conclusions and Recommendations................................................................4-72 

4.8 LAND USE, RECREATION, AND VISUAL RESOURCES ......................................4-74 

4.8.1 Land Use .........................................................................................................4-74 

4.8.1.1 Temporary Extra Workspaces.......................................................4-74 

4.8.1.2 Aboveground Facilities .................................................................4-77 

4.8.1.3 Access Roads ................................................................................4-77 

4.8.1.4 Pipe Storage and Contractor Yards ...............................................4-78 

4.8.2 Acquisition of Land through Easements and Eminent Domain ......................4-78 

4.8.3 Land Use Impacts and Mitigation ...................................................................4-78 

4.8.3.1 Agricultural Areas.........................................................................4-78 

4.8.3.2 Open Water ...................................................................................4-79 

4.8.3.3 Forest.............................................................................................4-79 

4.8.3.4 Developed Land ............................................................................4-79 

4.8.3.5 Open Land, Beaches, and Other....................................................4-80 

4.8.3.6 Residences and Planned Residential Developments .....................4-80 

4.8.3.7 Recreation and Special Use Areas.................................................4-81 

4.8.3.8 Wetland Restoration and Mitigation Projects ...............................4-83 

4.8.3.9 Natural and Scenic Rivers .............................................................4-83 

4.8.3.10 Hazardous Waste Sites..................................................................4-83 

4.8.4 Visual Resources.............................................................................................4-84 

4.8.4.1 Pipeline Facilities ..........................................................................4-84 
TABLE OF CONTENTS (cont’d) 

Page

 iv Table of Contents 

4.8.4.2 Aboveground Facilities .................................................................4-84 

4.8.5 Coastal Zone Management..............................................................................4-85 

4.9 SOCIOECONOMIC RESOURCES ..............................................................................4-86 

4.9.1 Region of Influence.........................................................................................4-86 

4.9.2 Population .......................................................................................................4-86 

4.9.3 Employment and Economy .............................................................................4-87 

4.9.4 Housing ...........................................................................................................4-88 

4.9.5 Infrastructure and Public Services...................................................................4-90 

4.9.6 Transportation and Traffic ..............................................................................4-90 

4.9.6.1 Land Transportation ......................................................................4-90 

4.9.6.2 Marine Transportation...................................................................4-91 

4.9.7 Government Tax Revenue...............................................................................4-91 

4.10 CULTURAL RESOURCES ..........................................................................................4-93 

4.10.1 Consultation with Louisiana State Historic Preservation Officer ...................4-93 

4.10.2 Native American Consultation........................................................................4-93 

4.10.3 Results of Cultural Resources Survey.............................................................4-93 

4.10.4 General Impacts and Mitigation......................................................................4-95 

4.10.5 Unanticipated Discovery Plan.........................................................................4-96 

4.11 CUMULATIVE IMPACTS...........................................................................................4-97 

4.11.1 Water Resources..............................................................................................4-99 

4.11.2 Wetlands........................................................................................................4-103 

4.11.3 Biological Resources.....................................................................................4-103 

4.11.4 Land Use, Recreation, and Visual Resources ...............................................4-106 

4.11.5 Socioeconomics.............................................................................................4-106 

4.11.6 Shoreline Erosion..........................................................................................4-107 

4.11.7 Air Quality and Noise ...................................................................................4-107 

4.11.8 Cumulative Impacts Conclusions..................................................................4-108 

4.12 AIR QUALITY AND NOISE .....................................................................................4-109 

4.12.1 Air Quality ....................................................................................................4-109 

4.12.1.1 Affected Environment .................................................................4-109 

4.12.1.2 Regulatory Requirements............................................................4-109 

4.12.1.3 General Impacts and Mitigation..................................................4-112 

4.12.2 Noise .............................................................................................................4-113 

4.12.2.1 Affected Environment .................................................................4-114 

4.12.2.2 Impacts and Mitigation................................................................4-114 

4.13 RELIABILITY AND SAFETY...................................................................................4-116 

4.13.1 Safety Standards............................................................................................4-116 

4.13.2 Pipeline Accident Data..................................................................................4-120 

4.13.3 Impact on Public Safety ................................................................................4-122 

5.0 CONCLUSIONS AND RECOMMENDATIONS....................................................... 5-1 

5.1 SUMMARY OF THE STAFF’S ENVIRONMENTAL ANALYSIS .............................5-1 

5.1.1 Geology.............................................................................................................5-1 

5.1.2 Soils...................................................................................................................5-1 

5.1.3 Water Resources................................................................................................5-2 

5.1.4 Wetlands............................................................................................................5-3 

5.1.5 Vegetation .........................................................................................................5-3 
TABLE OF CONTENTS (cont’d) 

Page

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5.1.6 Wildlife and Aquatic Resources........................................................................5-4 

5.1.7 Threatened and Endangered Species.................................................................5-6 

5.1.8 Land Use, Recreation, and Visual Resources ...................................................5-7 

5.1.9 Socioeconomics.................................................................................................5-8 

5.1.10 Cultural Resources ............................................................................................5-8 

5.1.11 Cumulative Impacts ..........................................................................................5-9 

5.1.12 Air Quality and Noise .......................................................................................5-9 

5.1.13 Reliability and Safety........................................................................................5-9 

5.1.14 Alternatives .......................................................................................................5-9 

5.2 FERC STAFF’S RECOMMENDED MITIGATION....................................................5-10 
TABLE OF CONTENTS (cont’d) 

APPENDIX A DISTRIBUTION LIST 

APPENDIX B FACILITY LOCATION MAPS 

APPENDIX C LAND REQUIREMENTS FOR EXTRA WORKSPACES, ACCESS ROADS, 

AND PIPE STORAGE AND CONTRACTOR YARDS 

APPENDIX D LOCATION OF REQUESTED ALTERNATIVE MEASURES 

APPENDIX E PIPELINE CONSTRUCTION METHODS (BY MILEPOST) 

APPENDIX F ROUTE VARIATION MAPS 

APPENDIX G WATERBODY CROSSINGS 

APPENDIX H AFFECTED WETLANDS 

APPENDIX I DRAFT HORIZONTAL DIRECTIONAL DRILLING CONTINGENCY 

PLAN 

APPENDIX J DRAFT AQUATIC RESOURCE MITIGATION PLAN 

APPENDIX K SEA TURTLE CONSTRUCTION GUIDELINES 

APPENDIX L REFERENCES 

APPENDIX M LIST OF PREPARERS 

APPENDIX N SUBJECT INDEX 

 vi Table of Contents 
TABLES 

Number Title Page

1.3-1 Major Permits, Approvals, and Consultations for the KMLP Project.................................1-5 

1.4-1 Issues Identified in the Public and Agency Scoping Process for the KMLP Project ..........1-7 

2.1-1 Proposed KMLP Pipelines ..................................................................................................2-1 

2.1.1-1 Pig Launchers/Receivers and Mainline Block Valves ........................................................2-4 

2.1.2-1 Interconnect Locations and Connecting Pipelines ..............................................................2-6 

2.1.3-1 Number of Ancillary Areas by Parish/County ....................................................................2-7 

2.2-1 Locations and Land Requirements for the Project ..............................................................2-8 

2.3-1 Acceptance or Denial of Requested Alternative Measures...............................................2-11 

2.3.1-1 Construction Methods by Category ..................................................................................2-12 

3.2-1 Comparison of KMLP’s Proposed System with System Alternatives ................................3-6

3.3-1 Comparison of KMLP’s Proposed Route with Major Route Alternatives for Leg 1........3-11 

3.4-1 Route Variations Considered in Developing the Proposed Route for Leg 1.....................3-14 

3.4.1-1 Environmental Comparison of Blue Buck Point Route Variation ....................................3-15 

3.4.1-2 Bottom Substrate Crossed by the Blue Buck Pipeline Route Variation within 

Sabine Lake.......................................................................................................................3-15 

3.4.2-1 Environmental Comparison of Garrison’s Ridge Route Variation ...................................3-16 

3.4.3-1 Environmental Comparison of Vinton Drainage Canal Route Variation..........................3-17 

3.4.4-1 Environmental Comparison of Bayou Choupique Route Variation..................................3-17 

3.4.5-1 Environmental Comparison of Calcasieu River Route Variation .....................................3-18 

3.4.6-1 Environmental Comparison of Tom Herbert Road Route Variations #1 and #2 ..............3-19 

3.4.7-1 Environmental Comparison of I-10 Route Variation........................................................3-19 

3.4.8-1 Environmental Comparison of the Freeland Road Route Variation .................................3-20 

3.4.9-1 Environmental Comparison of Bayou Nezpique Route Variations #1 and #2..................3-21 

3.4.10-1 Environmental Comparison of US Highway 190 Route Variation...................................3-21 

3.4.11-1 Environmental Comparison of the South Forty Acre Subdivision Route Variation.........3-22 

3.4.12-1 Environmental Comparison of the Old Schoolhouse Road Route Variation....................3-22 

3.4.13-1 Environmental Comparison of the Perron Road Route Variation.....................................3-23 

4.1.1-1 Geology Along the Proposed KMLP Project......................................................................4-2 

4.1.1-2 Oil and Gas Wells Within 150 feet of the KMLP Project...................................................4-4 

4.2.1-1 Soils Crossed by the Proposed KMLP Pipeline................................................................4-10 

4.3.1.1-1 Drinking Water Wellhead Protection Areas That Would be Crossed by the KMLP 

Project ...............................................................................................................................4-17 

4.3.1.1-2 Wells Located Within 150 Feet of the KMLP Projecta ....................................................4-18 

4.3.2.1-1 Water Quality/Use Designations Other Than No Quality/Use .........................................4-20 

4.3.2.1-2 Sensitive Waterbodies Affected by the Proposed Project.................................................4-21 

4.3.2.1-3 Features Crossed Using HDD Along the Kinder Morgan Louisiana Pipeline..................4-21 

4.3.2.2-1 Hydrostatic Test Water Source and Discharge Locations.................................................4-26 

4.4.1-1 Common Wetland Species Identified Within the KMLP Project Area.............................4-30 

4.4.1-2 Summary of Wetlands Affected by the KMLP Project.....................................................4-31 

4.4.1-3 Acceptance or Denial of Requested Alternative Measures from our Procedures .............4-34 

4.4.1-4 The Coastal Wetlands Planning, Protection, and Restoration Act Projects in the 

Vicinity of the KMLP Project ...........................................................................................4-36 

4.5.1-1 Upland Vegetation Types Crossed by the KMLP Project.................................................4-42 

 vii Table of Contents 
TABLES (cont’d) 

Number Title Page

 viii Table of Contents 

4.5.2.1-1 Upland Vegetation Cover Types Affected by the KMLP Project.....................................4-43 

4.6.1-1 Habitats and Typical Non-Fish Wildlife Species Found within the Project Area.............4-47 

4.6.2.1-1 Freshwater Aquatic Species Occurring Within Waterbodies Crossed by the 

Proposed KMLP Project ...................................................................................................4-51 

4.6.3.1-1 Marine Species Occurring Within Waterbodies Crossed by the Proposed KMLP 

Project ...............................................................................................................................4-55 

4.6.3.1-2 Bottom Substrate Crossed by the KMLP Project within Sabine Lake..............................4-56 

4.6.4.1-1 Summary of EFH Categories Potentially Used by Specific Life Stages of 

Federally Managed Species...............................................................................................4-60 

4.6.4.1-2 Relative Abundance of Managed Species within the Project Area...................................4-61 

4.7.1-1 Federally Listed Species Potentially Occurring in the KMLP Project Area.....................4-66 

4.8.1-1 Land Use Affected by Construction and Operation of the KMLP Project........................4-75 

4.8.1-2 Existing Rights-of-Way Paralleled by the KMLP Projecta...............................................4-76 

4.8.1.2-1 Acres of Land Affected by Construction and Operation of the Aboveground 

Facilities............................................................................................................................4-77 

4.8.3.6-1 Structures Within 50 Feet of the Construction Work Areas .............................................4-81 

4.9.2-1 Population Conditions in the Vicinity of the Proposed Project.........................................4-86 

4.9.2-2 Estimated Workforce in the Vicinity of the Proposed Project ..........................................4-87 

4.9.3-1 Employment Conditions in the Vicinity of the Proposed Project .....................................4-88 

4.9.4-1 General Housing Conditions in the Vicinity of the Proposed Project...............................4-89 

4.9.4-2 Unoccupied Housing Characteristics in the Vicinity of the Proposed Project..................4-89 

4.11-1 Existing, Approved, or Proposed Projects and Activities that Could Contribute to 

Cumulative Impacts with the KMLP Project ..................................................................4-100 

4.11-2 Resources of Concern that Could be Affected by Construction or Development 

of Existing, Approved, or Proposed Projects or Activities in the Vicinity of the 

KMLP Project .................................................................................................................4-102 

4.11-3 Cumulative Impacts to Environmental Resources Resulting from the Construction 

and Operation of Projects in the Vicinity of the KMLP Project .....................................4-104 

4.12.1.2-1 National Ambient Air Quality Standards........................................................................4-110 

4.12.1.3-1 Emission from Construction Activities...........................................................................4-112 

4.12.1.3-2 Emission from Heaters Located at Interconnect Sites ....................................................4-113 

4.13.1-1 Area Classifications ........................................................................................................4-118 

4.13.2-1 Natural Gas Service Incidents by Cause .........................................................................4-121 

4.13.2-2 Outside Forces Incidents by Cause (1970-1984) ............................................................4-122 

4.13.2-3 External Corrosion by Level of Control (1970-1984).....................................................4-122 

4.13.3-1 Annual Average Fatalities - Natural Gas Transmission and Gathering Systems............4-123 

4.13.3-2 Nationwide Accidental Deaths........................................................................................4-123 
FIGURES 

Number Title Page

2.1-1 General Location of KMLP Project ....................................................................................2-2 

2.3.1.1-1 Upland Pipeline Construction Sequence...........................................................................2-13 

2.3.1.1-2 Typical Cross-Section for Upland Construction of 42” Pipe Without Topsoil 

Segregation........................................................................................................................2-17 

2.3.1.1-3 Typical Cross-Section for Upland Construction of 42” Pipe Adjacent to Foreign 

Pipe without Topsoil Segregation .....................................................................................2-18 

2.3.1.1-4 Typical Cross-Section of 42” Pipe with Full-Width Topsoil Segregation........................2-19 

2.3.1.1-5 Typical Cross-Section for Upland Construction of 42” Pipe Adjacent to Foreign 

Pipe with Ditch-plus-Spoil-Side Topsoil Segregation ......................................................2-20 

2.3.1.1-6 Typical Cross-Section for Upland Construction of 42” and 36” Parallel Pipes 

within the Sabine Pass LNG Terminal without Topsoil Segregation ...............................2-21 

2.3.1.1-7 Typical Cross-Section for Upland Construction of 36” Pipe within the Sabine 

Pass LNG Terminal without Topsoil Segregation ............................................................2-22 

2.3.1.1-8 Typical Cross-Section for Upland Construction of 24” Pipe Adjacent to Foreign 

Pipe without Topsoil Segregation .....................................................................................2-23 

2.3.1.2-1 Unsaturated Wetland Crossing with Topsoil Segregation ................................................2-25 

2.3.1.2-2 Unsaturated Wetland Crossing with Topsoil Segregation ................................................2-26 

2.3.1.2-3 Saturated Wetland Crossing without Topsoil Segregation ...............................................2-28 

2.3.1.2-4 Saturated Wetland Crossing without Topsoil Segregation ...............................................2-29 

2.3.1.2-5 Typical Submerged Marsh Crossing (Push-Pull)..............................................................2-30 

2.3.1.3-1 Typical HDD Waterbody Crossing...................................................................................2-32

2.3.1.3-2 Flume Crossing Method....................................................................................................2-35 

2.3.1.3-3 Typical Access Canal in Open Water ...............................................................................2-37

2.3.1.3-4 Typical Inland Open Water Construction, <8 feet depth of water ....................................2-38 

2.3.1.3-5 Typical Inland Open Water Construction, >8 feet depth of water ....................................2-39 

2.3.1.3-6 Typical Foreign Pipeline Crossing....................................................................................2-41

3.2-1 System Alternatives for the KMLP Project.........................................................................3-5 

3.3-1 Major Route Alternatives for the KMLP Project................................................................3-9 

4.11-1 Existing, Approved, or Proposed Gas Pipeline and LNG Projects that Could 

Contribute to Cumulative Impacts ....................................................................................4-98 

 ix Table of Contents 
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LIST OF ACRONYMS AND TERMS 

ACHP Advisory Council on Historic Preservation 

ANR ANR Pipeline Company 

APC area of probable concern 

APE area of potential effects 

API American Petroleum Institute 

AQCR Air quality control region 

ASME American Society of Mechanical Engineers 

BA Biological Assesment 

BACT Best Available Control Technology 

Bcf/d billion cubic feet per day 

BMP Best Management Practices 

BOD biochemical oxygen demand 

Cameron Cameron Pipeline 

CEQ Council on Environmental Quality 

Certificate Certificate of Public Convenience and Necessity 

CGT Columbia Gulf Transmission 

CMD Coastal Management Division 

COE U.S. Army Corps of Engineers 

Construction Conditions Sea Turtle and Smalltooth Sawfish Construction Conditions 

CRP Conservation Reserve Program 

CTP Creole Trail Pipeline 

CUP Coastal Use Permit 

CWA Clean Water Act 

CWPPRA Coastal Wetland Planning, Protection, and Restoration Act 

CZMA Coastal Zone Management Act of 1972 

CZMP Coastal Zone Management Program 

DO dissolved oxygen 

DOE U.S. Department of Energ 

DOT U.S. Department of Transportation 

DSM Demand Side Management 

Dth decatherms 

E2EM estuarine emergent 

E2SS estuarine scrub-shrub 

EFH essential fish habitat 

EI Environmental Inspector 

EIA Energy Information Administration 

EIS environmental impact statement 

EPA U.S. Environmental Protection Agency 

ES&C Erosion & Sediment Control 

ESA Endangered Species Act 

FEMA Federal Emergency Management Agency 

FERC or Commission Federal Energy Regulatory Commission 

FGT Florida Gas Transmission 

FMP Fishery Management Plan 

FWS U.S. Fish and Wildlife Service 

GIWW Gulf Intracoastal Waterway 

GMFMC The Gulf of Mexico Fishery Management Council 

GPP Golden Pass Pipeline 

GPS Global Positioning System 

 xi List of Acroynms and Terms
HAPs Hazardous Air Pollutants 

HCA High-Consequence Areas 

HDD Horizontal Directional Drilling 

IRP Integrated Resource Planning 

KMLP Kinder Morgan Louisiana Pipeline LLC 

LDEQ Louisiana Department of Environmental Quality 

LDNR Louisiana Department of Natural Resources 

LDOT Louisiana Department of Transportation 

LDWF Louisiana Department of Wildlife and Fisheries 

LOSCO Louisiana Oil Spill Coordinators Office 

LPDES Louisiana Pollution Discharge Elimination System 

LNG Liquefied Natural Gas 

LNWR Lacassine National Wildlife Refuge 

MACT Maximum Achievable Control Technology 

MAOP Maximum Allowable Operating Pressure 

Memorandum Memorandum of Understanding on Natural Gas Transportation Facilities 

MLV Mainline block valves 

MMBtu million British thermal units 

MMBtu/d million British thermal units per day 

MP milepost 

MSA Magnuson-Stevens Fishery Conservation and Management Act 

NEPA National Environmental Policy Act of 1969 

NGA Natural Gas Act 

NGPL Natural Gas Pipeline Company of America 

NGPSA Natural Gas Pipeline Safety Act 

NHP National Heritage Program 

NHPA National Historic Preservation Act 

NNSR Non-attainment New Source Review 

NOAA National Oceanic and Atmospheric Administration 

NOAA Fisheries Service NOAA's National Marine Fisheries Service 

NOI Notice of Intent To Prepare an Environmental Impact Statement for the 

Proposed Kinder Morgan Pipeline Project and Request for Comments on 

Environmental Issues 

NPDES National Pollutant Discharge Elimination System 

NRCS National Resource Conservation Service 

NRHP National Register of Historic Places 

NSA Noise Sensitive Area 

NSPS New Source Performance Standards 

NSR New Source Review 

NWF National Wildlife Refuge 

NWI National Wetlands Inventory 

OEP FERC's Office of Energy Projects 

OPS Office of Pipeline Safety 

our Plan FERC’s Upland Erosion Control, Revegetation and Maintenance Plan 

our Procedures Wetland and Waterbody Construction and Mitigation 

PAP Port Arthur Pipeline 

PEM palustrine emergent 

PFO palustrine forested 

PGA Peak Ground Acceleration 

PHMSA Pipeline and Hazardous Materials Safety Administration 

ppt parts per thousand 

 xii List of Acroynms and Terms
PSD Prevention of Significant Deterioration 

psig pounds per square inch gauge 

PSS palustrine scrub-shrub 

RCW red-cockaded woodpecker 

SAV submerged aquatic vegetation 

SCADA Supervisory Control and Data Acquisition 

SH State Highway 

SHPO State Historic Preservation Office 

SNWR Sabine National Wildlife Refuge 

SPECT Sabine Pass Pipeline/ Creole Trail Extension/ Creole Trail Pipeline 

sp. specie 

SPP Sabine Pass Pipeline 

spp. species 

SPRP Spill Prevention and Response Plan 

SWPPP Stormwater Pollution Prevention Plan 

Tcf trillion cubic feet 

TCEQ Texas Department of Environmental Quality 

TPWD Texas Parks and Wildlife Department 

tpy tons per year 

TTS Temporary Threshold shift 

USGS United States Geologic Survey 

UTOS Enbridge Offshore Pipeline 

VOC volatile organic compound 

WRP Wetlands Reserve Program 

 xiii List of Acroynms and Terms
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EXECUTIVE SUMMARY 

INTRODUCTION 

This draft Environmental Impact Statement (EIS) for the Kinder Morgan Louisiana Pipeline 

Project (Project) has been prepared by the staff of the Federal Energy Regulatory Commission (FERC or 

Commission) to fulfill the requirements of the National Environmental Policy Act (NEPA). The purpose 

of this document is to inform the public, the Commission, and federal and state agencies about the 

potential adverse and beneficial environmental impacts of the Project and its alternatives, and to 

recommend mitigation measures that would avoid or reduce any significant adverse impacts to the 

maximum extent possible. This document has been prepared in coordination with our1

 federal 

cooperating agencies for the Project, the U.S. Army Corps of Engineers (COE) and the U.S. Fish and 

Wildlife Service (FWS). 

This draft EIS was filed with the U.S. Environmental Protection Agency and a formal notice of 

availability was published in the Federal Register. In accordance with the Council on Environmental 

Quality regulations implementing NEPA, the public has the opportunity to comment on this draft EIS in 

the form of written comments or during public meetings to be held in the project area (to be announced in 

a separate notice). We would review and use the comments to prepare the final EIS for the Project. All 

timely and substantive comments received on the draft EIS would be addressed in the final EIS. 

PROJECT BACKGROUND 

Kinder Morgan Louisiana Pipeline LLC (KMLP) filed a request to implement the Commission’s 

Pre-filing Process on January 31, 2006. We approved this request on February 17, 2006 and a pre-filing 

docket number (PF06-16-000) was established to file related documents into the public record. 

On September 8, 2006, KMLP filed an application with the Commission, pursuant to section 7(c) 

of the Natural Gas Act, as amended, and Parts 157 and 284 of the Commission’s regulations. Under 

Docket No. CP06-449-000, KMLP seeks a Certificate of Public Convenience and Necessity (Certificate) 

to construct, own, operate, and maintain the natural gas pipelines and associated infrastructure to deliver 

regasified liquefied natural gas (LNG) from the Sabine Pass LNG Terminal into the national pipeline and 

underground gas storage grid. 

PROPOSED ACTION 

The Project would deliver gas to 10 existing interstate pipelines and one existing intrastate 

pipeline via 14 interconnect installations with a total take-away capacity of about 4.0 billion cubic feet per 

day (Bcf/d) and a total downstream interconnecting capacity of about 11.4 Bcf/d. Having such broad 

access to markets in the Gulf Coast, Northeast, Mid-Atlantic, South, Midwest, and Southeast, through 

multiple pipeline connections, would allow shippers to redirect supplies as pipeline capacity is available 

and in response to market dynamics. The pipeline system would provide natural gas delivery flexibility 

in addition to widespread market access. Specifically, the Project facilities would include: 

• Leg 1 – 132 miles of 42-inch-diameter pipeline beginning within the Sabine Pass LNG 

Terminal in Cameron Parish and extending northward and easterly through Calcasieu, 

Jefferson Davis, and Acadia Parishes until it connects with an existing Columbia Gulf 

Transmission interstate pipeline in Evangeline Parish, Louisiana. 

 

1

 “Our,” “we,” and “us” refer to the environmental staff of the Federal Energy Regulatory Commission’s Office of 

Energy Projects. 

 ES-1 Executive Summary
• Leg 2 – 1.22 miles of 36-inch-diameter pipeline beginning within the Sabine Pass LNG 

Terminal and extending to a point of interconnection with the existing Natural Gas Pipeline 

Company of America pipeline just south of State Highway 82 in Cameron Parish, Louisiana. 

• The Florida Gas Transmission (FGT) Lateral – 2.3 miles of 24-inch-diameter pipeline 

extending eastwardly from Leg 1 at approximately milepost (MP) 110.60 until it connects 

with the existing FGT Company's Compressor Station No. 7 near the town of Williams in 

Acadia Parish, Louisiana. 

• Associated mainline block valves, metering, tie-in, and pigging facilities. 

KMLP proposes to commence construction on Leg 1 and Leg 2 in November 2007 and on the 

FGT Lateral in October 2008. Leg 2 and interconnects would be completed by April 2008 and brought 

into service by October 1, 2008. Leg 1, the FGT Lateral, and their respective interconnects would be 

completed by November 2008 and brought into service by April 1, 2009. 

PUBLIC OUTREACH AND COMMENTS 

As part of the pre-filing process, we issued a Notice of Intent to Prepare an Environmental 

Impact Statement for the Proposed Kinder Morgan Louisiana Pipeline Project Request for Comments on 

Environmental Issues, and Notice of Public Scoping Meetings (NOI) on March 24, 2006. We sent the 

NOI to 1,642 interested parties including federal, state, and local officials; agency representatives; 

conservation organizations; local libraries and newspapers; and property owners along the pipeline routes. 

We received comment letters in response to our NOI from the National Oceanic and Atmospheric 

Administration National Marine Fisheries Service (NOAA Fisheries Service), FWS, and Louisiana 

Department of Wildlife and Fisheries (LDWF). We received no comment letters from landowners or 

other stakeholders. 

On April 26, 2006, we issued a Notice of Site Visit and Public Meetings to provide notice to the 

public of our site visit and three scheduled public scoping meetings, which were held on May 8, 9, and 

11, 2006, in Ville Platte, Sulphur, and Iowa, Louisiana, respectively. At each of the meetings, we heard 

comments from two individuals. Transcripts of these comments are part of the public record for the 

KMLP Project. On May 10, 2006, we conducted an aerial review of the Project by helicopter and we 

took a boat tour of the pipeline route in the northern end of Sabine Lake and vicinity. On May 9 and 11, 

2006, we conducted a ground-based site visit of the entire route, which was open to the public. 

We also conducted agency consultations and participated in interagency meetings to identify 

issues that should be addressed in this draft EIS. These consultations included interagency meetings on 

May 11 and October 5, 2006, both in Lake Charles, Louisiana. Participants at both meetings included 

representatives from the COE, FWS, NOAA Fisheries Service, and LDWF. We used the scoping 

comments to help focus the analysis in the draft EIS on potentially significant environmental issues 

related to the proposed action. 

ENVIRONMENTAL IMPACTS 

Construction and operation of the Project would result in numerous impacts to the environment. 

We evaluated the impacts to geology, soils, water resources, wetlands, vegetation, wildlife and aquatic 

resources, threatened and endangered species, land use, socioeconomics, cultural resources, air quality, 

noise, and safety. We also considered the cumulative impacts of this Project with current and foreseeable 

projects in the area. The primary issues with the Project were related to impacts to wetlands and 

waterbodies. Major findings and conclusions are summarized below. 

ES-2 Executive Summary
Most of the land affected by the Project is agricultural land, open land (consisting of rangeland, 

non-forested wetlands, transitional areas, and sandy areas), and open water. Construction would affect a 

total of 3,030.7 acres. Operation of the Project would affect 840.9 acres, including 821.7 acres of the 

permanent right-of-way, 12.3 acres of aboveground facilities, and 6.9 acres of the permanent access 

roads. All construction would follow our Upland Erosion Control, Revegetation and Maintenance Plan

(Plan) and Wetland and Waterbody Construction and Mitigation Procedures (Procedures), with a few 

minor alternative measures that we have specifically reviewed and found acceptable. 

The Project would be constructed across 310 waterbodies, including Sabine Lake, the Gulf 

Intracoastal Waterway (GIWW), and Calcasieu River. To minimize impacts, KMLP proposed to conduct 

18 horizontal directional drill (HDD) operations to install the pipeline under 24 waterbodies (some of the 

HDDs would encompass more than one waterbody). In addition, 147 waterbodies would be crossed by 

bore and two would be crossed using a flume. Based on the characteristics of the identified waterbodies, 

KMLP’s proposed construction methods and operations procedures, its implementation of waterbodyrelated measures described in our Procedures, and our recommended measures, we believe that effects to 

surface waters resulting from construction and operation of the Project would be temporary and localized. 

Sabine Lake is a large waterbody with important aquatic resources such as essential fish habitat 

(EFH) and oyster resources. KMLP proposes to cross Sabine Lake by HDD at the lake’s southern and 

northern shorelines and via open-cut construction methods requiring the use of spud barges across the 

lake’s open water. The use of HDD crossing methods at the northern and southern banks of Sabine Lake 

would avoid impacts to shoreline erosion, oyster reefs, and EFH wetlands. Open-cut construction across 

approximately 13 miles of Sabine Lake would affect water quality during construction, temporarily 

causing sediment re-suspension and related impacts in the water column. The Project would not directly 

affect known oyster reefs, but oysters inhabiting the area could be affected by increased turbidity or by 

deposition of sediments suspended by construction activities. KMLP would compensate LDWF for each 

bottom substrate directly impacted by pipeline construction and also for oysters lost due to sedimentation 

on the reefs. 

The Project would be constructed in areas of extensive estuarine and palustrine wetlands. The 

construction right-of-way would affect 352 wetlands covering approximately 504.2 acres of wetlands. Of 

this total, about 99.5 acres are considered EFH wetlands. Most of the wetlands affected by pipeline 

construction would be restored, reseeded, and allowed to naturally revegetate and return to 

preconstruction conditions. Forested wetlands within the permanent right-of-way would be converted and 

maintained as an emergent or scrub-shrub wetland. Operation of the pipeline facilities would result in the 

permanent conversion of 14.9 acres of forested wetlands. The COE has not yet verified the KMLP 

wetland delineation for the Project; therefore, the acreage of wetlands affected by the Project may change. 

To minimize temporary construction impacts on wetlands, KMLP would implement protective measures 

in our Procedures, the recommendations made in this draft EIS, and the mitigation measures described in 

an Aquatic Resources Management Plan. Additionally, KMLP would cross several wetlands along the 

Project using the HDD method, which would avoid impacts on these wetlands. 

Based on consultations and comments received from FWS and NOAA Fisheries Service, we 

evaluated the impacts of the Project on the bald eagle, brown pelican, red-cockaded woodpecker (RCW), 

and five species of sea turtles. We have determined that there would be no adverse effects for the bald 

eagle or brown pelican. With the protective measures recommended by NOAA Fisheries Service, the 

impacts on sea turtles are expected to be temporary, localized, and minor; therefore, the Project would not 

adversely affect these species. With regard to the RCW, we are recommending that KMLP file 

documentation of further consultation with FWS along with survey reports and FWS comments on all 

necessary RCW surveys. We are also recommending that KMLP not begin construction until we 

complete our consultation with FWS and NOAA Fisheries Service, and KMLP receives written 

 ES-3 Executive Summary
notification from the Director of Office of Energy Projects (OEP) that construction and/or implementation 

of conservation measures may begin. 

Detailed descriptions of all impacts, proposed mitigation measures to minimize these impacts, 

and our recommendations to further avoid, minimize, and mitigate these impacts are described in section 

4.0 of this draft EIS. 

ALTERNATIVES CONSIDERED 

We evaluated the no action or postponed action alternatives, which would eliminate the shortand long-term environmental impacts identified in this draft EIS. However, the objectives of the Project 

would not be met, and KMLP would not be able to deliver regasified LNG to markets in Louisiana and 

the rest of the United States as proposed. We evaluated system alternatives to examine whether other 

existing or proposed natural gas pipeline systems would meet the Project objectives while offering an 

environmental advantage over the Project. Currently, there is no existing pipeline system that could be 

used to meet the Project objectives and we determined that two system alternatives involving proposed 

pipeline systems, including the approved Sabine Pass Pipeline, do not offer significant environmental 

benefits relative to the proposed action. We also evaluated four major route alternatives to the Project 

route. However, none of these major route alternatives would offer significant environmental advantages 

over the proposed route, and we eliminated them from further consideration. Lastly, we evaluated 15 

route variations to avoid or reduce construction impacts to localized, specific resources. Variations that 

lessened environmental impacts were adopted by KMLP as part of the proposed Project route. 

In summary, with KMLP’s proposed mitigation and our recommendations, the proposed route is 

environmentally least damaging and we are recommending use of the proposed route as the preferred 

alternative. 

CONCLUSIONS 

We have determined that construction and operation of the KMLP Project would result in limited 

adverse environmental impacts based on information provided by KMLP and data developed from 

information requests; field investigations; literature research; alternatives analysis; comments from 

federal, state, and local agencies; and public input. These limited impacts would be most significant 

during the construction period. 

As part of our review, we developed specific mitigation measures that we believe would 

appropriately and reasonably reduce the environmental impacts resulting from construction and operation 

of the Project. We believe that environmental impacts would be minimized if the Project is constructed 

and operated in accordance with applicable laws and regulations, KMLP’s proposed mitigation, and our 

additional mitigation measures. The primary reasons for our conclusion are: 

• About 54 percent of the proposed route would collocate with or parallel existing rights-of-way; 

• KMLP would use HDD across most sensitive areas, including major waterbodies, oyster reefs, 

several wetlands, congested pipeline corridors, and select roads and developed areas; 

• KMLP would consult with resource agencies to further avoid and minimize impacts to 

wetlands, EFH, and threatened and endangered species; and 

• Construction would be done in accordance with our Plan and Procedures and all applicable 

permits and authorizations, and an environmental inspection and monitoring program would 

ensure compliance with all mitigation measures that become conditions of any Commission 

authorization. 

ES-4 Executive Summary
1.0 INTRODUCTION 

On September 8, 2006, Kinder Morgan Louisiana Pipeline LLC (KMLP) filed an application with 

the Federal Energy Regulatory Commission (FERC or Commission) under section 7(c) of the Natural Gas 

Act (NGA). As filed in Docket No. CP06-449-000, KMLP seeks a Certificate of Public Convenience and 

Necessity (Certificate) to construct, operate, and maintain a natural gas pipeline in southwest Louisiana. 

For the purposes of this draft environmental impact statement (EIS), the project is referred to as the 

“Project” or “KMLP Project.” 

The Project has been designed to deliver a peak day capacity of not less than 3,395,000 

decatherms (Dth) of regasified natural gas from the Sabine Pass Liquefied Natural Gas (LNG) Terminal 

to various intrastate and interstate natural gas pipeline systems. The Sabine Pass LNG Terminal is under 

construction, and will be owned and operated by Sabine Pass LNG, L.P., on an 853-acre tract of land 

along the eastern bank of Sabine Pass, south of Louisiana State Highway (SH) 82 in southwestern 

Louisiana. The FERC issued an Order on December 21, 2004, granting approval under Section 3(a) of 

the NGA for Sabine Pass LNG, L.P.’s proposal (FERC Docket No. CP04-47-000) to construct and 

operate Phase I facilities at the LNG import terminal and granting approval under Section 7(c) of the 

NGA for 16 miles of 42-inch-diameter pipeline and associated facilities (called the Sabine Pass Pipeline). 

This order was based on, among other analyses, the Final Environmental Impact Statement, Sabine Pass 

LNG and Pipeline Project (Phase I Project FEIS) published in November 2004 (FERC 2004). Sabine 

Pass LNG, L.P. has subsequently applied for, and the FERC issued an Environmental Assessment in May 

2006 on, proposed expanded – or Phase II – facilities at the terminal (FERC 2006a). These activities and 

facilities at the Sabine Pass LNG Terminal are not within the scope of the Project. 

Pipelines and associated facilities proposed by KMLP for the Project include: 

• Leg 1 – 132 miles of 42-inch-diameter pipeline beginning within the Sabine Pass LNG 

Terminal in Cameron Parish and extending northward and easterly through Calcasieu, 

Jefferson Davis, and Acadia Parishes until it connects with an existing Columbia Gulf 

Transmission (CGT) interstate pipeline in Evangeline Parish, Louisiana. 

• Leg 2 – 1.22 miles of 36-inch-diameter pipeline beginning within the Sabine Pass LNG 

Terminal and extending to a point of interconnection with the existing Natural Gas Pipeline 

Company of America (NGPL) pipeline just south of SH 82 in Cameron Parish, Louisiana. 

• The Florida Gas Transmission (FGT) Lateral – 2.3 miles of 24-inch-diameter pipeline 

extending eastwardly from Leg 1 at approximately milepost (MP) 110.60 until it connects 

with the existing FGT Company's Compressor Station #7 near the town of Williams in 

Acadia Parish, Louisiana. 

• Associated mainline block valves (MLVs), metering, tie-in, and pigging facilities. 

To the extent feasible, KMLP Project rights-of-way would parallel and overlap existing pipeline 

and utility rights-of-way, while providing a safe separation distance between the KMLP Project and any 

existing pipelines and utility lines. The width of the necessary construction rights-of-way for the various 

KMLP pipeline segments would differ according to the type of terrain encountered and the corresponding 

pipeline construction method that would be used, as further discussed in section 2 of this draft EIS. 

Approximately 3,031 acres of land would be temporarily affected by construction of the pipeline, storage 

yards, access roads, and aboveground facilities. Approximately 841 acres of land would be permanently 

affected by operation of the Project. 

 1-1 Introduction 
We1

 prepared this draft EIS to assess the environmental impact associated with construction, 

operation, and maintenance of the KMLP Project in Cameron, Calcasieu, Jefferson Davis, Acadia, and 

Evangeline Parishes, Louisiana as summarized above and more fully described in section 2 of this draft 

EIS. 

1.1 PROJECT PURPOSE AND NEED 

The KMLP Project would site, construct, operate, and maintain the natural gas pipelines and 

associated infrastructure to deliver regasified LNG from the Sabine Pass LNG Terminal into the national 

pipeline and underground gas storage grid. The two capacity holders at the Sabine Pass LNG Terminal 

(Total Gas & Power North America and Chevron U.S.A.) are the shippers on the KMLP Project. The 

Project would provide access to an additional 11 inter-and intra-state natural gas pipelines at 14 

interconnect points with a total take-away capacity of about 4.0 billion cubic feet per day (Bcf/d) and a 

total downstream interconnecting capacity of about 11.4 Bcf/d. These pipelines serve markets throughout 

much of the eastern half of the United States. Having such broad access to markets in the Gulf Coast, 

Northeast, Mid-Atlantic, South, Midwest, and Southeast, through multiple pipeline connections, would 

allow shippers to redirect supplies as pipeline capacity is available and in response to market dynamics. 

The pipeline system would provide natural gas delivery flexibility in addition to widespread market 

access. 

The U.S. Department of Energy (DOE) Energy Information Administration (EIA) forecasts 

increasing demand for natural gas and a need for additional supplies of natural gas. In its Annual Energy 

Outlook 2006, the EIA projects that natural gas demand in the United States will grow from 22.4 trillion 

cubic feet (Tcf) in 2004 to almost 26.9 Tcf in 2030 (DOE 2006). About 60 percent of the demand growth 

is projected by EIA to occur east of the Mississippi River, which is the area served by the pipelines that 

would be connected to the KMLP Project. With an expected decline in imports from Canada, and modest 

increases from domestic production, LNG is expected to be a major supplier of this need. LNG imports 

in the EIA reference case reach 12 Bcf/d by 2030, or 16 percent of total demand. The importance of LNG 

to natural gas markets lies in providing additional supplies that help to moderate prices and in giving 

North American markets access to broader world-wide natural gas resources. 

1.2 PURPOSE AND SCOPE OF THIS STATEMENT 

The FERC is the federal agency responsible for authorizing applications to construct and operate 

natural gas pipeline facilities. The FERC is the lead federal agency for the preparation of this draft EIS in 

compliance with the requirements of the National Environmental Policy Act of 1969 (NEPA), the Council 

on Environmental Quality (CEQ) regulations for implementing NEPA (40, Code of Federal Regulations 

(CFR) 1500-1508), and the FERC’s regulations implementing NEPA (18 CFR 380). The FERC will use 

the results of the draft EIS as an element in its review of KMLP’s application to determine whether to 

authorize the project. The FERC will consider the environmental issues, including our recommended 

mitigation measures, as well as non-environmental issues in making its decision. Final authorization 

would be granted only if the FERC finds that the Project is in the public interest. The environmental 

impact assessment and mitigation development described herein are important factors in this final 

determination. 

The U.S. Army Corps of Engineers (COE) and U.S. Fish and Wildlife Service (FWS) are 

cooperating agencies for the preparation of this draft EIS. A cooperating federal agency has jurisdiction 

 

1

 “We,” “us,” and “our” refer to the environmental staff of the FERC’s Office of Energy Projects (OEP). 

 1-2 Introduction 
by law or special expertise with respect to environmental impacts involved with the proposal and is 

involved in the NEPA analysis. The Louisiana Department of Wildlife and Fisheries (LDWF) and the 

U.S. Department of Commerce, National Oceanic and Atmospheric Administration (NOAA), National 

Marine Fisheries Service (NOAA Fisheries Service) also assisted us in the preparation of this draft EIS. 

Our principal purposes in preparing this draft EIS are to: 

• Identify and assess potential impacts on the human environment that would result from the 

Project; 

• Describe and assess reasonable alternatives to the Project that would avoid or minimize 

adverse effects on the human environment; 

• Identify and recommend specific mitigation measures to minimize environmental impacts; 

and 

• Facilitate public involvement in identifying the significant environmental impacts. 

Our analysis in this draft EIS focuses on the facilities that would be under the FERC’s 

jurisdiction. The FERC jurisdictional facilities included in the Project would consist of three segments of 

pipelines as described above, including aboveground sites providing delivery interconnections, MLVs, 

pigging facilities, control systems, and other facilities, as further described in section 2 of this draft EIS. 

No compressor stations are proposed as part of the Project. 

The topics addressed in this draft EIS include geology; soils and sediments; water resources; 

wetlands; upland vegetation; wildlife; aquatic resources; essential fish habitat (EFH); threatened, 

endangered, and special-status species; land use, recreation, and visual resources; socioeconomics; 

cultural resources; air quality and noise; reliability and safety; cumulative effects; and alternatives. This 

draft EIS describes the affected environment as it currently exists, discusses the environmental 

consequences of the Project, and compares the Project’s potential impact to that of alternatives. This draft 

EIS also presents our conclusions and recommended mitigation measures. 

1.3 PERMITS, APPROVALS, AND REGULATORY REQUIREMENTS 

As the lead federal agency for the KMLP Project, the FERC is required to comply with section 7 

of the Endangered Species Act (ESA), the Magnuson-Stevens Fishery Conservation and Management Act 

(MSA), section 106 of the National Historic Preservation Act (NHPA), and section 307 of the Coastal 

Zone Management Act of 1972 (CZMA). Each of these statutes has been taken into account in the 

preparation of this document. 

Section 7 of the ESA, as amended, states that any project authorized, funded, or conducted by any 

federal agency (e.g., the FERC) should not “...jeopardize the continued existence of any endangered 

species or threatened species or result in the destruction or adverse modification of habitat of such species 

which is determined...to be critical...” (16 United States Code (USC) § 1536(a)(2)(1988)). The FERC, or 

the applicant as a non-federal party, is required to consult with the FWS and NOAA Fisheries Service to 

determine whether any federally listed or proposed threatened or endangered species or their designated 

critical habitat occur in the vicinity of the Project. If, upon review of existing data or data provided by the 

applicant, the FERC determines that these species or habitats may be affected by the Project, the FERC is 

required to prepare a biological assessment to identify the nature and extent of adverse impact, and to 

recommend measures that would avoid the habitat and/or species, or would reduce potential impact to 

 1-3 Introduction 
acceptable levels. If, however, the FERC determines that no federally listed or proposed threatened or 

endangered species or their designated critical habitat would be affected by the Project, no further action 

is necessary under the ESA. See section 4.7 of this draft EIS for the status of this review. 

The MSA, as amended by the Sustainable Fisheries Act of 1996 (Public Law 104-267), 

established procedures designed to identify, conserve, and enhance EFH for those species regulated under 

a federal fisheries management plan. The MSA requires federal agencies to consult with NOAA Fisheries 

Service on all actions or proposed actions authorized, funded, or undertaken by the agency that may 

adversely affect EFH (MSA §305(b)(2)). Although absolute criteria have not been established for 

conducting EFH consultations, NOAA Fisheries Service recommends consolidated EFH consultations 

with interagency coordination procedures required by other statutes, such as NEPA, the Fish and Wildlife 

Coordination Act, or the ESA in order to reduce duplication and improve efficiency (50 CFR 600.920(f)). 

As part of the consultation process, the FERC has prepared an EFH Assessment included in section 4.6.3 

of this draft EIS. 

Section 106 of the NHPA requires the FERC to take into account the effects of its undertakings 

on properties listed on or eligible for listing on the National Register of Historic Places (NRHP), 

including prehistoric or historic sites, districts, buildings, structures, objects, or properties of traditional 

religious or cultural importance, and to afford the Advisory Council on Historic Preservation (ACHP) an 

opportunity to comment on the undertaking. The FERC has requested that KMLP, as a non-federal party, 

assist in meeting the FERC’s obligation under section 106 by preparing the necessary information and 

analyses as required by the ACHP procedures in 36 CFR 800. See section 4.10 of this draft EIS for the 

status of this review. 

The CZMA calls for the “effective management, beneficial use, protection, and development” of 

the nation’s coastal zone and promotes active state involvement in achieving those goals. As a means to 

reach those goals, the CZMA requires participating states to develop management programs that 

demonstrate how these states will meet their obligations and responsibilities in managing their coastal 

areas. In the state of Louisiana, the Department of Natural Resources (LDNR) is the agency responsible 

for administering the Coastal Zone Management Program (CZMP). Because section 307 of the CZMA 

requires federal agency activities to be consistent to the maximum extent practicable within the 

enforceable policies of a management program, the FERC has requested that KMLP seek a determination 

of consistency with Louisiana’s CZMP. See section 4.8.5 of this draft EIS for additional discussion of 

Louisiana’s CZMP. 

In addition to the preceding authorities, the COE has the authority to issue permits for work or 

structures in navigable waters under section 10 of the River and Harbors Act and the discharge of dredged 

or fill material into waters of the United States under section 404 of the Clean Water Act (CWA). The 

COE would regulate the filling and grading activities in wetlands and waterbodies crossed by the Project. 

The U.S. Environmental Protection Agency (EPA) has the authority to review and veto COE decisions on 

section 404 permits. 

Major permits, approvals, and consultations required at the federal, state, and local levels for the 

Project are identified in table 1.3-1. At the federal level, required permits and approval authority outside 

of the FERC’s jurisdiction include compliance with the CWA and the Rivers and Harbors Act. The 

FERC encourages cooperation between applicants and state and local authorities, but this does not mean 

that state and local agencies, through application of state and local laws, may prohibit or unreasonably 

delay the construction or operation of facilities approved by the FERC. Any state or local permits issued 

 1-4 Introduction 
TABLE 1.3-1 

Major Permits, Approvals, and Consultations for the KMLP Project 

Agency Permit/Approval/Consultation 

FEDERAL AGENCIES 

Federal Energy Regulatory Commission NGA Section 7(c), Certificate of Public Convenience and 

Necessity 

U.S. Army Corps of Engineers Clean Water Act (CWA) Section 404 Permit 

Rivers and Harbors Act Section 10 Individual Permit 

U.S. Fish and Wildlife Service (U.S. Department 

of the Interior) 

Section 7, Endangered Species Act (ESA) Consultation, 

Migratory Bird Treaty Act Consultation 

National Marine Fisheries Service (U.S. Section 7, ESA Consultation 

Department of Commerce, National Oceanic and 

Atmospheric Administration) Magnuson-Stevens Fishery Conservation and Management 

Act, Essential Fish Habitat Consultation 

Natural Resources Conservation Service (U.S. 

Department of Agriculture) 

Prime Farmland, Hydric Soil/Soil Erosion and Sedimentation, 

Seed Mixture, and Conservation Reserve Program (CRP) 

Lands Consultation 

STATE AGENCIES 

Louisiana Department of Natural Resources, Coastal Use Permit (CUP) 

Coastal Management Division Coastal Zone Management Plan Consistency Determination 

Louisiana Department of Wildlife and Fisheries State-listed Threatened and Endangered Species Consultation 

Consultations Regarding Activities in Sabine Lake and 

Protection of Oyster Resources 

Louisiana Department of Environmental Quality CWA, Section 401, Water Quality Certification 

Louisiana Pollutant Discharge Elimination System (LAPDES): 

Construction Stormwater General Permit and Hydrostatic Test 

Water General Permit 

Louisiana Department of Culture, Recreation, 

and Tourism, Office of Cultural Development, 

Division of Archaeology 

National Historic Preservation Act, Section 106 Consultation 

Louisiana Department of Transportation Road Crossing Permits 

LOCAL AGENCIES 

Parish Police Juries Building and Road Crossing Permits, Floodplain Development 

Permit 

Irrigation Districts Canal Crossing Approval 

Levee Districts Letter of No Objection 

Local entities (e.g., County Roads, Economic 

Development, etc.) 

Planning and Development Consultation 

with respect to jurisdictional facilities must be consistent with the conditions of any authorization the 

FERC may issue.2

 

2

 See, e.g., Schneidewind v. ANR Pipeline Co., 485 U.S. 293 (1988); National Fuel Gas Supply v. Public Service 

Commission. 894 F.2d 571 (2d Cir. 1990); and Iroquois Gas Transmission System, L.P., et al., 52 FERC ¶ 

61,091 (1990) and 59 FERC ¶ 61,094 (1992). 

 1-5 Introduction 
1.4 PUBLIC REVIEW AND COMMENT 

On January 31, 2006, KMLP filed a request with the FERC to implement the Commission's PreFiling Process for the Project. Also on February 17, 2006, the FERC granted KMLP’s request and 

established a pre-filing docket number (PF06-16-000) to place information filed by KMLP and related 

documents issued by the FERC into the public record. The purpose of the Pre-Filing Process is to 

encourage the early involvement of interested stakeholders, facilitate interagency cooperation, and 

identify and resolve issues before an application is filed with the FERC. 

The application for the Project requires the submittal of an Environmental Report to the FERC, 

consisting of 12 Resource Reports as specified in 18 CFR 157.14(a)(6-a), § 380.3, and § 380.12. Each 

Resource Report evaluated existing conditions and potential effects on a particular aspect of the 

environment. KMLP submitted a Preliminary Draft Resource Report 1 and Alternatives Analysis 

Summary (to be included in Resource Report 10) on March 17, 2006, followed by Draft Resource 

Reports 1 through 12 on June 2, 2006, and Revised Draft Resource Reports 1 through 12 on July 14, 

2006. A list of environmental information requests based on a review of each round of the draft Resource 

Reports was prepared by the FERC and submitted to KMLP on July 3, 2006 and August 7, 2006. 

Revised Resource Reports were subsequently prepared by KMLP and submitted to the FERC along with 

its application filed on September 8, 2006. After accepting this filing, the FERC established a traditional 

docket number (CP06-449-000) to place related information submitted or developed subsequently into the 

public record. 

KMLP has conducted public outreach activities to inform the public, resource agencies, industry, 

local government, and other interested parties about the Project and to identify public concerns. 

Company-sponsored outreach activities included meetings with regulatory agencies and meetings with 

special interest and stakeholder groups. KMLP held meetings with regulatory agencies on May 12, 2005, 

July 21, 2005, December 7, 2005, and July 23, 2006. KMLP held public open houses in Hackberry, 

Iowa, Iota, and Ville Platte, Louisiana during March, 2006. KMLP considered public views and concerns 

identified during its outreach activities in the preparation of its Environmental Report. On March 6, 7, 9 

and 13, 2006, FERC staff toured the pipeline routes and attended the applicant-sponsored open houses to 

answer questions about the Pre-Filing Review process. 

On March 24, 2006, the FERC issued a Notice of Intent To Prepare an Environmental Impact 

Statement for the Proposed Kinder Morgan Pipeline Project and Request for Comments on Environmental 

Issues (NOI). The NOI was sent to 1,642 interested parties including federal, state, and local officials; 

agency representatives; conservation organizations; local libraries and newspapers; and property owners 

along the pipeline routes. Issuance of the NOI opened the time period for receiving written comments 

and established a closing date of April 24, 2006 for receiving comments. However, we kept the comment 

period open beyond that date and informed interested parties that we would continue to take comments 

throughout our review of the Project. We received letters with comments in response to our NOI from 

NOAA Fisheries Service, FWS, and LDWF. 

On April 26, 2006, the FERC issued a Notice of Site Visit and Public Meetings, which provided 

notice to the public that the FERC staff was conducting a site visit and holding three scoping meetings for 

the KMLP Project on May 8, 9, and 11, 2006. The April 26 notice included the specific times and 

locations (Ville Platte, Sulphur, and Iowa, Louisiana) for the scoping meetings. The scoping meetings 

provided an opportunity for the general public to learn more about the Project and to participate in our 

analysis by commenting on issues to be included in the EIS. Two persons commented at the Ville Platte 

meeting, two persons commented at the Sulphur meeting, and two persons commented at the Iowa 

meeting. Transcripts of these comments are part of the public record for the KMLP Project. On May 10, 

 1-6 Introduction 
2006, we conducted an aerial review of the Project by helicopter and we took a boat tour of the pipeline 

route in the northern end of Sabine Lake and vicinity. On May 9 and 11, 2006, we conducted a groundbased site visit of the entire route, which was open to the public. 

In addition to the public notice process discussed above, we conducted additional agency 

consultations to identify issues that should be addressed in this draft EIS. These consultations included 

interagency meetings on May 11 and October 5, 2006, both in Lake Charles, Louisiana. Participants at 

one or both meetings included representation from the COE, NOAA Fisheries Service, FWS, and LDWF. 

Issues discussed during these meetings included routing alternatives to avoid impacts to wetlands, 

potentially affected EFH and oyster beds, construction methods at wetland and waterbody crossings, and 

potential effects to the Perry Ridge Shore Protection Project and the Black Bayou Hydrologic Restoration 

Project. 

Issues identified in scoping comments and through input from resource agencies are summarized 

in table 1.4-1. We used the scoping comments to help focus the analysis in the draft EIS on potentially 

significant environmental issues related to the proposed action. 

TABLE 1.4-1 

Issues Identified in the Public and Agency Scoping Process for the KMLP Project 

Issue Specific Topics Raised in Comments 

EIS Section Where 

Comments are 

Addressed 

Proposed Action Purpose of the project; construction methods; depth of pipeline; 

right-of-way widths. 

1.1, 2.2, 2.3 

Alternatives Possibility of using existing pipelines instead of building a new 

one; routing alternatives to avoid impacts to wetlands, oyster 

beds, or lands suitable for new housing. 

3.0 

Geology and Soils Soil compaction after laying pipe across crawfish ponds and rice 

fields. 

4.2.2.1 

Water Use and Quality Potential impacts on water quality; potential impacts to 

underground irrigation systems. 

4.3 

Wetlands Potential impacts on wetlands; potential impacts on hydrologic 

restoration projects. 

4.4, 4.4.2.5 

Vegetation Potential impacts on riparian habitat; clearing of forested areas 

for drill sites. 

4.3.2.2, 4.4.2, 4.5.2, 

4.6.1.2 

Wildlife and Aquatic 

Resources 

Potential impacts on fisheries, marine fishery resources, EFH, 

and nesting habitat for colonial wading birds. 

4.6 

Threatened and 

Endangered Species 

Potential impacts on federally and state listed threatened, 

endangered, and special status species. 

4.7 

Land Use Potential impacts to the existing dredge material placement area 

on the northern bank of the Calcasieu River. 

4.8 

Socioeconomics Potential secondary impacts. 4.9 

Reliability and Safety Conformance with safety standards; responsibilities of 

construction contractors. 

4.13 

Mitigation Measures to avoid, minimize, and offset impacts to wetlands. All sections and 5.2 

This draft EIS was filed with the EPA. A formal notice indicating the availability of the draft EIS 

was published in the Federal Register, and the document has been mailed to individuals and organizations 

 1-7 Introduction 
on the mailing list prepared for the project (see appendix A). In accordance with the CEQ regulations 

implementing NEPA, the public has the opportunity to comment on the draft EIS in the form of written 

comments. We would review and use the comments to prepare the final EIS for the KMLP Project. All 

timely comment letters received on the draft EIS would be addressed in the final EIS. In addition, the 

FERC will hold public meetings in the project area to obtain comments on the draft EIS. We will issue a 

separate notice announcing the times and locations of those meetings. 

1.5 NONJURISDICTIONAL FACILITIES 

Under section 7 of the NGA, the FERC is required to consider, as part of a decision to certificate 

jurisdictional facilities, all factors bearing on the public convenience and necessity. Toward this end, the 

FERC may need to consider the environmental impact of related “nonjurisdictional” facilities that would 

be constructed upstream or downstream of the jurisdictional facilities for the purpose of delivering, 

receiving, or using the proposed gas volumes. Nonjurisdictional facilities are those facilities related to the 

Project that would be constructed, owned, and operated by others not subject to FERC jurisdiction. 

The jurisdictional facilities for the Project are described in detail in section 2.1 of this draft EIS. 

The only nonjurisdictional facility would consist of a pipeline to connect the KMLP Project to the 

existing Bridgeline intrastate pipeline. The Bridgeline interconnect site would be located at the end of the 

Enbridge Offshore Pipeline (UTOS) near Johnsons Bayou, on the north side of SH 82, approximately 16 

miles east of the Sabine Pass LNG Terminal. The connecting pipeline would be approximately 500 feet 

long (its diameter is still being determined) and would require about 1.15 acres of land, all contained 

within an existing natural gas facility. The pipeline would be constructed by its owner/operator, 

Bridgeline Holdings, L.P., at a time that is expected to coincide with the construction timeframe for the 

KMLP Project in order to be available when the KMLP Project is placed in service by April 1, 2009. 

Organizations responsible for approving the connecting pipeline would include the Coastal Management 

Division of LDNR (for a CUP), the COE (for review of jurisdictional wetland issues, if any), and other 

resource agencies (e.g., for threatened and endangered species and cultural resources). 

We use four factors to determine whether there is sufficient federal control and responsibility 

over a project as a whole to warrant environmental analysis of Project-related nonjurisdictional facilities. 

These factors are: 

• Whether the regulated activity comprises “merely a link” in a corridor type project (e.g., a 

transportation or utility transmission project); 

• Whether there are aspects of the nonjurisdictional facility in the immediate vicinity of the 

regulated activity that affect the location and configuration of the regulated activity; 

• The extent to which the entire Project would be within the FERC’s jurisdiction; and 

• The extent of cumulative federal control and responsibility. 

With regard to the first factor, the jurisdictional facilities (i.e., the KMLP Project) are a link in a 

natural gas transportation project. The KMLP Project would connect the Sabine Pass LNG Terminal with 

other interstate and intrastate pipelines that ultimately deliver natural gas downstream to consumers. 

Therefore, this factor favors the FERC’s review of the proposed nonjurisdictional facility. 

With regard to the second factor, the Project would transport natural gas received from the Sabine 

Pass LNG Terminal to the nonjurisdictional Bridgeline connecting pipeline, but the design and route of 

 1-8 Introduction 
the KMLP Project has not been uniquely influenced by the location or configuration of the 

nonjurisdictional facility. The KMLP Project would interconnect with one other pipeline in the Johnsons 

Bayou area in addition to the Bridgeline pipeline (at the Southwest Loop Johnson’s Bayou Delivery 

Point). In addition, Kinder Morgan states that the proximity of the NGPL pipeline to the Sabine Pass 

LNG Terminal, the availability of lease capacity on the existing NGPL and UTOS pipelines, and the 

multiple pipelines potentially available at the end of the UTOS pipeline were the factors that influenced 

the decision to transport gas to the Johnsons Bayou area. Therefore, this factor does not favor the FERC’s 

review of the proposed nonjurisdictional facility. 

With regard to the third factor, intrastate pipeline facilities are regulated by state and local 

permitting agencies. The FERC has no authority over the permitting, licensing, funding, construction, or 

operation of the nonjurisdictional Bridgeline connecting pipeline. Therefore, this factor also weighs 

against extending the scope of the environmental review. 

With regard to the fourth factor, federal control is determined by the amount of federal financing, 

assistance, direction, regulation, or approval inherent in a project. The nonjurisdictional Bridgeline 

connecting pipeline would be a private construction project under state and local jurisdiction. The federal 

government has no financial involvement, and no federal funds are involved. As noted above, the 

Bridgeline connecting pipeline would be located within the fenced area of an existing natural gas facility 

that has been previously disturbed. Although no wetlands appear within the footprint of the interconnect 

site, construction of the connecting pipeline could impact wetlands (e.g., from runoff and erosion) that are 

part of the nearby coastal marsh. It is anticipated that such impacts, if any, would be minor and 

temporary and would be authorized under a COE nationwide permit. Other federal agencies are expected 

to have either very limited or no involvement in the approval of the nonjurisdictional Bridgeline pipeline. 

Therefore, cumulative federal control is minimal, and this factor does not warrant extending the FERC’s 

environmental review. 

Based on the results of this four factor test applied to the KMLP Project, we have determined that 

only one factor favors examining the nonjurisdictional facility. Therefore, insufficient justification exists 

to warrant extension of the FERC’s environmental review to include the nonjurisdictional facility. 

 1-9 Introduction 
[This page intentionally left blank] 
 2-1 Description of the Proposed Action 

2.0 DESCRIPTION OF THE PROPOSED ACTION 

2.1 PROPOSED FACILITIES 

KMLP proposes to construct and operate a natural gas pipeline system (the “Project”) to 

interconnect the Sabine Pass LNG Terminal (Docket No. CP04-47-000) currently under construction with 

intrastate and interstate pipeline infrastructure in southwest Louisiana. The Project would consist of three 

segments of pipelines (totaling 135.7 miles), associated pipeline-support facilities (such as pig1

 launchers, 

pig receivers, and MLVs), and 14 interconnects (including regulation and metering equipment) with 

existing intrastate and interstate pipelines. Figure 2.1-1 shows the Project vicinity and appendix B 

provides detailed maps. 

This section describes the three pipeline segments (known as Leg 1, Leg 2, and the FGT Lateral), 

their support facilities, workspaces extra to the pipelines’ rights-of-way, interconnect sites, access roads, 

and yards for pipe storage and contractor use during the construction phase. Table 2.1-1 summarizes the 

pipelines proposed. 

TABLE 2.1-1 

Proposed KMLP Pipelines 

MP 

Parish Begin End 

Length 

(miles) 

Leg 1, 42-inch-diameter 

Cameron 

Calcasieu 

Jefferson Davis 

Acadia 

Evangeline 

Leg 2, 36-inch-diameter 

Cameron 

FGT Lateral, 24-inch-diameter 

Acadia 

Project Total 

0.0 

24.6 

74.9 

99.4 

112.5 

0.0 

110.6a

24.6 

74.9 

99.4 

112.5 

132.2 

1.2 

2.3 

24.6 

50.3 

24.5 

13.1 

19.7 

1.2 

2.3 

135.7 

_______________ 

a

 The FGT Lateral would start at MP 110.6 on Leg 1 and go for 2.3 miles. 

KMLP proposes to commence construction on Leg 1 and Leg 2 in November 2007 and on the 

FGT Lateral in October 2008. Leg 2 and interconnects would be completed by April 2008 and brought 

into service by October 1, 2008. Leg 1, the FGT Lateral, and their respective interconnects would be 

completed by November 2008 and brought into service by April 1, 2009. 

 

1

 A pig is a mechanical device that passes through the interior of a pipeline to clean or to inspect it. 
2-2 

PUBLIC 

FIGURE 2.1-1 

General Location of KMLP Project 
 2-3 Description of the Proposed Action 

2.1.1 Pipelines 

The KMLP Project would include the construction and operation of Leg 1, Leg 2, and the FGT 

Lateral. These three pipelines would be built from carbon-steel pipe manufactured in accordance with 

API 5L – the American Petroleum Institute’s specifications for seamless and welded steel line pipe for 

conveying gas in the natural gas industries. 

Leg 1 

Leg 1 would consist of 132.2 miles of 42-inch-diameter pipeline. It would receive gas from the 

Sabine Pass LNG Terminal at up to 1,440 pounds per square inch pressure gauge (psig) and would have a 

firm, peak day capacity of at least 2,130,000 decatherms (Dth) per day. 

The route followed by Leg 1 would originate at the Sabine Pass LNG Terminal (currently under 

construction) located on the east bank of the Sabine Pass waterway and the south side of SH 82 in 

Cameron Parish. From the Terminal it would proceed northwards, crossing SH 82, and enter Sabine 

Lake, which it would traverse in a north-northeasterly direction without entering the Texas portion of 

Sabine Lake at any point. Leg 1 would exit Sabine Lake at Shell Island near the mouth of the Sabine 

River and then proceed eastwards along the southern banks of the Sabine River and then, entering 

Calcasieu Parish, along the southern banks of the Gulf Intracoastal Waterway (GIWW). After crossing 

the GIWW in a northeasterly direction, Leg 1 would proceed eastwards again, cross Bayou Choupique, 

cross the Calcasieu River and Devil’s Elbow just north of Choupique Island – thus avoiding Lake Charles 

to the north – and then turn northwards to a point south of Iowa, Louisiana before turning in an eastnortheasterly direction and leaving Calcasieu Parish. 

Leg 1 would continue in an east-northeasterly direction, crossing Interstate Highway 10, to a 

point adjacent to Gum Gully, then turn eastwards, crossing Bayou Nezpique and entering Acadia Parish. 

After crossing Bayou Nezpique, Leg 1 would proceed in a north-northeasterly direction and cross SH 190 

into Evangeline Parish. Once in Evangeline Parish, the route would proceed in a generally northeasterly 

direction and terminate at an interconnect site with the CGT pipeline system. 

Leg 2 

Leg 2 would consist of 1.2 miles of 36-inch-diameter pipeline. It would receive gas from the 

Sabine Pass LNG Terminal at up to 1,100 psig, and would have a firm, peak day capacity of at least 

1,265,000 Dth per day. Leg 2 would commence at a receipt point within the Sabine Pass LNG Terminal 

and continue to a point of interconnection with the existing NGPL pipeline just south of SH 82 in 

Cameron Parish, Louisiana. Leg 2 would include 200,000 Dth per day of leased transportation capacity 

on the existing portion of the NGPL pipeline and the UTOS lateral extending to the Johnsons Bayou 

Southwest Loop area, also in Cameron Parish. 

Leg 1 and Leg 2 would be interconnected within the Sabine Pass LNG Terminal to allow bidirectional metering and provide flow capacity of not less than 1,065,000 Dth per day. 

FGT Lateral 

The FGT Lateral would consist of 2.3 miles of 24-inch-diameter pipeline. It would receive gas at 

up to 1,440 psig from Leg 1 and would have a potential capacity of up to 319,500 Dth per day. The 

lateral would originate on Leg 1 at MP 110.6, in Acadia Parish, run eastwards across Bayou des Cannes, 

and terminate at FGT compressor station #7, also in Acadia Parish. 
 2-4 Description of the Proposed Action 

Pig Launchers/Receivers and Mainline Block Valves 

Pig launchers/receivers and MLVs are necessary for proper maintenance and operation of a 

pipeline. The proposed milepost locations of these facilities are provided in table 2.1.1-1. 

TABLE 2.1.1-1 

Pig Launchers/Receivers and Mainline Block Valves 

Facility MP Parish 

Leg 1

MLV #1 0.0 Cameron 

Pig Launcher 0.0 Cameron 

MLV #2 20.1 Cameron 

MLV #3 39.1 Calcasieu 

MLV #4 47.7 Calcasieu 

MLV #5 54.5 Calcasieu 

MLV #6 73.8 Calcasieu 

MLV #7 93.1 Jefferson Davis 

MLV #8 110.0 Acadia 

MLV #9 116.8 Evangeline 

Pig Receiver 132.2 Evangeline 

MLV #10 132.2 Evangeline 

Leg 2

MLV #1 0.0 Cameron 

Pig Launcher 0.0 Cameron 

Pig Receiver 1.2 Cameron 

MLV #2 1.2 Cameron 

FGT Lateral

MLV #1 0.0 Acadia 

Pig Launcher 0.0 Acadia 

Pig Receiver 2.3 Acadia 

MLV #2 2.3 Acadia 

In order to undertake periodic cleaning and inspections by means of intelligent pigging, an 

appropriately sized pig launcher would be temporarily installed at the origin of each of the three pipelines 

along with a pig receiver of the same size at the endpoint. Although the installation of these launchers 

and receivers would be temporary and periodic, the piping and valves for each of the three pipelines 

would have to be configured to accommodate them. 

MLVs would be installed to enable the isolation of individual pipeline segments in order to 

contain unplanned pipeline-system upsets and permit controlled venting as part of a planned blowdown of 

the Project. Each pipeline would have a MLV at its origin and endpoint. Leg 1 would have eight 

additional MLVs installed at locations specified by U.S. Department of Transportation (DOT) safety 

regulations, i.e., in areas of relatively sparse population in order to minimize the social impacts of 

blowdown noise and the likelihood of vandalism. All MLVs would be installed within the permanent 
 2-5 Description of the Proposed Action 

right-of-way and, to the extent practicable, located near existing roads so as to minimize the construction 

of access roads. Each MLV would be fenced, gated, and locked; the valve itself would be buried but 

valve operators and controls would be located above ground. Each MLV would be capable of being 

remotely operated and controlled by a Supervisory Control and Data Acquisition (SCADA) system that 

would monitor operating parameters (e.g., valve position, gas pressure, and flow rate) and detect any 

leaks. The SCADA control room would be located in Houston, Texas. 

Jurisdictional Interconnects 

Interconnecting pipelines from the Project to interstate (but not intrastate) pipelines are subject to 

FERC jurisdiction, as is the Sabine Pass LNG Terminal. These 15 interconnecting pipelines are described 

in section 2.1.2 below along with the 14 interconnect sites at which they would connect with the Project. 

2.1.2 Aboveground Facilities 

The Project would deliver gas to 15 existing interstate pipelines and one existing intrastate 

pipeline via 14 interconnect installations. These installations would regulate and meter the flow of gas 

from the pipelines of the Project to the recipient pipeline system. Each interconnect site would comprise 

one or more meter runs consisting of: 

• Custody-transfer flow meter; 

• Pressure regulator; 

• Isolation block valves; 

• Flow control and high-pressure override valves; and 

• Associated instrumentation and controls. 

The sites would be fenced and gated and include a communications building that would contain a 

satellite link to the SCADA system and a telephone service for SCADA back-up as well as vocal 

communications. Electrical power would be provided for cooling, lighting, and ventilation as well as for 

the monitoring and control equipment. 

Interconnects would be located as close as practicable to the intersections of the Project and each 

individual customer pipeline system in order for the connecting pipelines to be as short as possible. 

Approximate locations and lengths of the interconnects are listed in table 2.1.2-1. 

The connecting pipelines would be built, owned, and operated by their respective customer 

pipeline companies2

. Because each of those companies (with the exception of Bridgeline Holdings, 

whose lateral would be intrastate) would be required to obtain authorization from the FERC to construct 

them, these connecting pipelines are not included in the environmental analysis presented in this draft 

EIS. 

 

2

 It is assumed that the connecting pipelines would be constructed and ready for service when the KMLP Project 

becomes operational. 
 2-6 Description of the Proposed Action 

TABLE 2.1.2-1 

Interconnect Locations and Connecting Pipelines 

Interconnect Name MP Parish Lateral Owner/Operator 

Lengtha

(feet) 

Leg 1

Transcontinental Gas Pipeline Corporation 0 

Texas Gas Transmission 0 

Southwest Loop Delivery 

Point 

28.2 Calcasieu 

Florida Gas Transmission 0 

Sabine Interconnect 61.4 Calcasieu Sabine Pipeline, LLC 0 

TGTPL Interconnect 87.5 Jefferson Davis Tennessee Gas Pipeline Company 0 

TLG Interconnect 91.5 Jefferson Davis Trunkline Gas Company, LLC 0 

TGT Interconnect 110.0 Acadia Texas Gas Transmission 300 

ANR #1 Interconnect 111.3 Acadia ANR Pipeline Company 0 

ANR #2 Interconnect 112.0 Acadia ANR Pipeline Company 0 

TET Interconnect 117.0 Evangeline Texas Eastern Transmission, LLC 0 

Transco Interconnect 122.1 Evangeline Transcontinental Gas Pipe Line 

Corporation 

200 

CGT Interconnect 132.2 Evangeline Columbia Gulf Transmission 100 

Leg 2 

NGPL Interconnect 1.2b Cameron Natural Gas Pipeline Company of America 0 

Bridgeline Interconnect N/Ac Cameron Bridgeline Holdings, L.P. 100 

Transcontinental Gas Pipeline Corporation 100 

Texas Gas Transmission 100 

Southwest Loop, Johnsons 

Bayou Delivery Point 

N/Ac Cameron 

Florida Gas Transmission 100 

FGT Lateral

FGT Interconnect 2.3 Acadia Florida Gas Transmission 0 

_______________ 

a

 A value of 0 feet indicates the lateral is expected to be located completely within the interconnect facility. b

 Located at the end of Leg 2 within Sabine Pass LNG Terminal property. 

c

 Located in Johnsons Bayou near the end of the existing UTOS system. 

2.1.3 Ancillary Areas 

Ancillary areas would include temporary workspaces outside of the construction right-of-way, 

access roads to the pipeline right-of-way, and pipe storage and contractor yards (see table 2.1.3-1). 

Extra Workspaces 

KMLP has requested permission for 864 extra workspaces totaling 303.5 acres. These 

workspaces would be needed in areas where special construction techniques are required, such as road, 

railroad, wetland, and waterbody crossings, as described fully in section 2.3. The size, shape, and 

configuration of each proposed extra workspace are unique due to the particular conditions at its proposed 

location, although they are typically 0.2 acres or less. These are shown in the facility maps in appendix B 

and are listed in appendix C. 
 2-7 Description of the Proposed Action 

TABLE 2.1.3-1 

Number of Ancillary Areas by Parish/County 

Parish/County Extra Workspaces Access Roads 

Pipe Storage and 

Contractor Yards 

Orange County, TX 3 0 0 

Cameron Parish, LA 86 5 0 

Calcasieu Parish, LA 354 43 5 

Jefferson Davis Parish, LA 213 13 4 

Acadia Parish, LA 81 9 0 

Evangeline Parish, LA 127 5 3 

Total 864 75 12 

Access Roads 

To the extent possible, KMLP would access the right-of-way and facilities (once built) from 

existing access roads and from roads crossed by the right-of-way. These include private roads, drives, 

lanes, and other roads that may require some modifications or improvements in order to support the 

expected loads and size of construction equipment and materials safely. 

Construction of and/or modifications to these access roads would include grading plus 

maintaining to prevent rutting, and, in some instances, placing of additional gravel onto the existing 

surface. Wherever possible, new access roads would be constructed of board matting, which would be 

removed after the construction phase. 

Appendix C, table C-2 lists access roads, including their locations and dimensions; the type of 

construction, including modifications or improvements proposed; and the amount of surface area affected 

by them. 

Pipe Storage and Contractor Yards 

KMLP proposes to use 12 temporary yards for pipe storage and contractor staging during 

construction of the Project facilities. See table C-3, appendix C for the location of the pipe storage and 

contractor yards. 

2.2 LAND REQUIREMENTS 

Construction of the Project would disturb 3,031 acres in total. Of this, 841 acres would be 

required for operation of the Project facilities. The remaining 2,190 acres would be restored to preconstruction land use. Table 2.2-1 summarizes the land requirements of all facilities of the Project. 

2.2.1 Pipeline Rights-of-Way and Extra Workspaces 

KMLP proposes to use a variety of construction right-of-way widths that would differ not only 

according to the diameter of the pipeline being installed, but also by land cover and whether topsoil would 

be segregated or not. Table 2.2-1 identifies land disturbed during construction and operation of the 
 2-8 Description of the Proposed Action 

Project. Approximately 2,565.5 acres would be disturbed in the rights-of-way and extra workspaces 

needed to construct Leg 1, Leg 2, and the FGT Lateral. KMLP’s proposed construction rights-of-way 

widths include the following configurations based on its proposed construction methods. The 

construction methods are described in more detail in section 2.3.1. 

Uplands: 

• A 125-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 36-inchdiameter Leg 2 with no soil segregation; 

• A 155-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 36-inchdiameter Leg 2 with ditch-plus-soil-side segregation; 

• A 165-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 36-inchdiameter Leg 2 with full-width segregation; 

• A 100-foot-wide construction right-of-way for the 24-inch-diameter FGT Lateral with no soil 

segregation; 

• A 120-foot-wide construction right-of-way for the 24-inch-diameter FGT Lateral with ditchplus-soil-side segregation; and 

• A 130-foot-wide construction right-of-way for the 24-inch-diameter FGT Lateral with fullwidth segregation. 

Unsaturated Wetlands: 

• A 100-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 24-inchdiameter FGT Lateral in wetland crossings of less than 100 feet (see section 4.4.2.3 for 

further discussion); 

TABLE 2.2-1 

Locations and Land Requirements for the Project 

Facility 

Land Affected 

During 

Construction 

(acres) 

Land Affected 

During 

Operation 

(acres) 

Leg 1 Pipeline 2,239.2 806.3 

Leg 2 Pipeline 7.0 1.5 

FGT Lateral 27.9 13.9 

Extra Workspaces 291.5 0.0 

Aboveground Facilities 12.3 12.3 

Pipe Storage and Contractor Yards 378.7 0.0 

Access Roads 74.2 6.9 

TOTAL 3,030.7 840.9 

_______________ 

Note: Due to rounding, totals may not add up. 
 2-9 Description of the Proposed Action 

• A 125-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 24-inchdiameter FGT Lateral in wetland crossings of greater than 100 feet (see section 4.4.2.3 for 

further discussion); and 

• A 155-foot-wide construction right-of-way where the 42-inch-diameter Leg 1 and 36-inchdiameter Leg 2 are parallel and 50 feet apart. 

Saturated Wetlands (Marsh): 

• A 100-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 and the 24-inchdiameter FGT Lateral in wetland crossings of less than 100 feet (see section 4.4.2.3 for 

further discussion); and 

• A 125-foot-wide construction right-of-way for the 42-inch-diameter Leg 1 in wetland 

crossings of greater than 100 feet (see section 4.4.2.3 for further discussion). 

Open Water (Sabine Lake): 

• A 300-foot-wide construction right-of-way for Leg 1 in water less than 8 feet deep; and 

• A 200-foot-wide construction right-of-way for Leg 1 in water greater than 8 feet deep. 

KMLP requested construction rights-of-way widths greater than 125 feet in upland areas along 

Leg 1 with ditch-plus-spoil-side or full-width topsoil segregation; along the FGT Lateral with full-width 

topsoil segregation; and along the segment where Leg 1 and Leg 2 are parallel and 50 feet apart. We 

approve the request for a 155-foot-wide construction right-of-way where Leg 1 and Leg 2 are parallel and 

50 feet apart. We also approve the request for up to 125-foot-wide construction rights-of-way for Leg 1 

in uplands due to the large diameter of the pipe and local soil conditions and to accommodate topsoil 

segregation. However, we do not believe that the other requests for widths greater than 125 feet are 

justified by KMLP and we do not believe that KMLP has justified the request for a construction right-ofway width of more than 100 feet along the FGT Lateral (see table 2.3-1 in the following section). 

Therefore, we recommend that: 

• KMLP limit its nominal construction right-of-way width for Leg 1 and the FGT Lateral 

in upland areas to 125 feet and 100 feet, respectively. If additional right-of-way width is 

necessary, KMLP shall file with the Secretary a site-specific construction plan and 

written justification for any additional right-of-way width for review and written 

approval by the Director of OEP prior to construction.

In wetlands, KMLP requested a 125-foot-wide construction right-of-way for wetland crossings of 

greater than 100 feet. KMLP further requested that a 100-foot-wide construction right-of-way be used for 

wetland crossings of less than 100 feet. For comparison, our Procedures limit the construction right-ofway width in wetlands to 75 feet. KMLP justified the expanded rights-of-way in saturated wetlands 

based the feasibility to cross these wetlands using the push-pull method. The push-pull method would be 

used in wetland crossings less than 100 feet, but in crossings greater than 100 feet the push-pull method is 

not feasible due to the excessive distance between accessible fabrication staging areas. In unsaturated 

wetlands, KMLP justified the expanded rights-of-way based on the large diameter of the pipeline, heavy 

equipment, poor soil stability, and accessibility to upland areas to place spoil. The justifications provided 

by KMLP are acceptable for the installation of the 42-inch-diameter Leg 1, but not for the 24-inchdiameter FGT Lateral. Therefore, we are restricting the construction in wetlands along the FGT Lateral to 

a 75-foot-wide right-of-way as required by our Procedures. 
 2-10 Description of the Proposed Action 

Following construction, KMLP would maintain a 50-foot permanent right-of-way for operation of 

the pipeline(s). Approximately 806.3 acres would be retained for the permanent right-of-way for Leg 1, 

1.5 acres for Leg 2, and 13.9 acres for the FGT Lateral. 

2.2.2 Aboveground Facilities 

The 14 proposed interconnect sites would be located on a total of 12.3 acres. In general, sites 

would be 200 feet by 200 feet; and the largest would be 202 feet by 225 feet. Land within the fenced 

perimeter would be occupied by a communications building, piping, and other equipment. Portions of 

these sites may be paved, covered with gravel, or landscaped, depending on facility operations and 

maintenance requirements. 

2.2.3 Ancillary Areas 

A total of 74.2 acres would be required for access roads during the construction phase, about 7 

acres of which would be retained during the operations phase. All temporary access roads would be 

restored to the preconstruction condition and uses. The dimensions, location, and type of each access 

road are given in appendix C. 

The 12 temporary yards for pipe storage and contractor staging would range in size from 

approximately 20 acres to 60 acres and in total would require approximately 379 acres of land. The 

proposed locations of these yards are identified in appendix C. All yards would be returned to the 

preconstruction condition and former usage. 

2.3 CONSTRUCTION AND RESTORATION PROCEDURES 

This section describes the general construction procedures proposed by KMLP. Section 4.0 

contains more detailed descriptions of proposed construction, mitigation, and restoration procedures as 

well as additional measures to mitigate environmental impacts. 

The Project would be designed, constructed, operated, and maintained in accordance with the 

DOT regulations 49 CFR Part 192, “Transportation of Natural and Other Gas by Pipeline: Minimum 

Federal Safety Standards”; 18 CFR 380.15, “Guidelines to be Followed by Natural Gas Pipeline 

Companies in the Planning, Clearing, and Maintenance of Rights of Way and the Construction of 

Aboveground Facilities”; and other applicable federal and state regulations. 

KMLP would construct the Project facilities in accordance with its specifications (including a 

Construction Drawing Package of approved pipeline, facility, and equipment drawings) as well as with 

the FERC’s Upland Erosion Control, Revegetation and Maintenance Plan (our Plan) and Wetland and 

Waterbody Construction and Mitigation Procedures (our Procedures). KMLP has requested certain 

alternative measures to our Plan and Procedures, which are addressed in table 2.3-1 and discussed further 

in section 4.0. 

KMLP would prepare a Stormwater Pollution Prevention Plan (SWPPP), which would include an 

Erosion & Sediment Control (ES&C) Plan and a Spill Prevention and Response Plan (SPRP), for the 

proposed pipeline system. These plans would address potential spills of fuels, lubricants, and other 

hazardous materials and describe spill-prevention practices, spill-handling and emergency procedures, 

and training requirements. The SWPPP would incorporate state, county, and parish requirements and 

provisions of our Plan and Procedures (in particular, section IV.A of the latter) with any FERC-accepted 
 2-11 Description of the Proposed Action 

TABLE 2.3-1 

Acceptance or Denial of Requested Alternative Measures 

Applicable 

Item Requested Variance 

Justification for 

Variance Request 

Accepted/

Denied 

Basis for 

Acceptance/Denial 

Upland Erosion Control, Revegetation, and Maintenance Plan 

IV.A.2 A typical temporary 

construction right-of-way 

width of 125 feet in uplands 

(see specific MP locations 

in appendix D) 

To provide a safe work site 

and space for spoil storage 

Accepted 

only along 

Leg 1 

Accepted only for specific sites along 

Leg 1 listed in appendix D (not project 

wide) based on large pipe and local soil 

conditions and to accommodate topsoil 

segregation (see section 2.2.1) 

V.A.5 Land surfaces restored to 

pre-construction contours, 

unless such contours 

threaten the integrity of the 

pipeline 

To arrest erosion if the 

existing land surface within 

the right-of-way is rapidly 

eroding before construction 

and to prevent ponding of 

water 

Denied Denied project wide, but the FERC will 

consider based on site-specific 

information to be submitted by KMLP 

prior to construction (see section 4.1) 

VII.A.5 Annual vegetation 

maintenance (mowing) on a 

50-foot corridor 

Excessively long growing 

period in southwest 

Louisiana 

Denied Denied because annual mowing over 

entire 50-foot right-of-way would 

continually disrupt vegetation (see 

section 4.5.2.1) 

Wetland and Waterbody Construction and Mitigation Procedures 

IV.A.1.d 

& e 

Refueling activities in 

waterbodies 

Vessels and waterborne 

equipment have to be used 

in Sabine Lake and Sabine 

River 

Accepted Accepted only for Sabine Lake and 

Sabine River (see section 4.4.2.3) 

VI.A.3 A typical temporary 

construction right-of-way 

width of 125 feet in wetlands 

where the crossing length 

exceeds 100 feet and a 

right-of-way width of 100 

feet in wetlands where the 

crossing length is less than 

100 feet (see specific MP 

locations in appendix D) 

Larger equipment and soil 

limitations require a larger 

right-of-way to assure a 

safe work site and space for 

spoil storage 

Accepted 

only along 

Leg 1 

Accepted only for specific sites along 

Leg 1 listed in appendix D (not project 

wide) based on large pipe and local soil 

conditions (see section 4.4.2.3) 

VI.A.6 Two aboveground facilities 

located within jurisdictional 

wetlands (see specific MP 

locations in appendix D) 

Locations of interconnects 

dictated by intersection of 

the proposed pipeline and 

existing pipelines and by 

the location of the Sabine 

Pass LNG Terminal 

Accepted Accepted only for specific MP locations 

identified in appendix D (not project 

wide) based on the lack of practicable 

upland locations (see section 4.4.2.3) 

VI.B.1.e A portion of access roads 2 

and 3 constructed in 

wetlands 

Access is required from the 

GIWW to reach the HDD 

workspace needed to 

minimize impacts to 

wetlands 

Accepted Accepted only for specific portions of 

access roads 2 and 3 because these 

roads would permit the use of HDD, 

which avoids about 25 acres of wetland 

impacts (see section 4.4.2.3) 

VI.B.1.a Some extra workspaces 

located within 50 feet of 

wetland boundaries (see 

specific MP locations in 

appendix D) 

Justification is site specific 

(see appendix D) 

Accepted Accepted only for specific sites listed in 

appendix D (not project wide) based on 

lack of practicable locations with 50-foot 

setbacks; also some sites are to 

facilitate HDD or other methods 

designed to reduce impacts (see 

appendix D) 

V.B.2.a Some extra workspaces 

located within 50 feet of 

water's edge (see specific 

MP locations in appendix D) 

Justification is site specific 

(see appendix D) 

Accepted Accepted only for specific sites listed in 

appendix D (not project wide) based on 

lack of practicable locations with 50-foot 

setbacks; also some sites are to 

facilitate HDD or other methods 

designed to reduce impacts (see 

appendix D) 
 2-12 Description of the Proposed Action 

alternative measures. These plans would be in force during the construction and operation phase of the 

project. To ensure that these plans are developed, we recommend that: 

• KMLP file its project-specific SWPPP, including an ES&C Plan and SPRP, with the 

Secretary for review and written approval by the Director of OEP prior to construction.

2.3.1 Pipelines 

Construction of the Project would involve a range of construction methods that fall into a number 

of categories shown in table 2.3.1-1. Appendix E shows the pipeline construction methods proposed by 

milepost (other than for crossings of waterbodies, roads and railroads, and foreign pipelines). 

TABLE 2.3.1-1 

Construction Methods by Category

Category Construction Methods 

Upland Conventional 

(described in section 2.3.1.1 of this 

draft EIS) 

• Upland Construction without topsoil segregation 

• Upland Construction without topsoil segregation, KMLP 42” pipeline adjacent 

to foreign pipeline 

• Upland Construction without topsoil segregation, KMLP 24” pipeline adjacent 

to foreign pipeline 

• Upland Construction with full-width topsoil segregation, KMLP 42” pipeline 

• Upland Construction, KMLP 42” pipeline adjacent to foreign pipe with ditch 

plus spoil side 

• KMLP 36” and 42” pipelines within LNG Terminal, no topsoil segregation 

• KMLP 36” pipeline within LNG Terminal, no topsoil segregation 

Wetland 

(described in section 2.3.1.2 of this 

draft EIS) 

• Unsaturated Wetland with topsoil segregation 

• Saturated Wetland with topsoil segregation 

• Submerged Wetland without topsoil segregation (“Marsh Buggy 

Construction”) 

Sabine Lake 

(described in section 2.3.1.3 of 

this draft EIS) 

• Inland Open Water at water depth of less than 8 feet 

• Inland Open Water at water depth of 8 feet and more 

Special 

(described in section 2.3.1.3 of 

this draft EIS) 

• Horizontal Directional Drilling (HDD) 

• Water-body crossings (other than Sabine Lake) 

• Road and railroad crossings 

• Foreign pipeline crossings 

• Techniques for construction in rice fields and crawfish ponds 

• Techniques for construction in cropland and pasture 

• Techniques for residential areas 

• Techniques for commercial and industrial areas 

2.3.1.1 Conventional Upland Construction Methods 

In upland terrain of the Project, KMLP would use conventional overland construction techniques 

for large-diameter pipelines. Construction would follow a set of sequential operations as shown in figure 

2.3.1.1-1 and as further described below. In the typical pipeline construction scenario, the construction 

spread (crew) would proceed along the pipeline right-of-way in one continuous operation. As the spread 

moves along, construction at any single point along the pipeline, from initial surveying and clearing to 

backfilling and finish grading, would last approximately six to ten weeks. The number of construction 
2-13 

FIGURE 2.3.1.1-1 

Upland Pipeline Construction Sequence 

PUBLIC 
 2-14 Description of the Proposed Action 

spreads will be determined upon selection of a construction contractor. The entire process would be 

coordinated in such a manner as to minimize the total time an individual tract of land is disturbed and, 

therefore, exposed to erosion and temporarily precluded from its normal use. 

The basic steps of upland construction are described below. This description focuses on upland 

construction without topsoil segregation, but variations involving topsoil segregation and routing 

alongside foreign pipelines are also noted. KMLP would use Special Construction Techniques such as 

HDD in sensitive locations. These techniques are described in section 2.3.1.3 and listed in table 2.3.1-1. 

Surveying and Staking 

After notification of and coordination with affected landowners, a KMLP crew would conduct a 

civil survey and stake the outside limits of the right-of-way, the centerline of the pipeline, drainage 

centerlines and elevations, highway and railroad crossings, and any temporary extra workspace, such as 

lay down areas or staging areas for stream crossings. The Louisiana One Call system would be contacted 

and underground utilities (e.g., cables, conduits, and pipelines) would be located and flagged. 

Clearing and Grading 

Following surveying, KMLP would clear the right-of-way of obstacles. Large obstacles such as 

trees, rocks, brush, and logs would be removed. Timber would only be removed when absolutely 

necessary for construction purposes. Timber and other vegetation debris might be chipped for use as 

erosion-control mulch, burned, or otherwise disposed in accordance with applicable state and local 

regulations and landowner crossing agreements. Burning would be conducted in such a manner as to 

minimize the fire hazard and prevent heat damage to surrounding vegetation. Where necessary, fences 

would be cut and braced along the right-of-way, and temporary gates would be installed to control 

livestock and limit public access. The right-of-way would then be graded where necessary to create a 

reasonably level working surface to allow safe passage of construction equipment and materials. Where 

applicable – such as in residential and certain agricultural areas, as outlined in section 2.3.1.3 – conserved 

topsoil would be stockpiled separately from excavated subsoil. Temporary erosion control measures, 

such as silt fencing and interceptor dikes, would be installed immediately after initial disturbance of the 

soil. 

Trenching 

A rotary trenching machine, a track-mounted backhoe, or similar equipment would be used to 

excavate to a sufficient depth to allow a minimum of three feet of soil cover between the top of the pipe 

and the final land surface after backfilling. Due to the absence of consolidated bedrock near the surface, 

no blasting is anticipated. 

The trench would be excavated at least 12 inches wider than the diameter of the pipe, or a 

minimum of 54 inches for the 42-inch-diameter Leg 1, 48 inches for the 36-inch-diameter Leg 2, and 36 

inches for the 24-inch-diameter FGT Lateral. The sides of the trench would be sloped (for safety) with 

the top of the trench up to 30 feet across, or more, depending upon the stability of the native soils. 

Excavated soils would typically be stockpiled along the right-of-way on the side of the trench (the 

spoil side) away from the construction traffic and pipe assembly area (the working side). On actively 

cultivated agricultural tracts (except in most rice fields) and in residential areas, subsoil would be 

stockpiled separately from topsoil (see section 2.3.1.3). Where the route is collocated adjacent to an 

existing pipeline, the spoil would be placed on the same side of the trench as, but not directly over, the 

existing pipeline to keep working equipment off the operating pipeline. 
 2-15 Description of the Proposed Action 

Stringing 

Steel pipe for the pipeline would be procured in nominal 40-foot lengths called “joints” that 

would be protected with an epoxy coating that would have been applied at an external coating yard and 

shipped to strategically located materials storage areas known as pipe yards. (The beveled ends would 

have been left uncoated for the welding step.) 

The individual joints would be transported to the right-of-way by truck and placed by small crane 

in a single continuous line (i.e., strung) along the excavated trench. This would leave the strung pipe 

easily accessible to the construction personnel on the working side of the trench and allow the subsequent 

lineup and welding operations to proceed efficiently. See section 2.3.1.3 for a variation at waterbody 

crossings. 

Pipe Bending 

Since the joints of pipe delivered to the job site would be straight, bending of the joints would be 

required to allow the pipeline to follow natural grade changes and turns in the right-of-way. Prior to 

welding, selected joints would be bent to the desired angle in the field by track-mounted hydraulic 

bending machines. 

Pipe Assembly and Welding 

After stringing and bending are complete, the joints of pipe would be placed on temporary 

supports adjacent to the trench. The ends would be carefully aligned and welded together. Multiple 

passes would be made to achieve a full penetration weld. Only qualified welders would be allowed to 

perform the welding. Welders and welding procedures would be qualified according to applicable 

American Petroleum Institute (API) standards. 

Non-Destructive Examination and Weld Repair 

To ensure that the assembled pipe meets or exceeds the design strength requirements, the welds 

would be inspected visually and tested for integrity by means of non-destructive examination methods 

such as radiography (X-ray), or ultrasound, in accordance with American Society of Mechanical 

Engineers (ASME) standards. Welds displaying unacceptable slag inclusions, void spaces, or other 

defects would be repaired or cut out and re-welded. 

Coating Field Welds, Inspection, and Repair 

Following welding, the previously uncoated ends of the pipe at the joints would be epoxy coated. 

The coating on the completed pipe section would be inspected and any damaged areas would be repaired. 

Pipe Lowering 

The completed portion of pipe would be lifted off the temporary supports and lowered into the 

trench by side-boom tractors or equivalent equipment. Prior to lowering the pipe, the trench would be 

inspected to ensure that it is free of rocks and other debris that could damage the pipe or the coating. 

De-watering would also be undertaken if there were any stormwater in the trench. Before the pipe is 

lowered into the trench, the pipe and trench would be inspected to ensure that the pipe and trench 

configurations are compatible. 
 2-16 Description of the Proposed Action 

Figures 2.3.1.1-2 through 2.3.1.1-8 show typical cross-sections (at the stage of pipe lowering) for 

construction spreads respectively for different variations of upland construction methods. 

Padding and Backfilling

After the pipe is lowered into the trench, the trench would be backfilled. Previously excavated 

materials would be pushed back into the trench using bladed equipment or backhoes. Wherever the 

previously excavated material is found to contain large rocks or other materials that could damage the 

pipe or coating, clean fill or protective coating would be placed instead around the pipe prior to 

backfilling. Following backfilling, a small crown of material might be left to account for any future soil 

settling that might occur. Excess soil would be distributed evenly on the right-of-way, only in upland 

areas, while maintaining existing contours. Wherever topsoil segregation is performed, segregated topsoil 

would be placed in the trench after backfilling with subsoil is complete. 

Hydrostatic Test and Final Tie-In 

Following backfilling of the trench, the pipeline would be hydrostatically tested in accordance with DOT 

regulations to ensure that it is capable of safely operating at the design pressure. The testing process 

involves filling a segment of the pipeline with water and maintaining a prescribed pressure for a 

prescribed duration. The exact steps of that process would be as follows: 

1. Surface water used for testing is drawn through a screened intake; 

2. Test segments of the pipeline are capped and filled with water; and 

3. The water in the pipe is pressurized and held for a minimum of 8 hours. 

Any loss of pressure that cannot be attributed to other factors, such as temperature changes, 

would be investigated. If a leak or break in the line were to occur during testing, it would be repaired and 

the segment of pipe retested until DOT specifications were met. 

Upon completion of the test, the water would either be pumped to the next segment for testing or 

discharged. The test water would be discharged through an energy-dissipating device (two rows of hay 

bales staked to the ground with a silt fence in between in a 30-35-foot circle) in compliance with NPDES 

permit conditions. Although topography and the availability of test water would determine the length of 

each test segment, anticipated hydrostatic test water withdrawal and discharge locations are discussed 

further in section 4.3.2.2. Test water would contact only new pipe, and no chemicals would be added. 

Upon the successful testing and drying of a segment of pipe, the test cap and manifold would be 

removed, and the pipe would be connected to the remainder of the pipeline. No desiccant or chemical 

additives would be used to dry the pipe. See section 2.3.1.3 for a variation for pipeline segments installed 

through HDD. 

Cleanup and Restoration

Post-construction restoration activities would be in accordance with our Plan and Procedures as 

applicable, and FERC’s acceptance of the alternative measures requested by KMLP. After the segment of 

pipe has been installed, backfilled, and successfully tested, the right-of-way, temporary extra workspaces, 

and other disturbed areas would be finish-graded, and the construction debris would be disposed of 

properly. After construction, all disturbed areas would be restored to original contours, except at those 

locations where permanent changes in drainage would be required to prevent erosion, scour, and possible 

exposure of the pipeline (subject to the FERC’s acceptance of a site-specific request by KMLP prior to 

construction, as noted in table 2.3-1 and discussed further in section 4.1). See section 2.3.1.3 for the use 
2-17 

FIGURE 2.3.1.1-2 

Typical Cross-Section for Upland Construction of 42” Pipe Without Topsoil Segregat

PUBLIC 
2-18 

FIGURE 2.3.1.1-3 

Typical Cross-Section for Upland Construction of 42” Pipe Adjacent to Foreign Pipe without Tops

PUBLIC 
2-19 

FIGURE 2.3.1.1-4 

Typical Cross-Section of 42” Pipe with Full-Width Topsoil Segregation 

PUBLIC 
2-20 

FIGURE 2.3.1.1-5 

Typical Cross-Section for Upland Construction of 42” Pipe Adjacent to Foreign Pipe 

with Ditch-plus-Spoil-Side Topsoil Segregation 

PUBLIC 
2-21 

FIGURE 2.3.1.1-6 

Typical Cross-Section for Upland Construction of 42” and 36” Parallel Pipes within t

Sabine Pass LNG Terminal without Topsoil Segregation 

PUBLIC 
2-22 

FIGURE 2.3.1.1-7 

Typical Cross-Section for Upland Construction of 36” Pipe within the 

Sabine Pass LNG Terminal without Topsoil Segregation 

PUBLIC 
2-23 

FIGURE 2.3.1.1-8 

Typical Cross-Section for Upland Construction of 24” Pipe Adjacent to 

Foreign Pipe without Topsoil Segregation 

PUBLIC 
 2-24 Description of the Proposed Action 

of measures to return segregated topsoil in areas of cropland and pasture and in rice fields and crawfish 

ponds. 

Temporary and permanent erosion and sediment control measures, including silt fencing, 

diversion terraces, and vegetation, would also be installed per our Plan and Procedures. In most upland 

locations, an herbaceous vegetative cover would be re-established by spreading a grass seed and hydromulch mixture over the disturbed surface. See section 2.3.1.3 for a variation involving re-vegetation in 

areas of cropland and pasture. 

The type of seed would be selected to match adjacent cover, or as otherwise requested by the 

landowner or land management agency, or as recommended by the county extension agent. Depending 

upon the time of year, a seasonal variety, such as ryegrass, might be spread until a more permanent cover 

could be established. Steep slopes (e.g., stream banks) might require erosion control mats, revetments, or 

sod. Reseeding, fertilizing, and other measures would be employed until a cover equivalent to 

approximately 80 percent of similar, adjacent areas were achieved. Forested areas would be allowed to 

recover, except that no trees would be allowed to grow within the pipeline operational right-of-way so as 

to facilitate pipeline inspections. See section 2.3.1.3 for re-seeding of cropland, pasture areas, residential 

areas, and commercial areas. 

The success of re-vegetation would be monitored by KMLP (see section 2.5). Temporary and 

interim erosion control measures would be removed from areas where permanent measures are 

successfully in place. Private and public property, such as fences, gates, driveways, and roads that are 

disturbed by the pipeline construction would be restored to original or better condition. 

2.3.1.2 Wetland Construction Techniques 

Construction across delineated wetlands would occur in accordance of our Procedures, except 

where requested alternative measures are accepted. The construction technique used would be 

determined by the wetland conditions. In an unsaturated wetland, soil conditions would allow for topsoil 

segregation. In saturated wetlands, it would not be practicable to segregate topsoil. If there is enough 

standing water, floating construction techniques would be used such as push-pull method from a marsh 

buggy. In sensitive wetland areas or adjacent to large waterbodies, KMLP would use HDD to avoid 

impacts, as is described in section 2.3.1.3. 

Prior to commencement of construction in wetlands, KMLP would work with the COE, FWS, 

NOAA Fisheries, LDWF, other state and local agencies, and landowners to develop an acceptable sitespecific re-vegetation plan. 

Construction in Unsaturated Wetland 

The construction method employed in these areas would be similar to conventional upland 

techniques described in section 2.3.1.1, with some exceptions. Figures 2.3.1.2-1 and 2.3.1.2-2 show a 

typical cross-section for a construction spread in unsaturated wetlands. 

If normal construction equipment were to cause rutting or mixing of topsoil and subsoil, either 

low-ground-pressure equipment would be substituted for it, or a temporary board road would be installed. 

The choice of which of these two alternatives to use would be up to the construction contractor; both 

would allow passage of equipment with minimal disturbance to the surface and vegetation. 
 2-25 Description of the Proposed Action 

FIGURE 2.3.1.2-1 

Unsaturated Wetland Crossing with Topsoil Segregation 

PUBLIC 
 2-26 Description of the Proposed Action 

FIGURE 2.3.1.2-2 

Unsaturated Wetland Crossing with Topsoil Segregation 

PUBLIC 
 2-27 Description of the Proposed Action 

Trees would be cut to grade but only the stumps within 15 feet of the edge of the pipe trench 

would be removed unless safety concerns were to dictate otherwise. Topsoil over the pipe trench would 

be segregated from subsoils. A vegetated buffer zone would be left between the wetland and the upland 

construction areas, except in the pipe trench and travel lane. Erosion-control measures such as silt fences, 

interceptor dikes, and hay-bale structures would be installed and maintained to minimize sedimentation 

within the wetland. Trench plugs would be installed where necessary to prevent the unintentional 

draining of water from the wetland. 

Upon completion of construction, the right-of-way would be restored. Original surface hydrology 

would be re-established by backfilling the pipe trench and grading the surface either with backhoes or 

draglines operating from the board road or with low-ground-pressure tracked vehicles working in the 

spoil pile, depending upon the ambient water level, degree of soil saturation, and the bearing capacity of 

the soils. Segregated topsoil would be replaced in unsaturated wetlands. 

Marsh and wetlands along the Project range from saline to fresh, with varying degrees of 

saturation and water elevation, requiring a variety of plant species to be re-established. Unsaturated 

wetlands would be seeded. Areas where roots and stumps were removed in the pipe trench would allow 

existing vegetation to recover more rapidly in the remainder of the right-of-way once the board roads and 

spoil piles have been removed. In forested wetlands, trees greater than 15 feet in height would not be 

allowed to grow within 15 feet of the pipeline. Otherwise, unsaturated wetlands would be restored to 

their original state. 

Construction in Saturated Wetland 

The construction method employed in these areas would be similar to that described above for 

construction in unsaturated wetlands (see figure 2.3.1.2-3 and 2.3.1.2-4). Topsoil would be segregated 

except in areas where standing water is present or soils are saturated or frozen. In saturated soils, a 

concrete-coated pipe may be required to maintain negative buoyancy. 

Board mats and timbers would be used to facilitate the movement of equipment through and work 

within the wetlands. Equipment not associated with construction of the Project would be allowed to pass 

through the wetland in accordance with the our Procedures. 

Upon completion of construction, the right-of-way would be restored. Original surface hydrology 

would be re-established by backfilling the pipe trench and grading the surface either with backhoes or 

draglines operating from the board road or with low-ground-pressure tracked vehicles working in the 

spoil pile, depending upon the ambient water level, degree of soil saturation, and the bearing capacity of 

the soils. If topsoil is segregated, it would be replaced. Vegetation would be restored in accordance with 

our Procedures. 

Construction in Coastal (and other Submerged) Wetland 

Tidal marsh located between SH 82 and the southern shore of Sabine Lake between MP 1.5 to 

MP 3.92 and submerged freshwater marsh between MP 32.3 and MP 35.2 would be crossed using the 

push-pull method where conditions are compatible (i.e., wetland crossings less than 100 feet). 

A crane mounted on specially designed pontoons equipped with tracks, known as a marsh buggy, 

would be used to excavate a pipe trench (see figure 2.3.1.2-5). By backing the marsh buggy along the 

pipe trench centerline, and backfilling by tracking along the remains of the spoil pile after pipe 

installation, the construction right-of-way would be kept to the minimum width necessary for the pipe 

trench and the spoil pile, with no separate equipment space or passing lane. However, because of the 
 2-28 Description of the Proposed Action 

FIGURE 2.3.1.2-3 

Saturated Wetland Crossing without Topsoil Segregation 

PUBLIC 
 2-29 Description of the Proposed Action 

FIGURE 2.3.1.2-4 

Saturated Wetland Crossing without Topsoil Segregation 

PUBLIC 
 2-30 Description of the Proposed Action 

FIGURE 2.3.1.2-5 

Typical Submerged Marsh Crossing (Push-Pull) 

PUBLIC
 2-31 Description of the Proposed Action 

saturated condition of the soils, the slopes of both the pipe trench and the spoil pile would be very 

shallow, requiring a proportionately wider construction space for the trench and spoil pile (estimated to be 

90 feet). By keeping the stringing and welding of the pipe out of the submerged wetlands between 

staging areas, the area affected by construction would be kept to a minimum. Topsoil segregation would 

not be practical because the soil horizon would not be visible under water and the water would cause 

mixing of the topsoil and the subsoil. The pipe trench would remain flooded with water at all times, 

allowing flotation of the pipe. 

Temporary staging areas would be established at locations along the right-of-way that are 

accessible for construction equipment, personnel, and the delivery of materials via existing roads or 

waterways. Some staging areas might be set up on spud barges temporarily anchored in navigable 

waterways. Push-pull sections would be fabricated within these staging areas using a process similar to 

that described below for construction on barges in open inland waters. However, rather than moving the 

barge forward upon completion of each joint, the pipe would be pushed into the pipe trench. Floats would 

be strapped onto the pipe to keep it afloat to minimize drag on the bottom of the trench. A cable would be 

strung from the leading end of the push-pull section to the next staging area and placed in tension to guide 

the pipe along the trench. Because of the large bending radius of the 42-inch-diameter concrete-coated 

pipe, the trenches between staging areas would have to be nearly straight. The distances between staging 

areas would be limited by the weight of the pipe section and the pushing/pulling capacity of the 

construction equipment. 

Once the section of pipe has been floated into place, the floats would be cut and the pipe would 

be allowed to sink to the bottom of the trench. The marsh buggy would then backfill the trench and the 

disturbed area would be restored. Original surface hydrology would be re-established by backfilling the 

pipe trench (and flotation channel, where applicable) and grading the surface either with backhoes or 

draglines operating from low-ground-pressure tracked vehicles working in the spoil pile, depending upon 

the ambient water level, degree of soil saturation, and the bearing capacity of the soils. 

Submerged wetlands would typically be re-vegetated by transplanting mature herbaceous 

specimens at pre-established spacing. Some of these plants might be ones that were on the right-of-way 

before construction and were stored in temporary nurseries until restoration. Other plants would be 

obtained preferably from adjacent wetlands (collected over an area sufficiently large to minimize negative 

impact in the donor wetland) or else from local commercial nurseries. 

2.3.1.3 Special Pipeline Construction Techniques 

HDD Crossing Technique 

Major and other select waterbodies (not including open water construction across Sabine Lake), 

select highways, particularly congested pipeline corridors, and some wetland areas would be crossed by 

means of HDD. HDD would also be used to enter and exit Sabine Lake. KMLP is proposing a total of 

18 HDDs for the Project. A typical HDD installation for waterbody crossing is shown in figure 2.3.1.3-1 

and proposed HDD locations are listed by milepost in table 4.3.2.1-3 and appendix E. A complete 

description of the HDD process, including contingency plan, is provided in appendix I. 

HDD involves drilling a pilot hole under the waterbody, foreign pipeline, road, railroad, or 

wetland. The hole would be enlarged through successive reamings until the hole is large enough to 

accommodate the pipe. Throughout the process of drilling and enlarging the hole, a slurry called drilling 

mud of naturally occurring non-toxic materials such as bentonite clay and water, would be circulated 

through the drilling tools to lubricate the drill bit, remove drill cuttings, and hold the hole open. To 

capture drilling fluids in water-to-water HDDs and to minimize the release of drilling fluids to the surface 
2-32 

FIGURE 2.3.1.3-1 

Typical HDD Waterbody Crossing

PUBLIC 
 2-33 Description of the Proposed Action 

waterbody, a casing would be placed between the entry pit and the drill barge. Solids from any drilling 

fluids released to a surface waterbody would either settle out in the containment pits, or be rapidly 

dissipated by natural currents. Pipe sections long enough to span the entire crossing would be staged and 

welded along the construction work area on the opposite side of the waterbody (or other area being 

crossed) and then pulled through the drilled hole. 

The length of pipeline that can be installed by HDD depends upon soil conditions and pipe 

diameters, and is limited by available technology and equipment sizes (however, the maximum limit of 

HDD is about 5,000 feet). The main advantage of HDD is that the planned disturbance of the surface 

between the entry and exit points of the HDD is minimal, i.e., limited to the temporary deployment of 

telemetry cable, provided there is reasonable access to the entry and exit points for the drilling rig and 

fluids handling equipment. Also, it requires prefabrication of a section of pipe aboveground that is equal 

to the length of the HDD portion, and then pull that string back into the hole, the process disturbs the land 

cover and can create a depression (called a false trench) in areas outside of the construction right-of-way. 

Waterbodies crossed by HDD are discussed in section 4.3.2.1. Table 4.3.2.1-3 lists the 

approximate entry and exit locations, drill length, and features crossed by each proposed HDD.

Open-Cut Waterbody Crossing Technique 

The open cut crossing method is proposed for most minor waterbody crossings where dry 

(unsaturated) coil conditions are anticipated on the banks. This technique is similar to an upland open-cut 

technique. It would involve excavation of the pipeline trench across the waterbody, installation of a 

prefabricated segment of pipeline, and backfilling of the trench with native material. No effort would be 

made to isolate the stream flow from the construction activities. Backhoes and other excavation 

equipment would typically operate from one or both banks of the waterbody but could operate within the 

waterbody to achieve the necessary reach. Equipment in the waterbody would be limited to that needed 

to complete the crossing. All other construction equipment would cross the waterbody over equipment 

bridges, unless otherwise allowed by our Procedures for minor waterbodies. 

KMLP would minimize impacts to aquatic environments by implementing our Procedures. 

Construction activities would be scheduled so that the trench would be excavated immediately prior to 

pipe-laying activities. The duration of construction within each waterbody would be limited to 24 hours 

for minor waterbodies (10-feet wide or less) and 48 hours for intermediate waterbodies (greater than 10-

feet wide but less than or equal to 100 feet in width). In accordance with the FERC’s Procedures, 

excavated spoil would be stockpiled in the construction right-of-way at least 10 feet from the stream bank 

or in approved additional work areas, and would be surrounded by sediment-control devices. The 

waterbody banks would be restored to as near to pre-construction conditions as possible within 24 hours 

of completion of each open-cut crossing. 

Dry Waterbody Crossing Techniques 

Crossings of small perennial and intermediate streams would be accomplished in accordance with 

our Procedures. The pipeline would be installed by means of a dry-ditch method for crossings of 

waterbodies up to 30-feet wide (at the water’s edge at the time of construction) that are state-designated 

significant warmwater fisheries. KMLP proposes to cross all waterbodies up to 30-feet wide by dry ditch 

method, e.g., flume and horizontal bore. Appendix F lists all water bodies crossed and the crossing 

method. 

The dry flume crossing method would be used for some minor and intermediate waterbodies and 

would involve installation of a temporary dam and a flume pipe to divert the entire stream flow over the 
 2-34 Description of the Proposed Action 

construction area and allow for trenching of the crossing in dry or nearly dry conditions (see figure 

2.3.1.3-2). A 10-foot vegetated buffer zone would be left between the edge of the waterbody (or any 

associated wetlands) and the upland construction area. Dams would be constructed of sand bags, sand 

bags and plastic sheeting, or inflatable bladders to direct the flow into the flume pipe. Spoil removed 

during the trenching would be stored at least 10 feet away from the water’s edge (topographic conditions 

permitting). A section of pipe long enough to span the entire crossing would be fabricated on one bank 

and slipped under the flume pipe to the opposite bank. The trench would be backfilled and the bottom of 

the watercourse and banks restored and stabilized before the flume pipe and dams are removed. Sediment 

barriers, such as silt fencing, staked straw bales and trench plugs, would be installed to prevent spoil and 

sediment-laden water from entering the waterbody. 

Horizontal boring is a method that would involve pushing the pipe through a hole below minor 

waterbodies. Often, these waterbodies are drainaige ditches along the side of a road in which case both 

the waterbody and road would be bored. First, a bore pit would be dug on one side of the crossing and a 

receiving pit on the other. Both would be excavated to at least 5 feet below the surface. The bore pit 

would be graded such that the bore would be at the proper elevation for installation of the pipe. A boring 

machine would then be lowered to the bottom of the bore pit and placed on supports. The boring machine 

would cut a shaft under the waterbody by means of a cutting head mounted on an auger. The pipe would 

then be pushed through behind the auger. This method is also used for most major road or railroad 

crossings, as described below. 

Sabine Lake Crossing 

Leg 1 of the pipeline would enter and exit Sabine Lake by HDD. The construction methods in 

these areas would be as described below for HDDs, except that the pre-fabricated HDD pull sections at 

both the southern and northern end of the lake would be dewatered, floats would be strapped to the 

pipeline to provide positive buoyancy, and the pipeline would be floated across the water using tugboats 

(rather than allowed to drag across the lake bottom). KMLP anticipates that the installation of the pull 

section into the borehole can be completed in less than 24 hours. 

For construction in the open waters of Sabine Lake (from approximately MP 4.8 to MP 18.0), 

Leg 1 of the Project would be installed using shallow draft spud barges. The use of spud barges in areas 

of the lake that are less than 8 feet deep would require the excavation of a flotation channel within a 

construction right-of-way up to 300 feet wide. Using barges with anchor spuds would eliminate the 

need for an anchor spread and anchor-handling boats, minimizing the area affected by construction 

operations. Based on pre-construction surveys, KMLP proposes the following construction steps in the 

open water areas of Sabine Lake. 

The pipeline route would not cross over the Sabine River, but rather turn east at the mouth of the 

river around MP 18.6 and proceed along its southern banks through a series of HDDs and open cuts. 

However, the proposed HDD at the mouth of the Sabine River would have a temporary extra workspace 

that would protrude into the river and a pull section that would be floated across the river using tugboats. 

Other HDDs along the southern banks of the Sabine River would also have floating pull sections 

extending into the river, which would be held in place by timber piles. KMLP anticipates that the pull 

sections would lie across the water for less than 24 hours. 
 2-35 Description of the Proposed Action 

FIGURE 2.3.1.3-2 

Flume Crossing Method 

PUBLIC 
 2-36 Description of the Proposed Action 

Pre-Construction Survey 

KMLP has conducted a shallow-hazards survey within a 3,000-foot-wide corridor in Sabine Lake 

to identify existing foreign (i.e., third-party) pipelines, obstructions that may adversely affect 

construction, and potentially significant submerged cultural resources. Where water depths are 

sufficiently shallow, the pre-construction survey was accomplished by means of small, shallow draft 

boats equipped with remote-sensing instrumentation, including a magnetometer/gradiometer, side-scan 

sonar, sub-bottom profiler, bathometer, and Global Positioning System (GPS) navigation. Adjustments to 

the proposed centerline were made, where feasible, to avoid magnetic anomalies that might indicate 

obstructions or significant cultural resources. Where avoidance was not feasible, anomalies were further 

investigated by probing, sampling, or diving, and either removed or recovered, as appropriate and as 

approved by local agencies. KMLP plans to conduct a second shallow-hazards survey within the 

construction right-of-way immediately prior to construction to verify that conditions have not changed 

since the original survey and to locate foreign pipelines. The right-of-way centerline and boundaries 

would then be staked with bamboo poles or floating buoys for excavation. 

Excavation 

The trench for the Project would be excavated by means of a barge-mounted clam-bucket (or 

equivalent) dredge. With a draft of up to seven feet, it would be necessary for the dredge barge to 

excavate a flotation channel to provide access for itself from existing navigation channels to the right-ofway (see figure 2.3.1.3-3), and along the right-of-way, in water depths of less than 8 feet (see figure 

2.3.1.3-4). In water depths greater than 8 feet, a flotation channel would not be required (see figure 

2.3.1.3-5). The dredge barge would cast pipe-trench and flotation-channel spoil to either side of the rightof-way centerline, keeping the spoil below the water surface, where feasible, to minimize wave-generated 

turbidity. 

In waters that support powered marine vessel traffic, the spoil would be placed parallel to the 

trench in 500-foot-long piles, with 50-foot-wide openings to allow the passage of local watercraft. To 

ensure the safety of the boating public, the spoil piles and openings would be marked with timber piles, 

warning signs, and navigation lights. Surveyors would ensure the dredge remains on the approved 

centerline, verify that the spoil remains within the 300-foot construction right-of-way, and confirm that 

the bottom of the pipe trench was at the designed depth. 

Pipe Fabrication and Lowering 

The pipeline would be fabricated aboard a string of shallow-draft spud barges, lashed together in 

a line to form the lay barge. The concrete-coated pipe would first be offloaded from tugboat-towed 

supply barges by means of a crane mounted on the lead barge. Each pipe joint would then be aligned 

end-to-end with the previous joint on a set of rollers that would extend the length of the lay barge. The 

pipe joints would be assembled into one continuous pipeline by passing them through multiple welding, 

inspection, repair, and coating stations. Only qualified welders would be allowed to perform the welding. 

Welders and the welding procedure would be qualified according to applicable API standards. To ensure 

that the assembled pipe met or exceeded the design strength requirements, the welds would be visually 

inspected and examined by means of X-ray, ultrasound, or other approved methods, in accordance with 

American Society of Mechanical Engineers standards. Welds displaying unacceptable slag inclusions, 

void spaces, or other defects would be repaired or cut out and re-welded. Once each weld had passed 

inspection and received its final coating, the pipe would be lowered off the back end of the lay barge into 

the pipe trench by lifting the anchor spuds of the lay barge and moving the lay barge forward the length of 

one pipe joint. The next pipe joint would be rolled into position for welding and the process would be 

repeated. 
 2-37 Description of the Proposed Action 

FIGURE 2.3.1.3-3 

Typical Access Canal in Open Water 

PUBLIC 
 2-38 Description of the Proposed Action 

FIGURE 2.3.1.3-4 

Typical Inland Open Water Construction, <8 feet depth of water 

PUBLIC 
 2-39 Description of the Proposed Action 

FIGURE 2.3.1.3-5 

Typical Inland Open Water Construction, >8 feet depth of water 

PUBLIC 
 2-40 Description of the Proposed Action 

To ensure boating safety, barges and tugboat traffic associated with construction of the pipeline 

would comply with all U.S. Coast Guard requirements. KMLP would also provide information to allow 

the Coast Guard to issue a Notice to Mariners. 

Jetting 

Following lowering in, surveyors would confirm that the pipe is at sufficient depth to provide a 

minimum of four feet of soil cover, as required by the COE. Should the minimum cover not have been 

achieved, the pipe would be lowered farther using a barge-mounted hydraulic jetting system. 

Foreign Pipeline Crossings in Open Water 

The crossing of foreign pipelines in open water would require a specialty crew and equipment to 

pass the proposed pipeline under the existing pipeline, raise the proposed pipeline to the surface to make 

the tie-in, and to place concrete mats between the pipelines to ensure minimum separation distance is 

maintained. 

Backfilling and Final Grading 

Once sufficient depth of the pipe has been achieved to provide the minimum soil cover, the 

dredge barge would return to backfill the pipe trench and flotation channel, using the available spoil 

adjacent to the excavation. The bottom would be restored to within 1 foot of the original contour using 

the clam bucket. Surveyors would confirm that final grade and tolerance have been achieved. Where the 

1 foot-grade tolerance was not achieved, a joint of pipe or similar device would be mounted on the dredge 

line and dragged across the bottom to remove high spots, until the contours had been restored to within 

the allowable tolerance. Where insufficient spoil remained to completely backfill the trench and channel 

to within 1 foot of original contours due to erosion of the spoil piles and suspension of solids in the water 

column during handling, the trench and channel would be allowed to naturally fill with sediments over 

time. 

Calcasieu River Crossing 

The Calcasieu River and the major tributary that serves as a ship channel to the Trunkline LNG 

Terminal (from MP 49.6 to MP 51.1) would be crossed just north of Choupique Island by means of two 

back-to-back HDD crossings separated by an approximately half-mile stretch of conventional upland 

construction across the intervening peninsula. The entry hole for the first HDD and the exit hole for the 

second would have to be located in a COE dredge-spoil disposal area in that peninsula. KMLP would 

design the pipeline through this area with consideration for the potential placement of additional 

overburden and the consolidation and settlement of dredge spoil materials. 

Foreign Pipeline Crossings 

The Project would cross numerous foreign pipelines. KMLP pipelines would be installed by 

horizontal bore under most single pipelines, as shown in figure 2.3.1.3-6. In areas where pipelines are 

highly congested or are near major waterbodies or wetlands, HDD would be used (see table 4.3.2.1-3). 

KMLP proposed to use two consecutive HDDs to cross a high concentration of pipelines from MP 25.3 to 

MP 26.8. Because the HDD plans in KMLP’s application were incomplete, we recommend: 

• KMLP file with the Secretary a site-specific construction plan for the crossing of foreign 

pipeline corridors between MP 25.3 and MP 26.8. These site-specific plans should 

include scaled drawings identifying all areas that would be disturbed by construction. 
 2-41 Description of the Proposed Action 

FIGURE 2.3.1.3-6 

Typical Foreign Pipeline Crossing 

PUBLIC 
 2-42 Description of the Proposed Action 

KMLP should file these plans for review and written approval by the Director of the 

OEP prior to construction. 

Road and Railroad Crossings 

A total of 104 major paved highways and railroads, along which traffic could not be interrupted, 

would be crossed by horizontal boring or by HDD under the roadbed. Most of the smaller unpaved roads 

would be crossed by open trenching, and then restored to pre-construction conditions or better. If an 

open-cut road were to require extensive construction time, provisions would be made for temporary 

detours or other measures to allow safe traffic flow during construction. 

The pipeline would be buried to a depth of at least 5 feet below the road surface, and 10 feet 

below the rail of the railroad, and would be designed to withstand anticipated external loadings. At points 

of access to the right-of-way from hard-surfaced roads, a stone pad would be installed as a construction 

entrance to control mud and dirt from tracking onto the highway. Casings will be installed only where 

specifically required by railroad or road authorities. 

Extra workspaces for the Project as a whole, including those associated with road and railroad 

crossings, are shown in appendix C. 

Crop and Pasture Crossings 

KMLP would segregate topsoil in actively cultivated and rotated cropland and improved 

pastureland. A maximum of 12 inches of topsoil would be segregated in accordance with our Plan and 

Procedures in these areas, and in other areas at the specific request of the landowner or land management 

agency, if applicable (e.g., Louisiana State Lands, FWS). The topsoil and subsoil would be temporarily 

stockpiled in separate windrows on the construction right-of-way and would not be allowed to mix. 

Where topsoil is less than 12 inches deep, the actual depth of the topsoil would be removed and 

segregated. The depth of the ditch would be sufficient to allow for at least three feet of cover on top of 

the pipe. 

After construction, compacted subsoil would be disked, and the segregated topsoil would be 

returned to its original horizon, unless otherwise requested by the landowner. Actively cultivated 

cropland would be left unseeded at the request of the landowner if preparation of the ground for planting 

is due to occur right after the completion of construction. Pasture would be reseeded with species similar 

to pre-construction and nearby vegetation. 

Rice Field and Crawfish Pond Crossings 

Rice fields and crawfish ponds (or isolatable sections thereof) would be drained before 

commencement of construction of the Project. KMLP would attempt to schedule construction during 

times when the fields and ponds are not normally flooded. If necessary, KMLP would also negotiate with 

the landowners a deferral of flooding or planting for the season or year in which construction were due to 

take place. This would improve the chances of the soil being dry and thus reduce the chance of soft spots 

in the soil remaining over the pipeline after construction. Typically, the conventional upland construction 

methods (described in section 2.3.1.1) would be appropriate. Should soil saturation be too great at the 

commencement of construction, temporary timber mats would be used resulting in a construction method 

more similar to unsaturated-wetland construction methods. If soil saturation were even greater, a 

saturated-wetland construction method would be used. 
 2-43 Description of the Proposed Action 

Topsoil would be segregated unless the water level and degree of soil saturation were too high at 

the time of construction or if there were no obvious horizon between the topsoil and subsoils. Compacted 

subsoil would be disked, and the segregated topsoil would be returned to its original horizon, unless 

otherwise requested by the landowner. 

Residential Area Crossings 

There are no residences (i.e., homes) within 50 feet of the edge of the proposed construction 

right-of-way. However, the pipeline would cross several residential areas between MP 38 and 124 which 

would involve barns and sheds within 50 feet of the edge of the construction right-of-way.. 

In these areas, KMLP would reduce construction workspace areas as practicable to minimize 

inconvenience to property owners; at some locations, HDD might be used to minimize surface 

disturbance to residences and other buildings near the right-of-way. If construction were to require the 

removal of private property features, such as gates or fences, the landowner or tenant would be notified 

and consulted prior to the action. Following completion of major construction, the property would be 

restored as requested by the landowner, insofar as the landowner's requirements are compatible with 

KMLP’s standards regarding restoration and maintenance of the right-of-way, and applicable regulations, 

except that permanent structures would not be allowed within the 50-foot operating right-of-way. 

Property restoration would be in accordance with any agreements between KMLP and the landowner. 

The FERC's residential construction procedures would be followed. 

Residential lawns would be re-seeded or sodded according to the variety of the original grass. 

Wherever practical, shrubs and small trees would be temporarily transplanted and replaced unless they 

were too close to the right-of-way to begin with. 

Commercial and Industrial Area Crossings 

Impacts to commercial and industrial areas would be limited to the construction and postconstruction restoration periods when construction activities could inconvenience business owners, 

employees, and customers. KMLP would maintain close coordination with business owners to maintain 

access, decrease construction duration, and generally minimize impacts. Specifically, impacts to 

commercial facilities located on the east side of the Calcasieu River would be avoided by HDD. 

Commercial lawns would be re-seeded or sodded according to the variety of the original grass. 

Wherever practical, shrubs and small trees would be temporarily transplanted and replaced unless they 

were too close to the right-of-way to begin with. 

2.3.2 Aboveground Facilities 

Construction of the meter station and interconnection facilities would involve typical industrial 

facility construction procedures. Construction activities and storage of construction materials and 

equipment would be confined to the facility footprint. Following the initial earth work, excavation would 

be completed as needed for the concrete foundations for the metering equipment and any buildings. 

Subsurface friction piles may be required to support foundations, depending upon the bearing capacity of 

the existing soils and the equipment loads. Forms would be set, rebar installed, and the concrete poured 

and cured in accordance with applicable industry standards. Backfill would be compacted in place, and 

excess soil would be used elsewhere or distributed around the site to improve grade. Construction debris 

and wastes would be disposed of appropriately. 
 2-44 Description of the Proposed Action 

The metering equipment and other materials would be delivered to the site by truck, off-loaded 

using cranes or front-end loaders (or both), positioned on the foundations, leveled, grouted where 

necessary, and secured with anchor bolts. All components in high-pressure natural gas service would be 

hydrostatically tested, and all controls and safety equipment and systems, including emergency shutdown, 

relief valves, and gas and fire detection equipment would be checked and tested before being placed in 

service. Following completion of construction, each site would be fenced and most areas in and around 

the meters and associated piping and equipment would be covered with crushed rock (or equivalent). 

Roads and parking areas may be crushed rock, concrete, or asphalt. Other ground surfaces, including 

adjacent areas outside the fence, would be restored, seeded, and revegetated. 

Pig launchers and receivers would be installed completely within the boundaries of the associated 

meter station/interconnect sites. MLVs would be installed within the pipeline right-of-way. 

2.3.3 Ancillary Facilities 

Each extra workspace would be surveyed and staked, cleared, and graded in a manner that took 

account the use of the land on which it is to be located. In general, this would be the same manner as the 

nearest portion of right-of-way (because their land uses would in general be identical). Similarly, after 

construction, each extra workspace would be restored in a manner appropriate to the original land use. 

Previously existing access roads that were modified and used during construction would be 

returned to original or better condition upon completion of the pipeline facilities installation. New access 

roads constructed specifically for the Project would be removed, the surface graded to original contours, 

and the land restored to its original use, unless otherwise requested by the landowner, or unless the roads 

would be required for ongoing access to the right-of-way during pipeline operations, and in accordance 

with any permit requirements. Temporary erosion-control measures would be removed upon final 

stabilization and installation of permanent erosion control measures. 

As discussed in section 2.1.3, KMLP proposes to use 12 pipe storage and contractor staging areas 

during construction of the Project (see appendix C). The modifications that KMLP proposes to make to 

these areas during construction consist of: 

• Grading; 

• Adding road base, i.e., geotech lining and gravel; and 

• Constructing pipe supports, i.e., dirt berms. 

Upon completion of the construction phase, all temporary facilities (e.g., trailers, sheds, latrines, 

pipe supports, fencing, and gates) would be removed from the pipe storage and contractor yards. Unless 

otherwise requested by the landowner, each site would be graded to original contours and the land 

restored to its original use. The site would be re-vegetated, any permanent erosion-control measures 

would be installed, and temporary erosion-control measures would be removed. 

2.4 OPERATION AND MAINTENANCE PROCEDURES 

KMLP would operate and maintain the proposed pipeline and aboveground facilities in 

compliance with 49 CFR 192, the FERC’s regulations at 18 CFR 380.15, and our Plan and Procedures. 

KMLP would employ locally based, full-time staff to operate and maintain the proposed pipeline 

system. Maintenance activities would include monitoring, inspection, and repair of the right-of-way, and 
 2-45 Description of the Proposed Action 

cleaning of the pipeline. Periodic aerial and ground inspections would be performed to identify soil 

erosion that may expose the pipeline; dead vegetation, which may indicate a leak in the pipeline; 

unauthorized encroachment on the right-of-way, e.g., by buildings; and other conditions that could 

constitute a safety hazard or require preventative maintenance or repairs. The pipeline impressed-current 

cathodic protection system would also be monitored and inspected periodically to ensure proper and 

adequate corrosion protection. All MLV sites would be regularly inspected and maintained. Intelligent 

pigging would be undertaken periodically to inspect the interior of the pipeline. 

KMLP would maintain vegetation on the permanent right-of-way in upland areas by mowing, 

cutting, and trimming. Large brush and trees would be removed periodically from within the operational 

right-of-way. Trees greater than 15 feet in height, or deep-rooted shrubs that could damage the pipeline’s 

protective coating, obscure periodic surveillance, or interfere with potential repairs, would not be allowed 

to grow within 15 feet of the pipeline in wetlands or within 25 feet of the pipeline in uplands. The 

frequency of vegetation maintenance would depend upon the growth rates, but would not be more 

frequent than dictated by our Plan and Procedures. Vegetation maintenance would not normally be 

required in agricultural or grazing areas. Other than preventing tree growth as described above, vegetation 

maintenance would not normally be required in wetlands.

Pipeline facilities would be clearly marked at line-of-sight intervals and at crossings of roads, 

railroads, waterbodies, and at other key points in accordance with DOT regulations. Markers would 

clearly indicate the presence of the pipeline and provide a telephone number and address where a 

company representative could be reached in the event of an emergency or prior to any excavation in the 

area of the pipeline by a third party. 

2.5 ENVIRONMENTAL COMPLIANCE, INSPECTION, AND MITIGATION MONITORING 

KMLP would employ a tracking system to ensure that relevant pre-construction surveys, 

clearances, permits, and plans were completed prior to releasing the construction contractors to begin 

construction activities. 

For purposes of quality assurance and compliance with mitigation measures, other applicable 

regulatory requirements, and project specifications, KMLP would be represented on each pipeline spread 

by a Chief Inspector, one or more Craft Inspectors, and at least one Environmental Inspector (EI). The EI 

position would be a full-time position. EIs would have authority to stop work and require corrective 

actions to achieve environmental compliance. Their duties would be consistent with those contained 

within Paragraph II.B (Responsibilities of Environmental Inspectors) of the FERC’s Plan and would 

include ensuring compliance with any environmental conditions attached to the FERC Authorization, any 

other permits or authorizations, and environmental designs and specifications. Because KMLP has not 

yet defined these details for the Project, we recommend that: 

• KMLP file with the Secretary for review and written approval by the Director of OEP 

the proposed number of spreads, EIs per spread and for the entire Project, and the 

specific duties of those EIs prior to the issuance of the final EIS.

KMLP also would develop a project-specific environmental training program that would be 

designed to ensure that: 

• Qualified environmental training personnel provide thorough and well-focused training 

sessions regarding the environmental requirements applicable to the trainees’ activities; 

• All individuals receive environmental training before they begin work; 
 2-46 Description of the Proposed Action 

• Adequate training records are kept; and 

• Refresher training is provided as needed to maintain high awareness of environmental 

requirements. 

KMLP would file with the Commission any updates to its proposed environmental inspection 

program. KMLP is considering but has not committed to requesting the use of our Third-Party 

Compliance Monitoring and Variance Request Program for pipeline construction and restoration. In 

addition to KMLP’s program, we would conduct periodic inspections to monitor the project for 

compliance with the Commission’s environmental conditions. 

2.6 SAFETY CONTROLS 

DOT regulations in 49 CFR Part 192 require that KMLP prepare an Integrity Management Plan, 

to prevent system losses and failures, and an Emergency Response Plan, to protect the public, workers, 

and the environment in the event of loss or failure. 

Engineering features and maintenance aspects have been incorporated by KMLP in its Project 

design to prevent system losses and failures. Engineering features include: 

• Corrosion protection system; 

• Overpressure protection system; 

• SCADA and leak-detection system; 

• MLVs; and 

• Hydrostatic testing as part of commissioning. 

Maintenance aspects include: 

• Preventative maintenance program; 

• Aerial surveillance flights; 

• On-ground leak-detection surveys; and 

• Intelligent pigging. 

Protection against corrosion would be provided by an external fusion-bonded epoxy coating 

together with an impressed-current cathodic-protection system. Cathodic-protection protection units 

would be monitored regularly to maintain the requisite pipe-to-soil potential in accordance with the 

specifications of the relevant DOT regulations. 

In accordance with DOT regulations, KMLP would devise and implement an Emergency 

Response Plan to be followed in the event of an emergency such as a gas leak, fire, explosion, or other 

damage to the pipeline system. Procedures would include: 

• Training of employees on emergency procedures; 

• Establishing liaisons with appropriate fire, police, and other community officials; and 

• Informing the public on how to identify and report an emergency condition. 
 2-47 Description of the Proposed Action 

2.7 FUTURE PLANS AND ABANDONMENT 

At this time, KMLP has no plans for future expansion of any facilities associated with the Project. 

If ever an expansion is envisioned (for example, additional interconnects to deliver gas to other pipelines, 

compression facilities to increase system capacity, or new access roads to gain access to these or other 

new facilities), it would require FERC authorization, following appropriate analysis, and be subject to 

applicable federal, state, and local regulations in force at that time. 

KMLP envisions a 25-year life for the Project. However, the facilities themselves would, with 

proper maintenance, be capable of being operated for 50 years or more, according to KMLP. Regardless 

of the duration of utilization of the proposed pipeline system, abandonment of any facilities would require 

FERC authorization, following appropriate analysis, and be subject to applicable federal, state, and local 

regulations in force at that time. 
[This page intentionally left blank.] 
 3-1 Alternatives 

3.0 ALTERNATIVES 

A fundamental principle of NEPA is that an agency should consider reasonable alternatives to the 

proposed action to ensure that the project objectives are met while minimizing environmental impacts. 

To satisfy this requirement, we have evaluated a range of alternatives to the KMLP Project. The 

proposed action before the Commission is to consider issuing a certificate of public convenience and 

necessity under section 7 of the NGA. 

The alternatives to the proposed action considered in this section of the EIS include: (1) no 

action—the Commission does not approve the pipeline or it postpones the approval (section 3.1); (2) use 

of other pipeline systems, which may already exist, are proposed, or are previously approved by the 

Commission and not yet constructed (section 3.2); (3) major route alternatives for significant portions of 

the proposed pipeline route (section 3.3); and (4) route variations for relatively short distances to avoid a 

site-specific resource (section 3.4). 

The criteria for evaluating alternatives included whether the alternatives can achieve the goals of 

the Project at significantly reduced environmental impacts, while being technically and economically 

practicable. The objectives of the KMLP Project are: 

• Provide substantial take-away capacity from the Sabine Pass LNG Terminal; 

• Integrate LNG supplies into the U.S. pipeline grid and gas storage infrastructure by providing 

substantial downstream interconnecting capacity to other pipelines; 

• Provide the LNG shippers flexibility of access to multiple markets by means of this 

interconnecting capacity; and 

• Meet the project in-service date of October 2008 for Leg 2 and April 2009 for Leg 1 and its 

interconnects with other pipelines, including the FGT Lateral. 

The shippers of record for the Project include Total LNG USA (a subsidiary of Total AG) and 

Chevron USA, who together have acquired 2 Bcf/d of regasification capacity at the Sabine Pass LNG 

Terminal. Total LNG USA and Chevron have signed binding precedent agreements with KMLP for use 

of the full capacity of the pipeline for 20-year terms. 

In considering the alternatives, we proceeded from a comparison of whether alternatives could 

meet the above objectives of the Project, to more detailed considerations of specific siting and 

environmental trade-offs. Further, our analysis focused on those aspects of the Project for which an 

alternative could minimize or avoid environmental impacts, such as wetlands, residences, or other 

sensitive areas of concern. The results of our analysis are presented below. 

3.1 NO ACTION OR POSTPONED ACTION ALTERNATIVE 

The Commission can take one of three actions in processing the KMLP application. It can grant 

the certificate with or without conditions; deny the certificate; or postpone the action pending further 

study. If the Commission denies KMLP’s application, the short- and long-term environmental impacts 

identified in this draft EIS would not occur. If the Commission postpones action on the application, the 

environmental impacts identified in this draft EIS would be delayed, or if KMLP decided not to pursue 

the Project, the impacts would not occur at all. However, if the Commission were to select the no action 

or proponed action alternative, the objectives of the Project would not be met, and KMLP would not be 

able to deliver re-gasified LNG to markets in Louisiana and the rest of the United States as proposed. 
 3-2 Alternatives 

Denying the certificate for KMLP would force all of the output from the Sabine Pass LNG 

Terminal to go through the Cheniere Sabine Pass Pipeline (SPP), which has been approved by the 

Commission as part of the Sabine Pass LNG and Pipeline Project. Total LNG USA and Chevron have 

not contracted for capacity on this pipeline. The Cheniere SPP also would have less capacity and fewer 

interconnections with downstream pipelines than would the KMLP Project. Since Cheniere SPP is sized 

to carry only 2.6 Bcf/d, this potentially could reduce the amount of gas available to the market by up to 

1.4 Bcf/d or about 0.5 Tcf/year. Also, because the certificated pipeline would have fewer pipeline 

interconnections, not approving the KMLP Project would tend to limit the geographic access of the regasified LNG. 

Energy alternatives to this reduced gas supply could include increased use of more polluting fuels 

such as oil and coal in the markets that would have been served by KMLP. It is more likely, however, 

that the difference in gas supply would be made up by gas from other LNG terminals, imports from 

Canada, or from other sources of domestic supply. The overall effect of the no action alternative could be 

somewhat higher gas prices due to less supply reaching markets than under the KMLP proposal. Higher 

prices in turn could push users toward coal, oil, or other less costly alternative energy sources, some of 

which would be more polluting. 

Energy conservation potentially could make up for the difference in supply under the no action 

alternative. Energy conservation programs aimed primarily at residential and commercial markets are 

being promoted by state regulators and the federal government through broad-based efficiency programs 

and demand side management (DSM) and integrated resource planning (IRP) initiatives. These programs 

rely on economic tests of avoided energy costs to determine which conservation program designs and 

technologies should be implemented. With the no action alternative, less gas supply entering the market 

could result in slightly higher gas prices, which in turn would improve the economics of conservation, as 

well as the attractiveness of other less costly but more polluting fuels. These effects would be small 

across the size of the markets served by the Project. It is difficult to draw a connection between these 

programs’ effectiveness and a single LNG pipeline, and hence energy conservation is not considered an 

adequate alternative to the proposed action. 

3.2 SYSTEM ALTERNATIVES 

System alternatives are alternatives that could use different pipeline systems to achieve the same 

objectives as the Project, but at a reduced level of construction and environmental impact. Our analysis 

of pipeline system alternatives included examination of the use of existing or approved pipelines that 

could be modified and combined to accept KMLP throughput, reasonably and economically, and still 

meet the objectives of both systems. These objectives include the transportation of vaporized LNG (up to 

4 Bcf/d) into the interstate and intrastate natural gas pipeline system for subsequent transportation to 

markets in Louisiana and elsewhere in the United States.1

 KMLP’s contractual agreement with its 

shippers is that it will not install compression on the pipeline and therefore not charge its shippers a fuel 

charge. 

One of the principal metrics used to evaluate system alternatives is whether a potential alternative 

provides sufficient downstream interconnecting capacity with other pipelines serving the markets that 

KMLP’s shippers intend to serve. Downstream interconnecting capacity refers to the sum of the 

capacities of the pipelines that interconnect with the KMLP Project and the system alternatives. Neither 

the KMLP Project nor the system alternatives discussed in this section directly serve gas markets; all of 

 

1

 We evaluated alternatives for Leg 1 mainline only. 
 3-3 Alternatives 

them interconnect with long-haul pipelines that do serve gas markets, hence the relevance of the 

downstream interconnecting capacity. In order for a system alternative to be viable, the total downstream 

interconnecting capacity for the system alternative should equal, and ideally exceed, the KMLP Project’s 

capacity. This allows shippers the flexibility to swing their gas supplies between pipelines and markets 

to meet demand or respond to price movements. 

3.2.1 Use of Existing Pipeline Systems 

Currently, there is no existing pipeline system that could be used to move vaporized LNG from 

the Sabine Pass LNG Terminal location to the existing interstate and intrastate natural gas pipeline 

systems. Within 3 miles of the LNG Terminal in the Sabine Pass area, there are two 30-inch-diameter 

NGPL pipelines and two 24- and one 16-inch-diameter Transco pipelines. The combined capacity of 

these existing pipeline systems are inadequate to meet the objectives of the KMLP Project. 

3.2.2 Use of Proposed Pipeline Systems 

We also evaluated whether other proposed pipeline systems in the vicinity of the KMLP Project 

could replace all or a part of the Project. We determined that the following other proposed systems in the 

area are not viable system alternatives for the reasons stated. 

• Cheniere SPP. This pipeline provides only 3.86 Bcf/d in downstream interconnecting 

pipeline capacity, compared to the 11.37 Bcf/d that would be provided by the KMLP Project. 

This project is only 16 miles long and would require significant additional facilities to serve 

KMLP’s customers, and by itself would not meet the Project’s objectives and has been 

eliminated from further evaluation. 

• Liberty Pipeline. This is a short pipeline intended to connect the Liberty Storage facility 

with the pipeline network. It would not meet the KMLP Project’s objectives. 

• Trunkline Pipeline Lateral. This is another relatively short pipe connecting the Lake 

Charles LNG Terminal to Trunkline’s main pipeline. As such, it would not meet the KMLP 

Project’s objectives. 

• Golden Pass Pipeline. This pipeline is designed to serve the Golden Pass LNG Terminal, 

under development by ExxonMobil. It runs westward around the western side of Port Arthur, 

Texas. It interconnects with the Transco main line, with a number of Texas intrastate 

pipelines, and with ExxonMobil’s Beaumont Refinery. This alternative provides only 

7.68 Bcf/d in downstream interconnecting capacity compared to the 11.37 Bcf/d that would 

be provided by the KMLP Project. It therefore would lack the degree of flexibility to serve 

those markets that the KMLP Project requires. As a result, we have eliminated it from further 

evaluation. 

• Port Arthur Pipeline. This pipeline is associated with the Sempra Port Arthur LNG 

Terminal, located just northwest of the Golden Pass LNG Terminal, across the Sabine River 

from the Sabine Pass LNG Terminal. The pipeline would interconnect with four pipelines: 

Sabine, Tennessee, Texas Eastern, and Transco, with a total downstream interconnecting 

capacity of 3.92 Bcf/d compared to the 11.37 Bcf/d that would be provided by the KMLP 

Project. This system thus lacks the amount of downstream interconnecting capacity and 

diversity of pipelines to be a viable alternative to the proposed action. Further, Gas Daily

(September 29, 2006; p. 6) reported that Sempra was considering delaying the construction of 

the Port Arthur Terminal by a year. Because of the lack of an equivalent amount of 
 3-4 Alternatives 

downstream interconnecting capacity and the uncertainty around the project, we eliminated it 

from further evaluation. 

• Cameron Pipeline. This pipeline is designed to take the sendout from the Sempra Cameron 

LNG Terminal, about 7 miles south and west of the Lake Charles LNG Terminal and about 

15 miles north of the Creole Trail LNG Terminal. The pipeline would interconnect with 

Florida Gas, Tennessee, Texas Eastern, and Transco, with a total downstream interconnecting 

capacity of only 4.09 Bcf/d compared to the 11.37 Bcf/d that would be provided by the 

KMLP Project. Therefore, we eliminated this pipeline from further evaluation. 

We identified two pipeline systems—which we call System Alternative #1 and System 

Alternative #2 in this draft EIS—that potentially meet the KMLP Project’s objectives in terms of takeaway capacity from the Sabine Pass LNG Terminal and downstream interconnecting capacity to other 

pipelines that serve the same markets proposed to be served by KMLP’s shippers. These system 

alternatives are shown in figure 3.2-1 and compared to the proposed system in table 3.2-1. 

System Alternative #1 would consist of looping three pipelines proposed by Cheniere: (1) the 

Chenier SPP (approved); (2) the Creole Trail Segment 1 Amendment that has recently been proposed by 

Cheniere to interconnect the Cheniere SPP with the Creole Trail Pipeline (proposed); and (3) the Creole 

Trail Pipeline (approved Segments 2 and 3). The latter is intended to provide take-away capacity from 

the Creole Trail LNG Terminal. 

System Alternative #2 would consist of looping the same three elements included in System 

Alternative #1 but only to a point 20 miles north of the Creole Trail LNG Terminal, where the KMLP 

proposed route for Leg 1 would cross the Creole Trail Pipeline (at approximately MP 48). From this 

point, the KMLP proposed route would follow its proposed easterly route to its terminus at MP 132.2 near 

Eunice, Louisiana. 

System Alternatives #1 and #2 would consist of looping the three segments described above to 

meet the commercial objectives of the KMLP Project as well as to to provide market access for natural 

gas volumes from the Creole Trail LNG Terminal. Staff reviewed KMLP’s submitted hydraulic 

modeling of System Alternative #1 and determined that the submitted model is hydraulically feasible and 

could provide the proposed volumes and delivery pressures. However, significant additional facilities 

would be required, as discussed in more detail below. 

3.2.2.1 System Alternative #1 

On August 4, 2006, Cheniere Creole Trail Pipeline L.P. filed an amendment to the Creole Trail 

Pipeline Project (CTPP) to extend the approved CTPP by adding 18.1 miles of pipeline and appurtenant 

facilities in Cameron Parish, Louisiana. This extension, called the Segment 1 Amendment Project, would 

connect Cheniere’s CTPP with the Cheniere SPP. With this interconnection, a potential new system 

alternative to the KMLP Project became available. This system alternative could allow gas from the 

Sabine Pass LNG Terminal to flow ultimately into an enhanced Creole Trail Pipeline, where it would 

share pipeline capacity with the Creole Trail LNG Terminal output. Total downstream pipeline 

interconnecting capacity would be 15.56 Bcf/d, which is more than the 11.37 Bcf/d that would be 

provided by the KMLP Project. 

Under System Alternative #1, KMLP would have to increase the capacities of the Cheniere SPP, 

the proposed Creole Trail Segment 1 Amendment, and the Creole Trail Pipeline to accommodate the 

sendout volumes from both the Sabine Pass and Creole Trail LNG Terminals. In particular, the following 

would be required: 
3-5 

Non-Internet Public 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

KINDER MORGAN LOUISIANA PIPELINE PROJECT 

Docket No. CP06-449-000 

Page 3-5 

Figure 3.2-1 System Alternatives for the KMLP Project 

Public access for this Non-Internet Public information is available only through t

Room, or by e-mail at public.referenceroom@ferc.gov. 
 3-6 Alternatives 

TABLE 3.2-1 

Comparison of KMLP’s Proposed System with System Alternatives 

 Unit 

KMLP’s Proposed 

System and Routea

System 

Alternative

#1b

System 

Alternative 

#2b

Pipeline Facilitiesc

Total length of pipeline miles 132.2 167.5 158.2 

New pipeline (42-inch-diameter) miles 132.2 0.0 101.8 

Loop pipeline (42-inch-diameter) miles 0.0 167.5 56.4 

Environmental Factors 

Construction right-of-wayd acres 2030.3 2537.9 2397.0 

Permanent right-of-wayd acres 806.3 1015.2 958.8 

Length adjacent to existing right-of-way percent 54.0 31.1 52.6 

Length in wetlandse miles 35.8 48.4 28.5 

Total perennial waterbodies crossedf number 55 46 52 

Major river crossings (>100 feet) number 9 6 9 

Natural and scenic rivers number 0 2 0 

Federally listed threatened or endangered species number 8 8 8 

Federal land crossedg miles 0 0 0 

State land crossedg miles 0 0 0 

Other recreational/designated land use areas crossedg number 0 0 0 

Existing residences within 50 feet of construction work area number 0 10h 10h

Cultural resourcesi number 0 0 0 

_______________ 

a

 We evaluated alternatives for Leg 1 mainline only. 

b

 Data for Sabine Pass, Creole Trail Segment 1 Amendment, and Creole Trail Pipelines were gathered from “Final Environmental Impact 

Statement; Sabine Pass LNG and Pipeline Project; Sabine Pass LNG, L.P. Docket No. CP04-47-000; Cheniere Sabine Pass Pipeline 

Company, Docket Nos. CP04-38-000, CP-04-39-000, CP04-40-000,” “Cheniere Creole Trail Pipeline, LP's Resource Report 1- General Project 

Description to its application requesting authorization to extend the Cheniere Creole Trail Pipeline under CP05-357” (FERC Online Document 

No. 2006-0810-0089) and “Cheniere Creole Trail Pipeline LP submits revised pages from Resource Report 1, 2, 3, 6, and 8 to correct the 

acreage discrepancies under CP05-357” (FERC Online Document No. 20060825-0059), and “Final Environmental Impact Statement; Volumes 

I & II; Creole Trail LNG Terminal and Pipeline Project; Creole Trail LNG, L.P. Docket No. CP05-360-000; Cheniere Creole Trail Pipeline 

Company, Docket Nos. CP05-357-000, CP05-358-000, CP05-359-000.” 

c

 Facilities listed for system alternatives are those facilities required to be added to the proposed/approved system to accommodate the capacity 

of KMLP’s proposed system. Compression facilities were not considered in the analysis because KMLP’s precedent agreements would not 

bear compression fuel charges. 

d

 We assumed a 125-foot construction right-of-way and a 50-foot permanent right-of-way for the total pipeline lengths. Right-of-ways are for only 

the Leg 1 mainline and do not include extra work spaces, access roads, pipe yards, and interconnecting pipelines and sites because those 

details are unknown for System Alternatives #1 and #2. 

e

 Wetland data were obtained from the National Wetlands Inventory database. 

f

 The waterbody crossings for each system alternative were gathered by querying the available ESRI Tiger U.S. Census dataset using estimated 

pipeline locations. When necessary, the data were adjusted to reflect only one waterbody crossing for Sabine and Calcasieu Lakes. 

g

 Presented values for the federal, state, and other recreational/designated land uses(such as wilderness areas, parks, ballfields, campgrounds, 

etc.) were gathered from the identified references for each pipeline. These values are for the original proposed construction rights-of-way and 

could not be adjusted for the expanded construction right-of-way needed for looping in the system alternatives. We do not anticipate that the 

presented values would vary significantly for the expanded construction right-of-way needed for looping. 

h

 A total of 10 residences within 50 feet of the proposed construction right-of-way were identified for the original Creole Trail Pipeline (Segments 

2 and 3) and 0 residences have been identified within 50 feet of the proposed construction right-of-way for the proposed Creole Trail Segment 1 

Amendment. However, it was not possible to identify the number of residences within 50 feet of the expanded construction right-of-way for 

system alternatives that include the Creole Trail Pipeline without performing a field survey and review of recent aerial photography. 

i

 Based on surveys and consultations completed to date, there are no National Historic Landmarks or properties listed on the National Register 

within the area of potential effect of the proposed route or any alternative. 
 3-7 Alternatives 

• Additional facilities would be required. As shown in table 3.2-1, the additional facilities 

would include 167.5 miles of 42-inch-diameter looping of proposed pipeline. This would be 

necessary in lieu of installing compression to carry the combined volumes of both terminals. 

The total length of pipeline in System Alternative #1 would be 35.3 miles longer than the 

proposed KMLP Project. 

• We assume a 125-foot construction right-of-way and 50-foot permanent right-of-way would 

be required for the looped pipeline. 

• Because of the additional pipeline looping, the cost of System Alternative #1 would exceed 

the combined cost of the KMLP Project and the three Cheniere segments by an estimated 

$200.9 million. 

• Contractual agreements between Total LNG USA and Chevron and KMLP would have to be 

modified to accommodate the combined facilities and they may affect shipper commitments 

to the project. 

• It is possible that some of the proposed interconnecting points with downstream pipelines that 

are on the Creole Trail Pipeline segment of System Alternative #1 do not have the same 

capacities as envisioned by the KMLP precedent agreements with its shippers, and therefore 

may require further modification. This would be in spite of the fact that the total downstream 

interconnecting capacity of System Alternative #1 exceeds that of the KMLP Project. 

System Alternative #1 would avoid having to construct the entire 132.2-mile Leg 1 pipeline, 

along with its attendant environmental impacts. However, it would entail substantial construction of 

expanded right-of-way by looping the three Chenier pipeline segments, which would disturb a total of 

2,537.9 acres during construction. That would be 507.6 acres more than the proposed system would 

disturb during construction. Compared to KMLP’s proposed system, System Alternative #1 would cross 

nine fewer perennial waterbodies, but would cross two waterbodies listed as natural and scenic rivers. 

System Alternative #1 would require 208.9 acres more in permanent right-of-way, parallel existing rightsof-way to a smaller extent (31.1 percent compared to 54.0 percent) and cross 12.6 more miles of 

wetlands. In addition, since this alternative is similar to the first 34 miles of KMLP’s Southern Route 

Alternative #2 (see figure 3.3-1), it would have the same adverse impacts as described in section 3.3.2 

below. Based on this analysis, the proposed system is environmentally less damaging than System 

Alternative #1. 

3.2.2.2 System Alternative #2 

As shown in table 3.2-1, this alternative would require 158.2 miles of pipeline. It is estimated 

that this routing would have a downstream interconnecting capacity of 12.93 Bcf/d, which is more than 

the 11.37 Bcf/d that would be provided by the KMLP Project. This system alternative would require the 

following: 

• Approximately 101.8 miles of new 42-inch-diameter pipeline and 56.4 miles of 42-inchdiameter pipeline looping would have to be constructed. 

• As for System Alternative #1, we assume looping would require a 125-foot construction 

right-of-way and 50-foot permanent right-of-way. 

• The 18.1-mile Creole Trail Segment 1 Amendment and the eastern half of the KMLP Leg 1, 

stretching about 84 miles, would have to be constructed. 
 3-8 Alternatives 

• The additional cost of this system alternative over the combined KMLP and Cheniere 

pipeline segments would be $149.2 million. 

• All of the major interconnects with downstream pipelines would remain the same as with the 

KMLP Project. One exception is the interconnect with the Southwest Loop, where that 

interconnect would be replaced by one at Johnsons Bayou. 

System Alternative #2 would avoid having to construct the western KMLP Leg 1 segment (MP 0 

to MP 48) and its associated environmental impacts. However, this alternative would still result in 

construction impacts across 2,397.0 acres compared to 2,030.3 acres for the proposed system. Compared 

to the proposed system, System Alternative #2 would cross 7.3 less miles of wetlands and three less 

perennial waterbodies, but it would require 152.5 acres more in permanent right-of-way. In addition, as 

with System Alternative #1, this alternative would have the same impacts in its first 34 miles as described 

in section 3.3.2 for Southern Route Alternative #2. Based on this analysis, the proposed system is 

environmentally less damaging than System Alternative #2. 

3.3 MAJOR ROUTE ALTERNATIVES 

In evaluating alternatives that would meet the Project’s purpose and need, we reviewed both 

major route alternatives and route variations for Leg 1 of the Project. Major route alternatives follow 

different alignments for a significant portion of the proposed route whereas route variations are relatively 

short deviations from the proposed route that would potentially avoid or reduce project impacts on 

specific localized resources that may include cultural resource sites, residences, sensitive habitats, or sitespecific terrain conditions. We did not consider major route alternatives for Leg 2 of the Project because 

it would be only 1.2 miles long and located entirely within the Sabine Pass LNG Terminal property. 

Similarly, we did not consider major route alternatives for the FGT Lateral because there are no viable 

alternatives for getting from Leg 1 to the FGT compressor station that would be substantially different 

than the proposed route. 

During the pre-filing process for this Project, we evaluated major route alternatives considered by 

KMLP and assisted in developing the proposed route in consultation with the COE, FWS, NOAA 

Fisheries Service, and LDWF. This evaluation used information from field studies, aerial photographs, 

National Wetlands Inventory (NWI) maps, and U.S. Geological Survey (USGS) quadrangle maps to 

generate a variety of routes that would each meet the project objectives while avoiding excessive 

environmental impacts. We focused on five possible routes (see figure 3.3-1): 

• Proposed Route; 

• Southern Route Alternative #1; 

• Southern Route Alternative #2; 

• Northern Route Alternative; and 

• Center Route Alternative. 

We also considered the possibility of paralleling portions of the Liberty Pipeline and Cameron 

Pipeline routes that are in the vicinity of the Project; however, we concluded that these routes are not 
3-9 

Non-Internet Public 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

KINDER MORGAN LOUISIANA PIPELINE PROJECT 

Docket No. CP06-449-000 

Page 3-9 

Figure 3.3-1 Major Route Alternatives for the KMLP Project 

Public access for this Non-Internet Public information is available only thro

Reference Room, or by e-mail at public.referenceroom@ferc.go
 3-10 Alternatives 

viable as major route alternatives because they could only serve as variations to parts of the Northern 

Route Alternative and would not avoid the sensitive areas associated with that alternative, as discussed in 

section 3.3.3. 

The major route alternatives that we considered in detail are compared in table 3.3-1 according to 

various criteria and are discussed in separate sections below. We give primary consideration to the use or 

extension of existing rights-of-way to reduce potential impacts on sensitive resources. Installation of the 

new pipeline along existing, cleared utility rights-of-way (such as those of power lines, roads, railroads, 

and existing pipelines) may be environmentally preferable to construction along new rights-of-way. In 

particular, construction effects and cumulative impacts may often be reduced by means of previously 

cleared rights-of-way, which avoid the creation of new rights-of-way through undisturbed areas, reducing 

long-term and permanent environmental impacts. Based on this analysis, the proposed route is 

environmentally least damaging and we are recommending use of the proposed route as the preferred 

alternative. 

3.3.1 Southern Route Alternative #1 

As shown in figure 3.3-1, this alternative would proceed east from the Sabine Pass LNG Terminal 

along the north side of SH 82 to Johnsons Bayou. From there it would turn north along an existing 

pipeline corridor to an intersection with an existing NGPL pipeline. Paralleling the NGPL pipeline, it 

would pass through 6.3 miles of the Sabine National Wildlife Refuge (SNWR), cross Calcasieu Lake west 

to east, continue in a generally northeastern direction across Jefferson Davis and Acadia Parishes, and 

terminate north of Eunice in Evangeline Parish. This alternative would avoid the Sabine Lake crossing of 

KMLP’s proposed route, but it would cross Calcasieu Lake instead. 

As shown in table 3.3-1, Southern Route Alternative #1 would cross less open water (2.9 miles), 

less forested areas (1 mile), and less agricultural areas (9.9 miles), and have one fewer road crossing and 

three fewer railroad crossings, when compared to the proposed route. However, it would have 13 more 

waterbody crossings, impact more wetlands (14.3 miles), and disturb a greater area for construction 

(69.7 acres), and is 1.5 miles longer overall. This alternative would also run adjacent to existing rightsof-way for 18 miles less than the proposed route. 

The significantly greater length of wetlands crossed and the sensitivity of the areas crossed raised 

serious concerns about Southern Route Alternative #1. In particular, federal and state agencies objected 

to the crossing of the NWR and expressed concern about passing through several miles of coastal marsh 

east of Calcasieu Lake. KMLP’s proposed route would avoid the NWR entirely and the pipe would be 

installed by HDD at the southern and northern shores of Sabine Lake and across most of the wetlands to 

the north of Sabine Lake to minimize impacts to aquatic resources. Therefore, we believe that the 

proposed route is environmentally less damaging than Southern Route Alternative #1. 

3.3.2 Southern Route Alternative #2 

As shown in figure 3.3-1, this alternative would proceed east from the Sabine Pass LNG Terminal 

along the north side of SH 82 and continue past Johnsons Bayou and Holly Beach to the west bank of the 

Calcasieu River near Cameron. It would then proceed north, cross Calcasieu Lake, turn east to avoid 

residential areas southeast of Lake Charles, proceed in a generally northeast direction across Jefferson 

Davis and Acadia Parishes, and terminate north of Eunice in Evangeline Parish. We considered this 

alternative to avoid the Sabine NWR crossing of Southern Route Alternative #1. 
 3-11 

TABLE 3.3-1 

Comparison of KMLP’s Proposed Route with Major Route Alternatives for Leg 1 

Characteristic 

or Resource 

Leg 1 

Proposed 

Route 

Southern 

Route 

Alternative #1 

Southern 

Route 

Alternative #2 

No

R

Alte

Total Length 132.2 miles 133.7 miles 137.6 miles 133.Area Disturbed for Construction 2995.9 acresa 3065.6 acres 3154.3 acres 3060Length Adjacent to Existing Rights-of-Way 71.4 miles 53.4 miles 53.9 miles 76.9 Length in Wetlands 35.8 miles 50.1 miles 40.0 miles 35.9 Number of Waterbody Crossings 53 66 49 Number of Natural and Scenic River Crossings 0 0 0 Length in Open Water (incl. lakes, streams, and canals) 16.5 miles 13.6 miles 16.1 miles 15.6 Length in Forested Areas 3.8 miles 2.8 miles 2.8 miles 22.5 Length in Agricultural Areas 90.5 miles 80.6 miles 88.2 miles 65.6 Length in National Wildlife Refuges 0 6.3 miles 0 Length in Other Areas of Recreational/Designated Land Useb 0 0 0 Residences within 50 feet of Construction Work Area 0 TBDc TBDc TNumber of Federally Listed Threatened or Endangered Species 8 8 8 Number of Cultural Resourcesd 0 0 0 Number of Road Crossings 125 124 128 Number of Railroad Crossings 5 2 5 _______________ a This number differs from the one reported in table 3.2-1 because it includes the estimated areas for extra work spaces, aboveground facilities, pipe ya

associated with Leg 1. b Such as wilderness areas, parks, ballfields, campgrounds, etc. c TBD = to be determined. The alternate routes have not been studied in detail through aerial photographs and field surveys to determine the presence 

construction work areas. d Based on surveys and consultations completed to date, there are no National Historic Landmarks or properties listed on the National Register within t

the proposed route or any alternative. 
 3-12 Alternatives 

Table 3.3-1 compares this alternative to the proposed route according to several criteria. 

Compared to the proposed route, Southern Route Alternative #2 would cross four fewer waterbodies, less 

open water (0.4 mile), less forested areas (1 mile), and less agricultural areas (2.3 miles). However, it 

would disturb a greater area for construction (158.4 acres), impact more wetlands (4.2 miles), have three 

more road crossings, and it would be 5.4 miles longer overall. This alternative would also run adjacent to 

existing rights-of-way for 17.5 miles less than the proposed route. 

Geological review conducted subsequent to the development of this route alternative revealed that 

the chenier on which SH 82 is built is the one remaining chenier east of Johnsons Bayou, leaving no 

space for a new pipeline. As a result, the pipeline would have to be constructed in the coastal emergent 

marsh to the north of the chenier. In addition, the chenier on which SH 82 is built is highly vulnerable to 

storm damage, which raises concerns about the long-term stability of the road. The Louisiana 

Department of Transportation and Development stated that they have had insufficient budget to repair 

SH 82 if it was severely damaged by a storm and would consider abandoning the road, as was done in 

Texas when SH 87 between Sabine Pass and High Island was destroyed by a storm. In the event that SH 

82 is damaged by a storm and not repaired, access to the pipeline to ensure continued maintenance and 

integrity could be jeopardized. The area was under water during the recent hurricanes (Katrina and Rita). 

Hurricane Rita completely wiped out the town of Holly Beach located along SH 82. 

Other potential problems associated with this alternative include: 

• Greater potential impacts to oysters in Calcasieu Lake than in Sabine Lake (Southern Route 

Alternative #2 would cross an oyster seed ground in Calcasieu Lake, whereas the proposed 

route would cross a public oyster tonging area in Sabine Lake); 

• Impacts to wildlife refuges and sensitive marsh near Calcasieu Lake; and 

• Longer crossings of coastal emergent marsh and impacts to associated EFH compared to the 

proposed route. 

For these reasons, we believe that the proposed route is environmentally less damaging than 

Southern Route Alternative #2. 

3.3.3 Northern Route Alternative 

As shown in figure 3.3-1, this alternative would leave the Sabine Pass LNG Terminal and enter 

Sabine Lake in a northbound direction. It would pass through Sabine Lake in a generally north-northeast 

direction and exit the lake near Shell Island. It would then parallel the eastern bank of the GIWW to 

Perry’s Ridge. Crossing into Calcasieu Parish, it would follow Perry’s Ridge north, pass to the west of 

Vinton, Louisiana, and go to an intersection with an existing Transco pipeline near Starks, Louisiana, 

which it would parallel in a generally east-northeast direction across the Calcasieu River and across 

Jefferson Davis Parish. At MP 110 in Acadia Parish, it would turn northeast and continue to a point north 

of Eunice in Evangeline Parish where it would terminate. 

Agencies expressed concern regarding the potential impacts to distinctive managed pine and 

hardwood forests along the Northern Route Alternative, which could include habitat for the endangered 

Red-cockaded Woodpecker. In total, the Northern Route Alternative would cross 18.7 more miles of 

forest than the proposed route, as reported in table 3.3-1. In addition, in order to target the narrowest 

point for crossing the Calcasieu River, which the LDWF designates as a Louisiana Natural and Scenic 

River in the area north of Lake Charles, this alternative would have to go through about 6 miles of 

bottomland hardwood. It would not be feasible to cross this entire 6-mile stretch using HDD. 
 3-13 Alternatives 

Also, compared to the proposed route, the Northern Route Alternative would cross less open 

water (0.9 mile), less agricultural areas (24.9 miles), and 16 fewer roads, as shown in table 3.3-1. The 

Northern Route Alternative would run adjacent to existing rights-of-way for 5.5 miles longer than the 

proposed route. However, it would cross six more waterbodies, disturb a greater area for construction 

(64.3 acres), cross more wetlands (0.1 mile), and be slightly longer (1.3 miles). 

In summary, the Northern Route offers no real advantage compared to the proposed route and 

would create more environmental concern by trading impacts to agricultural areas with more impacts to 

forested areas and the potential habitat of an endangered species. Therefore, we believe that the proposed 

route is environmentally less damaging than the Northern Route Alternative. 

3.3.4 Center Route Alternative 

As shown in figure 3.3-1, this alternative would follow the proposed route until approximately 

MP 62.5 southeast of Lake Charles. However, rather than taking a northern turn at that point like the 

proposed route, the Center Route Alternative would continue east and then dip south to make numerous 

pipeline connections. It would then turn northeast, rejoin the proposed route near Bayou Nezpique 

around MP 99.4, and continue northeasterly along the proposed route before terminating at a point north 

of Eunice in Evangeline Parish. 

Table 3.3-1 compares this alternative to the proposed route in terms of several environmental 

criteria. Compared to the proposed route, the Center Route Alternative would cross less open water 

(0.3 mile), cross three fewer railroads, and run adjacent to existing rights-of-way for 6.4 more miles. 

However, it would be 5 miles longer than the proposed route and it would impact 149.2 acres more during 

construction, cross five more waterbodies, cross more wetlands (2.7 miles), cross more forested areas 

(0.2 mile), cross more agricultural areas (2.8 miles), and cross 19 more roads. Based on this analysis, the 

Center Route Alternative does not offer any significant environmental advantages and would create more 

impacts to waterbodies, wetlands, forests, and agricultural lands than the proposed route. Therefore, we 

believe that the proposed route is environmentally less damaging than the Center Route Alternative. 

3.4 ROUTE VARIATIONS 

Route variations differ from system or route alternatives in that they are identified to avoid or 

reduce potential construction impacts to specific localized resources such as wetlands, waterbodies, 

residences, cultural resources, recreational lands, and specific terrain conditions. While route variations 

may be a few miles in length, most are relatively short and in proximity to the proposed route. 

As part of its project development and route selection process prior to filing its application, 

KMLP considered 15 route variations to Leg 1. These variations were considered as the result of issues 

raised by the staff, other agencies, landowners, and KMLP. Variations that lessened environmental 

impacts were adopted by KMLP as part of the proposed route. 

These 15 variations are shown in the figures included in appendix F and summarized in table 

3.4-1. A description of each variation, including a table summarizing the characteristics and 

environmental resources for the variation and the proposed route, is provided below. 
3-14 

TABLE 3.4-1 

Route Variations Considered in Developing the Proposed Route for Leg 1 

Route Variation 

(Page in Appendix F 

Showing Map) 

MP Range on 

Proposed Route 

for Leg 1 Reason for Consideration Comments 

Blue Buck Point (F-1) 1.1 – 7.1 Avoid marsh south of Sabine Lake – variation 

considered at request of the Commission and other agencies 

Would avoid marsh but cause greater impact to oysters 

Garrison’s Ridge (F-2) 2.1 – 4.6 Share a greater length of right-of-way with another 

proposed pipeline – variation considered at request of the Commission 

Would increase pipeline length and length of wetlands crossed 

Vinton Drainage Canal (F-3) 31.2 – 35.7 Ensure sufficient workspace; reduce the risk of 

pipeline exposure due to shoreline erosion 

Would reduce risk associated with shoreline erosion but cause greater impact to wetlands 

Bayou Choupique (F-4) 40.1 – 45.2 Distance the route from a landfill – variation 

considered at request of Waste Management Inc. 

Would also avoid impact to high-quality forested wetland 

Calcasieu River (F-5) 40.1 – 45.2 Comply with constructability requirements; 

distance the route from wetlands 

Would avoid need for HDD workspace in COE dredge disposal site; would not come within 50 of a residence 

Tom Herbert Road #1 (F-6) 57.2 – 59.7 Minimize the subdividing of properties – variation 

considered at request of landowners 

Allows maximum collocation with existing pipeli

Tom Herbert Road #2 (F-6) 57.2 – 59.7 Minimize the subdividing of properties – variation 

considered at request of landowners 

Would not be collocated with existing pipelines 

Interstate Highway 10 (F-7) 74.9 – 78.4 Enable an HDD instead of a horizontal bore 

(thereby allowing an existing pipeline corridor to be used rather than new right-of-way) 

Would also avoid an existing and proposed residential area 

Freeland Road (F-8) 88.6 – 89.1 Distance the route from residences Would be 260 feet from nearest residence Bayou Nezpique #1 (F-9) 95.3 – 100.5 Distance the route from residences – variation 

considered at request of landowners 

Would be 320 feet from nearest residence 

Bayou Nezpique #2 (F-9) 95.3 – 100.5 Distance the route from residences – variation 

considered at request of landowners 

Would be 720 feet from nearest residence 

U.S. Highway 190 (F-10) 111.9 – 112.5 Distance the route from a residence; avoid 

construction in new right-of-way 

Would be 360 feet from nearest residence 

South Forty Acre Subdivision (F-11) 114.8 – 115.7 Distance the route from a proposed residential 

area 

Would be 940 feet from nearest existing residenand at least 50 feet from proposed subdivision boundary 

Old Schoolhouse Road (F-12) 122.0 – 123.2 Distance the route from residences Would be 160 feet from nearest residence Perron Road (F-13) 127.6 – 129.8 Distance the route from residences Would be 160 feet from nearest residence 
 3-15 Alternatives 

3.4.1 Blue Buck Point Route Variation (Leg 1 MP 1.1 – MP 7.1) 

This variation would diverge from the proposed route at MP 1.1, enter the Sabine Shipping 

Channel almost immediately and rejoin the proposed route at MP 7.1 in Sabine Lake. Table 3.4.1-1 

compares environmental factors of the Blue Buck Point Route Variation with the proposed route. 

TABLE 3.4.1-1 

Environmental Comparison of Blue Buck Point Route Variation 

Environmental Factor Proposed Route Variation 

Total Length 6.1 miles 7.3 miles 

Number of Road Crossings 1 1 

Number of Water Crossingsa 5 3 

Length in Streams and Canalsb 0.04 mile 0.6 mile 

Length in Wetlandsb 3.3 miles 0.2 mile 

Length in Industrial Areasb 0.2 mile 0 

Length in Lakesb 2.5 miles 6.5 miles 

Potential Submerged Cultural Resource Sites within Study Corridor in Sabine Lake 0 4 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

This variation was evaluated to minimize construction impacts to wetlands between the Sabine 

Pass LNG Terminal and Sabine Lake. As shown in table 3.4.1-1, the Blue Buck Point Route Variation 

would cross only 0.2 miles of wetlands, whereas the proposed route would cross 3.3 miles of wetlands. 

However, the impact of this variation on oyster populations and oyster habitat would be greater than that 

of the proposed route. From the results of the oyster survey, bottom substrate of the Blue Buck Point 

Route Variation through Sabine Lake was divided into seven bottom substrate categories, as listed in table 

3.4.1-2. The mollusks present, generally the Atlantic rangia, were located within the bottom substrates 

designated as reef and exposed shell, equating to a total area of 494.1 acres of bottom substrate suitable 

for or containing mollusks along the route variation. The majority of the oyster resources were found in 

approximately the first 4.5 miles of the Blue Buck Point Route Variation, although isolated patches of 

TABLE 3.4.1-2 

Bottom Substrate Crossed by the Blue Buck Pipeline Route Variation within Sabine Lake 

Substrate 

Acreage within 

Survey Corridor 

Percentage of 

Survey Corridor 

Soft Mud with Buried Shell 5,430.3 80.9 

Reef 487.8 7.3 

Moderately Firm Mud 281.5 4.2 

Firm Mud 238.0 3.5 

Soft Mud with Exposed Scattered Shell 229.6 3.4 

Soft Mud 36.2 0.5 

Exposed Shell 6.3 0.1 
 3-16 Alternatives 

oyster habitat occurred within the survey corridor until the route variation would join with the proposed 

route. Utilization of this variation would cause a disruption to 482.8 acres of oysters or oyster habitat that 

would be avoided by the use of the proposed pipeline route. In addition, the Blue Buck Point Route 

Variation would disrupt areas supporting higher densities of oysters. Along the route variation, samples 

indicate that approximately 8.2 live oysters per square meter occur within areas designated as reef, 

whereas only 0.6 live oysters per square meter occur along the reef areas of the proposed route. 

There is also concern that the Blue Buck Point Route Variation would take the pipeline into the 

Sabine Pass shipping channel. This channel has substantial marine traffic that would pose an increased 

risk to pipeline safety. 

For the above-mentioned reasons, we concluded that the Blue Buck Point Route Variation is 

environmentally inferior and hence not adopted. 

3.4.2 Garrison’s Ridge Route Variation (Leg 1 MP 2.1 – MP 4.6) 

This variation would diverge from the proposed route at MP 2.1 and rejoin it at MP 4.6 in Sabine 

Lake. Table 3.4.2-1 compares environmental factors of the Garrison’s Ridge Route Variation with the 

proposed route. We considered this variation as a way to run northwest along a chenier to Sabine Lake, 

potentially eliminating impacts to wetlands lying in lower areas. However, KMLP found that the chenier 

fades before reaching the lake and determined that the variation would not only add to the length of the 

pipeline but also increase the length of wetlands crossed by the Project. Acreage of wetlands impacted 

would be further increased by the need to use the saturated wetlands construction method along the route 

variation, which requires a 125-foot-wide right-of-way, rather than the marsh-buggy construction method, 

which requires a 100-foot-wide right-of-way (see section 2.3.1.2). Because of the potential for increased 

impacts to wetlands, this variation was not incorporated into the proposed route. 

TABLE 3.4.2-1 

Environmental Comparison of Garrison’s Ridge Route Variation

Environmental Factor Proposed Route Variation 

Total Length 2.5 miles 3.4 miles 

Number of Road Crossingsa 0 0 

Number of Water Crossingsa 3 3 

Length in Wetlandsb 2.5 miles 3.1 miles 

Length in Uplandsb 0.04 mile 0.3 miles 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1988 National Wetlands Inventory Data (USGS 2006b) 

3.4.3 Vinton Drainage Canal Route Variation (Leg 1 MP 31.2 – MP 35.7) 

This variation would diverge from the route originally considered during the pre-filing process at 

MP 31.2 and rejoin it at MP 35.7, with the two alignments running parallel to each other for 3.8 miles to 

the GIWW. Table 3.4.3-1 compares environmental factors of the variation with the original route. 

KMLP adopted this variation because its field surveys showed that the route originally considered ran too 

close to the GIWW for construction to be possible. The proposed route (variation) is intended to reduce 

risk of shoreline erosion of the GIWW and exposure of the proposed Leg 1 pipe over the life of the 

Project. It would, however, result in greater impacts to wetlands. 
 3-17 Alternatives 

TABLE 3.4.3-1 

Environmental Comparison of Vinton Drainage Canal Route Variation 

Environmental Factor Proposed Route (Variation) Originally Considered Route 

Total Length 4.6 miles 4.8 miles 

Number of Road Crossingsa 0 1 

Number of Water Crossingsa 1 1 

Length in Cropland and Pastureb 1.2 miles 1.5 miles 

Length in Wetlandsc 4.5 miles 3.4 miles 

Length in Uplandsc 0.1 mile 1.3 miles 

Length in Open Waterc 0.03 mile 0.04 mile 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

c

 1988 National Wetlands Inventory Data (USGS 2006b) 

3.4.4 Bayou Choupique Route Variation (Leg 1 MP 40.1 – MP 45.2) 

This variation has been incorporated into the proposed route. The route originally considered by 

KMLP during the pre-filing process diverged from the proposed route at MP 40.1 and rejoined it at 

MP 45.2. The proposed route (variation) was developed to address concerns raised by Waste 

Management Inc. regarding the proximity of the original alignment to an existing landfill less than 1,000 

feet from the route. Table 3.4.4-1 compares environmental factors of the proposed route (the adopted 

Bayou Choupique Canal Route Variation) with the originally considered route. Although 0.7 miles 

longer, the proposed route (variation) would result in one less water crossing and would avoid impacts to 

high-quality forested wetlands adjacent to Bayou Choupique. 

TABLE 3.4.4-1 

Environmental Comparison of Bayou Choupique Route Variation

Environmental Factor Proposed Route (Variation) Originally Considered Route 

Total Length 5.2 miles 4.5 miles 

Number of Road Crossingsa 11 7 

Number of Water Crossingsa 2 3 

Length in Cropland and Pastureb 4.8 miles 4.2 miles 

Length in Wetlandsc 1.4 miles 0.7 miles 

Length in Uplandsc 3.7 miles 3.8 miles 

Length in Open Waterc 0.1 mile 0.1 mile 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

c

 1988 National Wetlands Inventory Data (USGS 2006b)
 3-18 Alternatives 

3.4.5 Calcasieu River Route Variation (Leg 1 MP 47.8 – MP 52.4) 

This variation would diverge from the originally considered route at MP 47.8 and rejoin it at 

MP 52.4. KMLP developed this variation and incorporated it into the proposed route to: (1) avoid 

wetlands and ponds on the west side of the Calcasieu River; (2) avoid placing a HDD workspace within 

the COE dredge disposal site north of Devil’s Elbow; and (3) avoid wetlands on the east side of the 

Calcasieu River. Table 3.4.5-1 compares environmental factors of the proposed route (the adopted 

Calcasieu River Route Variation) with the originally considered route. As shown, the proposed route 

variation would cross one less road, one less waterbody, and 0.7 miles less of wetlands. Also, the 

proposed route (variation) would be more than 50 feet from an existing residence. 

TABLE 3.4.5-1 

Environmental Comparison of Calcasieu River Route Variation

Environmental Factor Proposed Route (Variation) Originally Considered Route 

Total Length 4.5 miles 4.6 miles 

Number of Road Crossingsa 7 8 

Number of Water Crossingsa 4 5 

Length in Cropland and Pastureb 2.1 miles 2.1 miles 

Length in Wetlandsc 1.2 miles 1.9 miles 

Length in Uplandsc 2.9 miles 1.8 miles 

Length in Open Waterc 0.4 mile 0.8 mile 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

c

 1988 National Wetlands Inventory Data (USGS 2006b) 

3.4.6 Tom Herbert Road Route Variations (Leg 1 MP 57.2 – MP 59.7) 

At the request of affected landowners who do not want their properties to be divided by the 

Project, KMLP evaluated two variations to the route originally considered during pre-filing for the 

crossing of Tom Herbert Road. Variation #1 would diverge northeast from the originally considered 

route at MP 58.0 and rejoin it at MP 59.7. Variation #2 would diverge southeast from the originally 

considered route at MP 57.2 and rejoin it at MP 59.7. Table 3.4.6-1 compares environmental factors of 

the two Tom Herbert Road Route Variations with the original route. Variation #1 was incorporated into 

the proposed route in preference to Variation #2 due to the far greater opportunity for collocation with 

existing pipelines. 
 3-19 Alternatives 

TABLE 3.4.6-1 

Environmental Comparison of Tom Herbert Road Route Variations #1 and #2

Environmental Factor 

Proposed Route 

(Variation #1) Variation #2 

Originally 

Considered Route 

Total Length 2.6 miles 2.6 miles 2.6 miles 

Number of Road Crossingsa 3 2 3 

Number of Water Crossingsa 0 0 0 

Length in Cropland and Pastureb 2.6 miles 2.6 miles 2.6 miles 

Length in Wetlandsc 0.03 mile 0 0 

Length in Uplandsc 2.5 miles 2.6 miles 2.6 miles 

Length Collocated with Other Pipelines 2.6 miles 0 0.8 mile 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

c

 1988 National Wetlands Inventory Data (USGS 2006b)

3.4.7 Interstate Highway 10 (I-10) Route Variation (Leg 1 MP 74.9 – MP 78.4) 

Table 3.4.7-1 compares environmental factors of this variation, which has been incorporated into 

the proposed route, with the route originally considered during the pre-filing process. The proposed route 

(variation) diverges from the original route at MP 74.9 and rejoins it at MP 78.4 near the proposed 

crossing of I-10. The crossing of I-10 was originally designed for installation using a horizontal bore. 

However, following field surveys, KMLP determined that using HDD to cross I-10 would allow for an 

approximately 0.2-mile reduction in pipe length. HDD would also allow the pipeline to be installed 

adjacent to an existing pipeline corridor rather than requiring construction of a new right-of-way. In 

addition, near MP 76.2, the proposed route (variation) would cross over an existing pipeline corridor to 

avoid an existing residential area and a future residential area, which the original route would have 

crossed. 

TABLE 3.4.7-1 

Environmental Comparison of I-10 Route Variation

Environmental Factor Proposed Route (Variation) Originally Considered Route 

Total Length 3.4 miles 3.6 miles 

# of Road Crossingsa 4 5 

# of Water Crossingsa 3 3 

Length in Cropland and Pastureb 3.3 miles 3.5 miles 

Length in Uplandsc 3.4 miles 3.6 miles 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

c

 1988 National Wetlands Inventory Data (USGS 2006b)
 3-20 Alternatives 

3.4.8 Freeland Road Route Variation (Leg 1 MP 88.6 – MP 89.1) 

Table 3.4.8-1 compares environmental factors of the Freeland Road Route Variation, which has 

been incorporated into the proposed route, with the originally considered route. The proposed route 

(variation) would diverge from the originally considered route at MP 88.6 and rejoin it at MP 89.1. It was 

developed to avoid residences south of Bryan Road around MP 88.9. The proposed route (variation) is 

260 feet away from the nearest residence, whereas the originally considered route was less than 50 feet 

from the nearest residence. It is about 0.1 mile longer than the originally considered route. 

TABLE 3.4.8-1 

Environmental Comparison of the Freeland Road Route Variation

Environmental Factor Proposed Route (Variation) Originally Considered Route 

Total Length 0.5 mile 0.4 mile 

Distance to Nearest Residence 260 feet less than 50 feet 

Number of Road Crossingsa 2 2 

Number of Water Crossingsa 0 0 

Length in Cropland and Pastureb 0.5 mile 0.4 mile 

Length in Uplandsc 0.5 mile 0.4 mile 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

c

 1988 National Wetlands Inventory Data (USGS 2006b)

3.4.9 Bayou Nezpique Route Variations (Leg 1 MP 95.3 – MP 100.5) 

At the request of a landowner who wanted the pipeline moved farther away from a residence, 

KMLP evaluated two variations to the route originally considered during pre-filing for the crossing of 

Bayou Nezpique. Variation #1 would diverge south from the original route around MP 96.7, cross over 

to the north of the original route at MP 99.0, and rejoin the original route at MP 100.5. Variation #2 

would diverge south from the original route at MP 95.3, join Variation #1 at MP 97.9, and continue on the 

Variation #1 route until it rejoins the original route at MP 100.5. Table 3.4.9-1 compares environmental 

factors of the two Bayou Nezpique Route Variations with the originally considered route. Although both 

variations are very similar in terms of most environmental parameters, Variation #2 was incorporated into 

the proposed route in preference to Variation #1 because it enabled the Project to be located farther from 

residences. 

3.4.10 US Highway 190 Route Variation (Leg 1 MP 111.9 – MP 112.5) 

This variation would diverge from the originally considered route at MP 111.9 and rejoin it at 

MP 112.5. The variation was developed and incorporated into the proposed route to avoid a residence 

east of MP 112.2. Table 3.4.10-1 compares environmental factors of the proposed route (the adopted U.S. 

Highway 190 Route Variation) with the original route. As shown, the proposed route (variation) would 

be 0.1 mile longer, but it would be approximately 180 feet farther away from the nearest residence. The 

proposed route (variation) would also allow greater collocation with an existing pipeline right-of-way. 
 3-21 Alternatives 

TABLE 3.4.9-1 

Environmental Comparison of Bayou Nezpique Route Variations #1 and #2

Environmental Factor 

Proposed Route 

(Variation #2) Variation #1 

Originally 

Considered Route 

Total Length 5.3 miles 5.2 miles 5.2 miles 

Number of Residences within 50 feet 0 0 6 

Distance to Nearest Residence 720 feet 320 feet less than 50 feet 

Number of Road Crossingsa 6 6 6 

Number of Water Crossingsa 3 3 3 

Length in Cropland and Pastureb 4.2 miles 4.2 miles 4.2 miles 

Length in Mixed Forest Landb 0.6 mile 0.6 mile 0.5 mile 

Length in Wetlandsc 0.4 mile 0.5 mile 0.5 mile 

Length in Uplandsc 4.9 miles 4.8 miles 4.7 miles 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

c

 1988 National Wetlands Inventory Data (USGS 2006b)

TABLE 3.4.10-1 

Environmental Comparison of US Highway 190 Route Variation

Environmental Factor Proposed Route (Variation) Originally Considered Route 

Total Length 0.6 mile 0.5 mile 

Distance to Nearest Residence 360 feet 180 feet 

Number of Road Crossingsa 2 2 

Number of Water Crossingsa 0 0 

Length in Cropland and Pastureb 0.2 mile 0.1 mile 

Length in Evergreen Forest Landb 0.4 mile 0.4 mile 

Length in Wetlandsc 0 0.02 mile 

Length in Uplandsc 0.6 mile 0.5 mile 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

c

 1988 National Wetlands Inventory Data (USGS 2006b)

3.4.11 South Forty Acre Subdivision Route Variation (Leg 1 MP 114.8 – MP 115.7) 

This variation would diverge from the originally considered route at MP 114.8 and rejoin it at MP 

115.7. The variation was developed and incorporated into the proposed route to avoid a proposed 

residential area, the South Forty Area Subdivision. Table 3.4.11-1 compares environmental factors of the 

proposed route (the adopted South Forty Acre Subdivision Route Variation) with the original route. As 

shown, the proposed route (variation) would be 0.35 miles longer, but it would be approximately 900 feet 

farther away from the nearest existing residence. In addition, the proposed route (variation) has been 

located more than 50 feet away from the expected boundary of the South Forty Area Subdivision, 

whereas the original route would run through the middle of this proposed subdivision. 
 3-22 Alternatives 

TABLE 3.4.11-1 

Environmental Comparison of the South Forty Acre Subdivision Route Variation

Environmental Factor Proposed Route (Variation) Originally Considered Route 

Total Length 0.9 mile 0.65 mile 

Distance to Nearest Residence 940 feet less than 50 feet 

Number of Road Crossingsa 3 3 

Number of Water Crossingsa 0 0 

Length in Cropland and Pastureb 0.9 mile 0.65 mile 

Length in Uplandsc 0.9 mile 0.65 mile 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

c

 1988 National Wetlands Inventory Data (USGS 2006b)

3.4.12 Old Schoolhouse Road Route Variation (Leg 1 MP 122.0 – MP 123.2) 

This variation would diverge from the originally considered route at MP 122.0 and rejoin it at 

MP 123.2. The variation was developed and incorporated into the proposed route to avoid several 

residences. Table 3.4.12-1 compares environmental factors of the proposed route (the adopted Old 

Schoolhouse Road Route Variation) with the original route. As shown, the proposed route (variation) 

would be 160 feet away from the closest existing residence, compared to the original route that would 

have been within 50 feet of three residences. 

TABLE 3.4.12-1 

Environmental Comparison of the Old Schoolhouse Road Route Variation

Environmental Factor Proposed Route (Variation) Originally Considered Route 

Total Length 1.3 miles 1.3 miles 

Number of Residences within 50 feet 0 3 

Distance to Nearest Residence 160 feet less than 50 feet 

Number of Road Crossingsa 2 2 

Number of Water Crossingsa 0 0 

Length in Cropland and Pastureb 1.3 miles 1.3 miles 

Length in Uplandsc 1.3 miles 1.3 miles 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

c

 1988 National Wetlands Inventory Data (USGS 2006b)
 3-23 Alternatives 

3.4.13 Perron Road Route Variation (Leg 1 MP 127.6 – MP 129.8) 

This variation would diverge from the originally considered route at MP 127.6 and rejoin it at MP 

129.8. The variation was developed and incorporated into the proposed route to avoid residential areas 

near MPs 128.4 and 129.7. Table 3.4.13-1 compares environmental factors of the proposed route (the 

adopted Perron Road Route Variation) with the original route. As shown, the proposed route (variation) 

is 0.1 mile longer. However, the proposed route (variation) would be 160 feet away from the closest 

existing residence, compared to the original route that would have been within 50 feet of two residences. 

TABLE 3.4.13-1 

Environmental Comparison of the Perron Road Route Variation

Environmental Factor Proposed Route (Variation) Originally Considered Route 

Total Length 2.2 miles 2.1 miles 

Number of Residences within 50 feet 0 2 

Distance to Nearest Residence 160 feet less than 50 feet 

Number of Road Crossingsa 4 4 

Number of Water Crossingsa 0 0 

Length in Cropland and Pastureb 2.2 miles 2.1 miles 

Length in Uplandsc 2.2 miles 2.1 miles 

_______________ 

a

 2000 ESRI Tiger Data (US Census Bureau 2004) 

b

 1990 USGS Land Use and Land Cover Data (USGS 2006a) 

c

 1988 National Wetlands Inventory Data (USGS 2006b)
[This page intentionally left blank.] 
 4-1 Environmental Analysis

4.0 ENVIRONMENTAL ANALYSIS 

The environmental consequences of constructing and operating the Project would vary in duration 

and significance. Four levels of impact duration were considered: temporary, short-term, long-term, and 

permanent. Temporary impacts generally occur during construction with the resource returning to 

preconstruction conditions almost immediately afterward. Short-term impacts would continue for 

approximately three years following construction. Impacts were considered long-term if resources would 

require more than three years to recover. Permanent impacts would occur as a result of activities that 

modify resources to the extent that they would not return to preconstruction conditions during the life of 

the Project, such as with construction of an interconnect. We considered an impact to be significant if it 

would result in a substantial adverse change in the physical environment. 

In this section, we discuss the affected environment, general construction and operational 

impacts, and proposed mitigation for each resource. KMLP, as part of its proposal, agreed to implement 

certain measures to reduce impacts, and we evaluated the proposed mitigation measures to determine 

whether or not additional measures would be necessary to further reduce impacts. These additional 

mitigation measures that we have identified appear as bulleted, boldface paragraphs in the text. We are 

recommending that these measures be included as specific conditions to the Certificate that the FERC 

may issue to KMLP for the Project. 

Conclusions in this draft EIS are based on our analysis of the environmental impact and the 

following assumptions: 

• KMLP would comply with all applicable laws and regulations; 

• The facilities would be constructed as described in section 2.0 of this draft EIS; and 

• KMLP would implement the mitigation measures identified in its application and 

supplemental filings to the FERC. 

This section of the draft EIS is organized by environmental resource. For most resources, the 

scope of our analysis includes the construction and operation of the facilities, which are limited to the 

pipelines, their support facilities, workspaces extra to the pipelines’ rights-of-way, interconnect sites, 

access roads, and yards for pipe storage and contractor use during the construction phase. The draft EIS 

also includes detailed discussion of natural gas pipeline reliability and safety (see section 4.13) and the 

cumulative impacts of the Project and other projects in the area (see section 4.11). 

4.1 GEOLOGIC RESOURCES 

4.1.1 Affected Environment 

Geologic Setting 

The entire state of Louisiana is within the physiographic section referred to as the Coastal Plain 

Province by the USGS. The surface of this region is underlain by geologically young sediments 

deposited in or adjacent to rivers and deltas in a coastal plain setting. Below the surface sediments are 

Tertiary rocks at a depth of thousands of feet. The KMLP Project begins in the Holocene coastal marshes 

of Cameron Parish and extends across the Pleistocene terraces of Calcasieu, Jefferson Davis, Acadia, and 

Evangeline Parishes (table 4.1.1-1). The Holocene coastal marshes are alluvium deposits associated with 

major rivers and tributaries along with coastal deposits of marine sediments, and account for 

approximately 55 percent of the surface in Louisiana. The Pleistocene terraces consist of sand, gravel, 
 4-2 

TABLE 4.1.1-1 

Geology Along the Proposed KMLP Project 

Map Unit 

Epoch Symbol Name Description 

Holocene HsM Small river meanderbelt deposits Point-bar and associated overbank deposits underlying meander belts of the Sabine R

surface of the meander-belt is characterized by ridge and swale topography. These d

typically consist of gray to reddish brown sand, silt, silty clay, and sandy clay. 

Holocene Hm Mermentau 

Alloformation 

Complex interfingering and interbedded, dark-colored marine muds, sandy and shelly deposits, organic marsh clays, and lacustrine and bay muds. These deposits bury the 

of the Prairie and Deweyville Allogroups. The Louisiana chenier plain forms the surfaMermentau Alloformation. The unit extends westward along the coast into Texas as fGalveston Bay. Eastward, it extends almost to the west shore of Vermilion Bay, wher

interfingers with deltaic sediments of the Teche delta lobe. Seaward of the shoreline, 

Mermentau Alloformation grades laterally into unnamed marine sediments. 

Holocene Hs Small river deposits, 

undifferentiated 

Undifferentiated alluvium of small coastal rivers, consisting of recognizable but unmapchannel and overbank deposits within the Calcasieu River Valley. 

Holocene Hua Undifferentiated 

alluvium of small upland streams 

Alluvial deposits of minor streams and creeks filling valleys cut into older deposits. Thfloodplain within these valleys constitutes the surface of the deposits. The lithology of alluvial deposits reflects the reworked lithology of their adjacent source. 

Pleistocene Ppbe Beaumont 

Alloformation 

Coastal plain deposits of late-to-middle-Pleistocene streams: the oldest and topographighest surface of the Prairie Allogroup units of southwestern Louisiana. It exhibits thchannels of the Red and Calcasieu rivers, and includes deposits of the Ingleside barri

the southwest of the Ville Platte quadrangle. 

Pleistocene Pper Relict Pleistocene 

coastal ridges 

Low-lying ridges delineated on the surface of the Beaumont Alloformation. Some of thare coast-parallel and others trend obliquely to the coast and radiate from the end of tmeander-belts. Limited drilling indicates that these ridges are either meander-belt ridgdeltaic distributaries of differing ages. The origins of other coastal ridges developed oBeaumont surface to the west of the Crowley quadrangle remain undetermined. 
 4-3 Environmental Analysis

and mud deposits and were formed as remnants of pre-existing floodplains tilted in response to the downwrapping of the crustal floor of the Gulf of Mexico. The Pleistocene terraces account for approximately 

25 percent of the surface in Louisiana (Louisiana Geological Survey 2006). 

Permeable Quarternary sedimentary deposits overlie sedimentary rock formations at depths of at 

least 5,000 feet along the northernmost reaches of the Project, and increase to over 10,000 feet near the 

coastline (Renken 1998). There is no bedrock exposure within 50 miles of the pipeline. 

The topography throughout the Project area is characterized by low elevation and relief. Slopes 

are generally flat to gentle except for river/stream banks, man-made levees, roadways, and areas of fill. 

The beginning of the Project in the vicinity of Sabine Lake has an elevation at sea level. Elevation rises 

to 65 feet above sea level at the end of the Project in Acadia Parish. 

Cheniers can be found along the Gulf Coast and within the vicinity of the Project. Cheniers are 

geomorphological formations consisting of ridges and low-lying marshes formed by alternating high and 

low sediment supply periods. The ridges are typically 1 to 3 feet above adjacent areas and provide 

elevated land for commercial and residential development. They support maritime forests typically of 

live oak, which provide important habitat for birds and mammals amongst the marshes of coastal 

Louisiana. The State of Louisiana provides special protection to chenier formations, requiring that 

“surface alterations which have high adverse impacts on natural functions shall not occur, to the 

maximum extent practicable, on barrier islands and beaches, isolated cheniers, isolated natural ridges or 

levees, or in wildlife and aquatic species breeding or spawning areas, or in important migratory routes” 

(Louisiana Administrative Code Title 43, Part I, Subchapter B, Coastal Use Guidelines, Section 711 (I)). 

Mineral Resources 

Mineral resources currently exploited or potentially exploitable in the region where the KMLP 

Project would be located include oil, gas, coal, salt, sand and gravel, gypsum, lime, and stone. 

Southern Louisiana is an active area for oil and gas production. Oil and gas wells in the vicinity 

of the KMLP Project were identified using maps and ownership databases obtained from the Louisiana 

Oil Spill Coordinators Office (LAOSCO). According to these data, there are 218 oil and gas wells within 

1⁄4 mile of the pipeline. Of those 218 wells, 21 are within 150 feet of the pipeline and 9 wells are within 

the construction work area. The approximate locations and status of these 21 wells are listed in table 

4.1.1-2. 

The closest major salt mine, Texas Brine Corp. in northern Jefferson County, Texas, is about 

25 miles west of the pipeline. No brine wells or other salt recovery operations have been found within the 

construction workspace of the KMLP Project. 

Sand and gravel operations are present in Calcasieu, Jefferson Davis, and Evangeline Parishes. 

The closest major sand and gravel operations are located in northwest Jefferson Davis Parish, about 

10 miles north of the Project (National Atlas 2006). Two borrow pits are located in the vicinity of the 

pipeline. One is located completely across the construction right-of-way at approximately MP 52.7. The 

other is located about 200 feet away from the pipeline with its entrance road at approximately MP 66.0. 
 4-4 

TABLE 4.1.1-2 

Oil and Gas Wells Within 150 feet of the KMLP Project 

MP Parish Owner/Operator Oil and Gas Field 

Distance from

Proposed 

Pipeline 

(feet) 

Within 

Constructio

Right-ofWay? 

1.2 Cameron Sabine Pass Terminal SWD Johnsons Bayou, West 52.2 Yes 

40.5 Calcasieu MGGT-GL Wildcat – So. LA Lafayette Dist. 122.5 No 48.4 Calcasieu Grady Mayeaux Wildcat – So. LA Lk. Charles Dist. 41.3 No 49.5 Calcasieu M CAM RE SUA; SL 11524 Moss Lake, East 4.5 Yes 49.5 Calcasieu William T. Burton IND Inc. Wildcat – So. LA Lafayette Dist. 5.8 Yes 57.5 Calcasieu Walker Unit A Lake Charles, South 135.8 No 67.9 Calcasieu Humoris Spears Manchester 28.7 Yes 69.3 Calcasieu Farmers Land and Canal Company Manchester 0.6 Yes 84.0 Jefferson Davis William E. Trimble Welsh, North 120.1 No 

104.9 Acadia Phillip Klumpp Wildcat – So. LA Lafayette Dist. 35.3 No 106.9 Acadia T. Ortego A SU; BNKHD Fruge Tepetate 94.2 No 107.0 Acadia Theogene Ortego Tepetate 134.3 No 107.4 Acadia T. Ortego A SU; L L Welch A Tepetate 63.3 No 107.5 Acadia L. L. Welch A Tepetate 42.5 Yes 108.3 Acadia J. R. Jones Tepetate 115.5 No 109.5 Acadia M. L. Vincent Jr. Tepetate, North 30.5 Yes 109.8 Acadia M. L. Vincent Tepetate, North 104.4 No 109.8 Acadia HMSKR B SUF; M L Vincent Jr. Tepetate, North 104.4 No 109.8 Acadia M. L. Vincent Jr. Tepetate, North 104.4 No 112.2 Acadia M. R. Jenkins Estate Wildcat – So. LA Lafayette Dist. 44.9 Yes 112.2 Acadia Mark Jenkins Estate Basile 44.9 Yes 
 4-5 Environmental Analysis

4.1.2 Impacts and Mitigation 

The primary effect of pipeline construction on geology would be disturbances to the existing 

topography along the construction right-of-way. As described in section 2.3, all areas disturbed during 

pipeline construction would be graded and restored as closely as possible to preconstruction contours 

during cleanup and restoration. Additionally, blasting is not anticipated because the Project would be 

unlikely to encounter bedrock exposures. For these reasons, we believe that construction, maintenance, 

and operation of the Project would be unlikely to result in significant alterations of the topography or 

geological resources of the Project area. 

The Project would cross the western-most portion of a chenier known as Garrison Ridge. This 

crossing would be done by HDD to avoid impacts to this chenier. Maintenance and operation of the 

pipeline would not disturb the chenier. There are two other cheniers, Saunders Ridge and Blue Buck 

Ridge, in the vicinity, but they would not be crossed by the Project. 

Mineral Resources 

As noted above, 9 oil and gas wells are reported to be within the construction right-of-way. 

However, no wells within the construction right-of-way were actually observed in locations where survey 

permission had been granted. Some wells may have been plugged and abandoned and surface features 

may no longer remain. The centerline has not been adjusted to miss these recorded well locations. The 

reported location of the well may be incorrect and moving the line could move it to the actual location of 

the well, or with the high level of oil and gas production in the area, could interfere with another well. To 

confirm the existence of active or plugged/abandoned wells within the pipeline construction right-of-way, 

and minimize impacts on those wells that could be affected, KMLP would: 

• Conduct a pre-construction physical survey using a magnetometer (or equivalent 

instrumentation) to identify non-reported or abandoned oil or gas wells, and to confirm the 

location of reported wells, in those areas along the right-of-way where wells are reported to 

be within 1⁄4 mile of the pipeline; 

• In the event a well is found, determine a safe buffer zone around the well for each 

construction procedure based on the size and current condition of the well, in consultation 

with the owner of the well; 

• Adjust the pipeline centerline, if necessary, to ensure that the pipe trench excavation would 

not interfere with the integrity of the well (generally, a minimum separation distance of 50 

feet would be maintained between the pipeline and the well); 

• Reduce the construction workspace, as necessary, to keep stockpiled spoil and associated 

equipment a safe distance from the well; 

• Flag wells within the construction right-of-way and place barricades at the edge of the buffer 

zone to exclude construction equipment and personnel; 

• Document the condition of each well before construction and repair any damage caused by 

pipeline construction activities to surface facilities or the well casing, as appropriate; and 

• Follow the safety precautions similar to those maintained while crossing foreign pipelines 

(e.g., no mechanized equipment within a prescribed distance, no open flames or smoking, and 
 4-6 Environmental Analysis

monitoring for detection of 25 percent of the lower explosive limit of natural gas in the air) in 

the vicinity of oil and gas wells, as appropriate. 

Minor route changes to reduce impacts on existing mineral resources, such as oil and gas 

production wells, may result in impacts to additional landowners or may affect other resources. If this 

occurs, KMLP would contact the FERC for any route realignments. Construction, operation, and 

maintenance of the Project would not affect future recovery of oil and gas, and nearby oil and gas wells 

would not affect the Project. The Project is limited to near-surface disturbance over a relatively small 

area that would not restrict access to oil and gas resources that are typically located at depths of more than 

1,000 feet. 

There are no salt or brine operations identified near the Project area. The nearest salt mine is 

about 25 miles west of the Project. No major sand and gravel mining operations are located near the 

project area. The nearest one is located at about 10 miles away. However, two borrow pits are located 

along Leg 1 near MP 52.7 and MP 66.0. The borrow pit near MP 52.7 would be crossed by Leg 1 and 

KMLP plans to cross this pit using HDD. KMLP has indicated the landowner/owner of the pit may 

receive inert highway demolition material for disposal to fill the pit in the future. KMLP has not provided 

any documentation of consultation with the owner of the pit. KMLP believes that since the pipeline 

would be installed by HDD and be separated from the bottom of the pit by a distance determined to be 

safe by KMLP engineering analysis, no impact to the integrity of the pipeline is anticipated nor would it 

cause any disruption to the disposal operations. However, in order to minimize impact to the borrow pit 

at MP 52.7, we recommend that:

• Prior to the closing of the draft EIS comment period, KMLP file with the Secretary a 

letter from the borrow pit owner addressing the existing and future use of this resource.

Upon completion of pipeline construction, no excavations would be allowed within the operating 

pipeline right-of-way to recover sand or gravel. These resources are relatively abundant throughout the 

area so the Project would have no adverse effect on the future commercial use of sand and gravel if 

limited areas are excluded from mining. 

Based on this analysis, we believe the Project would have an inconsequential effect on mineral 

resources in the area. 

Seismicity and Faulting 

Hazards associated with seismicity and faulting include ground shaking, surface rupture of faults, 

and offset along normal, reverse, or strike-slip faults. These are especially hazardous to linear, rigid 

structures, such as pipelines, in which the ground is not moving the same distance or in the same 

direction. According to seismic hazard maps of the United States and Louisiana, the Project would be 

located in a region of low seismic risk (USGS 2006c). The Gulf Coast, including the Project area, is 

within Seismic Zone 0, the lowest seismic hazard category, according to the Uniform Building Code’s 

Seismic Risk Map (International Conference of Building Officials 1997). The peak ground acceleration 

(PGA) with 10 percent probability of exceedance over 50 years (i.e., annual frequency of exceedance of 

0.002) in the vicinity of the Project is estimated to be extremely low at between 1 and 2 percent of the 

gravity acceleration. An earthquake with PGA between 1 and 2 percent of the gravity acceleration would 

not result in damage to the pipeline. 

There are numerous growth faults located throughout the Gulf Coast Region, but they present 

little risk of earthquakes since no earthquakes have been definitely attributed to any of the specific 

mapped fault systems (McCulloh 2001). The pipeline likely crosses several growth faults. However, 
 4-7 Environmental Analysis

movement along these growth faults, if active, would be a slow creep, measured in a few millimeters or 

fractions of millimeters per year. The minimum wall thickness proposed for the KMLP Project would be 

sufficient to withstand any expected ground movement associated with these growth faults. 

Based on the low historic seismicity and the slow creep of the faults in the area, we believe 

seismicity and faulting would not present a significant risk to the Project. Further, construction and 

operation of the Project would not change the local seismic and faulting conditions. 

Soil Liquefaction 

Soil liquefaction is a condition that occurs when loosely packed deposits change from a solid to a 

liquid state because of increased pressure and reduced stress resulted from seismic shaking or other 

events. The horizontal PGA required to induce soil liquefaction is typically more than 10 percent of the 

gravity acceleration (Youd and Idriss 2001). Since the PGA in the vicinity of the Project is only 1 to 2 

percent of the gravity acceleration, the potential for soil liquefaction would be very low. 

Subsidence 

Subsidence is lowering of the land surface from changes that take place underground such as 

dissolution of limestone in karst terrain areas, mining or extraction of underground resources, and 

consolidation of sedimentary deposits. There is no karst terrain or underground mines in the Project area. 

Extraction of oil and gas and the consolidation of sedimentary deposits are known to cause ground 

subsidence in southern Louisiana. However, since this type of subsidence is a gradual movement of the 

land surface over generally large areas, with little or no localized differential settlement, the potential for 

subsidence to occur and affect the KMLP facilities is low. At the same time, the construction and 

operation of the KMLP facilities would not increase subsidence in the area. 

Flooding from Hurricanes and Other Major Storms 

Coastal areas of Louisiana are subject to flooding and shoreline erosion from storm surge and 

heavy precipitation associated with hurricanes, tropical storms, and other major storms. Most of the 

Project in Cameron and Calcasieu Parishes would be located in the 100-year floodplain as defined by the 

Federal Emergency Management Agency (FEMA). The northeast sections are primarily out of the 

floodplain except where it crosses lowlands associated with bayous and other waterbodies. In total, 55 

miles of the 132 miles (about 42 percent) of Leg 1 of the Project would be within the 100-year floodplain. 

After construction, the original grade would be restored. Construction, operation, and 

maintenance would not significantly alter the floodplain. Flooding could increase the buoyancy of the 

pipelines, causing them to rise to the surface and become exposed. In areas that are saturated or could 

become saturated with water, KMLP proposes to use concrete weight-coated pipe to counteract buoyancy. 

Major waterbodies would be crossed by HDD, which would place the pipe at least 20 feet below the 

waterbody and minimize the chance that the pipeline would be exposed due to scour by fast moving water 

and debris. Regular maintenance activities along the right-of-way would identify areas of soil erosion, 

exposed pipe, or other flood-related damage. KMLP would use terrace repair or backfill replacement in 

areas of concern. 

Based on these precautions, the potential for the project to increase the frequency or magnitude of 

flooding is very low. 
 4-8 Environmental Analysis

Slope Stability 

Impacts to slope stability include landslides, debris flows, and rock falls, which are generally 

associated with steep slopes and can be instigated by cutting slopes, the use of heavy equipment, and/or 

unusually heavy precipitation. Topography along the Project is characterized as flat to gently sloping 

where slope failure would not be expected. Steeper slopes are present at some navigation and stream 

channel banks, flood control levees, and construction excavation and fill areas such as where Leg 1 

crosses Bayou Cannes near MP 124.7. These areas are relatively short in length and therefore any sliding 

would not result in any damage to the pipe integrity. Pipeline construction would be accomplished in 

accordance with our Plan, which includes measures to control runoff and erosion and to minimize the 

potential for slope failures. With these measures, construction, operation, and maintenance of the Project 

would not affect slope stability. 

KMLP proposed an alternative measure to item V.A.5 of our Plan, which requires land surfaces 

to be restored to pre-construction contours, unless such contours threaten the integrity of the pipeline. 

While we agree with this concept, KMLP did not provide sufficient justification for the alternative 

measure either for the Project as a whole or for any particular sites. Therefore, we recommend that:

• KMLP comply with the requirements of item V.A.5 of our Plan. If KMLP identifies a 

location(s) where it can not implement item V.A.5, KMLP should file with the Secretary 

for review and written approval by the Director of OEP, any alternative measures that 

it would use to ensure pre-construction contours are restored without compromising 

pipeline integrity. 
 4-9 Environmental Analysis

4.2 SOILS 

4.2.1 Affected Environment 

The Project would cross three Major Land Resource Areas (MLRAs), as designated by NRCS 

(2006a). The Project would originate in the Gulf Coast Marsh MLRA, which is generally dominated by 

Saprist and Aquent soils. These are hydric soils susceptible to frequent flooding because the water table 

is at or above the surface most of the time. This area supports marsh vegetation and is primarily used for 

wildlife habitat. The Project would cross the Gulf Coast Prairies MLRA where Aqualfs are the dominant 

soils. The area naturally drains poorly and in the past it supported forest vegetation. At present this area 

is primarily artificially drained and farmed for hay, soybeans, grain, cotton, corn, and rice. The Project 

would terminate in the Western Gulf Coast Flatwoods MLRA in which Aqualfs, Udalfs, and Udults are 

the dominant soils. These soils range from poorly drained to moderately well drained. About 72 percent 

of the Western Gulf Coast Flatwoods MRLA is managed for harvest of pine and hardwoods. 

Table 4.2.1-1 presents basic characteristics of the soil series along the Project that could affect 

pipeline construction or maintenance, including the soil series or complex name (and corresponding soil 

map unit), soil texture, presence of hydric soils, drainage class, flooding frequency and duration, presence 

of prime farmland, erosion factor, and compaction potential. All of the soils present at the interconnect 

sites are crossed by the pipeline with the addition of one map unit, Aquents (AN), and one soil complex, 

Hackberry-Mermentau (Hm). These characteristics were identified using data from NRCS’s online Soil 

Survey Geographic Database (NRCS 2006b and 2006c). 

Soil characteristics determine its susceptibility to erosion, flooding, and compaction, or make it 

suitable for agricultural uses. The erosion factor of a soil represents the likelihood of the soil to erode as 

determined by soil detachment and water infiltration properties. In general, the soils that would be 

crossed by the Project are low to moderately susceptible to erosion with erosion factors ranging from 0.24 

to 0.49. The majority of soils that would be crossed by the Project drain somewhat poorly to very poorly. 

The majority of soils also experience frequent and long duration flooding events and are characterized as 

hydric soils. Drainage properties, frequency and duration of flooding events, or the classification as 

hydric soils are all indicators of the relative wetness of the soil under natural conditions. Soil compaction 

can modify the structure and natural properties of the soil and affect hydrology, erodibility, and 

revegetation. Approximately 50 miles of the Project would cross soils with a severe compaction 

potential. None of the soils crossed have shallow bedrock and no blasting would be required during 

pipeline construction. All of the soils have a good revegetation potential after construction disturbance. 

Approximately two-thirds of the Project would cross through soils designated as prime farmland by 

NRCS. Soils designated as prime farmland provide the highest crop yield per unit energy expended due 

to the favorable conditions of the soils for agricultural production. 

4.2.2 Impacts and Mitigation 

4.2.2.1 Construction Impacts 

Construction activities associated with the Project, such as clearing, grading, trenching, and 

backfilling, have the potential to affect soil resources through multiple mechanisms. The most significant 

effects include the potential increases in soil erosion and compaction, the loss of soil productivity and 

fertility by mixing of topsoil and subsoil horizons, and changing drainage patterns. Removal of 

vegetative cover increases the possibility of erosion by wind and water. Mixing of topsoil with subsoil 

and compaction caused by passage of heavy construction equipment can adversely affect revegetation 
4-10 

TABLE 4.2.1-1 

Soils Crossed by the Proposed KMLP Pipeline 

Cumulative 

Length 

Crossed 

(miles) Map Unit 

Soil Series 

or 

Complex Namea Soil Texture 

Hydric

Soil? 

Drainage 

Class 

Flooding 

Frequency 

and 

Duration 

Prim

Farmla

1.3 AcB Acadia Silt loam No Somewhat Poorly N/A Yes 1.5 AdB Acadiana Silt loam No Moderately Well None Yes 1.2 AN Aquents Silty clay loam/silty 

clay/clay 

n/a Very Poorly Frequent No 

0.9 BA Bancker Muck Yes Very Poorly Frequent, Very 

Long 

No 

0.8 BSA Basile and Brule Silt loam/silty clay 

loam 

Yes Poorly (Basile), Moderately 

Well (Brule) 

Frequent, Long No 

0.1 BEA Basile and 

Cascilla 

Silt loam Yes Poorly Frequent, Very 

Long 

No 

0.7 Bw BasilenWrightsville Silt loam Yes Poorly Frequent, Long No 1.8 CO Clovelly Muck Yes Very Poorly Frequent, Very 

Long 

No 

1.2 CR Creole Mucky clay Yes Very Poorly Frequent, Very 

Long 

No 

6.5 Cr, CrA, 

CrB, 

Crowley Silt loam No Somewhat Poorly None Yes 

30.7 Cv Crowley-Vidrine Silt loam No Poorly, Somewhat Poorly N/A Yes 

0.1 FrA Frost Silt loam Yes Poorly Occasional, Brief Yes 1.1 GB Ged Clay Yes Very Poorly Frequent, Long No 3.1 GC Gentilly Muck Yes Very Poorly Frequent, Very 

Long 

No 

0.1 IoD Iota Silt loam No Well N/A No 0.9 Je Jeanerette Silt loam No Poorly N/A Yes 
4-11 

TABLE 4.2.1-1 (continued) 

Soils Crossed by the Proposed KMLP Pipeline 

Cumulative 

Length 

Crossed 

(miles) Map Unit 

Soil Series 

or 

Complex Namea Soil Texture 

Hydric

Soil? 

Drainage 

Class 

Flooding 

Frequency 

and 

Duration 

Prim

Farmla

1.7 Ju Judice Silty clay loam Yes Poorly Rare, Brief Yes 4.2 KpA, KpB Kaplan Silt loam No Somewhat Poorly N/A Yes 4.3 KvA Kinder-Vidrine Silt loam Yes Poorly N/A Yes 4.9 Lt, LeA Leton Silt loam Yes Poorly Rare, Brief Yes 0.4 MaB Mamou Silt loam No Somewhat Poorly N/A Yes 0.1 ME Mermentau Clay Yes Poorly Frequent, Brief No 0.7 Mn, MdA Midland Silty clay loam/silt 

loam 

Yes Poorly Rare, Brief Yes 

11.9 Mr Morey Loam No Poorly Rare, Brief Yes 

5.0 Mt, MtA Mowata Silt loam Yes Poorly N/A Yes 

14.7 Mt, MwA Mowata-Vidrine Silt loam Yes Poorly N/A Yes 

0.6 Pc PatoutvilleCrowelly Silt loam No Somewhat Poorly N/A Yes 1.9 SC Scatlake Mucky clay Yes Very Poorly Frequent, Very 

Long 

No 

12.6 UA, UD Udifluvents, 

varies 

Varies No N/A None No 

0.1 Up Urban Land N/A No N/A None No 

16.7 W Water, Large N/A n/a N/A None N/A 

5.5 Wv WrightsvilleVidrine Silt loam Yes Poorly and Somewhat Poorly N/A Yes 

_______________ a Soil series descriptions are from the Official Soil Series Descriptions (OSD) maintained by NRCS 
 4-12 Environmental Analysis

potential and agricultural productivity. Alteration of the surface topography can affect hydrology, 

influencing stormwater runoff and soil drainage patterns. 

In general, the above impacts would be avoided or minimized through implementation of our 

Plan. The Plan is intended to identify baseline mitigation measures for minimizing erosion and enhancing 

revegetation. These measures include erosion controls, reducing soil disturbance, and reestablishing 

preconstruction contours and vegetative cover as soon as practicable. Some of the relevant aspects of our 

Plan include: 

• segregate a maximum of 12 inches of topsoil in all actively cultivated or rotated croplands, 

pastures, residential areas, hayfields, and at other areas at the request of the landowner or land 

management agency; 

• provide temporary erosion and sediment control measures such as silt fences, straw bales, 

slope breakers, seeding, mulch, and erosion control fabric to minimize any impacts related to 

soil erosion and sedimentation that may result from precipitation runoff; 

• mitigate soil compaction following construction and right-of-way restoration activities, as 

described below; 

• ensure revegetation of all areas disturbed by project-related activities; disturbed upland areas 

would be seeded in accordance with written recommendations from local conservation 

authorities or as requested by the landowner; 

• provide post-construction monitoring of mitigation practices to ensure their success; and 

• utilize EIs to ensure implementation of the practices outlined above.

Erosion

The soils affected by the Project have a low to moderate susceptibility to erosion, and 

construction activities would remove vegetative cover and expose soils to erosive forces. Without 

mitigative measures, soil erosion can degrade soil quality, adversely affect nearby waterbodies, and 

impair revegetation efforts. KMLP would implement erosion control practices during construction and 

operation of the Project. Temporary control measures would be installed immediately after initial soil 

disturbance. Disturbed areas would be restored to their original contours and revegetation efforts would 

begin within six days of final grading, weather and soil conditions permitting. With the implementation 

of the above measures, we believe impacts associated with soil erosion would be minimized. 

Soil Compaction

Soil compaction during construction is caused by heavy construction equipment or other 

unauthorized vehicles. Soil compaction damages the structure of the soil and reduces transport of air and 

water to plant roots. Compacted soils may have lower productivity, slower plant growth, increased 

erosion, and change natural drainage of water. Approximately 50 miles of the Project and 11 of the 

interconnect sites would affect soils with a high soil compaction potential. In these areas, use of heavy 

equipment would result in compaction. Some of these impacts would be avoided by the use of HDD 

especially under waterbodies. In other areas, board roads or low-ground pressure equipment would be 

used to prevent severe compaction. The heavy equipment that would be used to construct the Project are 
 4-13 Environmental Analysis

tracked vehicles, with a ground pressure (i.e., pounds per square foot) similar to or less than the large 

four-wheel-drive tractors commonly used for rice farming in the region. 

In areas with compaction potential, KMLP would implement the measures specified in our Plan, 

as appropriate for the site-specific conditions, such as the use of a para-plow or other deep tillage 

equipment. Alternatively, KMLP may plant and plow under a green manure crop (a growing crop that is 

plowed under) to decrease soil density, with landowner approval. 

In rice fields and crawfish ponds, KMLP would attempt to schedule construction when fields are 

not normally flooded or negotiate with landowners to defer flooding so that construction would occur 

when the soils are dry. Drier soil conditions would allow KMLP to ensure that a reasonable degree of 

compaction at near-optimum moisture content can be achieved when backfilling the pipe trench. KMLP 

would ensure that the low permeability layer underlying the field is re-installed to near pre-construction 

conditions in order to contain water during subsequent flooding for crop production. With these 

measures, we believe impacts associated with soil compaction would be minor and temporary. 

Hydric Soils

Hydric soils are formed under conditions of saturation, flooding, or ponding long enough to cause 

anaerobic conditions. Hydric soils are poorly drained soils, and may still be considered hydric if 

artificially drained or protected from flooding. The status of hydric soils is part of the definition used by 

the COE to determine wetland status. The majority of soils that would be affected by the Project are 

hydric soils. Construction activities can cause compaction and rutting of hydric soils. Due to the unique 

condition of these wetland soils, special construction techniques would be used for construction in 

wetland areas, as described in section 2.3.1.2, to minimize impacts. Following construction, KMLP 

would restore these areas to their pre-construction conditions including restoring drainage systems and 

original contours. With these measures, we believe KMLP would minimize impacts to hydric soils. 

Revegetation

All of the soils that would be affected by the Project have a moderate to good revegetation 

potential. KMLP would restore affected areas to preconstruction conditions as practicable in accordance 

with our Plan and Procedures. For example, in upland areas, an herbaceaous layer would be reestablished by seeding. The type of seed would be selected to match adjacent cover or as requested by the 

landowner, management agency, or county extension agent. In agricultural areas, revegetation would be 

considered successful if crop yields are similar to adjacent undisturbed portions of the same field. In 

wetlands, revegetation would occur by the transplantation of similar mature specimens from adjacent 

areas or temporary nurseries. Revegetation efforts in wetlands would be monitored by KMLP until a 

cover similar to 80 percent of adjacent areas is achieved. If revegetation efforts in wetlands are not 

successful at the end of 3 years, KMLP would develop and implement a remedial revegetation plan to 

actively revegetate the wetland. Revegetation in wetlands would also be controlled according to a 

project-specific Aquatic Resources Mitigation Plan that KMLP would finalize in consultation with COE, 

FWS, and NOAA Fisheries Service (see section 4.4.2). Forested areas would also be recovered in a 

similar manner, except for in the permanent right-of-way where shrubs and small trees are not allowed. 

The areas inside interconnections would be permanently converted to an industrial use and covered with 

crushed rock around piping and equipment or reseeded with an easily maintained grass. 

Soil Contamination 

A potential impact during construction would include the accidental release of petroleum 

hydrocarbons or other hazardous materials, as well as the discovery of contaminated soils during trench 
 4-14 Environmental Analysis

excavation and grading activities. As discussed in section 2.3, KMLP would develop and implement a 

project-specific SWPPP and SPRP that provide a description of the containment and cleanup procedures 

that would be employed in the event of a spill or a leak of hazardous materials. In section 2.3 we are 

recommending these project-specific plans be filed with the Secretary for review and approval prior to 

construction. 

There are no known contaminated soils in the Project area. KMLP searched the National 

Priorities List (EPA 2006a), Leaking Underground Storage Tanks database (LDEQ 2006a), and Louisiana 

Department of Environmental Quality (LDEQ) Voluntary Remediation Program (LDEQ 2006b) and 

found no known contaminated sites within 0.25 miles of the Project. Further, no contaminated soils were 

identified during field studies. Although the potential to encounter contaminated soils during pipeline 

construction is relatively low, KMLP’s application proposed several steps that would be followed in the 

event contaminated soils are encountered, including immediately stopping working in the vicinity, 

restricting access to the suspected area, engaging qualified contractors to determine the nature and extent 

of contamination, notifying applicable environmental authorities, and devising site-specific plans for 

cleanup, risk minimization, and continued construction. To ensure that such steps are actually developed 

and implemented, and that they also address contaminated groundwater that may be associated with the 

soils, we recommend that: 

• Prior to construction, KMLP file with the Secretary for review and written approval by the 

Director of OEP, a Plan for the Discovery and Management of Contaminated Soils and 

Groundwater. 

With the use of KMLP’s proposed measures and our recommendation, we believe the risks 

associated with soil contamination would be minimized. 

Prime Farmland

The USDA defines prime farmland as “land that is best suited to food, feed, fiber, and oilseed 

crops” (USDA 1993). This designation includes cultivated land, pasture, woodland, or other lands that are 

either used for food or fiber crops or are available for these uses. Urbanized land and open water are 

excluded from prime farmland. Prime farmland typically contains few or no rocks, is permeable to water 

and air, is not excessively erodible or saturated with water for long periods, and is not subject to frequent, 

prolonged flooding during the growing season. Soils that do not meet the above criteria may be 

considered prime farmland if the limiting factor is mitigated (e.g., artificial drainage). 

Approximately 79 percent (1,437 acres) of the soils that would be affected during construction by 

the KMLP project are considered prime farmland. Impacts on prime farmland from construction of the 

proposed pipelines could include interference with agricultural drainage (if present), mixing of topsoil and 

subsoil, and compacting and rutting. These impacts would result primarily from trench excavating and 

backfilling, and vehicular traffic along the construction right-of-way. 

KMLP would minimize impacts on prime farmland by constructing the pipelines in accordance 

with our Plan and Procedures. Mitigation measures employed to minimize impacts on prime farmland 

would include topsoil segregation, compaction relief, removal of excess rock, and restoration of 

agricultural drainage systems. Any drain tiles, culverts, or other items damaged during construction would 

be repaired or replaced to preconstruction conditions. Adherence to these measures would minimize 

impacts on prime farmland and other agricultural land and would promote the long-term productivity of 

the soil. In addition, impacts caused by the pipeline faculties would be temporary and would not result in 

permanent conversion of prime farmland to non-agricultural uses. 
 4-15 Environmental Analysis

However, at the nine interconnect sites with soils designated as prime farmland, the operation of 

these sites would result in the permanent conversion of approximately 7.7 acres of prime farmland to 

industrial land. 

4.2.2.2 Operation Impacts 

Operation activities are not expected to result in further impacts to soil resources. The SWPPP 

and SPRP would remain effective during operation of the pipeline to minimize and mitigate impacts of 

soil contamination. Monitoring activities would include surveys for soil erosion or other conditions that 

may expose or harm the pipeline, or indicate a leak in the pipeline. 
 4-16 Environmental Analysis

4.3 WATER RESOURCES 

4.3.1 Groundwater 

Although the depth to groundwater is variable along the proposed pipeline route, it is often found 

at or near the ground surface. In all five parishes crossed by the KMLP Project, groundwater is the 

primary or only source of public water supply (LDOTD 2002). Four of the parishes crossed by the 

proposed pipeline utilize groundwater for the majority of their total water usage. In these parishes, 

groundwater is primarily used in the irrigation of rice fields (Jefferson Davis, Acadia, and Evangeline 

Parishes), for industrial purposes (Calcasieu Parish), and as a public water supply. Information regarding 

the groundwater resources located along the proposed pipeline route, including aquifers, Sole Source and 

primary source aquifers, wellhead protection areas, wells and springs, and contaminated groundwater, is 

presented below. 

4.3.1.1 Affected Environment 

According to the USGS, the Project is underlain by the Coastal Lowlands Aquifer System (USGS 

1998) which extends from coastal counties in Texas eastward into the Coastal Plain of Louisiana, 

Mississippi, and to a smaller extent southern Alabama and the western part of the Florida panhandle. 

Groundwater derived from the Coastal Lowlands Aquifer System is used for agricultural, public supply, 

commercial, and industrial purposes. This system is divided into five permeable zones (A–E) consisting 

of discontinuous beds of sand, silt, and clay. Permeable Zone A has also been referred to as the top layer 

of the Chicot Aquifer. The Chicot Aquifer underlies about 9,900 square miles of Louisiana, extending 

west from the Atchafalaya River into southern Texas and south to the Gulf of Mexico. The landward 

boundary of the aquifer consists of outcrop areas where the aquifer system feathers out at a point of 

contact with the underlying Vicksburg-Jackson confining unit (Lovelace et al. 2004). The Gulf-ward 

boundary is near the coastline where the water becomes increasingly saline and the upper boundary is the 

land surface (Ryder 1996). The Chicot Aquifer is the most heavily pumped aquifer system in 

southwestern Louisiana and provides approximately 800 million gallons of water per day for a variety of 

uses. The primary use is for agriculture (68 percent), in particular, rice irrigation. Other uses include 

public water supply (11 percent), industrial (9 percent), aquaculture (8 percent), power generation (2 

percent), and other (2 percent) (LSU AgCenter 2001). The Chicot Aquifer ranges from 50 to 1,050 feet in 

thickness and is composed of Pleistocene interbedded sands, silt, gravel, and clay deposited in fluvial, 

deltaic, and near-shore marine environments. 

Sole Source and Primary Source Aquifers 

In southwestern Louisiana, the Chicot Aquifer is designated as an EPA Sole Source Aquifer 

(USEPA 2006b). A Sole Source or primary source aquifer is defined by the EPA as an aquifer that 

supplies a minimum of 50 percent of the drinking water used in the area overlying the aquifer. The areas 

served by these aquifers may not have readily available alternate water sources. In southwestern 

Louisiana, the Chicot Aquifer is designated as an EPA Sole Source Aquifer (USEPA 2006b). All five 

parishes crossed by the KMLP Project utilize the Chicot Aquifer. 

Wellhead Protection Areas 

Wellhead protection areas are designated to protect drinking water supplies obtained from 

municipal or community wells. KMLP identified 10 wellhead protection areas that would be crossed by 

the Project. The locations of these wellhead protection areas are listed in table 4.3.1.1-1. 
 4-17 Environmental Analysis

TABLE 4.3.1.1-1 

Drinking Water Wellhead Protection Areas That Would be Crossed by the KMLP Project 

Aquifer Parish Begin MP End MP 

Chicot Aquifer Calcasieu Parish 50.8 52.4 

Chicot Aquifer Calcasieu Parish 51.0 52.8 

Chicot Aquifer Calcasieu Parish 53.5 54.3 

Chicot Aquifer Calcasieu Parish 56.2 57.2 

Chicot Aquifer Calcasieu Parish 58.0 59.1 

Chicot Aquifer Calcasieu Parish 59.8 61.3 

Chicot Aquifer Calcasieu Parish 73.8 74.7 

Chicot Aquifer Jefferson Davis Parish 75.6 77.8 

Chicot Aquifer Jefferson Davis Parish 95.7 96.9 

Evangeline Aquifer Evangeline Parish 119.6 121.7 

Wells and Springs 

Based on information provided by the Louisiana Department of Transportation and Development, 

28 wells would be located within 150 feet of the construction right-of-way, including eight domestic 

supply wells (two of which are either abandoned or plugged), two industrial wells, nine irrigation wells, 

four monitoring wells (all four are plugged), and five rig supply wells (three of which are plugged). 

These wells and their locations relative to the Project are listed in table 4.3.1.1-2. Because the locations 

of these wells are not precise, KMLP would confirm actual well locations in the field prior to construction 

and provide us with that information. In addition to the wells identified within 150 feet of the 

construction right-of-way listed in table 4.3.1.1-2, there are three wells located within 400 feet of 

proposed construction work areas. These include two domestic supply wells located approximately 194 

feet from the construction workspace near MP 104.2. There is also one rural public supply well located 

approximately 314 feet from the construction workspace near MP 120.7. 

No springs have been identified within the vicinity of the Project and therefore, construction and 

operation of the proposed project would not affect springs. 

Contaminated Groundwater 

No instances of contaminated groundwater have been identified within the vicinity of the Project. 

4.3.1.2 Impacts and Mitigation 

Construction of the proposed pipeline would result in several effects to groundwater resources 

including the Chicot Aquifer, which has been designated by the EPA as a Sole Source aquifer and 

wellhead protection area. Effects resulting from construction include temporary and permanent changes 

to infiltration/recharge rates, groundwater flow, and groundwater quality. Specifically, construction 

activities such as clearing and grading would alter local infiltration/recharge rates, which would affect the 

quality and quantity of groundwater resources within the immediate vicinity of the Project. Additionally, 

trenching, trench dewatering, and backfilling would alter infiltration/recharge rates and groundwater flow, 
 4-18 Environmental Analysis

TABLE 4.3.1.1-2 

Wells Located Within 150 Feet of the KMLP Projecta

Well Type Parish 

Approximate 

MPb

Approximate 

Well Depth 

(feet) 

Approximate 

Distance from 

Centerline 

(feet) 

Approximate 

Distance from 

Construction 

Workspace 

(feet) 

Rig Supply Calcasieu 31.1 606 88.0 13.0 

Industrial Calcasieu 34.3 603 155.0 120.0 

Industrial Calcasieu 34.3 780 82.2 47.2 

Monitoring Calcasieu 44.8 16 8.6 0.0 

Monitoring Calcasieu 44.8 77 8.6 0.0 

Monitoring Calcasieu 44.9 38 80.8 0.0 

Monitoring Calcasieu 44.9 38 80.8 0.0 

Rig Supply Calcasieu 48.4 242 29.9 0.0 

Rig Supply Calcasieu 49.6 265 14.7 0.0 

Domestic Calcasieu 54.1 245 102.0 67.0 

Domestic Calcasieu 55.5 249 36.6 0.0 

Irrigation Calcasieu 61.6 0 214.8 124.8 

Domestic Calcasieu 62.6 205 8.3 0.0 

Irrigation Calcasieu 65.1 30 148.3 113.3 

Rig Supply Calcasieu 69.3 240 154.2 64.2 

Domestic Calcasieu 71.0 215 234.9 144.9 

Domestic Jefferson Davis 87.8 145 96.0 0.0 

Domestic Jefferson Davis 87.8 145 96.0 0.0 

Irrigation Jefferson Davis 90.0 296 188.8 128.8 

Irrigation Jefferson Davis 91.4 0 139.3 95.6 

Irrigation Jefferson Davis 91.4 311 10.4 0.0 

Rig Supply Jefferson Davis 91.4 251 10.4 0.0 

Irrigation Jefferson Davis 94.3 260 53.1 18.1 

Domestic Acadia 106.8 168 32.0 0.0 

Irrigation Evangeline 121.6 275 68.4 0.0 

Domestic Evangeline 124.9 0 48.6 13.6 

Irrigation Evangeline 127.1 235 39.3 4.3 

Irrigation Cameron 0.6 255 200.3 114.2 

_______________ 

a Actual well locations may vary by as much as 100 feet due to the level of accuracy associated with well coordinate data. 

KMLP would confirm the actual location of the wells prior to construction. b All MPs are on Leg 1 except for the last row (MP 0.6), which is on the FGT Lateral. 

which would also result in changes to the quality and quantity of groundwater resources within the 

immediate vicinity of the Project. The disturbance of unknown contaminants and/or an inadvertent 

release of fuel and/or equipment-related fluids during construction could also affect groundwater quality. 

In order to minimize effects to groundwater resources resulting from construction of the Project, 

KMLP would implement groundwater-related measures described in our Procedures, including 
 4-19 Environmental Analysis

stormwater management measures, spill prevention and response procedures, and minimization measures 

related to the discharge of trench water and trench breakers. We are recommending that KMLP develop a 

plan for the Discovery and Management of Contaminated Soil and Groundwater to address encounters 

with unanticipated groundwater and soil contamination during construction (see section 4.2.2.1). 

Implementation of this plan would ensure that any previously existing groundwater contamination that 

may be encountered during construction would be managed in accordance with applicable regulatory 

requirements. Following construction, KMLP would also restore contours and manage the revegetation 

of affected lands, both of which would minimize effects to groundwater resources resulting from 

construction of the Project. 

Additionally, in order to minimize potential adverse effects to wells resulting from construction 

of the Project, KMLP would notify landowners in the general vicinity of the proposed construction rightof-way of their ability to request well testing and monitoring prior to and after construction. This 

monitoring would include water quality and well yield. KMLP has not stated the steps it would take if 

impaired water quality or well yield were observed; therefore, we recommend that: 

• Prior to construction, KMLP file with the Secretary a statement that if water quality or 

yield were found to be impaired due to the Project, KMLP would provide a temporary 

water supply and re-test the well within 30 days. In addition, KMLP should replace any 

potable water supply system that it damages during construction and cannot repair to 

its former capacity and quality. KMLP should identify in its report to the Secretary all 

potable water supply systems damaged by construction and how they were repaired. 

In general, operation of the Project would not significantly affect groundwater resources; 

however, the development of impervious surfaces and structures in association with the proposed 

aboveground facilities would result in minor effects to groundwater resources due to the alteration of 

infiltration/recharge rates. 

Based on the characteristics of the identified groundwater resources, KMLP’s proposed 

construction methods and operations procedures, and its implementation of groundwater-related measures 

described in our Procedures, as well as the acceptance of our recommendations, we believe that impacts 

to groundwater resources resulting from construction and operation of the Project would be temporary 

and localized, and would not significantly affect overall groundwater quantity and quality. 

4.3.2 Surface Water 

This section identifies the waterbodies that would be affected by the Project, and describes them 

and the impacts to them resulting from construction and operation of the Project. All affected 

waterbodies, with the exception of Sabine Lake and the Calcaseiu River which are addressed individually 

in section 4.3.2.3, are addressed in the following sections. 

4.3.2.1 Affected Environment 

Construction of the proposed pipeline would require 310 waterbody crossings. Appendix G 

identifies each of these crossings, their location, the proposed crossing method, the width of crossing, the 

waterbody type, and the impairment status and significance to fisheries/potable water sources, if 

applicable. 

In Louisiana, waterbodies have been designated by LDEQ which has developed a series of 

standards to maintain water quality, consistent with the associated goals of protecting public health, 

conserving fish and wildlife, and enhancing economic development, in accordance with a use(s) that 
 4-20 Environmental Analysis

characterizes the best intended use(s) of that waterbody. These designated uses include primary contact 

recreation; secondary contact recreation; fish and wildlife propagation; limited aquatic life and wildlife 

use; drinking water supply; oyster propagation; agriculture; outstanding natural resource waters; and no 

quality/use. With the exception of 12 waterbodies which account for 18 waterbody crossings, all of the 

identified waterbodies crossed by the proposed pipeline have been designated “no water quality/use.” 

The designated uses of the 12 waterbodies with uses other than “no water quality/use” are provided in 

table 4.3.2.1-1. 

TABLE 4.3.2.1-1 

Water Quality/Use Designations Other Than No Quality/Use 

Waterbody Name Designated Usea Number of Crossings 

Sabine Lake ABCE 1 

Sabine River ABC 4 

Burton Shell Slip ABC 1 

Black Bay Cutoff ABC 1 

GIWW ABC 2 

Vinton Drainage Canal ABC 1 

Bayou Choupique ABC 1 

Calcasieu River ABCE 1 

East Bayou Lacassine ABCF 2 

Gum Gully AB 1 

Bayou Nezpique ABCF 1 

Bayou des Cannes ABCF 2 

_______________ 

a Designated use codes for affected waterbodies: A - Primary Contact Recreation; B - Secondary Contact Recreation; C - Fish and 

Wildlife Propagation; E - Oyster Propagation; F – Agriculture.

The proposed pipeline would also cross 13 major waterbodies (16 waterbody crossings): Sabine 

Lake, Sabine River, Black Bay Cutoff, GIWW, Vinton Drainage Canal, Bayou Choupique, Calcasieu 

River, Calcasieu Tributary, Calcasieu Tributary (swamp), two unnamed waterbodies, Bayou Nezpique, 

and Tiger Point Gulley. Major waterbodies are those that are larger than 100 feet in width at the point of 

crossing. There is no official list of navigable waters in Louisiana, but numerous waterbodies that would 

be affected by the Project have been characterized as navigable, including Sabine Lake, Sabine River, 

Black Bay Cutoff, GIWW, and Calcasieu River. 

Sensitive Waterbodies 

Sensitive waterbodies generally include waterbodies that do not meet designated water quality 

standards; have been designated for intensified water quality management and improvement; contain 

threatened and endangered species or critical habitat; would be crossed less than three miles upstream of 

potable water intake structures; are classified as outstanding or exceptional quality waterbodies; are 

waters of particular ecological and recreational importance; are located in sensitive and protected 

watershed areas; have steep banks, potentially unstable soils, high-volume flows, and actively eroding 

banks; have associated important riparian areas; and are on or designated to be added to the Nationwide 

Rivers Inventory or a state river inventory. 
 4-21 Environmental Analysis

Sensitive waterbodies that have identified water quality impairments are identified in 

table 4.3.2.1-2. Sensitive waterbodies containing EFH and commercial and/or recreational fisheries are 

addressed in section 4.6. All other sensitive waterbodies are addressed as appropriate in sections 4.5 – 

4.8. As mentioned previously, Sabine Lake and the Calcasieu River are addressed in section 4.3.2.3. 

TABLE 4.3.2.1-2 

Sensitive Waterbodies Affected by the Proposed Project 

Waterbody Name MP of Crossing Impairment 

Vinton Drainage Canal 32.2 (Leg 1) Turbidity 

Bayou Choupique 44.3 (Leg 1) Dissolved oxygen 

East Bayou Lacassine 84.9 and 88.5 (Leg 1) Dissolved oxygen 

Bayou Nezpique 99.4 (Leg 1) Nitrate/nitrite, dissolved oxygen, sedimentation/siltation, total 

fecal coliform, total phosphorus, total suspended solids (TSS), 

and turbidity 

Bayou des Cannes 124.7 (Leg 1) and 1.57

(FGT Lateral) 

Carbofuran, fipronil, mercury, nitrate/nitrite, dissolved oxygen, 

sedimentation/siltation, total fecal coliform, total phosphorus, 

TSS, and turbidity 

Waterbody Crossing Methods

As described in section 2.3.1.3 and listed in appendix G, waterbody crossings would be 

conducted using conventional open-cut construction methods, flumes, boring techniques, and HDDs. Of 

the 310 waterbody crossings that would be required for construction of the proposed pipeline, 133 would 

be completed using open-cut methods, three would be completed using flumes, 147 would be completed 

using boring techniques, 24 would be completed using HDDs, and 3 would be completed using a 

combination of open-cut methods and HHDs. 

Waterbody crossings that would be completed using HDDs are listed in table 4.3.2.1-3. 

TABLE 4.3.2.1-3a

Features Crossed Using HDD Along the Kinder Morgan Louisiana Pipeline 

Directional 

Drill Number 

Approximate 

Entry MP 

Approximate 

Exit MP 

Length of Drill 

(feet) Features Crossed 

1 3.9 4.8 4,752 Big Forge Bayou; Wetlands; 

Southern Bank of Sabine Lakeb

2 18.0 18.6 3,485 Northern Bank of Sabine Lake; 

Wetlands; Mouth of Sabine Riverb,c

3 18.6 19.4 4,171 Sabine River;b,c Wetlands 

4 19.4 20.0 3,168 Sabine River;b,c Wetlands 

5 21.2 22.1 4,963 Sabine River;b,c Wetlands 

6 22.1 22.7 3,168 Sabine River;b,c Pipelines; Wetlands; 

Canal 

7 23.4 24.0 2,640 Burton Shell Slip; Pipelines; 

Wetlands 

8 25.3 26.0 4,066 Pipelines; Wetlands 

9 26.0 26.8 4,066 Pipelines; Wetlands 
 4-22 Environmental Analysis

TABLE 4.3.2.1-3a (cont’d) 

Features Crossed Using HDD Along the Kinder Morgan Louisiana Pipeline

Directional 

Drill Number 

Approximate 

Entry MP 

Approximate 

Exit MP 

Length of Drill 

(feet) Features Crossed 

10 30.4 31.5 5,808 Canal; Black Bay Cutoff;b

 GIWW;b

Pipelines 

11 31.5 32.4 5,069 Vinton Drainage Canal;b

 Wetlands; 

Pipelines 

12 43.7 44.5 4,171 Bayou Choupique;b Wetlands 

13 49.6 50.5 4,646 Calcasieu River;b

 Pond; Dredge Spoil 

Area 

14 50.5 51.3 4,488 Canal; Calcasieu Tributary;b Marina 

15 51.8 52.4 3,115 Industrial Area; Road 

16 52.4 53.1 3,590 Calcasieu Tributary (swamp);b

Forest; Unnamed Waterbody; Borrow 

Pit 

17 77.7 78.4 3,960 Agricultural Waterbodies;b,d

Interstate-10 

18 99.0 99.8 3,907 Bayou Nezpique;b Wetlands 

_______________ 

a Table includes three HDDs (Numbers 8, 9, and 15) not associated with a waterbody crossing. b Waterbodies greater than 100-feet wide at the proposed crossing. c

 Temporary construction areas limited to barges and flotation areas for HDD strings would extend into the Sabine River. d

 HDD 14 crosses 7 different agricultural waterbodies, 2 of which are greater than 100-feet wide.

KMLP has proposed to file with the Secretary prior to construction site-specific construction 

plans for all areas disturbed by construction at each major waterbody crossing; however, the site-specific 

construction plans for the major waterbody crossings filed by KMLP in its application are incomplete; 

therefore, to fully assess the potential impacts associated with these crossings, we recommend that:

• KMLP file with the Secretary a site-specific construction plan for the crossing of each 

waterbody proposed as a HDD crossing. These site-specific plans should include scaled 

drawings identifying all areas that would be disturbed by construction. KMLP should 

file these plans for review and written approval by the Director of the OEP along with 

the COE permit prior to construction across those waterbodies.

With one exception, all major waterbodies would be crossed using HDDs. Tiger Point Gulley is 

the only major waterbody that KMLP has not proposed to cross using a HDD. However, the FWS, COE, 

and the LDWF have recommended that Tiger Point Gulley along with Bayou Barwick and Bayou des 

Cannes be crossed using HDDs to avoid and minimize impacts to these waterbodies and adjacent 

resources; therefore we recommend that: 

• KMLP evaluate the feasibility of using the HDD method to cross Tiger Point Gulley at 

MP 113.3 and Bayou Barwick at MP 109.2 along Leg 1 and Bayou des Cannes along the 

FGT Lateral at MP 1.57, and develop a site-specific construction plan for each of these 

crossings in coordination with FWS and LDWF that clearly identifies all construction 

work areas including the laydown area for the pipe string if the HDD method is 

determined to be feasible. KMLP should file the results of its evaluation, the site-
 4-23 Environmental Analysis

specific construction plans, and any agreed-upon mitigation measures to minimize 

impacts on riparian areas and the associated forested wetlands. KMLP should file the 

above information with the Secretary for review and written approval by the Director 

of OEP prior to the close of the comment period on this draft EIS. 

Additionally, the use of three new access roads would require the crossing of three waterbodies. 

Two of the new access roads, Access Roads 15 and 19 at MPs 52.3 and 61.4 of Leg 1, respectively, would 

cross roadside drainage ditches, and the third access road would cross a minor tributary of Bayou des 

Cannes (Access Road FGT-2 at MP 2.3 of the FGT Lateral). KMLP has stated that access road 

improvements would include grading, placement of gravel for stability, replacing or installing culverts, 

and clearing of overhead vegetation; however, it does not specify how these waterbodies would be 

crossed and the COE has indicated that drainage ditches in this region function as flowing waters (COE, 

2006) and must be protected as waterbodies; therefore, we recommend that: 

• Prior to construction of Access Roads 15, 19, and FGT-2, KMLP reroute these access 

roads to avoid crossing drainage ditches at MPs 52.3 and 61.4 of Leg 1, and avoid 

crossing Bayou des Cannes Tributary at MP 2.3 of the FGT Lateral. KMLP should file 

with the Secretary the reroutes for these access roads, copies of the revised alignment 

sheets, and necessary environmental information for review and written approval by 

the Director of OEP. 

If any of these access roads can not be rerouted, KMLP should provide: 

a. justification why rerouting is infeasible; 

b. documentation of consultation with COE, including proposed mitigation measures; 

c. construction plans for these access roads; 

d. copies of necessary permits/approvals; and 

e. landowner concurrences. 

KMLP should not use these access roads until the Director or OEP notifies KMLP in 

writing that it may proceed. 

Minimization Measures 

In order to minimize potential impacts to waterbodies resulting from the construction of the 

proposed pipeline, KMLP would implement the measures described in our Procedures, which include: 

• a requirement to obtain all necessary permits from the COE and state agencies prior to 

construction and notify applicable state agencies at least 48 hours before commencing with 

instream trenching; 

• use of EIs during construction; 

• routing the proposed pipeline as close to perpendicular to the axis of the waterbody as 

practicable and minimize the number of individual crossings where waterbodies meander or 

have multiple channels; 

• limiting the use of equipment within the waterbody to that necessary to construct the 

crossing, and utilize equipment bridges for passage of other construction equipment; 

• placing spoil at least 10 feet away from the water’s edge with installation of sediment barriers 

to prevent the flow of spoil or silt-laden water into the waterbody; 
 4-24 Environmental Analysis

• completing all instream construction activity, including stabilization and re-contouring of 

banks, within 24 hours for minor waterbody crossings and 48 hours for intermediate 

waterbody crossings; 

• using temporary erosion and sediment control measures such as sediment barriers and trench 

plugs; and 

• restoration activities including restoration of preconstruction bank contours, installation of 

slope breakers, and revegetation of disturbed riparian areas. 

The use of an HDD could result in an inadvertent release of drilling mud that could return to the 

surface or enter a waterbody. This inadvertent release is commonly referred to as a “frac-out.” To 

minimize the effects of potential frac-outs occurring during HDD operations, KMLP would conduct 

geotechnical evaluations prior to construction to determine the potential for a frac-out to occur at a 

proposed HDD crossing and adjust its crossing plan accordingly. Should a frac-out occur during HDD 

operations, KMLP would implement measures outlined in its HDD Contingency Plan which describes 

how inadvertent releases of drilling fluids would be prevented or mitigated if a release of drilling fluids 

were to occur. A draft of KMLP’s HDD Contingency Plan is provided in appendix I. 

In addition to implementing these and other measures, KMLP would consult with state and 

federal resource agencies to finalize construction methods. As discussed in the beginning of section 2.3, 

KMLP would also develop and implement a SWPPP and SPRP to prevent and contain, if necessary, 

accidental equipment-related spills. 

4.3.2.2 Impacts and Mitigation 

Construction of the proposed pipeline through waterbodies using open-cut construction methods 

would result in several impacts to these waterbodies including changes to water quality and in-stream 

habitat. Construction activities including the clearing and grading of stream banks, in-stream trenching, 

trench dewatering, and backfilling of the in-stream trench would result in increased turbidity and 

sedimentation, decreased dissolved oxygen (DO) levels, modifications to aquatic habitat, and increased 

stream water temperatures. The removal of riparian vegetation associated with open-cut construction 

methods would also result in increased surface runoff, an increased erosion potential, and elevated water 

temperatures. In addition, the disturbance of unidentified contaminated soils and/or sediments could 

result in adverse impacts to water quality and aquatic resources. Operation of heavy equipment or other 

vehicles in and near surface waterbodies could also introduce chemical contaminants, such as fuels and 

lubricants, into surface waters or result in accidental spills during construction that would result in 

decreased water quality. The use of flumes during construction would result in impacts similar to those 

resulting from the use of open-cut construction methods; however, the use of flumes would significantly 

minimize these impacts especially the increases in turbidity and sedimentation commonly associated 

within pipeline crossings. 

Construction of the proposed pipeline through waterbodies using bores and HDDs would also 

significantly reduce impacts to crossed waterbodies. However, the use of an HDD could result in drilling 

mud entering a waterbody due to a frac-out. A frac-out would result in increased turbidity and 

sedimentation, which would decrease water quality and in-stream habitat integrity. Because drilling mud 

is primarily composed of freshwater, a small release would likely dissipate and would not be expected to 

adversely affect water quality beyond a temporary increase in turbidity. In larger quantities, the release of 
 4-25 Environmental Analysis

drilling fluid could negatively affect fisheries and/or vegetation, although impacts would generally be less 

than those associated with an open-cut crossing. 

Operation of the Project would not affect surface water resources. 

Sensitive Waterbodies 

Impacts to the Vinton Drainage Canal, Bayou Choupique, and Bayou Nezpique would be 

minimized by crossing these waterbodies using HDDs. As described above, the use of HDDs to cross 

these waterbodies would significantly reduce impacts to them. Impacts to Bayou des Cannes would be 

minimized by using a flume. Impacts to East Bayou Lacassine resulting from the two crossings of the 

waterbody would be minimized by using a flume at the crossing at MP 84.9. East Bayou Lacassine at MP 

88.5 would be crossed by open-cut, but we do not believe impacts resulting from this crossing would 

significantly contribute to the water’s DO impairment that has been created by adjacent agricultural 

operations. 

Hydrostatic Testing 

KMLP would hydrostatically test the pipeline after installation to ensure structural integrity in 

compliance with the DOT pipeline safety regulations identified in 49 CFR Part 192. The proposed 

hydrostatic test water sources, withdrawal locations, and estimated volumes of water required are 

identified in table 4.3.2.2-1. 

KMLP has indicated that all hydrostatic test waters would be discharged overland at the original 

source, discharged directly to the original source, or managed in compliance with applicable NPDES 

permit conditions. As described in section 2.3.1.1, KMLP would use energy dissipation devices at all 

discharge points to reduce discharge velocities and thereby prevent or minimize associated erosion and 

sedimentation. Additionally, no chemical additives would be used in hydrostatic test water. 

KMLP would minimize potential effects to waterbodies resulting from hydrostatic testing by 

implementing our Procedures, which include, but are not limited to the following measures: 

• obtain and comply with all applicable water withdrawal permits and special-status stream 

permits; 

• address the operation and fueling of any pumps located within 100 feet of waterbodies or 

wetlands in the Project-specific SPRP; 

• maintain adequate flow rates in all source waterbodies to protect aquatic life and to provide 

for all downstream uses; 

• screen all hydrostatic test water withdrawal intakes to prevent entrainment of fish and aquatic 

organisms; and 

• regulate the discharge of hydrostatic test waters using energy dissipation devices to prevent 

erosion, scour, turbidity, or excessive streamflow. 

With the implementation of our Procedures and the above measures, we believe that the surface 

water impacts associated with hydrostatic testing of the pipeline would be temporary. 
 4-26 Environmental Analysis

TABLE 4.3.2.2-1 

Hydrostatic Test Water Source and Discharge Locations 

Pipeline Withdrawal Source/Discharge 

Approximate 

Withdrawal 

Location (MP) 

Approximate Volume 

(gallons)a

Leg 1 Calcasieu River 49.6 18,837,000 

Leg 1 Calcasieu River 49.6 31,384,000 

Leg 1 Sabine Lake 4.8 684,000 

Leg 1 Sabine Lake 18.0 502,000 

Leg 1 Sabine River/GIWW 18.6 600,000 

Leg 1 Sabine River/GIWW 20.0 456,000 

Leg 1 Sabine River/GIWW 21.2 714,000 

Leg 1 Sabine River/GIWW 22.1 456,000 

Leg 1 Sabine River/GIWW 23.5 562,000 

Leg 1 Sabine River/GIWW 23.9 365,000 

Leg 1 Sabine River/GIWW 25.3 585,000 

Leg 1 Sabine River/GIWW 26.8 585,000 

Leg 1 Black Bayou Cutoff 30.6 836,000 

Leg 1 GIWW 32.4 730,000 

Leg 1 Bayou Choupique 43.4 600,000 

Leg 1 Calcasieu River 49.6 707,000 

Leg 1 LNG Terminal Channel 51.1 646,000 

Leg 1 LNG Terminal Channel 51.1 448,000 

Leg 1 LNG Terminal Channel 51.1 517,000 

Leg 1 Louisiana Irrigation Canal 76.0 570,000 

Leg 1 Bayou Nezpique 99.4 562,000 

Leg 2 Sabine Pass 0.0 339,000 

FGT Lateral Bayou des Cannes 2.3 285,000 

_______________ 

a

 HDD segments, which include all but the first two rows listed above for Leg 1, would be tested three times: (1) before 

installation; (2) after installation; and (3) with the entire pipeline system. 

Based on the characteristics of the identified waterbodies, KMLP’s proposed construction 

methods and operations procedures, its implementation of waterbody-related measures described in our 

Procedures, and our recommended measures, we believe that effects to surface waters resulting from 

construction and operation of the proposed project would be temporary and localized. 

4.3.2.3 The Sabine Lake and Calcasieu River Crossings 

Sabine Lake 

Sabine Lake is an estuarine waterbody located on the Texas/Louisiana border and connected to 

the Gulf of Mexico via the Sabine Pass. The lake has an average depth of 2.0 feet and covers a surface 

area of approximately 94 square miles. The land surrounding Sabine Lake is covered, in large part, by 
 4-27 Environmental Analysis

sensitive wetland areas that include EFH and provide habitat for a diversity of wildlife. The lake itself 

has been designated as supporting primary and secondary contact recreation, fish and wildlife 

propagation, and oyster propagation. Additionally, Sabine Lake supports both commercial and 

recreational fisheries and is a public harvesting area for oysters. No water quality impairments or 

contaminated sediments are reported for Sabine Lake. 

KMLP proposes to cross Sabine Lake via the HDD method at the lake’s southern and northern 

shorelines and via the open-cut construction method requiring the use of spud barges across the lake’s 

open water. Impacts to the southern bank of Sabine Lake, including riparian vegetation and nearshore 

oyster resources, would be avoided by using an HDD that would enter on land and exit within Sabine 

Lake at MP 4.8. From MP 4.8 to MP 17.9 of Leg 1, the open-cut construction method would be used. 

The crossing would be accomplished using a shallow draft spud barge with pipe supply barges connected 

in a line to form the lay barge spread. To accommodate vessel drafts, excavation of a floatation channel 

would be required in water depths of less than 8 feet. Where the floatation channel is needed, a 300-footwide construction right-of-way would also be required to accommodate the floatation channel, pipeline 

trench, and spoil pile. In water depths greater than 8 feet, the floatation channel would not be necessary 

and the construction right-of-way would be reduced to a width of 200 feet. The use of HDD would 

resume at MP 17.9 within Sabine Lake, exiting on land at MP 18.6, avoiding sensitive wetland habitats on 

the northern bank. A detailed description of the crossing methods through Sabine Lake is provided in 

section 2.3.1.3. 

KMLP conducted a shallow hazards survey over a 3,000-foot corridor centered on the proposed 

pipeline route through Sabine Lake to identify the locations of foreign pipelines and obstructions that 

could affect construction, as well as the locations of any submerged cultural resources. At locations 

where potential obstructions or significant cultural resources were found, KMLP adjusted the centerline 

route for avoidance. Where adjustments of the pipeline were deemed infeasible, locations of potential 

obstructions or cultural resources would be further investigated and regulatory agencies consulted as 

discussed in section 4.10 of this draft EIS. 

Major route alternatives and route variations were also considered. Three major route alternatives 

involved construction through Sabine Lake while two major route alternatives took a southern route, 

avoiding the lake altogether. As discussed in section 3.3, we did not consider the two southern routes to 

be environmentally preferable. Within Sabine Lake, the Blue Buck Point route variation was considered 

to potentially avoid marsh areas south of the lake. It was determined that although this route variation 

would cause fewer impacts to the marsh, it would cause greater impacts to oysters. Therefore, this route 

variation was not adopted (see section 3.4.1). 

The use of the HDD crossing method at the northern and southern banks of Sabine Lake would 

avoid impacts to sensitive vegetation, EFH, and other wildlife habitat, while also avoiding shoreline 

erosion. Open-cut construction would adversely affect water quality during construction, causing 

sediment resuspension and related impacts in the water column as discussed in section 4.3.2.2. Impacts 

to oyster resources and fishes within Sabine Lake are discussed in section 4.6.3 and impacts to vessel 

traffic through spoil pile placement are discussed in section 4.8.3.2. 

KMLP has proposed to allow refueling activities within Sabine Lake and the Sabine River. As 

discussed in section 4.4.1, we believe that this measure as well as an additional measure to allow certain 

extra workspaces within 50 feet of waterbodies is acceptable and would result in minimal effects to the 

environment. To minimize impacts to Sabine Lake during construction, KMLP would utilize BMPs 

developed with the construction contractor as part of the SWPPP prior to construction to address 

hazardous materials handling and storage, as well as spill prevention and response. 
 4-28 Environmental Analysis

Calcasieu River 

Calcasieu River is a freshwater river that drains a rural forest and bayou complex that connects to 

the estuarine Calcasieu Lake. The river has been designated as supporting primary and secondary contact 

recreation, fish and wildlife propagation, and oyster propagation. Additionally, the lake supports both 

commercial and recreational fisheries (see section 4.6.2.1). As described in section 4.6.2.2, the lower 

Calcasieu watershed contained areas of probable concern (APCs) in 1997; however, later surveys 

indicated that those APCs are no longer present, although some areas still contained contaminated 

sediments. 

KMLP would install the pipeline across Calcasieu River between MP 49.6 and MP 51.1 of Leg 1. 

Back-to-back HDDs are proposed for the crossing of the main shipping channel of Calcasieu River and 

the major tributary that serves as a ship channel to the Trunkline LNG Terminal. The proposed route 

would cross under a marina on the east bank of the river and a COE dredge spoil area, and one of the 

HDD pull strings would lie across this dredge spoil area. KMLP is currently consulting with the COE 

regarding potential effects to the disposal area. Since these consultations are still ongoing, we 

recommend that: 

• Prior to construction, KMLP file the following environmental information with the 

Secretary for review and written approval by the Director of OEP: 

a. site-specific construction plan for the HDD crossing of the Calcasieu River and 

marina between MP 49.6 and MP 51.1 along Leg 1; and 

b. documentation of consultation with COE for the HDD crossing of the Calcasieu 

River and use of the COE dredge spoil area located at MP 50.0. 

Crossing the Calcasieu River by the HDD method would eliminate impacts from the resuspension 

of potentially contaminated sediments and the removal of riparian vegetation. 
 4-29 Environmental Analysis

4.4 WETLANDS 

4.4.1 Affected Environment 

Wetlands are defined by the COE and the EPA as areas that are inundated or saturated by surface 

water or groundwater at a frequency and duration sufficient to support, and that under normal 

circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. 

Wetlands generally include swamps, marshes, bogs, and similar areas. Wetlands provide a number of 

valuable functions including flood flow attenuation, sediment retention, nutrient retention, wildlife 

habitat, groundwater recharge and discharge, recreation, and erosion control. 

KMLP conducted wetland delineations within the proposed pipeline construction right-of-way, as 

well as within the proposed locations for the pipe storage/contractor yards, access roads, aboveground 

facilities, and extra workspaces in accordance with the COE Wetland Delineation Manual (USACE 

1987). In areas where land access has not yet been granted (approximately 8.3 miles along the proposed 

route), NWI maps and aerial photographs were used to determine the presence of wetlands. 

A total of 352 wetlands, covering approximately 504.2 acres, would be affected by construction 

of the Project. The COE has yet to validate KMLP’s wetland delineations; therefore, the acreage of 

wetlands affected by the Project may change. The location, wetland classification, and affected acreage 

for each wetland that would be affected by construction and operation of the Project are listed in appendix 

H, table H-2. Wetland vegetative species found along the pipeline route are listed in table 4.4.1-1 

according to the wetland type. The FWS wetland Cowardin classification system (described in appendix 

H, table H-1) was used to classify the wetlands that would be affected by the Project (Cowardin et al. 

1979). According to the Cowardin classification, the wetlands crossed by the Project are classified as: 

• estuarine emergent (E2EM); 

• estuarine scrub-shrub (E2SS); 

• palustrine emergent (PEM); 

• palustrine scrub-shrub (PSS); and 

• palustrine forested (PFO). 

Estuarine wetlands are tidal habitats and adjacent tidal wetlands that are usually semi-enclosed by 

land but have open, partly obstructed, or sporadic access to the ocean, with ocean-derived water at least 

occasionally diluted by freshwater runoff from the land. The upstream and landward limit is where oceanderived salts measure less than 0.5 parts per thousand (ppt) during the period of average annual low flow. 

Palustrine wetlands are nontidal wetlands dominated by trees, shrubs, persistent emergents, 

emergent mosses, or lichens with salinities less than 5 ppt. A palustrine system can exist directly adjacent 

to or within an estuarine system. (Osmond et al. 1995) 
 4-30 Environmental Analysis

TABLE 4.4.1-1 

Common Wetland Species Identified Within the KMLP Project Area 

Common Name Scientific Name Common Name Scientific Name 

Estuarine Emergent Wetlands 

marsh elder Iva fructescens Cattail Typha latifolia

black rush Juncus roemerianus Bulrush Scirpus litoralis

salt meadow cordgrass Spartina patens 

Estuarine Scrub-Shrub Wetlands 

wax-myrtle Myrica cerifera Cattail Typha latifolia

marsh elder Iva fructescens Bulrush Scirpus litoralis

riverhemp Sesbania sp. black rush Juncus roemerianus

Chinese tallow Triadica sebifera salt meadow cordgrass Spartina patens

Palustrine Emergent Wetlands 

alligatorweed Alternanthera 

philoxeroides

Sedges Carex spp. and Cyperus 

spp.

bushy bluestem Andropogon glomeratus Bermudagrass Cynodon sp.

broomsedge bluestem Andropogon virginicus Spikesedges Eleocharis spp.

spadeleaf Centella asiatica carolina geranium Geranium carolinianum

pennyworts Hydrocotyle spp. soft rush Juncus effusus

smartweeds Polygonum spp. Cattail Typha latifolia

Palustrine Scrub-Shrub Wetlands 

sweetgum Liquidambar styraciflua saltwater false willow Baccharis angustifolia

elderberry Sambucus sp. eastern baccharis Baccharis halimifolia

Chinese tallow Triadica sebifera Buttonbush Cephalanthus 

occidentalis

giant cane Arundinaria gigantea marsh elder Iva fructescens

southern dewberry Rubus trivialis wax myrtle Myrica cerifera

dwarf palmetto Sabal minor Cherokee rose Rosa laevigata

Palustrine Forested Wetlands 

sweetgum Liquidambar styraciflua Chinese tallow Triadica sebifera

water oak Quercus nigra poison ivy Toxicodendron radicans

American elm Ulmus Americana Greenbriers Smilax spp.

winged elm Ulmus alata Raspberries Rubus spp.

hackberry Celtis sp. Violets Violaceae

Chinese privet Ligustrum sinense bald cypress Taxodium distichum

tupelo gum Nyssa aquatica swamp blackgum N. sylvatica var. biflora

swamp red maple Acer rubrum var. 

drummondii

black willow Salix nigra

pumpkin ash Fraxinus profunda green ash Fraxinus pennsylvanica

water elm Planera aquatica water locust Gleditsia aquatica

Virginia willow Itea virginica Buttonbush Cephalanthus 

occidentalis
 4-31 Environmental Analysis

Table 4.4.1-2 summarizes impacts to wetlands from construction and operation of the Project, 

including impacts from access roads, rights-of-way, pipe storage/contractor yards, extra workspaces, and 

aboveground facilities. 

TABLE 4.4.1-2 

Summary of Wetlands Affected by the KMLP Project 

Wetland Type 

Number of 

Wetlands 

Crossed 

Estimated 

Crossing 

Length 

(miles)a

Construction 

Impacts 

(acres)a,b

Operation 

Impacts 

(acres)a,c

E2EM 27 6.5 89.3 47.1 

E2SS 11 1.3 11.1 6.5 

PEM 197 20.7 296.2 114.2 

PSS 62 5.0 79.3 23.1 

Subtotal of Non-Forested 297 33.5 475.9 190.9 

PFO 55 3.4 28.3 14.9 

Total Wetlands 352 36.9 504.2 205.8 

_______________ 

E2EM = estuarine emergent 

E2SS = estuarine scrub-shrub 

PEM = palustrine emergent 

PSS = palustrine scrub-shrub 

PFO = palustrine forested 

a Acreages shown do not account for the wetlands that would be crossed by the HDD construction method and would not be 

affected by construction or operation of the Project. b Wetland impact calculations are based on a 125-foot-wide construction right-of-way in areas where the crossing distance is 

greater than 100 feet, and a 100-foot-wide construction right-of-way where the width of crossing is less than 100 feet. c Operation impacts for the pipeline facilities are based on a 50-foot-wide, permanent right-of-way. 

Temporary impacts to wetlands resulting from installation of all of the facilities including extra 

workspaces associated with the Project would include approximately 28.3 acres of forested wetlands and 

475.9 acres of non-forested wetlands. The pipeline facilities would result in the conversion of 14.9 acres 

of forested wetlands within the operational right-of-way to emergent or scrub-shrub wetlands and 

permanent impact to 0.8 acres of E2EM, 1.3 acres of PEM, and 0.6 acres of PSS wetlands resulting from 

the installation and operation of aboveground facilities. 

Prior-converted wetlands are wetlands that have been altered so that they no longer have potential 

to provide valuable wetland functions. Of the 504.2 acres of wetlands that would be impacted by 

construction of the Project, 182.8 acres have been classified as prior-converted. 

KMLP has identified several locations where proposed extra workspaces are located entirely or 

partially within wetlands. The use of these extra workspaces would temporarily affect 50.2 acres of nonforested wetlands and 1.1 acres of forested wetlands during construction. Three of the 14 interconnect 

sites would be located in wetlands and impact 2.7 acres of non-forested wetlands. In addition, three of the 

12 proposed pipe storage and contractor yards would be located in wetlands and impact 62.6 acres of nonforested wetlands. The Project would also require the construction of three new roads (Access Roads 2, 

3, and 4-5) and improvement of seven existing access roads in wetlands (Access Roads 1, 4-1, 6, 7, 10-1, 
 4-32 Environmental Analysis

13-1, and 16) for access to rights-of-way and workspaces that would impact 9.3 acres of non-forested 

wetlands and 0.1 acres of forested wetlands. 

NOAA Fisheries Service (2006a) has indicated that aquatic and tidally influenced wetland 

habitats in the Project area have been designated as EFH for various species of fish and invertebrates. 

Construction through the first 50 miles of the pipeline route would impact approximately 99.5 acres of 

EFH wetlands along the northern and southern banks of Sabine Lake, Shell Island, the Sabine and 

Calcasieu Rivers, and the GIWW. KMLP has routed the pipeline through Sabine Lake to avoid/minimize 

impacts to EFH wetlands and it would install the pipeline using HDD at the north and south shores of 

Sabine Lake. KMLP would also minimize impacts to EFH wetlands by using a combination of HDD and 

open-cut methods along the Sabine River/GIWW, and by using low-ground-pressure equipment, board 

roads, and marsh buggies during construction activities in saturated estuarine areas. Additional 

discussion of EFH wetlands is provided in section 4.6.3. 

Significant forested wetlands crossed by the Project include forested wetlands from MP 99.0 to 

99.7, in the vicinity of Bayou Nezpique, and a forested wetland from MP 1.3 to 1.6 along the FGT Lateral 

in the vicinity of Bayou des Cannes. Bayou Nezpique would be crossed by HDD, avoiding impacts to 

approximately 1.6 acres of forested wetlands. The FGT Lateral would be collocated with an existing 

right-of-way through a large forested area. Although collocation is generally acceptable as a way to 

minimize impacts to an area, this particular area is a quality forested wetland that would be disrupted by 

the clearing of the right-of-way and by widening the right-of-way through the area. FWS, COE, and 

LDWF have requested HDD through this area to minimize impact to forested wetland. Therefore, in 

section 4.3.2.1, we are recommending that the FGT Lateral cross Bayou des Cannes and associated 

wetlands by HDD. 

Wetland Construction Procedures 

KMLP would use wetland construction methods described in section 2.3 of this draft EIS, and 

applicable permit conditions to avoid or minimize impacts to wetlands. 

KMLP would cross numerous wetlands along the pipeline rights-of-way using the HDD method 

to avoid the need to clear or otherwise disturb about 7.0 acres of forested wetlands and 100.8 acres of 

non-forested wetlands. Use of HDD would minimize disturbance of the surface between the entry and 

exit points of the HDD. The disturbance would be limited to the deployment of telemetry cable. 

However, KMLP has not explained how it would clear the vegetation to facilitate deployment of 

telemetry cable. The COE has expressed concern that the mechanized clearing could result in greater 

impacts to wetland vegetation and prefers the use of hand clearing. Therefore, we recommend that: 

• KMLP use hand clearing methods for clearing vegetation in the path of HDDs in 

wetland areas.

KMLP would also use the push-pull method and marsh buggies for construction through coastal 

estuarine herbaceous marsh that is tidally influenced and mostly submerged. This construction method, 

as described in section 2.3, is generally used in large wetland areas with suitable hydrology and 

topography (i.e., flooded or saturated soils and minimal local relief). Push-pull construction generally 

requires a narrower right-of-way and minimizes the operation of construction equipment within wetlands. 

This method offers environmental advantages over conventional wetland construction approaches. 

Because of the potential environmental advantages of the push-pull construction method, Item VI.B.2.c in 

our Procedures requires that this method be used where sufficient water is present in the trench and other 

site conditions allow. KMLP proposes to cross approximately 63.7 acres of wetland using the push-pull 
 4-33 Environmental Analysis

method. Locations where the push-pull (typical submerged marsh) construction method would be used 

are listed in appendix E. 

In order to minimize construction-related impacts to wetlands, KMLP would implement measures 

outlined in our Procedures that include, but are not limited to, the following requirements: 

• Construction equipment operating within the right-of-way would be limited to that equipment 

necessary for clearing, excavation, pipe installation, backfilling, and restoration activities. 

All nonessential equipment would use upland access roads to the maximum extent 

practicable. 

• Equipment operating within saturated wetlands would be low-ground-weight equipment or 

would operate from timber or board mats. 

• Temporary erosion and sedimentation control measures would be installed immediately after 

the initial disturbance of wetland soils and would be inspected and maintained regularly until 

final stabilization. 

• Sedimentation controls would be installed across the construction right-of-way, as needed, 

within wetlands to contain trench spoil. 

• Grading and pulling of tree stumps would be limited to the area directly over the trenchline 

unless additional grading or stump removal is required for worker safety. 

• In unsaturated wetlands, the uppermost 12 inches of topsoil along the pipeline trench would 

be segregated from the underlying subsoil. 

• Project-specific restoration plans would be developed based on consultations with appropriate 

land management or state agencies. The wetland restoration plan should include measures 

for re-establishing herbaceous and/or woody species, controlling the invasion and spread of 

undesirable exotic species, and measures for monitoring the success of the revegetation and 

weed control efforts. 

• Monitoring of wetlands would be conducted for a minimum of three years post-construction 

to ensure the success of wetland revegetation. If revegetation is not successful after three 

years, a remedial revegetation plan would be developed and implemented. 

Requested Alternative Measures to Our Procedures 

KMLP has requested alternative measures to certain items in our Procedures. Items pertaining to 

wetlands and waterbodies are discussed below and summarized in table 4.4.1-3. 

Item IV.A.1.d of our Procedures requires that all equipment be parked overnight and/or fueled at 

least 100 feet from a waterbody or in an upland area at least 100 feet from a wetland boundary unless the 

EI finds, in advance, no reasonable alternative, and appropriate steps are taken to prevent and provide for 

prompt cleanup of spills. Item IV.A.1.e requires that hazardous materials (e.g., chemicals, fuels, 

lubricants) not be stored within 100 feet of a wetland or waterbody unless the location is designated for 

such use by a government authority. KMLP has requested alternative measures to these requirements 

based on site-specific circumstances and proposed construction methods. We have reviewed the Project 
 4-34 Environmental Analysis

TABLE 4.4.1-3 

Acceptance or Denial of Requested Alternative Measures from our Procedures 

MP 

Applicable 

Item in our 

Proceduresa Reason for Request 

Accepted/ 

Denied Basis for Acceptance/Denial 

Various IV.A.1.d & e Refueling activities in 

waterbodies 

Accepted This alternative measure is accepted for 

use only in Sabine Lake and the Sabine 

River as in-lake construction provides 

no practicable alternative to refueling 

from barges within the lake 

Various VI.A.3 A typical temporary construction 

right-of-way width of 125 feet in 

wetlands where the crossing 

length exceeds 100 feet and a 

right-of-way width of 100 feet in 

wetlands where the crossing 

length is less than 100 feet (see 

specific MP locations in 

appendix D) 

Accepted only 

along Leg 1 

This alternative measure is accepted 

because larger equipment and soil 

limitations require a larger right-of-way 

to assure a safe work site and space for 

spoil storage 

28.24 of 

Leg 1 and 

1.23 of the 

FGT 

Lateral 

VI.A.6 Two aboveground facilities 

located within jurisdictional 

wetlands (see specific MP 

locations in appendix D) 

Accepted Locations of interconnects dictated by 

intersection of the proposed pipeline 

and existing pipelines and by the 

location of the Sabine Pass LNG 

Terminal 

Various VI.B.1.e A portion of Access Roads 2 and 

3 constructed in wetlands 

Accepted Access is required from the GIWW to 

reach the HDD workspace needed to 

minimize impacts to wetlands 

Various VI.B.1.a Some extra workspaces located 

within 50 feet of wetland 

boundaries (see specific MP 

locations in appendix D) 

Accepted Accepted only for specific sites listed in 

appendix D based on lack of practicable 

locations with 50-foot setbacks; also 

some sites are to facilitate HDD or 

other methods designed to reduce 

impacts (see appendix D) 

Various V.B.2.a Some extra workspaces located 

within 50 feet of water's edge 

(see specific MP locations in 

appendix D) 

Accepted Accepted only for specific sites listed in 

appendix D, Table D-3 based on lack of 

practicable locations with 50-foot 

setbacks; also some sites are to 

facilitate HDD or other methods 

designed to reduce impacts (see 

appendix D) _______________ 

a Requirements specified in the referenced Procedure items are summarized below: 

 IV.A.1.d and e: Requires a 100-foot minimum setback from a waterbody or wetland for equipment parking, fueling, and hazardous 

materials storage; 

VI.A.3: Limits construction right-of-way width in wetlands to 75 feet; 

VI.A.6: Prohibits the location of aboveground facilities in wetlands except when in compliance with DOT; 

VI.B.1.a: Requires a 50-foot setback from water’s edge for all extra work areas (except where adjacent land is actively cultivated or rotated 

cropland or other disturbed land); and 

VI.B.1.e: Prohibits the use of access roads in wetlands without Director approval unless those access roads are existing and require no 

modification or impact to wetlands. 

and have determined that the alternative measures are justified within Sabine Lake and the Sabine River 

due to the use of spud barges during construction and a lack of practicable refueling options. 

Item VI.A.3 of our Procedures requires that the construction right-of-way width in wetlands be 

limited to 75 feet. KMLP proposes to use a 125-foot construction right-of-way within wetlands where the 
 4-35 Environmental Analysis

crossing length would exceed 100 feet. KMLP states that the 125-foot right-of-way is necessary to 

accommodate installation of the 42-inch-diameter pipeline, due to the unstable and saturated soil 

conditions, larger pipe-installation equipment, wider ditches, and non-cohesive spoil piles during 

construction. KMLP also stresses the need for safe construction practices that meet OSHA requirements 

and minimize the environmental impact. Milepost locations where a 125-foot construction right-of-way 

is requested for wetland crossings are given in appendix D. We believe that the justification KMLP has 

provided is adequate and reasonable for areas where the push-pull method is not viable; therefore, we 

accept the request for a construction right-of-way of 125 feet at the specific milepost locations listed in 

appendix D. 

Item VI.A.6 of our Procedures prohibits the location of aboveground facilities in any wetland, 

except where the location of such facilities outside of wetlands would prohibit compliance with DOT 

regulations. KMLP proposes to construct three aboveground facilities in wetlands: 

• The NGPL Interconnect Site (MP 1.2) is an industrial wetland area within the Sabine Pass 

LNG Terminal where no available upland areas were identified in the vicinity. 

• The Southwest Loop Delivery Point is proposed at MP 28.2, within the Black Bayou 

Hydrologic Restoration Project boundaries. KMLP states that the nearest upland area in this 

vicinity is located approximately 800 feet north of the proposed site, along the banks of the 

GIWW, and would require installation of the connecting pipeline under a major pipeline 

corridor. 

• KMLP has stated that the TGTPL interconnect site (MP 87.5) is within a rice field. 

We have reviewed the proposed locations for these interconnect sites and have determined that 

there are no practicable alternatives to locate these aboveground facilities outside of wetland areas. 

Therefore, we concur with KMLP.

Item VI.B.1.e of our Procedures states that the only access roads, other than the construction 

right-of-way, which can be used in wetlands without Director approval are those existing roads that can 

be used with no modification and no impact on the wetlands. Portions of Access Roads 2 and 3 would 

cross wetlands in order to provide access from the GIWW to the HDD workspaces for HDD equipment 

and construction access. The construction of these two access roads would temporarily impact 

approximately 0.9 acres of non-forested wetland, and the use of HDD at these two access points would 

avoid approximately 25.3 acres of wetlands as well as riparian areas and waterbodies. We believe that 

use of HDD would minimize impacts to wetlands; therefore, we accept the use of KMLP’s alternative 

measure to construct portions of Access Roads 2 and 3 within wetlands. KMLP also proposes to 

construct a portion of Access Road 4-5 within wetlands, but has not provided any justification for such 

construction in wetlands. Therefore, we recommend that: 

• KMLP evaluate alternative routes for Access Road 4-5 or provide justification for the 

wetland impacts associated with its construction in wetlands. Any revision to the route 

of Access Road 4-5 should be shown on revised alignment sheets. KMLP should file 

with the Secretary results of its evaluation and copies of the revised alignment sheets for 

review and written approval by the Director of OEP prior to the close of the comment 

period on the draft EIS. 

Items VI.B.1.a and V.B.2 of our Procedures require that all extra workspaces such as staging 

areas and additional spoil storage areas be located at least 50 feet from water’s edge or wetland 
 4-36 Environmental Analysis

boundaries, respectively, except where the adjacent upland consists of cropland or other disturbed land. 

KMLP proposes to locate 164 extra work areas within 50 feet of water’s edge or wetland boundaries. A 

list of the proposed extra workspaces requiring alternative measures is in appendix D along with the 

milepost location and justification for each. The justifications provided by KMLP for these alternative 

measures are adequate; therefore, we accept the use of each of the extra workspaces listed in appendix D. 

Wetland Restoration Projects 

There are seven Coastal Wetland Planning, Protection, and Restoration Act (CWPPRA) projects 

in the Project vicinity; each of these projects is described in table 4.4.1-4. Only two of the seven 

CWPPRA projects would be crossed by the Project. 

TABLE 4.4.1-4 

The Coastal Wetlands Planning, Protection, and Restoration Act Projects 

in the Vicinity of the KMLP Project 

Project Name Location Sponsor(s) Purpose 

Relationship to 

Project 

 Impact 

(acres) 

Black Bayou 

Hydrologic 

Restoration Project 

(CS-27) 

MP 22.3 -

30.7 

NOAA 

Fisheries and 

LDNR 

Restore coastal marsh habitat 

and slow the conversion of 

wetlands to shallow, open 

water 

7.6-mile crossing 153.5 

Perry Ridge Shore 

Protection Project 

(CS-24) 

MP 30.8- 

32.2 

NRCS and 

LDNR 

Reduce erosion at the GIWW 

shoreline and at the spoil 

banks protecting nearby 

marshes 

1.4-mile crossing 25.9 

East Sabine Lake 

Hydrologic 

Restoration 

(CS-32) 

MP 15 FWS, NRCS, 

and LDNR 

Restore the hydrologic regime 

within the Sabine NWR 

2.6 miles east of MP 

15 

No impact 

Plowed Terraces 

Demonstration 

(CS-25) 

MP 33 NRCS and 

LDNR 

Construct earthen terraces in 

shallow open water to allow 

the establishment of emergent 

vegetation 

1,000 feet south of 

MP 33 

No impact 

Perry Ridge West 

Bank Stabilization 

(CS-30) 

MP 27 NRCS and 

LDNR 

Construct riprap terraces along 

the GIWW to reduce wave 

fetch and allow the recovery 

of marshes 

1,000 feet north of 

MP 27 

No impact 

Clear Marais Bank 

Protection 

(CS-22) 

MP 40 COE and 

LDNR 

Prevent further erosion to a 

levee preventing 

encroachment of the GIWW 

into marshes 

1,000 feet north of 

MP 40 

No impact 

Black Bayou 

Culverts 

Hydrologic 

Restoration 

(CS-29) 

MP 55 NRCS and 

LDNR 

Prevent saltwater intrusion, 

excessive water levels, and 

erosion in areas near Calcasieu 

Lake 

500 feet north of MP 

55 

No impact 

_______________ 

Source: LaCoast 2006a,b. 
 4-37 Environmental Analysis

Black Bayou Hydrologic Restoration Project 

The Black Bayou Hydrologic Restoration Project, sponsored by NOAA Fisheries Service and 

LDNR, is a 25,529-acre wetland located in Cameron and Calcasieu Parishes, Louisiana. Bordered by the 

GIWW, Sabine Lake, Black Bayou, and Gum Cove Ridge, the restoration area consists of tidally 

influenced intermediate and brackish marshes. The goal of the Black Bayou Hydrologic Restoration 

Project is to restore coastal marsh habitat and to slow the conversion of wetlands to shallow, open water. 

The restoration projects are designed to limit the amount of saltwater intrusion into the surrounding 

marshes and reduce erosion caused by wave action from nearby boats and tides (LaCoast 2006a). The 

KMLP Project would traverse this restoration project area between MP 22.3 and MP 30.7. The Project 

would affect approximately 153.5 acres of the Black Bayou Hydrologic Restoration Project, much of 

which would be crossed by the HDD method. Of these 153.5 acres, 60.0 acres are comprised of 

nonforested wetlands and 2.8 acres of forested wetlands would be crossed by open-cut construction. 

During operations, 35.6 acres of non-forested and 1.8 acres of forested wetlands within the permanent 

right-of-way would be maintained in an herbaceous state. Because the objective of this project is to 

restore coastal marsh habitat and slow the conversion of wetlands to shallow open waters, impacts from 

the KMLP Project could temporarily delay any progress made in this restoration area. 

NOAA Fisheries Service expressed concern that the pipeline construction in the Black Bayou 

Hydrologic Restoration Project would interfere with future construction and maintenance activities for 

rock structures at various locations (e.g., MPs 23.9 and 30.7) and near Burton Shell Slip at MP 23.8. 

They also stated that KMLP and NOAA Fisheries Service would need to enter into an agreement that 

would allow KMLP to access and maintain the pipeline in a manner that would not damage any rock 

structures within the Black Bayou Hydrologic Restoration Project. Because several existing pipelines 

stretch through the Black Bayou Hydrologic Restoration Project area, KMLP proposes to install its 

pipeline using two HDDs (MPs 25.3 to 26.8). We believe use of the HDD method of construction would 

minimize disturbance to these rock structures and minimize impact to restoration activities in the Black 

Bayou Hydrologic Restoration Project (see sections 2.3.1.3 and 4.3.2.1 for more discussion). 

Perry Ridge Shore Protection Project 

The crossing of the Perry Ridge Shore Protection Project, sponsored by the NRCS and LDNR, 

would traverse the restoration area between MP 30.8 and 32.2. The construction right-of-way through 

this area would affect approximately 25.9 acres of land, including approximately 18.5 acres of fresh-tointermediate marsh and open water habitats. Operation of the Project would impact approximately 0.06 

acres of similar habitat. 

At the recommendation of various resource agencies, KMLP developed a pipeline route that 

avoids most of the Perry Ridge Shore Protection Project by staying on the southern bank of the GIWW 

until MP 30.7. In addition, most surface disturbance to the Perry Ridge Shore Protection Project would 

be avoided by installing the pipeline by two successive HDDs between MPs 30.4 and 32.4. Where 

conditions allow, approximately 0.2 miles of the pipeline within the Perry Ridge Shore Protection Project 

would be installed using the conventional method. The resulting impact to the Perry Ridge Shore 

Protection Project would be short-term, but would temporarily delay progress made within the protection 

area, in this case, affecting progress on the minimization of erosion along the GIWW and the associated 

impacts of that erosion to adjacent habitats. 

Areas within the permanent right-of-way within the Perry Ridge Shore Protection Project and the 

Black Bayou Hydrologic Restoration Project would be maintained in an herbaceous state for the life of 

the KMLP Project. KMLP has stated that a site-specific construction and restoration plan for the Black 

Bayou Hydrologic Restoration Project and the Perry Ridge Shore Protection Project would be developed 
 4-38 Environmental Analysis

in cooperation with LDNR, NOAA Fisheries Service, and FWS. To ensure that this plan addresses 

agency concerns, we recommend that: 

• KMLP consult with LDNR, NOAA Fisheries Service, and FWS, and develop sitespecific construction and restoration plans for crossing the Black Bayou Hydrologic 

Restoration Project and Perry Ridge Shore Protection Project. KMLP should file with 

the Secretary copies of its consultation, along with construction and restoration plans, 

for review and written approval by the Director of OEP prior to the completion of the 

final EIS. 

Conservation Reserve Program Lands 

The CRP is a voluntary program, administered by the Farm Service Agency (FSA) and planned 

and implemented by the NRCS. The goal of the CRP is to reduce soil erosion, protect the Nation’s ability 

to produce food and fiber, reduce sedimentation in streams and lakes, improve water quality, establish 

wildlife habitat, and enhance forest and wetland resources. It encourages farmers to convert highly 

erodible cropland or other environmentally sensitive areas to vegetative cover, such as native grasses, 

wildlife plantings, trees, or riparian buffers. Farmers receive an annual rental payment for the term of the 

multi-year contract (NRCS 2006b). 

Within the Parishes crossed by the Project, Acadia, Evangeline, and Jefferson Davis are known to 

contain several CRP lands (FSA 2006a), but according to local FSA offices, CRP lands in Acadia and 

Evangeline Parishes are located at least 0.3 miles away from the Project and therefore no impacts are 

expected from construction (Haller 2006, USDA 2006). Consultations are ongoing with regard to CRP 

locations in Jefferson Davis Parish. 

Should any CRP lands be crossed by the Project, the enrolled landowners would no longer be 

eligible to participate in the CRP and would lose the income provided by the NRCS. Additionally, 

KMLP would be required to obtain Compatible-Use Permits from the NRCS authorizing the crossing of 

any lands enrolled in the CRP. Therefore, we recommend that: 

• KMLP continue consultations with the FSA and NRCS to identify the extent and 

location of all CRP lands within Jefferson Davis Parish that would be affected by 

construction and operation of the Project. In addition, KMLP should file with the 

Secretary prior to construction, copies of its consultation and documentation of any 

stipulations or recommendations to avoid and minimize impacts to any CRP lands that 

would be affected. 

4.4.2 Impacts and Mitigation 

The COE requires that all appropriate and practicable actions be taken to avoid or minimize 

wetland impacts, pursuant to its section 404(b)(1) guidelines, which restrict discharges of dredged or fill 

material where a less environmentally damaging and practicable alternative exists. All wetland crossings 

would be subject to review by the COE to ensure that wetland impacts are fully identified and appropriate 

wetland restoration and mitigation measures are implemented. 

Construction Impacts 

Construction activities have the potential to diminish the value of wetlands through clearing, 

trenching, spoil placement, equipment passage, and related construction disturbances. Wetland functions 
 4-39 Environmental Analysis

such as erosion control, buffering and flood flow attenuation, sediment retention, and nutrient retention 

would also be affected by construction. These effects would typically be greatest during and immediately 

following construction, resulting in a temporary impact. Clearing of wetland vegetation would result in 

both short- and long-term loss of wetland wildlife habitat and some wetland functions, with the duration 

of the impact varying by habitat type. Forested wetlands would require as much as 30 years or more to 

recover from clearing and would be subjected to more stages of succession, ensuring the slow, but 

continuous alteration of available habitat until the land has been restored to a pre-construction state. 

Impacts to scrub-shrub wetlands would be mostly short-term, as restoration would likely occur within 

three years. Emergent wetlands, which can restore rapidly, would typically experience only short-term 

impacts, and may re-establish in one or two growing seasons. 

Excavation of the pipeline trench, installation of the pipe, and backfill of the trench would affect 

the rate and direction of water movement within wetlands. In addition, excavation activities may alter 

perched water tables by disturbing impermeable soil layers. This would adversely affect wetland 

hydrology and revegetation by creating soil conditions that might not support wetland communities and 

hydric vegetation at pre-construction levels. Failure to properly segregate soils during construction would 

result in mixed soil layers, which would alter biological components of the wetland and affect the 

reestablishment of native wetland vegetation. Temporary stockpiling of soil and the movement of heavy 

machinery across wetlands would lead to inadvertent compaction and furrowing of soils, which would 

alter natural hydrologic patterns, inhibit seed germination, and increase seedling mortality. Altered 

surface drainage patterns, stormwater runoff, runoff from the trench, accidental spills, and discharge of 

hydrostatic test water would also negatively affect water quality by increasing the potential for siltation 

and turbidity resulting from construction activities. 

KMLP would minimize impacts to wetlands by implementing our Procedures, as modified with 

accepted alternative measures, as discussed above. In accordance with our Procedures, KMLP would 

install sediment barriers across the entire construction right-of-way, as needed, within wetlands as well as 

along the edge of the construction right-of-way, when adjacent to wetlands, in order to prevent sediment 

flow into wetlands. Additionally, energy dissipating devices would be used to discharge hydrostatic test 

water to further minimize sedimentation in wetlands. Section 2.3.1 describes the specialized pipeline 

construction procedures that KMLP would implement to minimize impacts to wetlands, including the use 

of the push-pull method through wetlands where possible. Within the construction right-of-way, KMLP 

would grade tree stumps, but would only remove them within 15 feet of the proposed pipeline, and install 

erosion control devices to minimize sediment flow into the wetland. KMLP would reduce the maintained 

portion of the permanent pipeline right-of-way to 10 feet in wetlands, rather then the 50-foot width 

proposed for uplands. 

KMLP has stated that no shallow bedrock occurs at or near the surface of the pipeline route; 

therefore, no perched water tables are expected to be present. Soil segregation along the Project would 

occur in unsaturated wetlands but would not be practical in saturated and submerged wetlands. In 

unsaturated wetlands where rutting or mixing of the topsoil can occur, KMLP would use low-groundpressure equipment or temporary board roads for passage through the area. If the crossing length of an 

unsaturated wetland would be less than 100 feet, the spoil would be moved to adjacent upland areas 

located within the right-of-way, avoiding soil disturbance in the wetland. Board mats would also be used 

for passage through saturated wetlands. KMLP has stated that it would also disc any over-compacted 

soils found after construction. 

The proposed pipeline route is located adjacent to existing rights-of-way to the extent practical so 

that the construction right-of-way would overlap with existing permanent rights-of-way. The amount of 

overlap would be limited to 15 feet to minimize wetland impacts. 
 4-40 Environmental Analysis

Of the 18 proposed HDDs, 17 would cross waterbodies and/or wetlands (table 4.3.2.1-3). 

Through the use of HDD, KMLP would avoid impacts to approximately 87.8 acres of herbaceous 

wetlands (E2EM and PEM), 13.0 acres of scrub-shrub wetlands (E2SS and PSS), and 7.0 acres of 

forested wetlands. This includes the extensive bottomland forest located in Jefferson Davis Parish near 

Bayou Nezpique. Additionally, KMLP would avoid impacts to wetlands along the shores of Sabine Lake 

by routing the proposed pipeline through the open water as opposed to along the shoreline, where 

sensitive wetlands occur. 

KMLP has stated that all emergent and scrub-shrub wetlands impacted by construction would be 

restored to original contours, revegetated as appropriate, and monitored to ensure a successful recovery. 

Forested wetlands would be allowed to naturally revegetate with the exception of a 10-foot-wide corridor 

over the pipeline that would be maintained in an herbaceous state. Wetland recovery would be 

considered successful when native species cover at least 80 percent of the wetland. 

Sensitive or Unique Wetlands 

KMLP would minimize impacts to EFH wetlands by using a combination of HDD and open-cut 

construction methods along the Sabine River/GIWW, and by using low-ground-pressure equipment, 

board roads, and marsh buggies during construction activities in saturated estuarine areas. Wetlands 

designated as EFH are discussed in section 4.6.4 with regard to their importance as a habitat to federally 

managed fishes and invertebrates. 

Bayou Nezpique would be crossed by HDD, avoiding impacts to approximately 7.0 acres of 

forested wetlands. 

The FGT Lateral would be collocated with an existing right-of-way through a large forested area 

adjacent to Bayou des Cannes. Although collocation is generally acceptable as a way to minimize 

impacts, this particular area is considered a quality forested wetland that would be impacted by the 

widening of the existing right-of-way. Therefore, we are recommending in section 4.3.2.1 that KMLP 

evaluate the feasibility of the FGT Lateral to cross Bayou des Cannes and associated wetlands by HDD. 

Operation Impacts 

Operation of the pipeline would require 190.9 acres of non-forested wetlands to be maintained in 

an herbaceous state. Operation of the Southwest Loop Delivery Point and the NGPL and TGTPL 

interconnect sites would permanently convert 2.7 acres of non-forested wetlands to industrial land. 

Additionally, 14.9 acres of forested wetlands would be converted to herbaceous wetland for the life of the 

Project. 

KMLP would maintain a 10-foot-wide strip centered over the pipeline in a herbaceous state. 

Additionally, trees that are within 15 feet of the pipeline and greater than 15 feet in height would be cut 

and removed. These activities would not affect PEM wetlands. However, mowing, clearing, and tree 

removal would affect PSS and PFO wetlands along the permanent right-of-way, causing constant 

disruption to natural successional growth and increasing the chance of invasion by non-native species. 

Functions associated with these wetland types would be altered because forested or scrub-shrub wetlands 

within the maintained portion of the permanent pipeline right-of-way would be permanently converted to 

an herbaceous state. 

All emergent and scrub-shrub wetlands impacted by construction would be restored to preconstruction contours. KMLP would consult with the appropriate state and federal agencies to develop 

project-specific measures for re-establishing herbaceous and/or woody species. In accordance with our 
 4-41 Environmental Analysis

Procedures, KMLP would monitor the recovery of wetlands for a minimum of three years postconstruction to ensure the success of revegetation. If revegetation is not successful at the end of three 

years, a remedial revegetation plan would be developed and implemented in consultation with a 

professional wetland ecologist. The remedial revegetation plan would serve as a guide to actively 

revegetate the wetland with native wetland herbaceous and woody plant species. Revegetation efforts 

would be continued until revegetation was considered successful. 

Wetland Protection Measures 

We believe the implementation of our Procedures with the accepted alternative measures, along 

with the use of HDDs, existing access roads, mitigation, and avoidance of PFO wetlands to the extent 

practical, KMLP would have adequately avoided, minimized, and mitigated impacts to wetlands. 

Avoidance 

KMLP would avoid impacts to wetlands through the use of HDD crossing methods and the 

routing of the Project through less sensitive areas such as Sabine Lake in order to avoid the shoreline 

where sensitive EFH wetlands occur. Additional areas of avoidance include areas of collocation where 

the width of construction rights-of-way could be reduced by utilizing existing operational and maintained 

areas. 

Minimization 

KMLP would minimize impacts to wetlands through a variety of methods, including the use of: 

• The Aquatic Resources Mitigation Plan (appendix H); 

• BMPs to control erosion and sedimentation; 

• Routing that avoids wetlands to the extent practical; and 

• The push-pull construction method where feasible, which would avoid the need for access 

canal excavation. 

Mitigation 

KMLP would implement its Aquatic Resources Mitigation Plan to ensure that wetlands within the 

construction right-of-way would experience no net loss in functional value. Temporary impacts would be 

mitigated by full restoration, with the exception of forested wetlands within the permanent right-of-way, 

after construction has been completed. KMLP is evaluating wetland mitigation banking options (Dorsey 

2007) and is developing its draft Aquatic Resources Mitigation Plan in consultation with COE, FWS, 

NOAA Fisheries Service, LDNR, and LDWF; therefore, we recommend that: 

• Prior to construction, KMLP file with the Secretary a copy of the finalized Aquatic 

Resources Mitigation Plan developed in consultation with COE, NOAA Fisheries 

Service, FWS, LDNR, and LDWF. 
 4-42 Environmental Analysis

4.5 VEGETATION 

The vegetative communities that would be crossed by the Project can be generally grouped into 

uplands and wetlands. This section identifies and describes the vegetation types composing the two 

general vegetative communities and describes the impacts to these communities resulting from 

construction and operation of the Project. This section also addresses vegetation types of special concern, 

and exotic/invasive plant species. Section 4.4 addresses vegetation in wetlands. 

4.5.1 Affected Environment 

The upland vegetative community consists of several vegetation types: agricultural, upland forest, 

rangeland, and developed. The agricultural vegetation type consists of common crops and pasture 

grasses. The upland forest vegetation type consists of deciduous, evergreen, and mixed forests including 

managed pine forests. The rangeland vegetation type consists of common scrub-brush, herbaceous, and 

mixed vegetative species. The developed vegetative type consists of common grasses and shrubs 

associated with commercial, residential, and industrial lands as well as utility rights-of-way. The upland 

vegetative types crossed by the Project, as well as representative species occurring in each cover type, are 

listed in table 4.5.1-1. 

TABLE 4.5.1-1 

Upland Vegetation Types Crossed by the KMLP Project 

Vegetation 

Cover Type General Description Common Species 

Agricultural Cropland and pasture Rice (Oryza sativa), soybeans (Glycine spp.), corn (Zea spp.), sugar cane 

(Saccharum officinarum), turf grass, and sweet potatoes (Ipomoea 

batatas). 

Upland 

Forest 

Deciduous, evergreen, 

and mixed forests 

Red Maple (Acer rubrum), Ironwood (Carpinus carolinianum), hickories 

(Carya spp.), Hackberry (Celtis occidentalis), Sugarberry (C. laevigata), 

Yaupon Holly (Ilex vomitoria), Chinese Privet (Ligustrum sinense, invasive 

non-native), Sweetgum (Liquidambar styraciflua), Red Mulberry (Morus 

rubra), Loblolly Pine (Pinus taeda), White Oak (Quercus alba), Water oak 

(Q. nigra), Live Oak (Quercus virginiana), Chinese Tallow (Sapium 

sabiferum = Triadica sebifera, invasive non-native), Winged Elm (Ulmus 

alata), American Elm (Ulmus americana), Japanese Honeysuckle 

(Lonicera japonica, invasive non-native), greenbriers (Smilax spp.), Poison 

Ivy (Toxicodendron radicans), sedges (Carex spp.), and Carolina Violet 

(Viola villosa). 

Rangeland Scrub-brush, 

herbaceous, and 

mixed rangelands 

Giant Ragweed (Ambrosia trifida), sedges (Carex spp.), Bermudagrass 

(Cynodon dactylon), grasses in the genus Paspalum, Curly Dock (Rumex 

crispus), Chinese Tallow (invasive, non-native), Eastern Baccharis 

(Baccharis halimifolia), American Holly (Ilex opaca), Yaupon Holly, Marsh 

Elder (Iva frutescens), Chinese Privet (invasive non-native), Japanese 

Honeysuckle (invasive non-native), Osage Orange (Maclura pomifera), 

Virginia creeper (Parthenocissus quinquefolia), Smooth Sumac (Rhus 

glabra), Cherokee Rose (Rosa laevigata), Field Blackberry (Rubus 

arvensis) and other Rubus spp., Elderberry (Sambucus canadensis), 

Rattlebox (Sesbania drummondii), and Poison Ivy. 

Developed Commercial, industrial, 

residential, rights-ofway 

Grasses and small shrubs. 
 4-43 Environmental Analysis

Vegetation Types of Special Concern 

Based on field surveys and consultations with LDWF, no critically imperiled plant species have 

been identified within 0.5 miles of the Project. Additionally, no unique communities or communities of 

special concern are located within 0.5 miles of the Project. 

Several wetland and hydrologic restoration projects that have vegetative components occur in the 

vicinity of the Project and are addressed in sections 4.4 and 4.8. 

4.5.2 Impacts and Mitigation 

4.5.2.1 Primary Impact to Vegetative Cover Types 

Construction of the Project, including the pipeline, aboveground facilities, access roads, pipe 

storage/contractor yards, and extra work spaces would require the clearing of 1,463.4 acres of agricultural 

land, 115.4 acres of upland forest, 134.4 acres of rangeland, and 130.2 acres of developed land. 

Operation of the Project would require approximately 522.8 acres of upland vegetation, including 

43.8 acres of upland forest, to be converted to permanently maintained pipeline right-of-way, 

aboveground facilities, or permanent access roads. Table 4.5.2.1-1 identifies the number of acres of 

vegetation temporarily and permanently impacted by construction and operation of the Project. 

The majority of construction-related clearing would be temporary and cleared vegetation would 

be able to return to natural conditions after construction, with the exception of the permanent pipeline 

right-of-way that would be maintained in an herbaceous state throughout the life of the Project. The loss 

of vegetation along the pipeline route would result in forest fragmentation and the loss or conversion of 

wildlife habitat. Other impacts resulting from the removal of vegetation include increased erosion, 

TABLE 4.5.2.1-1

Upland Vegetation Cover Types Affected by the KMLP Project 

Pipelinea Ancillary Facilitiesb

Vegetation 

Cover Type 

Temporary 

Construction 

Impact 

(acres) 

Permanent 

Operations 

Impact 

(acres) 

Temporary 

Construction 

Impact 

(acres) 

Permanent 

Operations 

Impact 

(acres) 

Agriculturalc 1,178.5 415.8 284.9 7.9 

Upland Forest 114.9 43.8 0.6 0.0 

Rangeland 95.0 28.3 39.3 0.5 

Developed Land 56.4 18.5 73.7 8.1 

Total 1,444.8 506.3 398.5 16.5 

_______________ 

a

 Temporary construction acreages reflect a nominal 125-foot-wide construction right-of-way and temporary extra workspaces. 

The permanent operations acreages reflect a 50-foot-wide permanent easement that would be maintained in upland areas 

following construction. b For the purpose of this table, ancillary facilities include acres affected for interconnect sites, access roads, pipe 

storage/contractor yards.. c The acres of agricultural land reported above differs from acreage reported in section 4.8. This is because section 4.8 includes 

in agricultural land a category of “other” which is land without vegetative cover. Land without vegetative cover is excluded from 

the analysis of vegetation.
 4-44 Environmental Analysis

sediment runoff, altered soil chemistry, modified infiltration and groundwater recharge rates, and an 

increased susceptibility to colonization by invasive and/or exotic plant species. Additionally, the 

removal of trees on the right-of-way could expose formerly interior trees growing adjacent to the newly 

cleared areas to higher levels of wind, which may increase the risk of blow downs. 

The severity of these impacts would depend on the specific vegetation type affected and the time 

that it takes the vegetation type to return to pre-construction conditions. Specifically, most impacts to 

agricultural lands and rangelands would be short term as these vegetation types would return to their 

herbaceous or shrub-covered status within one to three growing seasons after the completion of 

construction activities, cleanup, and restoration. Areas planted with field crops are typically disturbed by 

periodic agricultural practices and would be replanted in the next growing season. The clearing of upland 

forest would result in a long-term impact as upland forests can take up to 30 years or more to return to 

pre-construction conditions. Impacts to upland forested areas constitute the most significant change in 

vegetative strata, appearance, and habitat, as mature trees would be replaced for a period of years by 

herbaceous plants, shrubs, saplings, and other successional species. Impacts to previously developed 

lands such as industrial areas and linear transportation corridors would result in short-term impacts due to 

the existing maintained or disturbed condition. 

In order to minimize impacts to affected vegetation types, KMLP would implement measures 

outlined in our Plan as described below and further discussed in section 2.3. Our Plan includes measures 

for minimizing erosion and enhancing revegetation in upland areas. To further minimize effects on 

vegetation, especially upland forests, KMLP proposed a pipeline route that would be collocated with 

existing rights-of-way to the extent practicable. Approximately 54 percent (73.7 miles) of the combined 

Leg 1, Leg 2, and FGT Lateral rights-of-way would be located adjacent to existing rights-of-way. By 

following existing rights-of-way, KMLP would avoid further segmentation of a relatively unfragmented 

forested area at MP 108.6, limiting the habitat disruption to a widening of the corridor that would need to 

be maintained. KMLP would also avoid impacts to many riparian areas located throughout the Project 

area through the use of HDD. 

Based on the characteristics of the identified vegetation types, the expected impacts to vegetation 

and KMLP’s described construction, restoration, and mitigation measures including the implementation 

of our Plan and Procedures, we believe that construction and operation of the Project would not 

significantly affect vegetation. 

4.5.2.2 Exotic/Invasive Plant Species 

Federal agencies are required to prevent the introduction and spread of invasive species, and to 

minimize the impacts that such species would cause by implementing feasible and prudent measures. 

Invasive species are generally characterized by their hardiness and a relatively increased ability to 

reproduce and spread. Invasive species are also commonly exotic species which are non-native species of 

trees, shrubs, and flowering or non-flowering plants. Within the project area, exotic and invasive plant 

species out-compete native plant species and decrease the amount of available habitat for wildlife that 

depend on native plants for nesting and feeding (GBEP 2006). Exotic and invasive species found in the 

project area include the Chinese tallow tree (Triadica sebifera) and the Chinese privet (Ligustrum sinese). 

The Chinese tallow tree is a small, rapidly growing tree found in every parish in Louisiana. The 

Chinese tallow tree is considered problematic in bottomlands, coastal prairies, and riparian areas. Until 

recently, the Chinese tallow was not considered a threat to upland forests because it grows poorly in the 

shade; however, its appearance in the understory of closed canopy forests and undisturbed sites has raised 
 4-45 Environmental Analysis

concerns about its potential to dominate gaps created by construction activities and operations 

maintenance and to prevent the regeneration of desirable plant species. 

The Chinese privet plant is considered to be one of the worst forest invaders in the Southeast 

because of its ability to dominate the understory, midstory, and edges of forests and to impede 

regeneration of desirable plants, including canopy trees. The Chinese privet grows easily under a variety 

of soil and light conditions, is bothered by relatively few pests, and is difficult to remove once 

established. 

The spread of any invasive species during construction and operation of the Project would 

displace native species and negatively alter the appearance, composition, and habitat value of the affected 

area. 

In order to minimize the spread of exotic and invasive species, KMLP would implement related 

measures in our Plan and Procedures. Specifically, KMLP would monitor the success of revegetation and 

weed control efforts. Additionally, our Plan and Procedures require post-construction monitoring for the 

first and second growing seasons in uplands, and for three years in wetlands, to evaluate the success of 

revegetation. As part of this monitoring program, KMLP would be required to examine the right-of-way 

for the presence of invasive species. In areas not used for agriculture, restoration would be considered 

successful when the density and cover of non-nuisance vegetation is similar to adjacent undisturbed land. 

Similarly, wetland revegetation would be considered successful if the cover and destruction of herbaceous 

and/or woody species is at least 80 percent of the type, density, and distribution of the vegetation in 

adjacent areas that were not disturbed by construction. 

KMLP has also developed an Invasive Species Control Plan as part of their draft Aquatic 

Resources Mitigation Plan (see appendix J) that would help control the spread of the Chinese tallow 

during construction and operation of the Project. In accordance with this plan, field personnel would be 

trained to identify Chinese tallow and would be registered to purchase and use regulated herbicides. 

Additionally, older trees would be controlled by mechanical cutting and chemical treatment while 

saplings would be removed by hand or machine. Each incidence of control activities would be 

documented and reported to the FERC and COE after the completion of the 3-year monitoring period. 

Based on our consultations with federal and state agencies, we believe that the measures outlined 

in KMLP’s Invasive Species Control Plan and those identified in our Plan and Procedures would be 

sufficient to control the spread of invasive species during construction and operation of the Project. 
 4-46 Environmental Analysis

4.6 WILDLIFE AND AQUATIC RESOURCES 

This section describes the existing wildlife, aquatic habitats, and biological communities along 

the Project route with emphasis on wetland habitat, unique or sensitive habitats, and the biological 

communities associated with those habitats. In addition, the discussion includes general and specific 

impacts that would occur during construction and operation, and the measures to avoid and minimize 

those impacts. 

4.6.1 Terrestrial Wildlife Resources 

A variety of habitat types would be crossed by the KMLP Project. These habitat types include 

agricultural lands, forested wetlands, non-forested wetlands, upland forests, rangeland, and developed 

land. Table 4.6.1-1 lists species commonly associated with these habitat types. Descriptions of the 

vegetation found in these habitats are provided in sections 4.4 and 4.5. Federal- and state-listed 

threatened and endangered species are discussed separately in section 4.7. 

4.6.1.1 Affected Environment 

Agricultural lands include actively harvested cropland, idle cropland, and open pasture. Within 

the Project area, the agricultural land is predominantly used for pasture, rice production, and crawfish 

farming (see section 4.8.3.1). Agricultural lands provide cover and foraging opportunities for wildlife 

species within the crops or pastures themselves, or within the small areas of natural vegetation, such as 

vegetation along streams or small forested patches, that sometimes occur within agricultural lands. 

Species found in these areas include those that prefer disturbed habitats and edge habitats between 

forested and open areas. Flooded rice fields and crawfish ponds provide important habitat for shorebirds, 

wading birds, and waterfowl. Wading birds and crustaceans are often found in irrigation ditches, while 

fencerows can serve as breeding areas for some song birds. 

Detailed discussion of wetland habitats potentially impacted by the Project is provided in 

section 4.4. Forested wetlands in the project area include bottomland hardwood forests and cypresstupelo-blackgum swamps which have been generally characterized as highly productive and providing an 

abundance of natural cover for numerous species. Bottomland hardwood forests are found along major 

waterbodies and are dominated by mature trees and shrubs. In general, bottomland forests provide high 

quality habitat, attracting a variety of birds, mammals, reptiles, and amphibians. Throughout their natural 

range, cypress-tupelo-blackgum swamps are forested, alluvial swamps growing on intermittently exposed 

soils. They are found along rivers, streams, and in back swamp depressions and swales. The vegetative 

community has low species diversity, but is generally co-dominated by bald cypress and tupelo gum. The 

undergrowth in these areas is generally sparse due to low light intensity and the long periods of soil 

inundation. 

Non-forested wetlands include estuarine and palustrine wetlands. Estuarine wetlands include salt 

marsh, brackish marsh, intermediate marsh, and freshwater marsh. Changes in salinity can cause the 

wildlife and vegetative species to change as the marsh becomes more saline or fresh. Marshes are 

typically interspersed with small ponds and pools, providing habitats for a diverse assemblage of birds, 

mammals, fishes, and reptiles. These habitats are important breeding and feeding grounds for many 

recreationally and commercially important species such as fish, crustaceans, fur-bearers, and waterfowl. 

The coastal marshes in Louisiana are part of the Mississippi Flyway and provide wintering grounds for 

over 20 species of ducks and geese. 
 4-47 Environmental Analysis

TABLE 4.6.1-1 

Habitats and Typical Non-Fish Wildlife Species Found within the Project Area 

Habitat/Common Name (Scientific Name) Habitat/Common Name (Scientific Name)

Agriculture 

eastern bluebirds (Sialia sialis) 

northern bobwhite (Colinus virginianus) 

rusty blackbird (Euphagus carolinus) 

white-tailed deer (Odocoileus virginianus) 

wood duck (Aix sponsa) 

woodcock (Scolopax minor) 

Forested Wetlands 

black bear (Ursus americanus) 

blue jay (Cyanocitta cristata) 

box turtle (Terrapene sp.) 

Chuck Will’s widow (Caprimulgus carolinensis) 

common raccoon (Procyon spp.) 

coral snake (Micrurus fulvius) 

eastern diamondback (Crotalus adamanteus) 

eastern gray squirrel (Sciurus carolinensis) 

mink (Mustela vison) 

mud turtle (Kinosternon sp.) 

northern cardinal (Cardinalis cardinalis) 

river otter (Lutra canadensis) 

striped skunk (Mephitis mephitis) 

vireos (Vireo spp.) 

western cottonmouth (Agkistrodon piscivorus leucostoma) 

white-tailed deer (Odocoileus virginianus) 

wild turkey (Meleagris gallopavo) 

wood duck (Aix sponsa) 

woodcock (Scolopax minor) 

Non-Forested Wetlands 

alligators (Alligator mississippiensis) 

American bittern (Botaurus lentiginosus) 

American wigeon (Anas Americana) 

beaver (Castor canadensis) 

diamondback water snake (Nerodia rhombifer) 

eastern narrowmoth toad (Gastrophryne carolinensis) 

marsh hawk (Circus cyaneus) 

marsh rice rat (Oryzomys palustris) 

mink (Mustela vison) 

Missouri slider (Pseudemys floridana hoyi) 

muskrat (Ondatra zibethicus) 

nutria (Myocastor coypus) 

red-winged blackbird (Agelaius phoeniceus) 

river otter (Lutra canadensis) 

southeastern myotis (Myotis austroriparius) 

Wilson’s snipe (Gallinago gallinago) 

Woodhouse’s toad (Bufo woodhousii) 

Upland Forests 

bobwhite (Colinus sp.) 

common raccoon (Procyon sp.) 

coyote (Canis latrans) 

flying squirrel (Glaucomys sp.) 

nine-banded armadillo (Dasypus novemcinctus) 

Virginia opossum (Didelphis virginiana) 

white-tailed deer (Odocoileus virginianus) 

wild turkey (Meleagris gallopavo) 

Rangeland 

bobwhite (Colinus sp.) 

common raccoon (Procyon spp.) 

coyote (Canis latrans) 

flying squirrel (Glaucomys sp.) 

nine-banded armadillo (Dasypus novemcinctus) 

Virginia opossum (Didelphis virginiana) 

white-tailed deer (Odocoileus virginianus) 

wild turkey (Meleagris gallopavo) 

Developed Land 

Species that utilize the vegetated areas of developed land 

are likely to include species that inhabit agricultural land, 

rangeland, and forest edge habitat. 

Palustrine wetlands are inland freshwater marshes and swamps. Wildlife generally uses these 

areas for breeding and foraging. These wetlands also serve as habitats for migratory species. Emergent 

wetlands consist primarily of grasses. Scrub-shrub wetlands consist of saplings and low-lying vegetation. 
 4-48 Environmental Analysis

Emergent and scrub-shrub wetlands supply breeding and foraging habitat, along with resting areas for 

migratory species. 

Upland forests consist of deciduous forests, evergreen forests, and forests of mixed evergreen and 

deciduous trees. Upland forests provide both interior and edge habitats that often attract different species 

based on their habitat preferences. Interior forested habitats are secluded, wetter, and more stable 

whereas edge habitats are more volatile, experiencing more dramatic environmental change. They are 

sunnier, drier, and windier, and are more prone to disturbance (LandOwner Resource Center 2005). 

Rangeland ecosystems are dominated by grasses, grass-like plants, forbs, or shrubs and other 

herbaceous species. Rangeland habitats are classified as shrub and brush, herbaceous, or mixed. Shrub 

and brush rangeland are dominated by woody vegetation. Herbaceous rangelands are dominated by 

naturally occurring grasses and or forbs, or are those lands that have been modified to include such 

vegetation as their natural cover. Mixed rangelands are those where more than one-third of the land is a 

mixture of herbaceous and shrub and brush rangeland species (NASA 1996). 

Developed lands are generally a mixture of paved and/or graveled areas, but may contain 

vegetated strata as well. Species utilizing developed land may include species that inhabit other grassy or 

shrub-covered areas although these areas are not expected to be a primary habitat. 

These terrestrial and aquatic habitats support various species of wild game. The American 

alligator, nutria, muskrat, river otter, raccoon, red swamp crawfish, red fox, and gray fox have an 

economic benefit for local trappers. Whitetail deer, fox squirrel, gray squirrel, swamp rabbit, eastern 

cottontail rabbit, waterfowl, northern bobwhite, eastern wild turkey, woodcock, rails, mourning dove, and 

Wilson’s snipe are important recreational species in the area. 

Unique or Sensitive Wildlife Habitats

The SNWR is a 124,511-acre coastal marsh administered by FWS. The primary objective of this 

NWR is to preserve a large area of coastal wetlands for wintering and migratory waterfowl, and it is 

known as an internationally important bird area. The SNWR is also a major nursery area for many 

estuarine-dependant marine species as well as home for alligators and other reptiles, mammals, and 

various species of wading, water, and marsh birds. Recreational activities available within the refuge 

include hunting, fishing, boating, and hiking (FWS no date a). The Project would not cross the SNWR, 

and at the closest point would pass approximately 0.25 miles from it. 

The Lacassine National Wildlife Refuge (LNWR), also administered by the FWS, is nearly 

35,000 acres, most of which is freshwater marsh habitat. The refuge preserves a major wintering site for 

waterfowl and provides habitat for nesting colonies of wading birds, alligators, mink, otter, and raccoon, 

among various other species. Threatened species such as the bald eagle and the Louisiana black bear 

have also been found residing in this refuge. The LNWR supports recreational activities such as hunting, 

fishing, bird-watching, and hiking (FWS no date b). The main unit of the LNWR would be 

approximately 15 miles southeast of the Project. The smaller Vidrine unit is the closest unit and the 

pipeline would be located approximately two miles southwest of this unit. 

The Project would impact two tracts of land included in the CWPPRA program. This program 

was implemented to create, protect, and enhance wetlands in Louisiana. Impacts to these specific tracts 

of land are discussed in section 4.4. 
 4-49 Environmental Analysis

In addition to specific tracts of sensitive land, forests and wetlands in Louisiana provide quality 

habitat for migratory waterfowl and colonial-nesting waterbirds, which are protected by the Migratory 

Bird Act. 

Louisiana, including the Project area, is an important stopover for migratory birds along the 

Mississippi Flyway, which extends from Alaska and central Canada along the Mississippi River drainage 

into central and South America. Forests, including riparian habitat, provide important stopover habitat for 

migratory birds. 

Colonial nesting birds share two general traits; they gather into large assemblages, called 

colonies, during the nesting season, and they obtain all or most of their food from the water. Colonial 

wading birds include the following: herons, egrets, night-herons, ibis, roseate spoonbills, anhingas, and/or 

cormorants. The Natural Heritage Program (NHP) of LDWF database indicates the presence of rookeries 

for the roseate spoonbill, a state-listed species of concern, and other colonial nesters in coastal Louisiana. 

The roseate spoonbill and other federal- and state-listed species are discussed in section 4.7. 

4.6.1.2 Impacts and Mitigation 

Construction Impacts 

Construction of the Project, including the pipeline, aboveground facilities, extra workspaces, 

access roads, and pipe storage and contractor yards would temporarily affect approximately 2,417.9 (total 

construction impacts less the following land types: open water, beaches, and other) acres of upland and 

wetland habitat suitable for wildlife. Of that, 16.5 acres of upland and 2.7 acres of wetland habitats 

within the footprint of aboveground facilities and access roads would be permanently converted to 

industrial areas. Following construction, extra workspaces and non-forested portions of the permanent 

right-of-way would be allowed to revert to pre-construction conditions. Portions of the permanent rightof-way in forested lands would be maintained in an herbaceous state in accordance with our Plan and 

Procedures (and approved alternative measures) to facilitate pipeline maintenance. Approximately 14.9 

acres of forested wetland and 40.6 acres of upland forest located within the permanent right-of-way would 

be converted to an herbaceous state for the life of the Project. 

Impacts to wildlife species and habitats resulting from construction and operation of the Project 

would depend on the vegetation type affected, the mobility and habitat requirements of affected wildlife 

species as well as the amount of adjacent wildlife habitat. Specifically, construction activities including 

increased noise and habitat disruption would impact wildlife by displacing, stressing, injuring or leading 

to the mortality of wildlife. Species typically move away from inhospitable environments, utilizing 

nearby suitable habitats until the disruption has passed. Less mobile species may experience direct 

mortality from habitat clearing and the passing construction spreads if unable to escape the area. 

Disruption of any habitat type could cause alterations in the breeding, feeding, nesting, and rearing 

activities of species that actively use those habitats. Impacts to habitats are often related to the growth 

rates of the vegetation species found there. 

Forested lands would require as much as 30 years or more to recover from clearing and would be 

subjected to more stages of succession, ensuring the slow, but continuous alteration of available habitat 

until the land has been restored to a pre-construction state. Impacts to wildlife from construction and 

operation in large forested tracts would be diverse and long-term or permanent. These impacts would 

include the loss of forest interior habitat, displacement of wildlife, inhibition of the migrations and 

foraging habits of forest interior species, invasion of non-native plant or animal species, and increased 

stress and mortality to local wildlife. 
 4-50 Environmental Analysis

Although the Project would cross through several forested areas, few of these would be 

considered forest interior habitat. The exceptions occur at approximately MP 99.1 and MP 108.6. One 

bottomland forested area located in Jefferson Davis Parish begins at MP 99.1 and ends at MP 99.7. This 

forested habitat includes Bayou Nezpique, and this habitat would be avoided using HDD. Another 

relatively large forested tract begins at approximately MP 108.6 in Acadia Parish, stretching for slightly 

less than a mile. Although this forest is relatively large, the pipeline route follows an existing right-ofway. This limits the habitat disruption to widening of an existing corridor and would not increase 

fragmentation of interior forest habitat. Two additional forested areas of concern are located in 

Evangeline and Acadia Parishes. In Evangeline Parish, the pipeline would enter a large, relatively 

unfragmented forested area, associated with Tiger Point Gulley, crossing for approximately 0.4 miles. 

Although there are nearby rights-of-way transecting this area, the pipeline route would cause further 

fragmentation, decreasing its value as a wildlife habitat. In Acadia Parish, the FGT Lateral would be 

collocated with an existing right-of-way through a large forested area associated with Bayou des Cannes. 

Although collocation is generally acceptable as a way to minimize impacts to an area, this particular area 

provides quality wildlife habitat that would be disrupted by widening the right-of-way through quality 

forest habitat. Therefore, in section 4.3.2.1, we are recommending that KMLP consult with LDWF, FWS, 

and COE regarding the appropriate crossing methods and collocation through the forested areas near MP 

113.1 of Leg 1 and MP 1.4 of the FGT Lateral. 

KMLP has also proposed to use a total of 18 HDDs to cross a variety of habitats consisting 

mainly of waterbodies and wetlands. HDD crossing methods would reduce impacts to these streams as 

well as to the adjacent wetlands, riparian areas, and bottomland hardwood communities. KMLP has 

provided potential opportunities for the mitigation and/or compensation of wetland losses in the draft 

Aquatic Resources Mitigation Plan (appendix J), but is still finalizing the plan in consultation with the 

relevant agencies. Therefore, in section 4.4, we are recommending that prior to construction, KMLP 

develop an Aquatic Resources Mitigation Plan developed in consultation with and approved by the COE, 

NMFS, FWS, LDNR, and LDWF. 

Operation Impacts 

To minimize impacts on wildlife and wildlife habitats, the affected areas would be revegetated 

and maintained according to our Plan and Procedures. Routine maintenance would be periodically 

conducted to maintain the permanent right-of-way in an herbaceous state. Along cropland, pasture, and 

emergent wetlands, no routine maintenance would be necessary. However, in forested areas including 

forested wetlands, routine mowing would be conducted to allow inspection of the pipeline corridor. Our 

Plan does not allow routine vegetative maintenance to occur more frequently than every three years, 

except along a 10-foot-wide corridor centered over the pipeline that can be maintained annually. 

Based on the characteristics of the affected wildlife habitats, the known habitat requirements of 

wildlife identified within proposed project areas, the anticipated impacts to wildlife and their habitats, 

KMLP’s stated construction measures, and its adherence to our Plan and Procedures with modified 

alternative measures; we believe that construction and operation of the project would not significantly 

affect wildlife resources. 

Waterbirds 

The Project route could include suitable habitat for migratory waterfowl and nesting habitat for 

various species of colonial wading birds. Although the closest known wading bird nesting colony is 

approximately 1 mile from the footprint of the Project, the NHP of LDWF cautions that rookeries may 

move from year to year, potentially placing them closer to, or within, the Project right-of-way. 
 4-51 Environmental Analysis

Noise and construction activities occurring in the vicinity of colonial waterbird rookeries have the 

potential to displace birds during active construction. In addition, displacement could result in the birds 

leaving the area. This displacement could disrupt breeding and nesting activities of the waterbirds within 

the Project area. 

KMLP has stated that it would employ a qualified biologist to survey the work area during the 

2007 nesting season, and again immediately prior to construction (in areas where construction occurred 

during the nesting season) to determine the presence of colonial waterbird rookeries. In accordance with 

recommendations given by FWS and the NHP of LDWF, the survey would notate any colony of wading 

birds (herons, egrets, night-herons, ibis, roseate spoonbills, anhinga, and/or cormorants) within 1,000 feet 

of the work area, as well as any colony of nesting gulls, terns, and/or black skimmers within 1,312 feet of 

the work area. KMLP would further consult with FWS and the NHP of LDWF in order to determine 

mitigation measures to minimize potential impacts to these nesting areas, should they be found. 

4.6.2 Freshwater Aquatic Resources 

This section discusses freshwater aquatic resources. Estuarine waterbodies are discussed in 

section 4.6.3. A table identifying all waterbodies crossed by the Project, as well as their width, state 

waterbody classification, crossing location, and crossing method is included as appendix G of this EIS. 

4.6.2.1 Affected Environment 

The Project would cross a total of 298 freshwater waterbodies, each of which supports 

warmwater fisheries. Aside from the potential utilization of the Calcasieu River by some estuarine 

species in seasons of high salinity, the Project would cross only freshwater aquatic habitats after entering 

Calcasieu Parish. Freshwater fishes common within affected waterbodies are listed in table 4.6.2.1-1. 

TABLE 4.6.2.1-1 

Freshwater Aquatic Species Occurring Within Waterbodies Crossed 

by the Proposed KMLP Project 

Common Name Scientific Name 

Fish Gars Lepisosteidae 

Bowfins Amiidae 

Catfishes Ictaluridae 

Eels Anguillidae 

Carps and Minnows Cyprinidae 

Sunfishes, Basses, and Crappies Centrarchidae 

Creek Chubsucker Erimyzon oblongus 

Inland Silverside Menidia beryllina 

Red-eared Sunfish Lepomis microlophus 

Swamp Darter Etheostoma fusiforme 

Mosquitofish Gambusia affinis 

Crustaceans Red Swamp Crawfish Procambarus clarkia 

White River Crawfish Procambarus zonangulus 
 4-52 Environmental Analysis

Fisheries of special concern include areas containing exceptional recreational or commercial 

fisheries, specially designated streams or rivers, and waterbodies supporting rare or endangered aquatic 

species. Potential impacts to threatened and endangered species are discussed in section 4.7. No 

freshwater waterbodies that have been designated as fisheries of special concern would be crossed by the 

Project. However, eight waterbodies - the Black Bayou Cutoff, GIWW, Vinton Drainage Canal, Bayou 

Choupique, Calcasieu River, East Bayou Lacassine, Bayou Nezpique, and Bayou des Cannes - that would 

be crossed by the Project are designated to support fish and wildlife propagation. These waterbodies 

provide aquatic habitat, food, resting and reproductive opportunities, and/or travel corridors to aquatic 

species. 

Commercial and Recreational Fisheries 

Each of the waterbodies identified as supporting fish and wildlife propagation also supports 

recreational and/or commercial fisheries with crappie and catfish being the main catch. The Calcasieu 

River is further designated for oyster propagation. According to the LDWF, due to recent hurricane 

activity no recreational fishery is present in Bayou Lacassine. Although the Calcasieu River and the 

GIWW are considered primarily freshwater waterbodies, they do support a number of commercial 

estuarine species including brown and white shrimp, and recreational fisheries for spotted seatrout, red 

drum, and southern flounder. 

Crawfish are also an important fishery within Louisiana, both recreationally and commercially. 

In the south, the fishery is dominated by just two species, the red swamp crawfish and the white river 

crawfish (LSU Ag Center 2006). Crawfish farming was the most valuable aquaculture crop in Louisiana 

for 2005; however, the wild-caught crawfish are preferred by many consumers due to its larger size. The 

volume of wild crawfish harvest is almost completely constrained by the timing and duration of the 

annual floodwater event in the Atchafalaya Basin (LSU Ag Center 2005). East of the Calcasieu River, 

significant numbers of crawfish farms occur along the route. See section 4.8 for a discussion on land use 

with regard to crawfish farms. 

4.6.2.2 Impacts and Mitigation 

Construction Impacts 

The crossing methods proposed for each waterbody are identified in appendix G of this draft EIS. 

Depending on the construction method used, direct and indirect impacts could occur to the aquatic 

habitats and the species that utilize them. Open-cut and flume crossing methods would directly impact 

crossed waterbodies whereas the use of HDDs or bores would generally avoid impacts. As proposed, 56 

percent of minor and intermediate waterbodies would be crossed by either HDD or bore; the remaining 44 

percent would be crossed by open-cut or flume methods. Each of the 10 major waterbodies would be 

crossed by HDD. 

Of the eight waterbodies supporting commercial and/or recreational fisheries, all but two would 

be crossed by HDD, avoiding impacts to the fisheries. The exceptions, Bayou des Cannes and Bayou 

Lacassine, would be crossed by flume and/or open-cut. Construction through the approximately 108 

crawfish ponds along the route would be accomplished by typical upland construction methods, including 

clearing and trenching. KMLP has stated that it would try to schedule construction through these areas 

during times when the fields and ponds are not normally flooded, or negotiate with the landowners so that 

flooding of the crawfish ponds would be deferred for the season. 

Pipeline construction using open-cut methods would cause an increase in the turbidity and 

sedimentation of a given waterbody. The suspension of sediments decreases the amount of light that 
 4-53 Environmental Analysis

penetrates through the water. With a decrease in light, photosynthetic organisms produce less oxygen, 

thereby decreasing the amount of DO available for uptake by fish and other aquatic species. Additionally, 

organic materials resuspended with the sediment can increase the BOD, further decreasing the available 

DO. During periods of low DO, fewer organisms can be supported in a particular area. Those individuals 

that are not displaced can experience stress, decreased food availability, and mortality. Sedimentation can 

also cause increased mortality to relatively immobile benthic organisms and fish eggs as they are covered 

by the falling sediment. Loss of these organisms can cause a decrease in the prey species available for 

various species of fish and aquatic organisms. 

The flume crossing method would be used for three waterbody crossings; one crossing of East 

Bayou Lacassine (MP 84.9), and two crossings of Bayou des Cannes (MP 124.7 of Leg 1 and MP 1.6 of 

the FGT Lateral). The water in these streams would be routed so that trenching activities would be done 

in relatively dry conditions. This method would reduce the amount of turbidity and sedimentation 

associated with a conventional open-cut crossing. To further reduce the potential for impacts within 

Bayou des Cannes at the FGT Lateral crossing, we include a recommendation in section 4.3.2 that KMLP 

evaluate the feasibility of the FGT Lateral crossing Bayou des Cannes by HDD. 

In both the open-cut and flume methods, removal of vegetation from riparian areas along the 

waterbodies would be necessary, causing an increase in surface runoff and erosion, contributing to the 

impacts mentioned above. Additionally, loss of riparian vegetation would result in a slight increase in 

water temperature from increased exposure to the sun. 

Impacts of erosion would be minimized by use of our Procedures, which require the use of 

temporary and permanent erosion controls such as silt fences and slope breakers. Temporary erosion 

controls would be required immediately after the initial disturbance of the waterbody or adjacent upland 

area has occurred and would remain until either replaced by permanent erosion controls or restoration of 

the adjacent upland has been completed. Additionally, trees and shrubs would be allowed to reestablish 

themselves on the waterbody banks with the exception of a 10-foot-wide corridor that must be maintained 

in an herbaceous state, helping to curb both erosion and temperature elevation. 

Our Procedures also require that minor and intermediate waterbodies generally be crossed in 24 

and 48 hours, respectively, resulting in a limited period of elevated turbidity. The rapid construction 

through these waterbodies, along with the mitigation measures mentioned in our Plan and Procedures, 

would reduce the impacts of turbidity and sedimentation to fish and other aquatic species. Overall 

impacts to freshwater aquatic species would be localized and short-term as only a small area of a crossed 

waterbody would be affected. 

KMLP proposes a total of 18 HDDs for pipeline installation across waterbodies (see table 

4.3.2.1-3). An additional 147 crossings of intermediate and minor waterbodies would be made by 

horizontal bore, which like HDD, typically avoids habitat impacts. While HDD is the preferred crossing 

method for sensitive or important habitats because the method avoids or minimizes impacts to these areas, 

they are not without risk and can affect the habitat by release of drilling fluid or a frac-out. Frac-outs and 

releases of drilling fluid would increase turbidity and sedimentation, contributing to the impacts 

mentioned above. A draft HDD Contingency Plan is provided in appendix I and details the procedures 

KMLP would implement if release of drilling fluid or a frac-out occurred. 

Hydrostatic testing of the pipeline would require the withdrawal of large volumes of water from 

certain waterbodies as listed in table 4.3.2.2-1 to test the structural integrity of the pipeline. Water would 

be withdrawn from eight freshwater waterbodies, three of which support recreational and/or commercial 

fisheries. Significant withdrawals of water from any one waterbody could cause a reduction in flow or an 

overall decrease in volume, disrupting microhabitats as the water level drops below the boundary that is 
 4-54 Environmental Analysis

normally inundated. The intake of water would cause the mortality of non-motile species, or species 

unable to avoid the flow field, as they are impinged upon the screen or entrained through it. Discharge of 

the test water could cause the erosion of stream banks and their vegetation or scouring of the waterbody 

bottom substrate. Erosion and scouring would increase the turbidity and sedimentation at the discharge 

point, causing stress to individuals and decreasing their ability to detect prey and predators. Increased 

turbidity, withdrawal of oxygen-rich waters, and discharge of the organic material created by the 

entrained individuals would decrease the amount of DO remaining in the waterbody. KMLP would 

prevent or limit these impacts from hydrostatic testing by implementing our Procedures which include 

measures that require the screening of intake hoses to prevent the entrainment of larger fish and 

maintaining adequate flow rates for the protection of aquatic life. 

During construction, water pollutants also could be introduced into waterbodies by releases of 

fuel and oil spills from construction equipment, herbicides, and disturbance of contaminated sediments. 

The introduction of pollutants to aquatic species can cause acute or chronic toxicity, mortality, an increase 

in stress, and decreases in reproduction, growth, recruitment, and predator/prey detection abilities. As 

discussed in section 2.3, KMLP would develop and implement a project-specific SWPPP and SPRP that 

describes the containment and cleanup procedures that would be employed in the event of a spill or a leak 

of hazardous materials. To avoid contamination within waterbodies, KMLP has stated that BMPs 

addressing hazardous materials handling and storage, and spill prevention and response, would be 

developed as part of the SWPPP prior to construction. KMLP would also adhere to our Plan and 

Procedures. 

Disturbance and resuspension of contaminated soils and sediments would result in adverse 

impacts to water quality and instream habitat. As indicated in the EPA’s National Sediment Quality 

Survey report of 1997, the lower Calcasieu watershed contained APCs indicating that the areas would 

likely have adverse effects on aquatic and human life (EPA 1997). Later surveys indicated that those 

APCs are no longer present, although some areas still contained contaminated sediments (EPA 2004). 

KMLP has proposed the HDD crossing method for the Calcasieu River, which would avoid contact and 

disturbance of contaminated sediments. HDD frac-outs could impact local species through increased 

turbidity and sedimentation, but that would not cause chemical contamination in the affected waterbody. 

In case unidentified contaminated soils are discovered during construction, we are recommending in 

section 4.2.2.1 that KMLP develop a Plan for the Discovery and Management of Contaminated Soils and 

Groundwater. This plan would minimize the risk of adverse effects to aquatic species through the 

resuspendion of contaminated soils and sediments. 

Operation Impacts 

Impacts to fisheries and aquatic habitats resulting from maintenance of the permanent right-ofway would be relatively minor. Our Procedures require that a riparian strip at least 25 feet wide be 

allowed to revegetate to preconstruction conditions along all waterbodies, with the exception of the 

permanent right-of-way that may be permanently maintained in an herbaceous state to facilitate pipeline 

surveys. Contamination could occur during operations by spills from vehicles used to survey the pipeline 

route or from herbicide use to curb excessive growth along the pipeline right-of-way. 

Our Procedures include measures to avoid using herbicides or pesticides within 100 feet of a 

waterbody (unless authorized by a land manager or state agency). In addition, the SWPPP, SPRP, and 

BMPs to be implemented by KMLP address hazardous materials handling and storage, and spill 

prevention, and response measures. Therefore, we believe that these measures would minimize adverse 

impacts on aquatic resources. 
 4-55 Environmental Analysis

4.6.3 Marine Fishery Resources 

4.6.3.1 Affected Environment 

The Project would cross a total of 12 estuarine waterbodies, each of which contains warmwater 

fisheries. Of the 12 estuarine waterbody crossings, five are major waterbodies and seven are intermediate 

waterbodies. All but two of these waterbodies are perennial. A table identifying all waterbodies crossed 

by the Project, as well as their width, state waterbody classification, crossing location, and crossing 

method is included as appendix G of this draft EIS. Marine species common along the route are listed in 

table 4.6.3.1-1. 

TABLE 4.6.3.1-1 

Marine Species Occurring Within Waterbodies Crossed by the Proposed KMLP Project 

Common Name Scientific Name 

Fish Sand Seatrout Cynocion arenarius 

Threadfin Shad Dorosoma petenense 

Gizzard Shad Dorosoma cepedianum 

Bowfin Amia calva 

Spotted Gar Lepisosteus oculatus 

Southern Flounder Paralichthus lethostigma 

Spanish Mackerel Scomberomorus maculatus 

Black Drum Pogonias cromis 

Red Drum Sciaenops occellatus 

Atlantic Croaker Micropogonias undulates 

Bay Anchovy Anchoa mitchilli 

Spot Leiostomus xanthurus 

Spotted Seatrout Cynoscion nebulosus 

Sheepshead Archosargus probatocephalus 

Gafftopsail Catfish Bagre marinus 

Gulf Menhaden Brevoortia patronus 

Mollusks Atlantic Rangia Rangia cuneata 

Crustaceans Brown Shrimp Penaeus aztecus 

White Shrimp Penaeus setiferus 

Blue Crab Callinectes sapidus 

Fisheries of special concern within the estuarine systems of the Project area include Sabine Lake 

and the Sabine and Calcasieu Rivers, each of which contains EFH for various species of marine fishes. 

The Calcasieu River, although considered freshwater for the purposes of this draft EIS, is part of an 

estuarine system that also contains EFH for various species. Impacts to these waterbodies and the 

managed species that occur within them are discussed in detail in section 4.6.4. Three of the waterbodies 

that would be crossed by the Project are designated to support fish and wildlife propagation, and therefore 

potentially contain spawning locations for commercial and recreational fisheries. Additionally, LDWF 

(2006a) has indicated that adult paddlefish migrate up into Bayou Nezpique to spawn from January 

through April. 
 4-56 Environmental Analysis

The commercial and recreational fisheries found within the estuaries crossed by the Project 

include oysters, shrimp, crab, and various fish. Sabine Lake is the major waterbody that supports these 

fisheries. 

Sabine Lake 

Sabine Lake is designated by the Louisiana Administrative Code (Title 33, Part 6) to support 

oyster propagation. The designation indicates that Sabine Lake supports economically important species 

of clams, oysters, mussels, or other mollusks. Eastern oysters are an important commercial species in 

Louisiana. In 2004, 55 percent of the landings of eastern oyster within the Gulf of Mexico came from 

Louisiana. Oysters require some hard substrate, or cultch, to settle on. They may eventually build large 

reefs, or may occur singly or in clumps on any manmade or natural structures with hard surface. Shell 

reefs also provide a habitat for a variety of species for foraging and cover. Impacts to oyster reefs or 

substrate suitable for settlement could decrease the socioeconomic and ecological value of these areas. 

Sabine Lake is considered to be a public oyster seed ground and public oyster tonging area. 

Activities affecting productive public oyster areas require a CUP that can be obtained by the applicant 

after a water bottom assessment is provided to LDWF and approved. The LDWF requires that impacts to 

the water bottoms of the public oyster areas associated with construction activities be compensated. 

Compensation may be in the form of replacing impacted habitat using oyster cultch material (limestone, 

crushed concrete, oyster shell, etc.) or by making a payment directly to the Public Oyster Seed Ground 

Development Account (LDNR 2006). 

KMLP conducted a bottom survey of Sabine Lake in March and April of 2006 to determine the 

extent of suitable habitat for oysters. The survey was conducted in compliance with guidelines developed 

by LDWF for sampling in oyster seed grounds, seed reservations, and tonging areas in order to 

characterize and quantify the different substrate types and to determine the presence, quantity, condition, 

and demography of oyster reefs within the area of interest. The survey corridor, approximately 3,000 feet 

wide and centered over the pipeline route, was subjected to a side scan sonar with sub-bottom profiling 

and then ground-truthed by manual poling. A ponar dredge was also used to collect samples and identify 

species in the surveyed areas. 

From the results of this survey, the bottom substrate of Sabine Lake was broken into three main 

categories: Types I, II, and III, pertaining to the suitability as oyster substrate, and seven subcategories 

specifying the substrate type (see table 4.6.3.1-2). The assessment identified 522.8 acres of oyster reefs 

and cultch substrate (Types II and III) within the survey corridor. Current conditions within the survey 

TABLE 4.6.3.1-2 

Bottom Substrate Crossed by the KMLP Project within Sabine Lake 

Substrate Acreage within Survey Corridor Percentage of Survey Corridor 

Soft mud with buried shell (Type I) 4,552.2 87.9 

Firm mud (Type II) 187.6 3.6 

Soft mud with exposed scattered shell 

(Type II) 

172.1 3.3 

Moderately firm mud (Type II) 151.8 2.9 

Soft mud (Type I) 105.5 2.0 

Reef (Type III) 5.9 0.1 

Exposed shell (Type III) 5.4 0.1 
 4-57 Environmental Analysis

corridor result in 0.0 marketable sacks per acre of water bottom; however, seed and spat data indicate that 

70.8 marketable sacks of oysters would be available in the future from the reef areas found within the 

survey corridor. 

The mollusks or shells present were generally found within the bottom substrates designated as 

reef and exposed shell (Type III substrates), equating to a total area of 11.3 acres of bottom substrate 

suitable for or containing mollusks. The majority of the oyster resources were found at the southern shore 

of Sabine Lake, which would be avoided by the HDD construction method, although isolated patches 

occurred within the survey corridor out to approximately 3.5 miles from shore, the closest being 

approximately 500 feet away from the proposed pipeline right-of-way. The mollusk species noted most 

often along the corridor was the Atlantic rangia, an estuarine bivalve; only one eastern oyster was found 

during dredge sampling. 

Sabine Lake also supports both recreational and commercial fisheries for shrimp, crab, and 

various fish. The Sabine River and Burton Shell Slip support only recreational fisheries, but the species 

would likely be the same as all three waterbodies are part of the same estuarine system. The LDWF 

marine fisheries manager described the fishery in Sabine Lake as including recreational fishing for 

spotted seatrout, red drum, black drum, and southern flounder (LDWF 2006a). Incidental catch may also 

include croaker and hardhead. The recreational fisheries of the Sabine River and the Burton Shell Slip 

would be expected to include the same species, although fishing effort may be lower, as all three 

waterbodies are part of the same estuarine system. The inshore fishing seasons are typically from midMay to early-July and again from mid-August to December. 

4.6.3.2 Impacts and Mitigation 

Construction Impacts 

The crossing methods proposed for each estuarine waterbody are identified in appendix G of this 

draft EIS. Depending on the construction method used, direct and indirect impacts could occur to the 

aquatic habitats and the species that utilize them. Open-cut methods would directly impact crossed 

waterbodies whereas the use of HDDs would generally avoid impacts. Of the waterbodies supporting 

marine fisheries – Sabine Lake, the Sabine River, and the Burton Shell Slip – the Burton Shell Slip would 

be crossed by HDD, avoiding impacts to the fisheries. The Sabine River would not be crossed by the 

pipeline route, but temporary extra workspaces would protrude into the river at four places with only 

minor, temporary effects. The crossing of Sabine River and Sabine Lake would be accomplished by a 

combination of HDD and open-cut methods, causing direct impacts to the waterbody and the species that 

utilize it. Crossing methods of Sabine Lake and the Sabine River are described in section 2.3. 

General impacts to fishes and crustaceans through open-cut crossing methods and hydrostatic test 

water withdrawal and discharge include waterbody contamination, loss of habitat, and increased turbidity 

and sedimentation. These are described under section 4.6.2.2 on freshwater aquatic resources and are 

identical to impacts in estuarine environments. 

As discussed in section 4.6.3.1, the southern portion of Sabine Lake supports the majority of 

oyster resources found along the pipeline route. Isolated patches of oyster resources also occur within 

1,500 feet of the pipeline route, the closest being less than 500 feet away. As the majority of bottom 

substrate along the pipeline survey corridor is relatively soft bottom with no structure, the loss of any 

oyster resources would impact a variety of estuarine species that use the hard bottom area for foraging 

and cover. KMLP proposes to avoid impacts to the nearshore oyster resources by use of an HDD that 

would exit at MP 4.82 within the open water of Sabine Lake. Open-cut construction through Sabine Lake 
 4-58 Environmental Analysis

would require a 200- to 300-foot-wide construction right-of-way and require excavation of a pipe trench 

as well as a floatation channel for spud barges in waters less then 8 feet deep. These construction 

procedures would place spoil piles within 350 feet of oyster resources, increasing turbidity and 

sedimentation in the area. 

Oyster resources occurring in the project area such as rangia are filter-feeders and require low 

levels of sedimentation and adequate water movement to supply them with food and remove wastes. 

Similar to other mollusks, oysters can tolerate thin layers of sediment or partial burial. Complete burial 

by gradual, natural sedimentation or dredge material disposal would cause mortality (Britton and Morton 

1989).

The proposed construction through Sabine Lake would result in a temporary loss of soft bottom 

habitat due to the placement of the spoil piles, which would temporarily cover the habitat at that location. 

Due to the expanse of soft bottom habitat in Sabine Lake, mobile species utilizing this habitat would be 

expected to be temporarily displaced; however, less mobile species, such as the benthic invertebrates that 

utilize soft bottom habitat, would be smothered and experience mortality through placement of the spoil 

piles. 

KMLP states that it will compensate LDWF for the disturbance of each bottom type within 

Sabine Lake that occurs as a direct result of pipeline construction. The LDWF indicated that 

compensation for impacts to public oyster seed grounds shall be in the form of planting cultch material 

(i.e., crushed concrete, limestone, oyster shell, etc.) at the rate of one cubic yard per acre of impacted area 

for barren, non-supportive areas of the seed grounds, 50 cubic yards for supportive areas, and 187 cubic 

yards for reef areas plus the value of any living oyster resources destroyed (LDWF 2005). KMLP reports 

that there are no active oyster leases along the proposed route. In addition, KMLP conducted an oyster 

survey and the proposed route would largely avoid oyster resources. The primary area along the proposed 

route with marketable oysters was near the HDD exit pit at MP 4.82. KMLP has agreed to compensate 

LDWF for oysters lost due to sedimentation on the reefs within 1,500 feet of this HDD exit pit based on 

existing information or pre- and post-construction surveys. 

Operation Impacts 

The operational impacts for marine fisheries resources would be the same as those discussed 

under freshwater aquatic resources in section 4.6.2.2. 

Thus, there would be no significant impacts to marine fishery resources during construction or 

operation of the Project. 

4.6.4 Essential Fish Habitat 

EFH was defined by the MSA as “those waters and substrate necessary to fish for spawning, 

breeding, feeding, or growth to maturity.” The MSA granted NOAA Fisheries Service legislative 

authority for fisheries regulation in the United States within a jurisdictional area between 3 and 200 miles 

offshore. NOAA Fisheries Service was also granted legislative authority to establish eight regional 

fishery management councils, each responsible for the proper management and harvest of finfish and 

shellfish resources within their respective geographic areas. The statute includes a mandate that federal 

agencies must consult with the Secretary of Commerce on all activities or proposed actions that are 

authorized, funded, or undertaken by the agency that might adversely affect EFH. NOAA Fisheries 

Service recommends consolidated EFH consultations with interagency coordination procedures required 

by other statutes such as NEPA or the ESA (50 CFR 600.920[e][I]) to reduce duplication and improve 

efficiency. The mandatory contents of an EFH Assessment are detailed in 50 CFR 600.920(e)(3). 
 4-59 Environmental Analysis

The estuarine waters within the Project area are within the jurisdiction of the Gulf of Mexico 

Fishery Management Council (GMFMC), which has designated all estuarine habitat as EFH, including: 

emergent and mangrove wetlands; submerged aquatic vegetation (SAV); algal flats; mud, sand, shell, and 

rock substrates; and the water column. The GMFMC manages approximately 450 species within the 

Gulf, grouped into seven Fishery Management Plans (FMPs). Five of these FMPs (including the red 

drum, reef fish, coastal migratory pelagic, shrimp, and stone crab FMPs) have designated all estuarine 

systems on the Gulf coast as EFH. The estuarine systems crossed by the KMLP Project would include 

Sabine Lake and the Sabine and Calcasieu Rivers. 

The EFH within Sabine Lake, Sabine River, and Calcasieu River include emergent wetlands, mud 

bottom substrate, shell reefs, and the water column itself. Estuarine emergent wetlands are among the 

most productive ecosystems on earth (Teal and Teal 1969, Odum et al. 1982). They are integral parts of 

the estuarine system, serving as nursery habitats for the larval stages of many fish and invertebrate 

species. Estuarine wetlands are also important in the removal of contaminants, and a buffer to reduce the 

erosion of inland areas. The mud bottom substrates of these waterbodies provide a habitat for various 

invertebrates, which in turn creates foraging habitat for other invertebrates and fishes. Shell reefs are 

generally composed of an upper zone consisting of live oysters and associated species, over a core of 

buried shell and mud (Bahr and Lancer 1981). This provides a structural complexity to the aquatic habitat 

that is used for feeding, breeding, and growth by a variety of species, managed or otherwise. 

We have incorporated EFH consultations for the KMLP Project with the interagency coordination 

procedures required under NEPA. For purposes of reviewing this Project under NEPA, FERC is the 

lead federal agency. As such, FERC requests that NOAA Fisheries Service consider this document 

as notification of initiation of EFH consultation. An assessment of potential effects of the Project is 

included below.

4.6.4.1 Affected Federally Managed Species 

Of the species with EFH designations in estuarine waterbodies, the brown and white shrimp, red 

drum, Gulf stone crab, and dog and lane snappers have EFH designations within the region of the Project 

(NOAA 2006b). NOAA Fisheries Service also indicated in written correspondence that waters in the 

Project area have been designated as EFH for the late juvenile, subadult, and adult stages of the 

bonnethead shark. Although none of these species is considered to be threatened or endangered, the red 

drum population is classified as overfished, or below the desired threshold, in the Gulf of Mexico. 

Table 4.6.4.1-1 lists the species and life stages within the EFH occurring in the Project area. 

Table 4.6.4.1-2 summarizes seasonal abundance data of each of the managed species that occur in the 

Project area. 

Brown Shrimp 

Brown shrimp are found in a range of habitats from estuaries to offshore depths of approximately 

360 feet. Spawning occurs offshore with the pelagic larvae migrating to the estuaries and becoming 

bottom-oriented (GMFMC 2004). Postlarvae and juveniles are associated with shallow vegetated 

habitats, silty sand, and non-vegetated bottoms. The density of these stages are highest in marsh edge 

habitat and SAV, followed by tidal creeks, inner marsh, shallow open water, and oyster reefs (GMFMC 

2004). Larvae initially consume planktonic algae and zooplankton, but become opportunistic as they age, 

feeding upon detritus, plants, and small fish and invertebrates (Darnell 1958, Perez-Farfante 1969). 
 4-60 Environmental Analysis

TABLE 4.6.4.1-1 

Summary of EFH Categories Potentially Used by Specific Life Stages 

of Federally Managed Species 

EFH Categories 

Species/Life Stage Water Column 

Emergent 

Wetlands 

Mud Bottom 

Substrates Shell Reefs 

Brown Shrimp 

Larvae/Postlarvae X X X X 

Juvenile X X X 

White Shrimp 

Larvae/Postlarvae X X X 

Juvenile X X 

Red Drum 

Larvae/Postlarvae X X X 

Juvenile X X 

Adult X X X X 

Gulf Stone Crab 

Eggs X 

Larvae/Postlarvae X X X 

Juvenile X X X 

Dog Snapper 

Juvenile X 

Lane Snapper 

Larvae 

Juvenile X 

Bonnethead Shark 

Late Juvenile X 

Subadult X 

Adult X 

_______________ 

Source: NOAA 2006b.

White Shrimp 

Similar to the brown shrimp, white shrimp habitats range from estuaries to offshore depths of 

approximately 130 feet. This species is known to spawn offshore and have pelagic larvae that migrate to 

the estuaries and become bottom-oriented. Postlarvae and juveniles generally utilize mud and peat 

bottoms with large amounts of detritus or vegetative cover (GMFMC 2004). Larvae of white shrimp also 

consume planktonic algae and zooplankton, but as juveniles have been reported to feed on sand, detritus, 

mollusk fragments, and small invertebrates (Darnell 1958). 
 4-61 Environmental Analysis

TABLE 4.6.4.1-2 

Relative Abundance of Managed Species within the Project Area 

Relative Abundance 

Species 

Life 

Stagea Low Salinity 

(March-May) 

Increasing 

Salinity 

(June-July) 

High Salinity 

(Aug-Oct) 

Decreasing 

Salinity 

(Nov-Feb) 

Brown Shrimp Adult C C C/R R 

Juvenile A A A C 

White Shrimp Adult C C HA HA 

Juvenile HA HA HA HA 

Red Drum Adult R C/R C/R C/R 

Juvenile C C C C 

Gulf Stone Crab Adult R R R R 

Juvenile R R R R 

Dog Snapper Adult NA NA NA NA 

Juvenile NA NA NA NA 

Lane Snapper Adult NA NA NA NA 

Juvenile NA NA NA NA 

Bonnethead Shark Adult NA NA NA NA 

Juvenile NA NA NA NA 

_______________ 

a Life stages for which EFH is mapped include only adults and juveniles. b EFH habitat for this life stage is noted as reefs and submerged aquatic vegetation not occurring within the Project area. 

C = Common, R = Rare, A=Abundant, HA = Highly Abundant, NA = Not Available 

Source: NOAA 1998.

Red Drum 

Red drum commonly occur in the Gulf of Mexico, from offshore waters to very shallow estuarine 

waters. They occur in virtually all of the Gulf’s estuaries over a variety of substrates including seagrass, 

sand, mud, and oyster reefs. Spawning occurs in the mouths of bays, inlets, and on the Gulf side of the 

barrier islands, after which, larvae are transported into the estuaries. Estuarine wetlands are especially 

important EFH for larvae, juvenile, and subadult stages. Common prey species of red drum include 

several species that are also estuarine dependant such as shrimp, blue crab, striped mullet, and pinfish. 

Larval drum eat small prey species such as mysids and amphipods (GMFMC 2004). 

Gulf Stone Crab 

Adult stone crabs are benthic organisms that can be found on a variety of hard substrates and 

seagrass beds from the shoreline to depths of 200 feet (GMFMC 2004). Although larvae generally utilize 

the pelagic waters of the estuaries, all other life stages utilize sand/shell bottoms, oyster reefs, and/or soft 

bottom habitats (GMFMC 2003). Stone crabs are primarily carnivorous at each life stage, with larvae 

feeding primarily on plankton, juveniles on invertebrates and mollusks, and adults on mollusks, carrion, 

and other stone crabs. The species is basically dependant on the prey produced in the estuaries and 

seagrass beds where freshwater runoff results in higher phytoplankton productivity (GMFMC 2004). 
 4-62 Environmental Analysis

Dog Snapper 

Adult dog snapper may use submerged aquatic vegetation within estuaries as feeding areas, but 

generally occur within the coastal and offshore areas of the Gulf and are most commonly found on coral 

reefs (GMFMC 2004). Early juveniles, however, are found on shallow water seagrass beds of coastal 

waters and estuaries, as well as in estuarine emergent marshes, and may enter rivers (GMFMC 2003, 

GMFMC 2004). The region of the Project contains nursery habitat for early and late stage juveniles, 

which are known to utilize emergent marshes for growth (GMFMC 2003). 

Lane Snapper 

The lane snapper is demersal, occurring over all bottom types although it is most common in 

coral reef and sandy bottom areas. Nursery habitat includes mangrove and grassy estuarine areas in 

southern Texas and Florida as well as shallow areas with sandy and muddy bottoms off each of the Gulf 

states (GMFMC 2004). Early and late juvenile stages utilize sand/shell and soft bottom substrates in 

estuaries for feeding and growth (GMFMC 2003). 

Bonnethead Shark 

The bonnethead shark is the smallest member of the hammerhead family. It inhabits sandy or 

muddy bottoms of shallow coastal waters, feeding primarily on crabs, shrimp, mollusks, and small fishes 

(FWRI no date). This species is relatively resistant to overfishing due to a fast growth-rate, annual 

reproduction, and lack of a commercial fishery (NOAA 2006b). 

4.6.4.2 Impacts and Mitigation 

Sabine Lake, Sabine River, and Calcasieu River support EFH that includes emergent wetlands, 

mud bottom substrates, shell reefs, and water column habitats. The Calcasieu River would be crossed by 

HDD; thus, avoiding impacts to the EFH and the managed species that occur there. The Sabine River 

would not be crossed by the pipeline, but temporary extra workspaces associated with HDD operations 

would protrude into the river at four locations. These temporary extra workspaces would have a minor, 

temporary impact to EFH in the Sabine River. The crossing of Sabine Lake would be accomplished by a 

combination of HDD and open-cut methods, causing direct impacts to the lake and the species that utilize 

it. 

Construction through the first 50 miles of the pipeline route would impact approximately 99.5 

acres of EFH wetlands. Impacted areas are located at the northern and southern ends of Sabine Lake, on 

Shell Island, and along Sabine and Calcasieu Rivers and the GIWW. Disturbance of these habitats would 

temporarily reduce the amount of foraging habitat and cover available to these species. Disturbance of 

these wetlands would also temporarily decrease the habitat available for recruitment, leaving new recruits 

susceptible to increased predation as they search for alternative habitat or remain in open waters. The use 

of tracked vehicles through estuarine wetlands has the potential to permanently impact wetlands 

designated as EFH. In order to avoid permanent impacts, low-ground-pressure equipment or temporary 

board roads would be used. Marsh buggies would be used in saturated EFH wetlands where the use of 

board roads would not be practical (MP 1.5 to MP 3.9 and from MP 32.3 to MP 35.2). 

The proposed construction through Sabine Lake would result in a temporary loss of soft bottom 

habitat due to the placement of the spoil piles, which would cover the habitat at that location. Due to the 

expanse of soft bottom habitat in Sabine Lake, the more mobile managed species utilizing this habitat 

would be expected to be temporarily displaced; however, less mobile stages of managed species that 
 4-63 Environmental Analysis

utilize soft bottom habitat could be smothered and experience mortality through placement of the spoil 

piles. 

The southern portion of Sabine Lake supports the majority of oyster resources found along the 

pipeline route and would be avoided by HDD. Isolated patches of oyster resources also occur within 

1,500 feet of the pipeline route, the closest being less than 500 feet away. As the majority of bottom 

substrate along the pipeline survey corridor is relatively soft bottom with no structure, the loss of any 

oyster resources would impact managed species for which shell reefs are considered EFH. KMLP would 

compensate LDWF for any oyster resources lost during pipeline construction as described in 

section 4.6.3.2. 

Disturbance of the water column would occur in Sabine Lake during trenching activities. The 

managed species are mobile and would likely avoid the area during construction and return shortly after 

the completion of construction. The increased turbidity and sedimentation, disruption of wetlands, 

hydrostatic test water withdrawal, and other impacts from Project construction may displace or cause the 

mortality of prey species of managed species. Some of these species serve as prey for other fish species 

managed by NOAA Fisheries Service and the GMFMC. The wetlands within Sabine Lake also produce 

nutrients and detritus, important components of the aquatic food web, which contribute to the overall 

productivity of the Sabine estuary system as well as of the near-shore environments of the Gulf of 

Mexico. 

KMLP states that it would implement a variety of mitigation measures in addition to following 

our Procedures in order to minimize impacts to aquatic habitats and the species that utilize them. These 

include: 

• Waterbody restoration. KMLP would re-establish original contours and monitor affected 

waterbodies following construction, as well as restore any levees or barriers that were 

removed as part of the construction activities. 

• Erosion and sedimentation control. KMLP would implement BMPs to control erosion and 

sediment as part of a project-specific SWPPP. 

• Riparian restoration. Maintenance of the permanent right-of-way would be limited to a 10-

foot-wide corridor, allowing the stream bank to revegetate to pre-construction conditions. 

• Contamination control. Herbicides would not be used within 100 feet of any waterbody 

without the consent of the land manager or a state agency. 

There would be no need for operation right-of-way clearing within Sabine Lake, Sabine River, 

and Calcasieu River, eliminating impacts to the EFH categories within it. Maintenance-related 

operational impacts to EFH would be limited to a 10-foot-wide right-of-way within estuarine wetlands. 

Trees in excess of 15 feet in height, should they occur within 15 feet of the pipeline right-of-way, may be 

cut and removed. The estuarine wetlands would be subjected to a site-specific monitoring plan based on 

recommendations given by NOAA Fisheries Service. With regard to these recommendations, and as 

stated in the draft Aquatic Resources Mitigation Plan (appendix J), monitoring would be primarily 

photographic in nature and would be taken from the ground at the work sites. These activities would take 

place pre-construction, immediately post-construction, and one growing season post-construction with 

photos of all work sites. The photos would be taken every 500 feet (with pictures taken in both 

directions) with the location recorded on GPS to allow a return to the exact site, and the exact location 
 4-64 Environmental Analysis

and direction of the photo would be recorded in a tabular form and referenced to an aerial photo 

documenting photo numbers. 

4.6.4.3 Conclusions 

We believe that the Project would have minimal impacts on EFH with implementation of our 

Procedures, a finalized Aquatic Resources Mitigation Plan developed in coordination with federal and 

state agencies, and the approved alternative measures to our Procedures (as discussed in this draft EIS). 

These measures would reduce the potential for unanticipated long-term impacts, and the resulting impacts 

of the Project would be insignificant and short term. 
 4-65 Environmental Analysis

4.7 THREATENED AND ENDANGERED SPECIES 

To comply with section 7 of the ESA, Kinder Morgan consulted with the FWS and NOAA 

Fisheries Service regarding the presence of federally listed or proposed threatened or endangered species 

and their critical habitats in the project area. Kinder Morgan, as the FERC’s non-federal representative 

for the purposes of complying with the ESA, has been assisting the FERC in meeting its section 7 

obligations by conducting informal consultation with the FWS and NOAA Fisheries Service. We also 

contacted and consulted with the FWS and NOAA Fisheries Service about which species under their 

respective jurisdictions would be potentially affected by the project. In addition to these consultations, 

Kinder Morgan consulted with the Natural Heritage Program (NHP) of LDWF to obtain a list of statelisted special status species in the project area. 

4.7.1 Federally Listed Threatened and Endangered Species 

The FWS and NOAA Fisheries Service have identified 12 federally listed threatened or 

endangered species in southern Louisiana that should be considered when determining the potential 

effects of the KMLP Project. According to FWS (2006a), the West Indian manatee, piping plover, Gulf 

sturgeon, and the green, leatherback, loggerhead, Kemp’s ridley, and hawksbill sea turtles are not known 

to occur in the Project area and therefore no further consultation with FWS is required for these species 

unless the scope or location of the Project changes. NOAA Fisheries Service concurred that the Gulf 

sturgeon is rarely found as far west as the Project site and stated that neither the Gulf sturgeon nor the 

smalltooth sawfish (due to low area abundance) require further consultation (NOAA 2006c). The West 

Indian manatee, piping plover, Gulf sturgeon, and smalltooth sawfish have thus been eliminated from 

further consideration in this EIS. Although FWS has determined that no further consultation is needed 

regarding four of the five species of sea turtles, NOAA Fisheries Service has joint jurisdiction over the 

five species of sea turtles known to occur in the Gulf of Mexico and has requested that these species be 

assessed with regard to potential impacts from the Project. Each of the eight remaining species are 

discussed below and shown in table 4.7.1-1 with regard to their protected status and our determination of 

impact. 

Sea Turtles 

The only threatened or endangered reptiles known to exist in the Project area are sea turtles. 

NOAA Fisheries Service is generally responsible for marine threatened and endangered sea turtles and 

FWS is responsible for sea turtles that are coming ashore to nest. No critical habitat is designated for the 

green, hawksbill, loggerhead, Kemp’s ridley, or leatherback sea turtles in the Project area. 

Leatherback Sea Turtle 

The leatherback sea turtle is primarily a pelagic species, although it will forage in coastal waters, 

and is distributed in temperate and tropical waters worldwide (NOAA and FWS 1992). It is the largest, 

deepest-diving, and widest-ranging sea turtle; the species has been federally listed as endangered since 

1970 (FWS 2002a). Leatherbacks undergo extensive migrations from feeding grounds to nesting beaches 

(NOAA 2002a). Although southeast Florida only supports minor nesting colonies, the area represents the 

most significant nesting activity within the continental United States (NOAA no date), with the nesting 

period extending from March through July (FWS 2002a). Leatherback sea turtles feed primarily on 

jellyfish, but also on sea urchins, squid, crustaceans, tunicates, fish, blue-green algae, and floating 

seaweed (FWS 2002a). Significant threats to the species include incidental capture in fishing gear and 

harvest of adults and eggs (NOAA no date). 
 4-66 Environmental Analysis

TABLE 4.7.1-1 

Federally Listed Species Potentially Occurring in the KMLP Project Area 

Species 

Federal 

Status 

State 

Status Parish Preferred Habitat Determination 

Reptiles 

Leatherback Sea Turtle 

(Dermochelys coriacea) 

E E Cameron Open sea and coastal waters. 

Prefer sandy beaches with 

deepwater approach for 

nesting. 

Not likely to 

adversely affect 

Loggerhead Sea Turtle 

(Caretta caretta) 

T T Cameron Tropical and temperate 

waters with temperatures 

above 10°C. 

Not likely to 

adversely affect 

Hawksbill Sea Turtle 

(Eretmochelys imbricate) 

E E Cameron Tropical and subtropical seas, 

including southern Florida and 

the northern Gulf of Mexico. 

Coral reefs, rocky outcrops, 

high energy shoals. 

Not likely to 

adversely affect 

Green Sea Turtle 

(Chelonia mydas) 

T/E T Cameron Lagoons, bays, inlets, shoals, 

and estuaries, as well as coral 

reefs, rocky outcrops, and 

high-energy beaches. Found 

throughout the Gulf of Mexico 

and adjoining beaches where 

the seawater temperature is 

above 25°C. 

Not likely to 

adversely affect 

Kemp’s Ridley Sea Turtle 

(Lepidochelys kempii) 

E E Cameron Shallow coastal waters, tidal 

rivers, estuaries, and 

seagrass beds with 

substrates of sand and mud. 

Not likely to 

adversely affect 

Birds 

Brown Pelican 

(Pelecanus occidentalis) 

E E Cameron Shallow coastal waters within 

20 miles or less of the 

shoreline and in depths up to 

80 feet. Breeds on small 

coastal islands and forages 

for fish along coastal and 

inland waterways. 

Not likely to 

adversely affect 

Bald Eagle 

(Haliaeetus 

leucocephalus) 

T E Cameron, 

Calcasieu 

Areas with abundant sources 

of large open waterways such 

as lakes, reservoirs, 

seacoasts, and large rivers. 

In addition to waterways, the 

availability of perches, usually 

tall trees or cliffs, adjacent to 

foraging and nesting areas. 

Occasional transient on rivers 

for foraging or feeding. 

Not likely to 

adversely affect 

Red-cockaded 

Woodpecker 

(Picoides borealis)

E E Calcasieu, 

Evangeline 

Open pine forests with large, 

widely spaces trees. Nests in 

large, old pines (60+ years). 

Forages in pine or pinehardwood stands that are 

greater than 30 years of age. 

Determination 

pending 
 4-67 Environmental Analysis

Loggerhead Sea Turtle 

The loggerhead sea turtle is the most abundant sea turtle in the Gulf of Mexico, although it is still 

federally listed as threatened. Loggerhead turtles are a cosmopolitan species, inhabiting temperate and 

tropical waters in the estuaries and continental shelves of both hemispheres (NOAA 2002b). Within the 

eastern Gulf of Mexico, the species is usually found in water depths of less than 65 feet (Fritts et al. 1983; 

Lohoefener et al. 1990; Hildebrand 1982). 

In the southeastern United States, females nest from late April through early September (NOAA 

and FWS 1991). Nesting occurs primarily on barrier islands adjacent to continental landmasses in warmtemperate and sub-tropical waters. Nest sites are typically located on open sandy beaches, above the 

mean high tide, and seaward of well-developed dunes. In Louisiana, this species has been found 

throughout the coastal region but nesting has only been recorded from the Chandeleur Islands, which is 

over 250 miles east of the potential habitat (Sabine Lake) within the Project area (LDWF 2005). Adults 

occupy a variety of habitats, ranging from turbid bays to clear waters of reefs, whereas subadults occur 

mainly in nearshore and estuarine waters. Hatchlings move directly to sea after hatching, and often float 

in masses of Sargassum. The loggerhead diet consists of a wide variety of benthic and pelagic food items, 

including conches, shellfish, horseshoe crabs, prawns and other crustacean, squid, sponges, jellyfish, 

basket stars, fish, and hatchling loggerheads. The most significant threats to the loggerhead populations 

are coastal development, commercial fisheries (especially shrimping), and pollution. 

Hawksbill Sea Turtle 

The hawksbill sea turtle is primarily coastal and is seldom seen in waters deeper than 65 feet 

(FWS 2002b). It inhabits rocky areas, coral reefs, lagoons, oceanic islands, shallow coastal areas, and 

narrow creeks and passes (FWS 2002b). Hawksbill sea turtles are found in tropical and subtropical 

waters in the Atlantic, Pacific, and Indian Oceans (FWS 2002b) and have been federally listed as 

endangered throughout their range since 1970 (FWS 2002b). The nesting season for this species 

generally occurs between April and November (FWS 2002b). Nesting occurs on undisturbed deep-sand 

beaches which range from high energy beaches to tiny pocket beaches several meters wide bounded by 

crevices of cliff walls. These beaches are normally low-energy, with woody vegetation near the 

waterline. 

Hawksbill turtles are the least common sea turtle in the Gulf of Mexico (MMS 2002), although 

they have been recorded in waters of all the states along the Gulf of Mexico (NOAA and FWS 1991). 

Adults usually forage around coral reefs and other hard bottom habitats (NOAA 2002a), and primarily eat 

sponges (FWS 2002b). This diet and their dependence on hard bottom communities make the species 

especially vulnerable to deteriorating conditions on coral reefs. Due to the lack of suitable foraging 

habitat, there is low probability of this species occurring within the Project area. 

Green Sea Turtle 

The green sea turtle is generally listed as threatened with the exception being the breeding colony 

populations in Florida and on the Pacific Coast of Mexico, which are federally listed as endangered. This 

species nests in tropical and subtropical waters worldwide and inhabits shallow waters (except when 

migrating) inside reefs, bays, and inlets. Within the southeastern U.S., green turtles generally nest 

between June and September (FWS 2002c). Hatchlings eat a variety of plants and animals (FWS 2002c) 

and forage in areas such as coral reefs, emergent rocky bottom, Sargassum mats, lagoons, and bays 

(MMS 2001). The adults feed on seagrass and marine algae, including species of Cymodocea, Thalassia, 

and Zostera (FWS 2002c). Feeding grounds in the Gulf of Mexico include inshore south Texas waters, 

the upper west coast of Florida, and the northwestern coast of the Yucatan Peninsula in Mexico. 
 4-68 Environmental Analysis

Incidental capture in fishing gear and, in some areas of the world, the harvest of eggs and adults affect the 

recovery of the green sea turtle population. Nesting within the Project area is highly unlikely, as green 

sea turtles prefer to nest on high energy beaches with deep sand and little organic content. 

Kemp's Ridley Sea Turtle 

The Kemp’s ridley sea turtle is an endangered species that occurs mainly in the coastal areas of 

the Gulf of Mexico and northwestern Atlantic Ocean. Nesting occurs mainly in Mexico from April to 

June, but Kemp’s ridley turtles also nest in small numbers along the Gulf coast. Juveniles and sub-adults 

occupy shallow, coastal regions and are commonly associated with crab-laden, sandy, or muddy water 

bottoms. Small turtles are generally found in nearshore areas of the Louisiana coast from May through 

October. Adults may be abundant near the mouth of the Mississippi River in the winter. Between the 

east Gulf coast of Texas and the Mississippi River Delta, Kemp’s ridleys can be found in nearshore 

waters, ocean sides of jetties, small boat passageways through jetties, and dredged and nondredged 

channels. They have been observed within both Sabine and Calcasieu Lakes. No sightings have been 

reported in the Project area Major threats to this species include over-exploitation on their nesting 

beaches, drowning in fishing nets, and pollution. (FWS 2006a). 

Sea Turtle Impacts 

Sea turtles are vulnerable to adverse impacts from many of the construction activities that would 

occur in Sabine Lake including: increased noise; pile driving; increased vessel traffic; and habitat 

degradation associated with trenching activities. Potential responses to noises generated during 

construction activities could cause avoidance behavior in sea turtles, as well as disorientation and 

behavioral disturbance. Pile-driving activities often involve loud, repetitive noises that could cause a 

temporary reduction in hearing sensitivity or a temporary threshold shift (TTS) in sea turtles. 

Potential effects on sea turtles from construction of the Project could include avoidance of the 

area due to noise and activity, alteration or loss of habitat, effects on prey species composition and 

abundance, and changes in water quality. Increased traffic and project activities may result in the 

temporary displacement of sea turtles from foraging and resting habitats due to increased water turbidity. 

These impacts are expected to be temporary, localized and minor, and as such adverse impacts on 

foraging and nesting sea turtles is not expected. 

Local noise levels would be increased due to passage and use of construction equipment. Piledriving would be used only to situate the signs marking the spoil piles for boater safety. 

Increased construction traffic in an area increases the likelihood of vessel/sea turtle interaction. 

Sea turtles can experience mortality and injury from collision with vessels. KMLP proposes to excavate 

both a trench through Sabine Lake for the pipeline and, in places where the water is less than eight feet 

deep, an excavation channel for the spud barges. Individuals coming into contact with construction 

equipment may be killed or injured. In a letter dated April 15, 2006, NOAA Fisheries Service provided 

their standard construction guidelines for projects occurring in areas inhabited by sea turtles, entitled “Sea 

Turtle and Smalltooth Sawfish Construction Conditions” and “Vessel Strike Avoidance Measures and 

Injured or Dead Species Reporting.” These measures are provided in appendix K. KMLP has stated that 

it would implement these guidelines during construction of the Project. With the implementation of these 

measures the construction of the Project is not likely to adversely affect sea turtles. 
 4-69 Environmental Analysis

Birds 

Brown Pelican 

The brown pelicans is found along the Atlantic and Gulf of Mexico coasts, inshore to usually no 

more than 20 miles out from shore. They are federally listed as endangered in the U.S. except along the 

Atlantic coast, Alabama, and Florida where they have been delisted due to recovery (FWS 1995). Sand 

spits and offshore sand bars are used extensively as daily loafing and nocturnal roost areas. The preferred 

nesting sites are small coastal islands which provide protection from predators and sufficient elevation to 

prevent flooding of the nests (FWS 1995). In southwestern Louisiana, brown pelicans are currently 

known to nest on Rabbit Island in Calcasieu Lake. Although no brown pelican nesting sites are known to 

occur in the Project area, they may use the area and surrounding habitat for feeding and/or loafing. 

Brown pelicans feed in shallow estuarine waters (e.g., Sabine Lake) using sand spits and offshore sand 

bars as rest and roost areas (FWS 2006a). Brown pelican are asynchronous nesters. The nesting season 

can extend from January through October, although peak egg laying usually occurs in March or April and 

often through June (NPS 2006a). Major threats to this species include chemical pollutants, colony site 

erosion, disease, and human disturbance. There is no critical habitat listed for the brown pelican. 

Brown pelicans are known to use the habitat types that occur within the Project vicinity and could 

use Sabine Lake for feeding and loafing. The known nesting colony on Rabbit Island in Calcasieu Lake 

is approximately 18 miles from the pipeline and would not be disturbed during construction or operation 

of the Project. Although feeding and loafing pelicans may be temporarily displaced by construction 

activities, we have determined that the Project is not likely to adversely affect the brown pelican. 

Bald Eagle 

The bald eagle nests in Louisiana from October through mid-May. Eagles typically nest in bald 

cypress trees near fresh to intermediate marshes or open water in the southeastern parishes. Areas with 

high numbers of nests include the Lake Verret Basin south to Houma, the southern marsh/ridge complex 

from Houma to Bayou Vista, the north shore of Lake Pontchartrain, and the Lake Salvador area. Eagles 

also winter and infrequently nest near large lakes in central, southwestern, and northern Louisiana (FWS 

2006a). The population of bald eagles began declining prior to 1940 due to a decline in prey species, loss 

of habitat, direct killing, and later, from DDT use, but has recovered to the point that it is being proposed 

for delisting (FWS no date c). Currently the population is considered threatened throughout the 

continental U.S. and Alaska. No critical habitat has been designated for the bald eagle. 

Breeding bald eagles occupy “territories” that they will typically defend against intrusion by other 

eagles, and that they are likely to return to each year. A territory may include one or more alternate nests 

that are built and maintained by the eagles, but may not be used for nesting in a given year. Potential nest 

trees within a nesting territory may, therefore, provide important alternative bald eagle nest sites. In 

forested areas, bald eagles often select the tallest trees with limbs strong enough to support a nest that 

may weigh more than 1,000 pounds. Nest sites typically include at least one perch with a clear view of 

the water or area where the eagles usually forage. Shoreline trees or snags located near large waterbodies 

provide the visibility and accessibility needed to locate aquatic prey (FWS 2006a). 

Bald eagles are most vulnerable to disturbance during courtship, nest building, egg laying, 

incubation, and brooding (roughly the first 12 weeks of the nesting cycle). Disturbance during this 

critical period may lead to nest abandonment, cracked and chilled eggs, and exposure of small young to 

the elements. Human activity near a nest late in the nesting cycle may also cause flightless birds to jump 

from the nest tree, thus reducing their chance of survival (FWS 2006a). Although the general area of high 

nest occurrence would not be impacted by the Project, the pipeline route would cross numerous 
 4-70 Environmental Analysis

freshwater and intermediate marshes and open water areas along the first portion of Leg 1. Bald eagles 

nesting in these areas could be disturbed by passage of the construction spreads. 

KMLP did not identify any bald eagle nests during field surveys conducted along the pipeline 

route. Should a bald eagle nest be encountered during construction and the construction workspace 

encroach within 1,500 feet of the nest, KMLP states that the Lafayette, Louisiana FWS office would be 

consulted to establish measures to mitigate potential impacts during the nesting season. During operation 

of the Project, KMLP has stated that no right-of-way maintenance would occur within 1,500 feet of a 

known bald eagle nests during the nesting season. Due to the absence of nests along the route, the 

consultation proposed for nests seen at a later date, and the elimination of right-of-way maintenance 

within 1,500 feet of known nests, we have determined that the construction and operation of the Project is 

not likely to adversely affect bald eagles.

Red-cockaded Woodpecker 

The red-cockaded woodpecker (RCW) is federally listed as endangered. Historically, its range 

occurred from east Texas and Oklahoma to Florida, and north to New Jersey and Maryland. The 

populations have since been extirpated from Missouri, Maryland, Tennessee, Kentucky, and New Jersey, 

with the remaining populations fragmented (FWS 1983). The preferred habitat consists of longleaf pine 

although other species of southern pine are also used. The RCW excavates cavities in large (i.e., 10 

inches or greater in diameter at breast height) living pines that are often suffering from red heart disease 

that causes the inner wood to become soft (FWS 2006a; FWS 1983). Nesting occurs in mature (greater 

than 60 years old) pine trees containing little hardwood understory or midstory (FWS 2006a); RCWs are 

intolerant of dense hardwood midstories resulting from fire suppression. The cavity trees and the 

foraging area within 200 feet of those trees are known as a cluster. Foraging habitat is defined as pine 

and pine-hardwood stands (i.e., 50 percent or more of the dominant trees are pines) over 30 years of age 

that are located contiguous to and within one-half mile of the cluster (FWS 2006a). The decline of the 

RCW is attributed primarily to the reduction of pine forest and to the encroachment of hardwood midstory 

due to fire suppression (FWS 1983). There is no critical habitat designated for this species. 

KMLP has stated that if suitable habitat exists along the remaining portion of the pipeline route, 

all suitable nesting habitat within a 0.5-mile radius of the Project boundary would be surveyed by a 

qualified biologist for the presence of RCW clusters in accordance with the RCW recovery plan (FWS 

2003) survey protocol, as requested by FWS (2006b). FWS has also requested that KMLP provide a 

determination of the age of pine stands along the pipeline route to determine if they are greater than 30 

years of age. KMLP has been unable to obtain access from some landowners to complete surveys of all 

potentially suitable habitat areas for RCW. Landowners have the right to deny access to their property. 

However, if KMLP is issued a Certificate by the Commission, KMLP would have the authority to access 

the portions of the property within 0.5 mile of the project boundaries to complete any required surveys 

including RCW surveys. 

At this time, FWS has not received a RCW survey report from KMLP confirming the locations 

and/or results of surveys or habitat assessments. For this reason, we do not have adequate information to 

allow for a complete review of potential Project impacts on this species. Therefore, we recommend that: 

• KMLP consult with the FWS to determine the need for and methodology of additional 

surveys for red cockaded woodpecker (RCW) along the pipeline route or provide 

concurrence from the FWS that the project is not likely to adversely affect the RCW. 

The results of consultation with the FWS, any additional survey reports, and FWS 

comments on the survey should be filed with the Secretary as soon as they become 
 4-71 Environmental Analysis

available before the close of the comment period for this draft EIS. Survey reports 

should include the following information: 

a. name(s) and qualifications of the person(s) conducting the survey; 

b. method(s) used to conduct the survey; 

c. date(s) of the survey 

d. area surveyed (include the mileposts surveyed); and 

e. proposed mitigation that would substantially minimize or avoid the potential impacts. 

4.7.2 State-Sensitive Species 

The NHP of LDWF has identified the following 10 state species of concern that may occur in the 

Project area. 

Birds 

Roseate Spoonbill 

The roseate spoonbill is considered rare in the state of Louisiana and is a species of special 

concern. It is found throughout the entire Gulf of Mexico coastline, south to Central America, South 

America, and the West Indies. From March through October, roseate spoonbills prefer the bays, marshes, 

and estuaries along the Gulf Coast, with the mating season beginning in March and ending in June. Nests 

are built in thick vegetation above water, and are well-built and deeply cupped. In winter, most roseate 

spoonbills migrate to Central and South America. (NPS 2006b) 

The roseate spoonbill is a colonial wading bird and could experience nesting site disturbance by 

passage of the construction spreads. Although there are no known nesting sites in the project area, KMLP 

has stated that it would employ a qualified biologist to survey the proposed work area during the 2007 

nesting season and immediately prior to construction scheduled during the nesting season to determine the 

presence of colonial waterbird rookeries. In accordance with recommendations given by FWS and the 

NHP of LDWF, the survey would notate any colony of wading birds, including the roseate spoonbill, 

within 1,000 feet of the work area. KMLP has stated that it would further consult with FWS and NHP of 

LDWF in order to determine mitigation measures to minimize potential impacts to these nesting areas, 

should they be found. Operational impacts to the roseate spoonbill would be limited to temporary 

displacement during maintenance of the permanent right-of-way. 

Crested Caracara 

The crested caracara is considered critically imperiled in Louisiana and is limited to the 

southwestern corner of the state. It is a vulture-sized bird that spends much of its time on the ground 

hunting snakes, rodents, and other available prey. Preferred habitat for this species includes mixed 

coastal prairie and marshes that have been recognized as ecologically significant and in need of 

conservation efforts, as well as open country habitat such as pasturelands, cultivated land, and semidesert. Nesting occurs from late-December to early-April and the nests are typically located in trees, rock 

ledges, or on the ground in secluded areas. The species is non-migrating and the nests will often be 

reused from year to year. One of the main causes of decline is the loss of habitat due to development and 

agriculture, as well as illegal shooting and trapping (LDWF 2006b, c). The NHP of LDWF has 

recommended that KMLP use BMPs to minimize impacts to the coastal prairie and marsh habitats 

preferred by the crested caracara. While KMLP has not developed any project-specific BMPs for this 
 4-72 Environmental Analysis

purpose, it would implement our Plan and Procedures with accepted variances to minimize impacts to the 

general habitats used by the crested caracara. These measures include the minimization of 

erosion/sedimentation and impacts to wetlands as well as the restoration of uplands and wetlands. We 

also recommend that KMLP further consult with the NHP of LDWF to determine if any additional BMPs 

are needed for the protection of the crested caracara. Operational impacts to the crested caracara would 

be limited to temporary displacement during maintenance of the permanent right-of-way. 

Crustaceans 

Old Prairie Crawfish 

The old prairie crawfish is considered very rare globally and is imperiled in Louisiana due to its 

restricted range. It has been noted in the Project vicinity, occurring in roadside ditches flooded by heavy 

rains or in complex burrows carved into the sandy-clay soils of roadside ditches, with a home range that 

does not exceed 82 feet. It is non-migratory and males are reproductively active during January, July, and 

August. Little else is known about the life history of this species. Threats to the old prairie crawfish 

include residential, commercial, and petroleum development. (LDWF 2006a, b) 

Maintenance of the permanent right-of-way would not be required in the roadside ditches that the 

old prairie crawfish would utilize; therefore, no impacts would be expected to occur to this species during 

operational maintenance. However, roadside ditches, the preferred habitat for the old prairie crawfish, 

would be crossed numerous times during construction of the Project and could cause direct mortality of 

any individuals that are residing in that particular ditch. LDWF has recommended that habitat for this 

species be protected (LDWF 2006b, c). KMLP has not proposed any measures for the protection of the 

old prairie crawfish. Therefore, we recommend that: 

• KMLP consult with the NHP of LDWF and develop mitigation measures to protect the 

old prairie crawfish during construction through roadside ditches. KMLP should file 

with the Secretary copies of its consultation prior to construction.

Plants 

Several of Louisiana’s critically imperiled plant species and communities occur in the Project 

area. These include the saltflat-grass, wild coco, Oklahoma grass-pink, low nutrush, short-beaked 

baldsedge, Lindheimer’s bee-balm, and remnants of coastal prairie. Coastal prairies are considered 

critically imperiled in the state of Louisiana and imperiled globally. This prairie region of southwestern 

Louisiana was once very extensive (about 2.5 million acres) but today is limited to small remnant parcels. 

On the southern edge of its range, the community may occur on “islands” or “ridges” surrounded by 

marsh (LDWF 2006b). None of these critically imperiled species, however, are located within 0.5 miles 

of the Project. The nearest coastal prairie remnant community is located 0.6 miles away from the Project. 

4.7.3 Conclusions and Recommendations 

A variety of measures have been proposed by KMLP that would limit impacts on federal- and 

state-listed species, including implementation of our Plan and Procedures. These measures would reduce 

the loss of vegetated habitats, minimize impacts to water quality, and result in restoration of areas 

temporarily disturbed during construction. Additionally, KMLP has committed to implementing 

measures to avoid and minimize potential impacts to federally listed species as identified in NOAA 

Fisheries Service’ “Sea Turtle and Smalltooth Sawfish Construction Conditions” and “Vessel Strike 

Avoidance Measures and Injured or Dead Species Reporting.” Based on the information provided to 
 4-73 Environmental Analysis

date, we believe that except for RCW for which a determination is pending, the Project is not likely to 

adversely affect any federally listed threatened or endangered species. 

We have not completed consultation with FWS and NOAA Fisheries Service. Therefore, we 

recommend that: 

• KMLP not begin construction activities until: 

a. The FERC completes any necessary consultations with the FSW and NOAA Fisheries 

Service; and 

b. KMLP receives written notification from the Director of OEP that construction and/or 

implementation of conservation measures may begin. 
 4-74 Environmental Analysis

4.8 LAND USE, RECREATION, AND VISUAL RESOURCES 

In this section, we further identify and characterize the land requirements for construction and 

operation of the Project, describe the current land use or cover type of those lands (including special 

status lands), discuss how land needed for the Project would be acquired, evaluate visual resource 

impacts, and discuss the relevance of the Project to the Louisiana coastal zone management process. A 

detailed description of the pipeline facilities is provided in section 2.1.1 and facility maps are provided in 

appendix B. 

4.8.1 Land Use 

Table 4.8.1-1 summarizes the current land uses of the acreage that would be affected by 

construction and operation of the Project. Construction of the Project would affect a total of 3,030.7 

acres, including 2,274.1 acres for construction rights-of-way, 291.5 acres for extra workspaces, 12.3 acres 

for aboveground facilities, 74.2 acres for access roads, and 378.7 acres for pipe storage and contractor 

yards. Of the 3,030.7 acres, about 821.7 acres would be maintained as permanent right-of-way and 19.2 

acres permanently used for aboveground facilities and access roads. Of the acreage affected by 

construction, 1,472.1 acres (48.6 percent) would be agricultural land and 569.1 acres (18.8 percent) would 

be open water. The remaining land uses would include beaches, forest, developed land, open land, and 

other (including strip mines, quarries, and gravel pits) and would comprise approximately 989.5 acres 

(32.6 percent). 

Following construction, all temporary workspaces would be allowed to revert to preconstruction 

condition. During operation, KMLP would maintain a 50-foot-wide permanent right-of-way, except 

where Leg 1 and Leg 2 are collocated it would maintain a 100-foot wide right-of-way. The permanent 

right-of-way and other facilities would encompass 427.0 acres of agricultural land (50.8 percent) and 

107.0 acres of open water (12.7 percent), with the remaining 36.5 percent being composed of primarily 

forest, developed land, or open land. 

KMLP has proposed a 125-foot-wide construction right-of way for Leg 1 when in upland terrain 

and for wetland crossings greater than 100 feet long. Further, as discussed in section 2.2.1, when working 

in saturated wetland crossings less than 100 feet long, rights-of-way would be 100-feet wide. In areas 

where Legs 1 and 2 are within 50 feet of each other, KMLP proposes a total combined right-of-way width 

of 155 feet. In addition, KMLP has proposed a 300-foot right-of-way when constructing in the open 

water of Sabine Lake with depths less than 8 feet. That right-of-way width would be reduced to 200-feet 

when water depths exceed 8 feet. Following construction, KMLP would generally maintain a 50-footwide permanent right-of-way centered over the pipeline. 

Approximately 73.7 miles (54 percent) of the Project would parallel existing rights-of-way 

(table 4.8.1-2). To ensure safe distances are maintained between construction activity and in-service 

utilities and to avoid potentially negative impacts on adjacent pipelines, construction right-of-way overlap 

with existing rights-of-way would be limited to approximately 15 feet. 

4.8.1.1 Temporary Extra Workspaces 

As detailed in section 2.1.3, KMLP would use temporary extra workspaces at road crossings, 

railroad crossings, crossings of existing pipelines and utilities, wetland and waterbody crossings, and 

other areas where specialized construction techniques would be used. Approximately 291.5 acres would 

be affected by the use of temporary extra workspaces; 50.1 percent would be agricultural, 20.5 percent 

would be open water, and 22.5 percent would be open land. See appendix C for more details. Following 
 4-75 

TABLE 4.8.1-1 

Land Use Affected by Construction and Operation of the KMLP Project 

Agricultural 

(Acres) 

Open Water 

(Acres) 

Forest 

(Acres) 

Developed 

Land 

(Acres) 

Open Land 

(Acres) 

Beaches 

(Acres) 

Oth

(Acr

 C O C O C O C O C O C O C 

Leg 1Pipeline ROW 1,030.2 413.7 509.1 106.9 128.5 53.1 44.9 18.1 524.4 213.7 0.2 0.1 2.0 Workspaces 144.6 0.0 59.8 0.0 9.9 0.0 9.5 0.0 61.3 0.0 0.0 0.0 0.0 Aboveground Facilitiesa 7.5 7.5 0.0 0.0 0.0 0.0 0.0 0.0 1.9 1.9 0.0 0.0 0.0 Access Roads 0.1 0.1 0.0 0.0 0.6 0.0 70.9 6.4 1.0 0.0 0.0 0.0 0.0 P & C Yards 277.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 101.4 0.0 0.0 0.0 0.0 Leg 2Pipeline ROW 0.0 0.0 0.0 0.0 0.9 0.2 0.9 0.2 5.2 1.1 0.0 0.0 0.0 Workspaces 0.0 0.0 0.0 0.0 0.1 0.0 0.8 0.0 1.9 0.0 0.0 0.0 0.0 Aboveground Facilitiesa 0.0 0.0 0.0 0.0 0.0 0.0 1.7 1.7 0.8 0.8 0.0 0.0 0.0 FGT LateralPipeline ROW 10.9 5.4 0.2 0.1 10.6 5.4 0.3 0.1 5.9 2.9 0.0 0.0 0.0 Workspaces 1.3 0.0 0.0 0.0 0.0 0.0 0.1 0.0 2.3 0.0 0.0 0.0 0.0 Aboveground Facilitiesa 0.3 0.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Access Roads 0.0 0.0 0.0 0.0 0.0 0.0 1.1 0.0 0.5 0.5 0.0 0.0 0.0 

Total 1,472.1 427.0 569.1 107.0 150.6 b 58.7c 130.2 26.6 706.6 221.0 0.2 0.1 2.0 

_______________ a Represents areas affected outside of construction or permanent rights-of-way. b This number includes 0.9 acres of Forested Wetland that KMLP reported as existing within the Sabine Pass LNG Terminal, but has since been cleared. c This number includes 0.2 acres of Forested Wetland that KMLP reported as existing within the Sabine Pass LNG Terminal, but has since been cleared. 

Notes: Due to rounding totals may not add up.  Agricultural includes cropland and pastureland. 

Open Water includes estuaries and bays, lakes, streams, and canals. 

Forest includes deciduous forest, evergreen forest, forested wetland, and mixed forestland. Developed Land includes industrial, residential, and transportation/communication/utility right-of-way. Transportation/communication/utility right-of-way may include m

Open Land includes rangeland, sandy (not beach) areas, transitional areas, and non-forested wetland. Other includes strip mines, quarries, and gravel pits. 

 C= Construction; O = Operation; Pipeline ROW = Pipeline Rights-of-Way; Workspaces = Temporary Extra Workspaces; Facilities = Aboveground Facilities; P & C Yar
 4-76 Environmental Analysis

TABLE 4.8.1-2 

Existing Rights-of-Way Paralleled by the KMLP Projecta

MP 

Begin 

MP 

End 

Approximate 

Length 

(Miles) Existing Parallel Facility 

Approximate 

Acreage 

Leg 1 and 2 

0.8 1.9 1.1 NGPL Pipelineb 2.0 

16.9 17.9 1.0 Foreign Pipeline 1.8 

22.6 22.8 0.2 36” Colonial Pipeline 0.4 

22.8 23.3 0.5 16” & 18” Sabine Pipeline 0.9 

23.3 23.7 0.5 36” Colonial Pipeline 0.8 

23.7 24.6 0.8 16” & 18” Sabine Pipeline 1.5 

24.6 25.5 0.9 16” & 18” Sabine Pipeline 1.7 

25.5 26.1 0.6 36” Colonial Pipeline 1.2 

26.1 26.4 0.2 16” & 18” Sabine Pipeline 0.4 

26.4 26.6 0.2 Shell Pipeline 0.3 

26.6 30.1 3.5 Enterprise Sabine Pipeline 6.4 

30.1 30.5 0.4 Strategic Pipeline 0.8 

31.3 40.2 8.8 Enterprise Pipeline 16.1 

44.3 45.3 1.0 4” Conoco Pipeline 1.7 

56.1 59.8 3.6 30” Trunkline Pipeline 6.6 

60.9 62.5 1.6 Gulf South Pipeline 2.9 

66.2 72.5 6.3 16” Dynegy Pipeline 11.5 

72.5 74.9 2.3 16” Texaco Petro-Chemical Pipeline 4.2 

74.9 76.3 1.4 16” Texaco Petro-Chemical Pipeline 2.6 

76.90 88.7 11.8 16” Texaco Petro-Chemical Pipeline 21.4 

89.0 89.7 0.6 16” Texaco Petro-Chemical Pipeline 1.2 

101.5 108.5 7.0 EHP Egan Pipeline 12.7 

108.5 111.3 2.8 26” ANR Pipeline 5.1 

112.0 112.4 0.5 30” ANR Pipeline 0.9 

118.3 122.0 3.7 Targa Pipeline 6.7 

122.0 131.9 9.9 30” Transco Pipeline 17.9 

FGT Lateral 

0.0 0.1 0.1 26" ANR 0.1 

0.1 2.3 2.2 24" FGT 4.1 

 Total 73.7 133.9 

_______________ 

a Construction right-of-way overlap with existing rights-of-way would be limited to approximately 15 feet. b Represents the only existing right-of-way along that portion of the project where Legs 1 and 2 would parallel one another. 
 4-77 Environmental Analysis

construction, all temporary extra workspaces would be allowed to revert to their preconstruction use and 

cover type. 

4.8.1.2 Aboveground Facilities 

KMLP would construct 14 aboveground facilities. Each of these facilities is an interconnect with 

an existing interstate or intrastate pipeline that would contain a mainline valve and a block valve. 

Typically, these facilities would be fenced and range in size from 0.3 to 1 acre (table 4.8.1.2-1). The total 

land requirements for the aboveground facilities would be 12.3 acres during construction and operation, 

the majority of which (63.4 percent) would be agricultural lands. All 12.3 acres would be permanently 

converted to commercial/industrial land use. 

TABLE 4.8.1.2-1 

Acres of Land Affected by Construction and Operation of the Aboveground Facilities 

Pipeline Facility MP 

Land Disturbed 

During Construction 

(acres) 

Land Required 

for Operation 

(acres) 

Leg 1 

Southwest Loop Interconnect Site 28.2 0.92 0.92 

Sabine Interconnect Site 61.4 0.92 0.92 

TGTPL Interconnect Site 87.5 0.97 0.97 

Trunkline Interconnect Site 91.5 0.94 0.94 

TGT Interconnect Site 110.0 0.92 0.92 

ANR #1 Interconnect Site 111.3 1.04 1.04 

ANR #2 Interconnect Site 112.0 1.02 1.02 

TET Interconnect Site 117.0 0.92 0.92 

Transco Interconnect Site 122.1 0.80 0.80 

CGT Interconnect Site 132.2 0.92 0.92 

Leg 2

NGPL Interconnect Site 1.2 0.84 0.84 

Bridgeline Interconnect Site N/Aa 0.86 0.86 

Southwest Loop Johnson’s Bayou Delivery Point N/Aa 0.86 0.86 

FGT Lateral 

FGT Interconnect Site 2.30 0.34 0.34 

Total 12.3 12.3 

_______________ 

a

 Located in Johnsons Bayou near the end of the existing UTOS system. 

4.8.1.3 Access Roads 

Appendix C lists the access roads, their location, modifications required, surface area potentially 

affected, and current land use of that area. Where feasible, KMLP would use existing public roadways, 

existing private roadways, and/or the pipeline right-of-way to gain access during construction and 

operation of the Project. KMLP has proposed the temporary use of 69 existing access roads of varying 

lengths. KMLP stated that 53 of the existing access roads, comprising a length of approximately 26.1 

miles, would require modifications to support construction-related traffic and equipment. Modifications 
 4-78 Environmental Analysis

may include grading and/or placement of additional gravel on the existing surface. Where possible, board 

matting would be used instead of constructing new roads. However, 6 new roads totaling 0.7 miles would 

be constructed. In total, the construction access roads would disturb a total of 74.2 acres. Following 

construction, 5 roads encompassing 6.9 acres would be maintained as permanent access roads. The 

remaining access roads would revert to their preconstruction uses. 

4.8.1.4 Pipe Storage and Contractor Yards 

KMLP has proposed the use of 12 pipe storage and contractor yards, encompassing 378.7 acres, 

during construction. Approximately 73.2 percent of this land would be agricultural and 26.8 percent 

would be open land. The general locations of these facilities are depicted in appendices B and C. All 

yards would be leased. Depending upon the condition of these yards and their current use, some surface 

grading, drainage improvements, placement of surface materials, and internal roadways may be required. 

Upon completion of construction activities, the pipe storage and contractor yards would be returned to 

their preconstruction condition or as specified by landowner agreement. 

4.8.2 Acquisition of Land through Easements and Eminent Domain 

KMLP would obtain easements from landowners to construct and operate the pipeline and 

associated facilities. The easements would give the company the right to construct, operate, and maintain 

the pipeline and establish a permanent right-of-way. In return, the company would compensate the 

landowner for use of the land. Easement agreements between the company and the landowner typically 

specify compensation for loss of use during construction, loss of non-renewable or other resources, and 

allowable uses and restrictions on the permanent right-of-way after construction. These terms can include 

restrictions on the construction of aboveground structures, including house additions, garages, patios, 

pools, or any other object not easily removable from the right-of-way, or the planting and cultivating of 

trees and orchards. 

KMLP could be granted the right of eminent domain (section 7(h) of the NGA and the procedures 

set forth under the Federal Rules of Civic Procedure [Rule 71A]) if easement agreements cannot be 

negotiated. Under these conditions, the landowner could receive compensation, but the compensation 

would be determined by the courts. 

4.8.3 Land Use Impacts and Mitigation 

4.8.3.1 Agricultural Areas 

The 1,472.1 acres of agricultural land affected by the Project would primarily include 

pastureland, land used for rice production, and areas used for crawfish production. The primary impact in 

these areas would be short-term loss of production due to construction-related activities. About 7.9 acres 

of agricultural land occupied by the aboveground facilities would be permanently converted to developed 

land. Agricultural land within the pipeline right-of-way would be allowed to revert to pre-construction 

conditions following construction. 

In accordance with our Plan, KMLP would implement special construction procedures in 

agricultural areas to minimize potential impacts. Topsoil would be removed and stockpiled separately 

from excavated subsoils and the natural flow patterns of all fields would be maintained by providing 

breaks in topsoil and subsoil stockpiles. KMLP would also work with landowners prior to construction to 

identify irrigation lines and drainage improvements in order to minimize construction-related impacts. In 

addition, crop yields would be monitored following construction to ensure that yields in areas affected by 

construction were similar to that in adjacent, undisturbed areas, as described in section 2.3. Finally, the 
 4-79 Environmental Analysis

owners of agricultural land would be compensated for the loss of agricultural production in accordance 

with the terms of landowner agreements. Therefore, we believe that impacts to agricultural land would be 

short term and offset by compensation agreed to during easement negotiations. 

4.8.3.2 Open Water 

Approximately 569.1 acres of open waters would be included in the construction right-of-way. 

The majority of that acreage would be in Sabine Lake (approximately 408.6 acres). Impacts to southern 

and northern shores of Sabine Lake would be avoided by use of HDD. Construction within the openwater portion of Sabine Lake would be conducted using shallow draft barges as described in 

section 2.3.1.3. This technique would require excavation of channels between existing navigation 

channels and the right-of-way and a channel along the right-of-way itself. To allow sufficient space for 

the storage of excavated spoil from the channels and pipe trenches, KMLP has requested a construction 

right-of-way width of 300 feet in water depths less than 8 feet and 200 feet in water depths greater than 

8 feet. 

To mitigate potential navigation impacts in Sabine Lake, KMLP has indicated that they would 

provide project-specific details to the U.S. Coast Guard such as the timing of and areas in which waterbased construction would occur, as well as the types of vessels that would be utilized. In addition, spaces 

would be left between spoil piles and KMLP would install timber piles with navigational lights and 

warning signals to allow shallow draft vessels to pass over the open trench. KMLP would comply with 

all navigation rules and regulations in the Project vicinity. Following construction, acreage within both 

the construction and permanent right-of-way would revert to their previous use. 

As discussed in section 4.6.3, Sabine Lake is a public oyster seed ground and public oyster 

tonging area in Louisiana. As such, KMLP has agreed to compensate LDWF for any construction-related 

impacts to oysters or shellfish in Sabine Lake. 

Therefore, we believe that impacts related to the temporary utilization of open water for 

construction would be minor and short term. 

4.8.3.3 Forest 

The 150.6 acres of forest that would be affected by the Project include deciduous forest, 

evergreen forest, mixed forest, and forested wetland. There are no pine plantations or other silviculture 

crops within the 150.6 acres. As detailed in section 4.5.2, impacts to forested land would be minor but 

would persist for the life of the Project. A total of 58.7 acres of currently forested land would be 

converted to maintained pipeline right-of-way. 

4.8.3.4 Developed Land 

About 130.2 acres of developed land would be crossed by the Project, consisting of congested 

pipeline corridors, transportation corridors, a marina on the east bank of the Calcasieu River, and the 

southern edge of the Trunkline LNG facility. Standard upland construction methods would be used in 

most of these areas and measures included in our Plan would be incorporated to minimize impacts to such 

developed lands. From MP 51.8 to MP 52.4 (see table 4.3.2.1-3), KMLP proposes to HDD under the 

marina on the east bank of the Calcasieu River. However KMLP has not provided its site-specific 

construction plans. We are recommending in section 4.3.2.3 that KMLP file site-specific construction 

plans for this area.
 4-80 Environmental Analysis

4.8.3.5 Open Land, Beaches, and Other 

The Project would affect 706.0 acres of open land, 0.2 acres of beaches, and 2.0 acres of other 

land uses within the construction right-of-way and temporary extra workspaces. In general, standard 

overland construction techniques would be used for installation of the pipeline and KMLP would use 

measures included in our Plan and Procedures to minimize impacts. Following construction, all open 

land, beach, and other acreage outside the permanent right-of-way would be allowed to revert to its 

preconstruction land use. The remaining 221.8 acres within the permanent right-of-way, primarily 

comprised of open land (221.0 acres), would be maintained as necessary for operation. With the use of 

our Plan and Procedures, impact to these areas would be minimal. 

4.8.3.6 Residences and Planned Residential Developments 

During pre-filing, a planned development called the South Forty Acre Subdivision was identified 

at approximately MP 114.0 of the Leg 1 route originally considered. As a result, KMLP modified the 

route to avoid this area as is further discussed in section 3.4.11 of this draft EIS). The currently proposed 

route would not impact any planned developments. 

KMLP identified 14 structures within 50 feet of the construction right-of-way (table 4.8.3.6-1). 

None of these structures were identified as residences. However, 9 of the 14 structures have been 

generically identified as buildings. Therefore, we recommend that: 

• KMLP revise table 4.8.3.6-1 and explicitly identify all structures and residences within 

50 feet of the construction work areas. KMLP should file the revised table with the 

Secretary prior to the close of the comment period on the draft EIS. 

To minimize potential disruptions to residential areas near construction work areas, KMLP would 

attempt to coordinate construction work schedules with affected landowners prior to starting construction. 

To further minimize impacts to residential areas within the vicinity of construction work areas, KMLP 

would implement the following measures on an as-needed basis: 

• notify land owners of the need to remove fences and gates; 

• install temporary safety fencing to control access and minimize the hazards associated with 

an open trench; 

• notify affected landowners in advance of any scheduled disruption of household utilities and 

limit the duration of any interruption to the smallest time possible; 

• repair any damages to residential property that result from construction activities or provide 

compensation at fair market value; and 

• restore all areas disturbed by construction work areas to “as before or better” conditions. 

As described in section 2.5, KMLP would be responsible for monitoring and ensuring compliance 

with all environmental mitigation measures required by the FERC Certificate. In fulfilling this 

responsibility, KMLP would be required to develop and implement an environmental complaint 

resolution procedure to provide landowners with clear and simple directions for identifying and resolving 

their environmental mitigation problems/concerns during construction of the Project and restoration of the 

right-of-way. In addition, in section 4.12 we are recommending that KMLP develop a noise mitigation 

and compliance plan for HDD in residential areas. 
 4-81 Environmental Analysis

TABLE 4.8.3.6-1 

Structures Within 50 Feet of the Construction Work Areas 

Structure MP Parish 

Distance from 

Pipeline 

Centerline 

(feet) 

Distance from 

the Construction 

Work Area 

(feet) 

Building 38.3 Calcasieu 40 75 

Barn 46.0 Calcasieu 25 100 

Building 48.3 Calcasieu 0 100 

Barn 48.4 Calcasieu 10 80 

Building 51.1 Calcasieu 5 75 

Building 51.1 Calcasieu 25 100 

Building 52.2 Calcasieu 25 100 

Building 52.2 Calcasieu 50 115 

Cattle Loading Pena 71.1 Calcasieu 0 20 

Building 87.7 Jefferson Davis 10 85 

Sheda 91.4 Jefferson Davis 0 5 

Shed 121.6 Evangeline 50 125 

Building 123.1 Evangeline 40 150 

Building 123.2 Evangeline 25 175 

_______________ 

a These structures, located entirely or partially within the construction workspace, would either be relocated or the landowner would

 be compensated accordingly. 

With the implementation of above measures, impact to residential areas would be minimal and 

these impacts would generally be limited to the construction period. 

4.8.3.7 Recreation and Special Use Areas 

Recreation and special use areas in the vicinity of the Project are defined to include inshore open 

waters with recreational uses; National Wildlife Refuges; scenic byways; Wetland and Hydrologic 

Restoration Projects; Conservation Reserve and Wetland Reserve Program lands; FWS Conservation 

Easements; national or state scenic rivers; levee crossings; and hazardous waste sites. For a detailed 

discussion of the Black Bayou Hydrologic Restoration Project, the Perry Ridge Shore Protection Project, 

Conservation Reserve Program Lands, and FWS Conservation Easements, see section 4.4. 

Inshore Open Waters 

Inshore waters of Louisiana, including Sabine Lake, provide recreational boating and fishing 

opportunities as well as means of transit to areas where these activities are pursued. Section 4.8.3.2 above 

summarizes the proposed construction methods in Sabine Lake along with the precautions that would be 

taken to avoid impacts to navigation. 

Assuming the construction spread occupies all of the approximate 13 miles of the pipeline route 

through Sabine Lake, at the maximum construction right-of-way width (300 feet), the decrease in the 

surface area of Sabine Lake available to recreational boaters would be less than 1 percent. This decrease 

in availability would be temporary, lasting only as long as the construction activities across Sabine Lake. 
 4-82 Environmental Analysis

Based on these factors, impacts to recreation on inshore waters are considered to be minor and 

short term. 

National Wildlife Refuges 

Sabine National Wildlife Refuge 

The SNWR occupies approximately 125,000 acres of marshes between Calcasieu and Sabine 

Lakes in southwest Louisiana. According to the FWS, the refuge provides habitat for migratory 

waterfowl and other birds, and was designated an “Internationally Important Bird Area” due to the 

abundant year-round populations of wading, water, and marsh birds. There are also large concentrations 

of alligators, muskrats, nutria, raptors, blue crabs, and shrimp. Approximately 280,000 people visit the 

area each year for a variety of recreational and educational activities such as hiking, fishing, boating, 

camping, and hunting (FWS no date a). 

The pipeline route does not cross the SNWR; at its closest points, between MP 15.0 and 17.0, the 

SNWR would be approximately 0.25 miles from the pipeline. During construction, noise associated with 

the installation of the pipeline may disturb wildlife; however, noise-related impacts would be short term 

and minor. Given the distance between the SNWR and the Project, construction and operation of the 

Project would not impact the SNWR. 

Lacassine National Wildlife Refuge 

The Lacassine National Wildlife Refuge (LNWR) encompasses about 35,000 acres, mostly 

freshwater marsh habitat that functions as a wintering site for waterfowl. Nesting colonies of wading 

birds, alligators, and furbearers such as mink, otter, and raccoon are found on the refuge. Threatened and 

endangered species that have used the refuge include bald eagles, peregrine falcons, and Louisiana black 

bears. The refuge is also used for recreational purposes, hunting and fishing being two of the most 

popular recreational activities (FWS no date b). 

The Project pipeline would not cross the Lacassine NWR. At its closest point, the pipeline would 

be approximately 2 miles southeast of the Vidrine Unit and more than 15 miles northwest of the main 

unit. Given this distance, construction and operation of the Project would not affect either unit of the 

LNWR. 

Scenic Byways 

The 180-mile Creole Nature Trail National Scenic Byway takes visitors through three different 

wildlife refuges and a bird sanctuary and offers drivers and their passengers a view of Louisiana's 

environment and wildlife. The roads that comprise the trail, SHs 82, 27, and 14, cut through the 

marshlands of southern Calcasieu and Cameron Parishes and then hug the coast of the Gulf of Mexico 

(MilebyMile 2006). 

The Project would cross the Creole Nature Trail National Scenic Byway at three locations: SH 82 

at MP 1.5; SH 27 at MP 47.8; and SH 14 at MP 64.7. The Project would cross these roadways using 

HDD or conventional boring construction methods, which would not require road closures or open cutting 

of the roadways. Impacts would be limited to potential short-term traffic disruptions associated with the 

construction equipment and alterations to the viewshed. Because KMLP would be required to maintain 

safe and accessible conditions at road crossings in accordance with our Plan, traffic disruptions would be 

minimal. See section 4.8.4 for a discussion of the minor visual impacts to the Byway. 
 4-83 Environmental Analysis

4.8.3.8 Wetland Restoration and Mitigation Projects 

Section 4.4 discusses the potential impacts to the Black Bayou Hydrologic Restoration Project 

and the Perry Ridge Shore Protection Project located in the Project vicinity. Section 4.4 also discusses 

the potential impacts to CRP lands. 

There would be no impacts to WRP lands because there are no such lands located in parishes that 

would be crossed by the Project. 

The FWS works with private landowners that voluntarily restore wetlands or other valuable 

wildlife habitats on their property by providing financial assistance from the federal government (FWS 

2006b). If such properties are along the route, KMLP would need to obtain a Compatible-Use 

Determination and ascertain the need for any Special Use Permit in association with the crossing of the 

conservation easement. Based on the most recent database currently available, which has not been 

updated since 1996, FWS indicates that there are no conservation easements in the project area (FWS 

2007). However, given the lack of updated information, FWS states that KMLP should conduct further 

consultation to determine if the Project could affect any conservation easements. Therefore, we 

recommend that: 

• KMLP consult with the FWS to determine if FWS conservation easement properties are 

crossed by the Project. KMLP should file with the Secretary documentation of its 

consultation with FWS, including any recommended mitigation measures, for review 

and written approval by the Director of OEP prior to construction. 

4.8.3.9 Natural and Scenic Rivers 

The Louisiana Natural and Scenic Rivers System was establish to preserve, protect, develop, 

retain, and enhance the wilderness qualities, scenic beauty, and ecological regime of certain streams or 

segments thereof. The program was also intended to preserve aesthetic, scenic, recreational, ecological, 

and other natural and physical features and resources found along these streams or segments thereof 

(LDWF 2006a). The Project would not cross any Natural or Scenic River. 

4.8.3.10 Hazardous Waste Sites 

During the pre-filing process, KMLP identified a Class C landfill approximately 990 feet north of 

the originally considered route. Subsequently, KMLP rerouted the pipeline route to avoid this facility 

(this route variation is discussed further in section 3.4.4 of this draft EIS). KMLP has reviewed both 

LDEQ and EPA websites to identify any known hazardous waste sites within 0.25 miles of the Project 

right-of-way. None have been identified. No sites were identified during environmental surveys of the 

Project route. 

In the unexpected event that construction of the Project encroaches on a contaminated area, 

KMLP would stop work, notify the appropriate state and federal agencies, and proceed in accordance 

with local, state, and federal regulations. As discussed in section 4.2.2.1, we are recommending that that 

KMLP develop a Plan for the Discovery and Management of Contaminated Soil and Groundwater. 

Development and implementation of this plan would ensure that any previously existing contamination 

that may be encountered during construction would be managed in accordance with applicable regulatory 

requirements. 
 4-84 Environmental Analysis

4.8.4 Visual Resources 

Visual resources refer to the composite of basic terrain, geologic features, hydrologic features, 

vegetative patterns, and anthropogenic features that influence the visual appeal an area may have for 

residents or visitors. The Project could alter existing visual resources in three ways: (1) construction 

activity and equipment may temporarily alter viewscapes; (2) construction and right-of-way maintenance 

would alter existing vegetation patterns; and (3) aboveground facilities would represent permanent 

alterations to the viewscape. The significance of these visual impacts would be primarily dependent upon 

the quality of the current viewshed, the degree of alteration of that view, the number of potential viewers, 

and the perspective of the viewer. 

Most of the Project would extend through open water and primarily rural areas that consist of 

agricultural lands and open lands with scattered residences. There are several existing pipelines in the 

vicinity of the Project, and the KMLP pipeline would parallel some of these existing rights-of-way. 

Many areas along the Project are either inaccessible or do not provide long-range unobstructed views, but 

public viewpoints are present along some of the roadways in the area. 

4.8.4.1 Pipeline Facilities 

Construction and operation of the pipeline may affect visual resources by altering the terrain and 

vegetation patterns during construction or right-of-way maintenance. The landscape setting along the 

pipeline route is generally flat, and views of the construction activities may extend for some distance. 

However, the construction work areas would be restored as near as possible to preconstruction contours 

and revegetated. Once revegetation is complete, there would be no significant alteration of the landscape 

of the region. 

As discussed in section 4.8.3.7, the pipeline would cross the Creole Nature Trail National Scenic 

Byway at three locations: SH 82 at MP 1.5; SH 27 at MP 47.8; and SH 14 at MP 64.7. While there are 

no federal or state regulations that protect the viewshed of the byway, it is an area that offers viewing 

opportunities for visitors and residents. KMLP would cross the Byway using HDD or conventional 

boring construction methods. Visual impacts would generally be temporary and minor, similar to those 

described above. 

4.8.4.2 Aboveground Facilities 

Aboveground facilities would be located within or immediately adjacent to the pipeline right-ofway. Most would either be constructed in areas whose existing viewsheds contain similar features, within 

existing utility rights-of-way or industrial facilities, or in areas where views would be screened by 

existing vegetation and/or topography. When not screened from view, aboveground facilities would 

appear as a small fenced area within a cleared right-of-way corridor or open field. The Transco 

Interconnect (MP 122.1) would be located near residences and would likely have a direct view of the site. 

Therefore, we recommend that: 

• KMLP develop a site-screening plan for the Transco Interconnect site (MP 122.1) and 

file that plan with the Secretary for review and written approval by the Director of OEP 

prior to construction. 
 4-85 Environmental Analysis

4.8.5 Coastal Zone Management 

The CZMA provides states the authority to review any project within that state’s coastal zone if it 

has a federally approved CZM program. Projects that require federal licenses or permits must draft a 

“consistency certification” to assure the project meets the state’s CZM program standards. 

Portions of the Project (MPs 0.0 to 23.1) fall within Louisiana’s coastal zone, which is managed 

by the Coastal Management Division (CMD) of the LDNR. KMLP has consulted with the CMD and will 

prepare and submit a Coastal-Use Permit application to the CMD as part of the Joint Permit Application 

with the COE. Upon receipt and review of that document, LDNR will determine if the Project is 

consistent with Louisiana’s coastal zone management program. A determination from the LDNR that the 

Project is consistent with the laws and rules of the CZM program must be received before we issue a 

notice to proceed. Therefore, we recommend that: 

• KMLP not begin construction on any facilities associated with the Project until it files 

with the Secretary a copy of the CZM Program consistency determination issued by the 

LDNR. 
 4-86 Environmental Analysis

4.9 SOCIOECONOMIC RESOURCES 

4.9.1 Region of Influence 

The Project would traverse five parishes in Louisiana (Cameron, Calcasieu, Jefferson Davis, 

Acadia, and Evangeline). For the purposes of our socioeconomic analysis, we define these parishes as the 

Project’s region of influence. Although an extra workspace has also been identified in Orange County, 

Texas (see section 2.2), this county was not included in the region of influence because quantifiable 

socioeconomic impacts would not be expected to result from the 50-foot by 4,200-foot floating prefabrication site alongside Goat Island in this area (approximately MP 17.9 to 18.6). 

4.9.2 Population 

Table 4.9.2-1 reports populations and selected demographic characteristics for Louisiana and the 

five Parishes that would be traversed. Based on census data for the year 2000 

(U.S. Census Bureau 2005a), the total population in these parishes is 321,341. Population levels were 

relatively stable between 2000 and 2005 with no parish having more than a 5 percent change in 

population over the five-year period. 

TABLE 4.9.2-1 

Population Conditions in the Vicinity of the Proposed Project 

Population Population Density 

State/Parish 2000 2005 Percent Change 2000 2005 

Louisiana 4,468,976 4,523,628 1.2% 102.6 103.8 

 Cameron Parish 9,991 9,558 -4.3% 7.6 7.3 

 Calcasieu Parish 183,577 185,419 1.0% 171.4 173.1 

 Jefferson Davis Parish 31,435 31,272 -0.5% 48.2 48.0 

 Acadia Parish 28,861 59,552 1.2% 89.8 90.9 

 Evangeline Parish 35,434 35,540 0.3% 53.3 53.5 

_______________ 

Based on 601 relocating (231 non-local workers and 2.6 peps per HH) 

0.21% pop change over project vicinity 

Population densities in the region of influence range from a low of 7.3 persons per square mile in 

Cameron Parish to a high of 173.1 persons per square mile in Calcasieu Parish. These densities are 

relatively low compared to urban area densities that typically range from 3,000 to 6,000 persons per 

square mile (FERC 2003) but are consistent with an area that is predominately rural and agricultural. 

Potential impacts to local populations from the Project would result from the influx of non-local 

workers for construction (temporary) and operation (permanent). As outlined in section 2.4. KMLP 

would make an effort to hire local workers where practical. This would mitigate any potential affects on 

population levels and or demographics. 

Construction of the Project would occur between November 2007 and November 2008 (see table 

4.9.2-2). The peak construction workforce is projected to be 385 workers. KMLP anticipates 
 4-87 Environmental Analysis

TABLE 4.9.2-2 

Estimated Workforce in the Vicinity of the Proposed Project

Project Component Parish 

Approximate Construction 

Dates 

Estimated

Workforce

Leg 1 Pipeline See comment below Nov 2007 Nov 2008 250 

Leg 2 Pipeline Cameron Nov 2007 April 2008 19 

FGT Lateral Acadia Sept 2008 Oct 2008 32 

Southwest Loop Delivery Point Calcasieu March 2008 April 2008 18 

Sabine Interconnect Site Calcasieu May 2008 June 2008 18 

TGTPL Interconnect Site Jefferson Davis July 2008 Aug 2008 18 

TLG Interconnect Site Jefferson Davis Sept 2008 Oct 2008 18 

TGT Interconnect Site Acadia Aug 2008 Sept 2008 18 

FGT Interconnect Site Acadia Oct 2008 Nov 2008 18 

ANR Interconnect Site Acadia April 2008 May 2008 18 

TET Interconnect Site Evangeline June 2008 July 2008 18 

Transco Interconnect Site Evangeline Aug 2008 Sept 2008 18 

CGT Interconnect Site Evangeline Oct 2008 Nov 2008 18 

NGPL Interconnect Site Cameron Nov 2007 Dec 2007 18 

Bridgeline Interconnect Site Cameron Jan 2008 Feb 2008 18 

Southwest Loop Johnsons Bayou Delivery Point Cameron Jan 2008 Feb 2008 12 

_______________ 

Leg 1, a 42-inch-diameter pipeline, would run 132 miles traversing five parishes in Louisiana (Cameron, Calcasieu, 

Jefferson Davis, Acadia, and Evangeline). 

that about 60 percent (231 employees at the peak) of the construction workforce would be made up of 

non-local workers who would temporarily locate to the Project vicinity. Although the construction phase 

is relatively short, some families may accompany non-local workers. Based on the peak non-local 

workforce of 231 persons and applying the U.S. Census Bureau’s 2000 statistic of 2.6 persons per 

household in Louisiana, as many as 601 people might temporarily relocate to the Project vicinity. If all 

workers were to reside in one parish at one time, moderate (up to 6 percent) population increases would 

occur. However, it is very unlikely that this would occur as KMLP has indicated that construction of the 

pipeline would entail the simultaneous activity of several individual construction spreads that would be 

distributed across the Project route. As such, workers would likely be distributed throughout the Project 

vicinity, resulting in negligible population and demographic alterations. 

During operation, KMLP estimates that the Project would employ approximately four full-time 

equivalent workers. This would represent a negligible, long-term change in population. 

4.9.3 Employment and Economy 

The civilian labor force within the Project vicinity includes about 137,485 individuals. The major 

employment sector in four of the five Parishes is education, health and social services. The exception is 

in Cameron Parish where the major employment sectors are agriculture, forestry, fishing and hunting, and 

mining. On average, the parishes within the Project vicinity report slightly lower unemployment and per 

capita income than the state-level values reported for Louisiana (table 4.9.3-1). 
 4-88 Environmental Analysis

TABLE 4.9.3-1 

Employment Conditions in the Vicinity of the Proposed Project 

State/Parish 

Per Capita 

Income 

1999

Civilian Labor 

Force 

2000

Unemployment 

Rate (percent) 

2000

Top Employment 

Industry 

2000

Louisiana $16,912 1,997,995 7.3 

Educational, health, 

and social services 

 Cameron Parish $15,348 4,384 4.6 

Agriculture, forestry, 

fishing and hunting, 

and mining 

 Calcasieu Parish $17,710 85,325 6.9 

Educational, health, 

and social services 

 Jefferson Davis Parish $13,398 12,597 7.9 

Educational, health, 

and social services 

 Acadia Parish $13,424 23,158 7.1 

Educational, health, 

and social services 

 Evangeline Parish $11,432 12,021 7.3 

Educational, health, 

and social services 

The actual workforce and proportion of local workers would depend on the capabilities of the 

contractor, available workforce, and maximized efficiencies. KMLP anticipates a total of 529 

employment opportunities would be necessary to construct the pipeline and that the peak construction 

workforce at any given point in time would be 385 employees. As indicated in section 4.9.2, KMLP 

expects that 40 percent of the construction workforce would be hired from the local workforce (i.e., 

existing residents of the region of influence), and 60 percent would come from outside the region of 

influence. Additional jobs could also be created as a result of secondary activity associated with 

construction of the Project, as purchases made by non-local workers on food, clothing, lodging, gasoline, 

and entertainment will have a temporary, stimulatory effect on the local economy. These jobs would 

represent a temporary, moderate increase in employment opportunities in the region of influence. 

During operation, four full-time equivalent positions would be created. Two of these positions 

would be stationed out the Sabine Pass LNG Terminal in Cameron Parish with the remaining serving as 

pipeline operators. These jobs would represent a negligible, permanent increase in the number of 

employment opportunities within the Project vicinity. 

4.9.4 Housing 

Tables 4.9.4-1 and 4.9.4-2 report selected housing statistics for Louisiana and the five parishes 

traversed by the pipeline. Table 4.9.4-1 reports total housing units, both occupied and unoccupied, 

median monthly rent rates and the rental vacancy rates. Table 4.9.4-2 provides further analysis of those 

units that are classified as unoccupied, or vacant, in 2000. 

There are approximately 7,479 vacant rental units and units used for seasonal, recreational, or 

occasional use. Additional hotel or motel rooms supplement this potential housing stock. Four of the five 

parishes in the Project vicinity have rental vacancy rates that exceeded Louisiana’s rental vacancy rate of 

9.3 percent in 2000. Median monthly rent is typically lower than the state average. In 2000 the number 

of unoccupied units ranged from a low of 1,522 in Evangeline Parish to a high of 7,382 in Calcasieu 

Parish. 
 4-89 Environmental Analysis

TABLE 4.9.4-1 

General Housing Conditions in the Vicinity of the Proposed Project 

State/Parish 

Total 

Housing 

Units 

Total 

Occupied 

Units 

Total 

Occupied 

Rental 

Units 

Total 

Unoccupied 

Units 

Median 

Monthly 

Rent 

Rental 

Vacancy 

Rate 

(percent) 

Louisiana 1,847,181 1,656,053 530,918 191,128 $466 9.3 

 Cameron Parish 5,336 3,592 536 1,744 $412 18.4 

 Calcasieu Parish 75,995 68,613 19,507 7,382 $465 14.1 

 Jefferson Davis Parish 12,842 11,480 2,883 1,344 $353 9.9 

 Acadia Parish 23,209 21,142 5,882 2,067 $332 9.9 

 Evangeline Parish 14,258 12,736 3,902 1,522 $289 6.4 

TABLE 4.9.4-2 

Unoccupied Housing Characteristics in the Vicinity of the Proposed Project 

State/Parish 

Vacant 

Rental 

Units 

Units

for 

Sale 

Units 

Rented 

or Sold, 

Not 

Occupied 

Vacant for 

Seasonal, 

Recreational,

or 

Occasional 

Use 

Vacant 

for 

Migrant 

Workers 

Other 

Vacant 

Total 

Unoccupied

Units 

Louisiana 54,485 18,097 18,144 39,578 525 60,599 

 Cameron Parish 121 52 57 1,331 0 183 1,744 

 Calcasieu Parish 3,191 849 607 684 27 2,024 7,382 

Jefferson Davis 

Parish 317 210 189 223 8 397 1,344 

 Acadia Parish 648 177 142 243 12 845 2,067 

 Evangeline Parish 267 149 83 472 3 548 1,522 

 Total 4,544 1,437 1,078 2,953 50 3,997 14,059 

At its peak, construction of the Project would require about 231 non-local workers, as described 

in section 4.9.2. If each worker required his or her own housing unit, the non-local work force would 

occupy about 16.4 percent of the temporary housing within the region of influence. Thus, the temporary 

housing available within the region of influence would be capable of meeting this temporary and 

moderate increased demand for housing resulting from construction of the Project. 

Housing demand for the four, permanent positions generated by operation of the Project would 

represent a permanent but negligible increase in housing demand. 
 4-90 Environmental Analysis

4.9.5 Infrastructure and Public Services 

Educational, medical, police, and fire protection employees in the counties and parishes traversed 

by the Project serve a population of approximately 320,000 people. 

Construction of the Project could temporarily increase demand for medical, police, and fire 

protection associated with permit issuance, traffic control, and potential response to accidents during 

construction. KMLP would work with local law enforcement and emergency response agencies to 

coordinate effective emergency response for the Project during construction and operation (see section 

4.13.1). 

We note that construction would occur during the school year. However, due to the nature of the 

construction and its relatively short duration (about a year), non-local workers are not expected to be 

accompanied by substantial numbers of children. 

Thus, any impact the provision of public services would be minor and temporary. The potential 

costs associated with this potential increase in demand would be offset by the Project-related increase in 

government revenues. 

During operation, workers filling the four full time positions and their associated family members 

would represent a minor, permanent increase in the demand for the provision of public services. 

However, this increased demand would be offset by the Project-related increase in government revenues 

associated with operation. 

4.9.6 Transportation and Traffic 

4.9.6.1 Land Transportation 

Potential short-term impacts to existing infrastructure would result from traffic delays due to 

deployment of equipment and construction personnel, and road crossings. The Project would primarily be 

accessed by SH 82, Route 27 and Interstate 10. Additional routes providing access to the pipeline off of 

Interstate 10 are SHs 397, 395, 385, 102, 101, 99, 97, 91, and 13. SHs 82 and 27 generally have light 

traffic levels given their rural location (FERC 2006b). Interstate 10 is subject to moderate levels of traffic 

with a 2001 average annual daily traffic count of 55,517 in the Lake Charles region (AA Roads 2006). 

A substantial increase in road traffic associated with transportation of construction equipment and 

pipe to the Project vicinity would result in traffic delays. However, such delays would be temporary and 

short-term. Upon delivery of construction equipment and pipe to the respective laydown areas and road 

crossings, construction based traffic would be limited to the right of way. 

Construction workers commuting to and from construction areas would likely have a minor 

impact on commuter traffic. Given the relatively short construction period, construction activities would 

utilize available daylight hours, resulting in off-peak hour commutes for workers. Further, construction 

workers would be dispersed across the pipeline right of way in five construction spreads, thus keeping 

disruptions in traffic to minor short-term impacts for any one location at any given time. 

Construction of new access roads would be limited to less than three quarters of a mile in total 

length, occurring primarily in Calcasieu Parish. The Applicant has indicated that upon completion of the 

pipeline, newly constructed access roads would be removed, and the land restored to its original contours 

and use. Exceptions may occur where requested by individual landowners or where the access road is 
 4-91 Environmental Analysis

required for ongoing maintenance of the pipeline right-of-way. This represents a short-term, negligible 

impact to the current land uses. 

KMLP indicates that most paved roads and railroads would be crossed using the boring or HDD 

method to mitigate traffic disruptions and direct surface impacts. Alternatively, unpaved roads and one 

abandoned railroad (approximate MP 74.9) would be crossed using the open cut method. This method 

can cause temporary traffic delays. However, through the use of adequate signs, safety barriers, and preestablished detours KMLP would minimize these interruptions to road traffic. During pipe installation at 

road crossings, which typical take only a day, construction practices include keeping one lane of traffic 

open where no reasonable detours are feasible or where construction takes place during peak traffic hours. 

KMLP has indicated that it would repair any significant damage done to transportation 

infrastructure that is a direct result of pipeline construction. Thus, impacts to land transportation facilities 

are expected to be minor and short-term. 

4.9.6.2 Marine Transportation 

Construction of the pipeline would cross Sabine lake, the Intracoastal Waterway, and the 

Calcasieu River. Potential impacts would be temporary impacts to commercial and recreational boats 

resulting from the construction activities associated with water crossings, as described in sections 4.8.3.2 

and 4.8.3.7. Impacts would be due to project-related marine traffic, including pipe and material delivery 

barges and construction barges. Project related impacts would primarily affect barges and smaller 

recreational vessels. 

In order to mitigate these potential impacts in Sabine Lake (approximate MP 4.8 to MP 18.0), 

KMLP has indicated that the pipeline would be installed using barges with anchor spuds. This procedure 

would minimize impacts resulting from construction operations. Furthermore, the Applicant has indicated 

that prior to construction it will provide project specific details to the U.S. Coast Guard such as the timing 

of, and areas in which, water-based construction would occur, as well as the types of vessels that would 

be utilized. The U.S. Coast Guard will then disseminate this information in a Notice to Mariners. In 

addition, construction practices within Sabine Lake would entail leaving spaces between spoil piles for 

navigational purposes. To facilitate passage through these areas KMLP would install timber piles with 

navigational lights and warning signals. Finally, the Applicant has indicated it would comply with all 

navigation rules and regulations in the Project vicinity. 

The pipeline would also cross the waters of the Intracoastal Waterway and Calcasieu River. 

These waters are important navigational channels for both commercial and recreational purposes. Leg 

one of the pipeline would cross the Intracoastal Waterway at several locations including approximate MP 

18.6 to MP 18.7, MP19.01 to MP 19.7, MP 21.4 to MP 22.0, and MP 30.7 to MP 31.0 and the Calcasieu 

River at approximate MP 49.6 to MP 49.8. These crossings would be accomplished using the HDD 

method, which will avoid or minimize potential impacts on vessel traffic in these areas. 

The operation of the pipeline in the waters of Sabine Lake, the Intracoastal Waterway, and 

Calcasieu River would not impact vessel traffic as the pipeline would be buried beneath the lake or river 

bottom. Thus, the pipeline would not impede vessel passage. 

4.9.7 Government Tax Revenue 

Tax revenue would be generated by the Project for the State of Louisiana and the respective 

parishes within the region of influence. KMLP has estimated annual taxes payable to local governments 

in the region of influence range from 1.1 million to 5.4 million. On average, operations-related taxes 
 4-92 Environmental Analysis

would represent approximately 2.0 percent of a parish’s total revenues. Thus, operation of the Project 

would provide a permanent, minor increase in government revenues. 

A portion of the estimated $65 million Project construction payroll would be spent locally for the 

purchase of housing, food, gasoline, and entertainment during construction by project employees. The 

exact amount spent would be dependent upon the proportion of the workforce that was local, the behavior 

of individual workers and the duration of their stay. In addition, KMLP has indicated that local suppliers 

would have the opportunity to submit proposals for Project-related work. To the extent that these local 

providers bid successfully, local expenditures during construction would increase. Construction-related 

expenditures made in Louisiana would be subject to Louisiana’s state sales tax of 4 percent. This increase 

in sales tax would represent a minor, short-term increase in government revenues. 
 4-93 Environmental Analysis

4.10 CULTURAL RESOURCES 

Section 106 of the NHPA requires that the FERC take into account the effects of its undertakings 

(including the issuance of permits or certificates) on “historic properties,” that is, properties listed on, or 

eligible for listing on, the NRHP. Section 106 also requires the FERC to provide the ACHP an 

opportunity to comment on the undertaking. KMLP, as a non-federal party, is assisting the FERC in 

meeting its obligations under section 106 and the implementing regulations in 36 CFR 800. 

KMLP provided the Louisiana State Historic Preservation Office (SHPO) with a plan for 

identifying historic properties and involving Indian tribes. KMLP sent letters to Indian tribes 

summarizing the results of archaeological surveys and requesting information about these or other sites 

that may have religious and cultural significance. KMLP will provide the SHPO with detailed cultural 

resources survey reports and request concurrence on its evaluations of NRHP eligibility of identified 

properties. These consultation efforts are described in more detail below. 

4.10.1 Consultation with Louisiana State Historic Preservation Officer 

Consultation regarding the Project with the Louisiana SHPO was initiated in January 2006, when 

a cultural resource scope of work was submitted to the Louisiana SHPO. In February 2006, the SHPO 

accepted the proposed scope of work, including the definition of the area of potential effects (APE), 

proposed survey methodology, and Native American groups to be contacted. KMLP submitted State of 

Louisiana Site Record forms to the SHPO in September 2006. Once Louisiana site numbers are assigned, 

KMLP will incorporate these into the survey report and submit it for the SHPO’s review and concurrence 

with eligibility evaluations. 

4.10.2 Native American Consultation 

KMLP submitted letters to the Alabama Coushatta Tribe of Texas, Caddo Nation, Chitimacha 

Tribe of Louisiana, Coushatta Tribe of Louisiana, Jena Band of Choctaw Indians, Mississippi Band of 

Choctaw Indians, Quapaw Tribe of Oklahoma, and Tunica-Biloxi Indians of Louisiana. Two letters were 

sent to representatives of these tribes, in April and August of 2006, informing them about the Project, the 

results of the initial cultural resources surveys, and requesting that they communicate any potential 

concerns they might have with respect to possible impacts to traditional cultural properties and historic 

properties. 

The Caddo Nation responded that it knows of no traditional cultural properties in the potentially 

affected parishes. The Nation requested notification and copies of reports, should any cultural resources 

or archaeological sites be discovered. The Chitimacha Tribe of Louisiana responded that Acadia Parish is 

part of the Chitimacha homeland. Their records and oral traditions do not indicate the presence of a 

specific Chitimacha archaeological site or traditional cultural property in the immediate vicinity of the 

Project. The Chitimacha requested notification to begin consultation if archaeological remains 

representing a village site or burial site are discovered during construction. Responses have not yet been 

received from the other tribes. 

4.10.3 Results of Cultural Resources Survey 

KMLP conducted background cartographic, archival, and archeological review, as well as 

pedestrian survey and systematic shovel testing of the proposed pipeline corridor and ancillary facility 

locations. The investigation also included an assessment of all standing structures 50 years old or older 
 4-94 Environmental Analysis

that were located in the pipeline corridor, access roads, aboveground facilities, and pipe storage and 

contractor yards. The gathered information was used to assess NRHP eligibility of cultural resources.

A total of 122 miles of the pipeline were surveyed for cultural resources, consisting of 108.6 

miles of terrestrial survey and 13.4 miles of underwater remote sensing. Ten interconnect sites that fell 

within the pipeline corridor were examined as part of the survey. Additionally, all 2.3 miles of the 24-

inch FGT Lateral pipeline were surveyed, as well as 10 pipe storage and contractor yards, 66 access 

roads, the surface of four HDD locations, and 44 extra workspaces immediately adjacent to the 

construction right-of-way. 

There remain 9.9 miles of the pipeline route, two pipe storage and contractor yards, four 

interconnect sites, and nine access road routes that have not been surveyed because permission from 

landowners to access these properties has not yet been obtained. KMLP has indicated that it will perform 

cultural resources surveys for the unsurveyed portions of the Project during subsequent investigations 

prior to construction. The surveys will include the inspection of the locations of three previously 

recorded archaeological sites that were not relocated during the initial survey, possibly because high 

water precluded thorough inspection. 

In total, the survey identified 21 cultural resources within or adjacent to the APE: 11 locations 

where cultural materials were found on or under the ground, one submerged cultural resource, six historic 

standing structures, two previously recorded archaeological sites, and a single historic cemetery. KMLP 

archaeologists assessed all of these sites as ineligible for NRHP listing, and recommended no further 

work for these cultural resources. SHPO review of the survey report and concurrence with the eligibility 

assessments and recommendations is pending. 

More specific information regarding the cultural resources survey results can be found in the 

sections below. 

Pipeline Corridors 

KMLP surveyed a 300-foot-wide corridor for the terrestrial portion of the pipeline route. A total 

of 15 cultural resources were discovered within the examined portion of the terrestrial section. In total, 

eight sites consisting of late nineteenth-century to early twentieth-century historic scatters, four early to 

mid-twentieth-century structures, and a single historic cemetery were encountered. Additionally, two 

previously recorded sites (16CM153 and 16CM154) between MP 4 and 5 were relocated and examined. 

Surveyors did not examine two previously recorded sites (16CM27 and 16CM59) between MPs 18 and 

20 because HDD would avoid ground disturbance in these areas. 

Because the pipeline corridor would be situated across an existing road from the cemetery, the 

historic cemetery would not be disturbed. KMLP proposes a HDD to avoid the two previously recorded 

archeological sites that were reexamined, as well as the two that were not reexamined. 

KMLP surveyed a 3,000-foot-wide corridor extending through Sabine Lake for 13.4 miles. The 

underwater survey identified 15 targets for further analysis along the proposed pipeline route, only one of 

which was designated as a potential submerged cultural resource after consultation with archaeologists. 

This target (Target 6) is located more than 1,000 feet from the pipeline center. All other identified targets 

appear to represent either casually discarded or lost debris, or structures related to the oil and gas industry, 

and require no further action. 

Gaps in data are present along the submerged pripeline route approximately 2,200 feet northeast 

of MP 6.0 near Tieline 401 and from approximately 900 feet north of MP 17 to landfall. Gaps are due 
 4-95 Environmental Analysis

primarily to the hazards of shallow water and the practical impossibility of operating remote sensing 

instruments in these waters. Significant underwater cultural resources are not anticipated in these shallow 

waters. 

KMLP archaeologists recommend either avoidance of Target 6 or further investigation in 

consultation with regulatory authorities. 

No cultural resources were identified within the current assessment of the FGT Lateral. 

Pipe Storage/Contractor Yards 

Of the 10 locations surveyed, a total of three cultural resource locations were encountered. Two 

consisted of late nineteenth-century to early twentieth-century historic scatters, and one was an early to 

mid-twentieth century historic standing structure. 

Aboveground Facilities 

No cultural resources were found on the 10 of the 14 interconnect sites surveyed. 

Access Roads 

KMLP anticipates that 75 temporary access roads would be required during construction. 

Cultural resource surveys have been completed for 66 of these routes, totaling 31.1 miles. The remaining 

nine access roads have not been surveyed because landowner permission has yet to be obtained. Two 

cultural resource locations were identified along access roads. One was a scatter of late nineteenth- to 

early twentieth-century historic materials, and one was an early to mid-twentieth century historic standing 

structure. 

4.10.4 General Impacts and Mitigation 

The results of cultural resources investigations to date have identified no properties eligible for 

the NRHP, and consequently no adverse effects to historic properties. The distance between the historic 

cemetery and pipeline trench is sufficient to avoid any ground disturbance to the cemetery. Pending 

SHPO review, KMLP has proposed avoidance or further investigations of one underwater target that may 

be a cultural resource. KMLP has also proposed to use HDD to avoid two previously recorded 

archaeological sites even though they are considered ineligible for the NRHP. 

KMLP has not yet completed cultural resources surveys for about 9.9 miles of the pipeline route, 

two potential pipe storage and contractor yards, four interconnect sites, and nine access road routes 

because landowner permission for access has not yet been obtained. The completion of surveys and 

evaluations within these areas, as well as review and concurrence from the Louisiana SHPO regarding 

NRHP eligibility and project effects, would be required to complete the process of compliance with 

section 106 of NHPA. 

Once cultural resources surveys and evaluations are complete, the FERC, in consultation with the 

Louisiana SHPO, would make determinations of NRHP eligibility and project effects. If any historic 

properties would be affected by the Project, we would seek ways to minimize or avoid adverse effects. 

KMLP has indicated that it would conduct the additional surveys required along the pipeline 

route and file appropriate reports prior to construction. To ensure that the Commission’s responsibilities 

under the NHPA and its implementing regulations are met, we recommend that:
 4-96 Environmental Analysis

• KMLP defer construction and use of facilities and staging, storage, and temporary work 

areas and new or to be improved access until it files with the Secretary cultural resource 

reports, as appropriate, and the SHPO's comments; and the Director of OEP reviews 

and approves all reports and notifies KMLP in writing that it may proceed. 

All material filed with the Commission containing location, character, and ownership

information about cultural resources must have the cover and any relevant pages 

therein clearly labeled in bold lettering: “CONTAINS PRIVILEGED INFORMATION-

-DO NOT RELEASE.” 

4.10.5 Unanticipated Discovery Plan 

As part of its application, KMLP provided its Unanticipated Discovery Plan to be used in the 

event that previously unidentified cultural resources such as archeological sites, historic features, or 

human remains are encountered during project construction. The Unanticipated Discovery Plan is 

acceptable. 
 4-97 Environmental Analysis

4.11 CUMULATIVE IMPACTS 

The CEQ (40 CFR 1508.7) defines a cumulative impact as “...the impact on the environment 

which results from the incremental impact of the action when added to other past, present, and reasonably 

foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such 

other actions. Cumulative impacts can result from individually minor but collectively significant actions 

taking place over a period of time.” The purpose of this cumulative impacts analysis is to identify and 

describe cumulative impacts to environmental resources that would potentially result from the KMLP 

Project when added to the impacts of other projects. This cumulative impact analysis follows the 

methodology set forth in CEQ’s guidance (CEQ 1997). 

We defined the scope of the cumulative impact analysis by determining the environmental impact 

issues associated with the proposed action; establishing a geographic scope for the cumulative impacts 

project area; establishing the time frame for the analysis; and identifying other past, present, or future 

actions that have affected, or could affect, the resources of concern within the project area. Each of these 

factors is discussed in turn below. 

With regard to the environmental impact issues to be evaluated, the scoping process conducted 

for the KMLP Project provided a useful means for determining the relevant cumulative impact issues 

associated with the KMLP Project and the surrounding area. We consulted with resource agencies and 

other interested parties to identify important environmental issues and resources within the project area, 

particularly those that could be affected by the KMLP Project. Through this process, we determined that 

water resources, wetlands, biological resources, and land use are especially important aspects of the 

affected environment from a cumulative impacts perspective. We also considered the cumulative effects 

of air quality, noise, socioeconomic, and shoreline erosion impacts. 

With regard to the geographic scope of the analysis, we considered the area over which the 

KMLP Project would directly or indirectly impact water resources, wetlands, biological resources, air 

quality, and other elements of the human environment. According to the direct and indirect impact 

analysis conducted in this draft EIS, most of the Project’s impacts would be localized, occurring in the 

immediate vicinity of the construction right-of-way. However, some impacts would extend beyond the 

construction right-of-way and temporary extra workspaces. Therefore, we used the boundaries of the 

watersheds crossed by the project to define the geographic area for the cumulative impacts analysis. 

Table 4.3.2.1-1 in section 4.3.2.1 of this draft EIS lists each watershed crossed by the KMLP Project,. 

With regard to the timeframe for the cumulative impacts analysis, we considered the duration of 

impacts associated with the Project. The majority of the impacts to environmental resources resulting 

from the Project would occur during periods of active construction. Most impacts to environmental 

resources associated with other projects would also occur during periods of active construction with some 

long-term and permanent impacts resulting from changes in land use. Projects associated with the 

recovery efforts in the Gulf Coast Region are already under construction or will be in the immediate 

future. Since the environmental impacts of the KMLP Project and most other projects located within the 

project area would occur within the next five years or less, the temporal span for this cumulative impacts 

analysis includes a five-year time period, 2005 to 2010. 

With regard to other past, present, or future actions to consider in this analysis, we included other 

actions based on their location in the project area and the likelihood that they would contribute impacts to 

environmental resources affected by the Project. Figure 4.11-1 shows existing and reasonably foreseeable 

gas pipeline and LNG projects in the cumulative impact analysis area. Consideration of past projects in a 

cumulative impacts analysis can assist in defining baseline conditions of the affected environment. 
4-98 

Non-Internet Public 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

KINDER MORGAN LOUISIANA PIPELINE PROJECT 

Docket No. CP06-449-000 

Page 4-98 

Figure 4.11-1 Existing, Approved, or Proposed Gas Pipeline and LNG Projects that C

Cumulative Impacts 

Public access for this Non-Internet Public information is available only through 

Room, or by e-mail at public.referenceroom@ferc.gov. 
 4-99 Environmental Analysis

However, agencies are not required to list or analyze the effects of individual past actions unless such 

information is necessary to describe the cumulative effect of all past actions combined (CEQ 2005). 

Baseline environmental conditions described in other sections of this draft EIS reflect the cumulative 

impacts of past projects. Table 4.11-1 lists ongoing and reasonably foreseeable future activities and 

projects that could contribute impacts to resources that would be affected by construction and operation of 

the KMLP Project within the same geographic area and a similar timeframe. Table 4.11-2 depicts the 

resources that would be affected by the construction and operation of the activities/projects listed in table 

4.11-1. Construction and/or implementation schedules of future projects depend on factors such as 

economics, funding, and politics. 

With the scope thus defined, the anticipated cumulative impacts of the Project and other projects 

and activities are discussed in the sections that follow. The analysis draws on table 4.11-3 which 

summarizes the cumulative impacts on waterbodies, wetlands, and forested areas resulting from the 

KMLP Project and other projects within the project area. These anticipated cumulative impacts are based 

on NEPA documentation, agency and public input, and best professional judgment. 

4.11.1 Water Resources 

Past and ongoing activities like agriculture, industrial operations, and the development of 

commercial, residential, energy, and transportation infrastructure have affected and will continue to affect 

water resources, wetlands, biological resources, and other elements of the environment within the project 

area. For example, Ruth (2006) reports that as much as 99% of the original prairies and grasslands in the 

Coastal Prairies Physiographic Province, which includes the project area, have been converted to 

agriculture. 

Multiple projects in the area would result in 427 open-cut water body crossings and 23,064,684 

cubic yards of required dredging. The KMLP Project accounts for 133 of the 427 (approximately 31%) 

open-cut waterbody crossings, but none of the required dredging. Impacts to water quality resulting from 

the KMLP Project and other projects would be temporary or short-term and minor, limited to the periods 

of construction within the water bodies. Most of the waterbodies crossed by the KMLP Project are not 

the same ones crossed by the other projects, and where the same waterbodies are crossed, the crossing 

points are usually miles apart. 

The most significant cumulative impact would be associated with the combined crossing of 

Sabine Lake by both the Kinder Morgan pipeline and the Port Arthur pipeline. However, the construction 

schedule for these two projects would not overlap and the routes of these two pipelines across Sabine 

Lake are generally separated by more than 2.5 miles, although they would come within 1 mile of each 

other in the northernmost part of the lake. In both cases, the construction of the pipelines across Sabine 

Lake would result in temporary localized increases in turbidity, expected to be observed approximately 

1,500 feet away from the construction activity and to dissipate in a few hours after the construction 

activity ceased. The increased turbidity would not result in long-term effects on water quality and the 

increased turbidity levels associated with the construction would not exceed naturally occurring levels 

during tropical storms. 

Several projects included in the Long-Term Community Recovery Plan (Louisiana Speaks 2006) include 

construction activities that would cause similar impacts to water resources as those discussed above. 

Additionally, specific types of projects (e.g., roadways, buildings, parking lots, etc.) could also result in 

an increase in impervious cover that can reduce groundwater recharge and increase the volume and 

velocity of surface water runoff. Such projects can also indirectly introduce chemicals such as oil and 

grease into runoff that eventually enters surface water bodies and the aquatic environment. Other projects 
 4-100 Environmental Analysis

TABLE 4.11-1 

Existing, Approved, or Proposed Projects and Activities that 

Could Contribute to Cumulative Impacts with the KMLP Project 

Activity/Project Description 

Timing/ 

Construction

Schedule 

Ongoing Activities/Projects 

Manufacturing/ 

Refining 

Oil and gas extraction, processing, and transportation, both onshore and 

offshore. 

Ongoing 

Dredging Maintenance dredging of various surface water bodies such as Sabine 

Lake, the Sabine River, the GIWW, and the Calcasieu Ship Channel. 

Periodic 

Recreation Fishing, hunting, boating, and bird watching. Ongoing 

Shipping Commercial ship traffic within waterbodies such as Sabine Lake, the 

Sabine River, the GIWW, and the Calcasieu Ship Channel. 

Ongoing 

Transportation 

Infrastructure 

Construction and maintenance of roadway infrastructure like the repair of 

US Highway 82 damaged by the hurricanes. Projects include asphalt 

widening and overlays, bridge reconditioning, new bridge construction, 

intersection improvements, etc. 

Ongoing 

Utility Infrastructure Construction and maintenance of new and existing utility infrastructure 

(e.g., powerlines). 

Ongoing 

Commercial and 

Residential 

Development 

Business and housing construction projects like those associated with the 

reconstruction of Holly Beach. 

Ongoing 

Agriculture and 

Silviculture 

Agricultural practices, including animal grazing, crawfish farming, rice 

farming, and pine plantations and associated management practices. 

Ongoing 

Environmental 

Restoration 

Shoreline stabilization (e.g., Perry Ridge Shore Protection Project), 

hydrologic restoration (e.g., Black Bayou Hydrologic Restoration Project), 

and wetland mitigation banks (e.g., Gum Cove Mitigation Bank). 

Ongoing 

Louisiana Long-Term 

Community Recovery 

Plan Projects 

In the aftermath of Hurricanes Katrina and Rita, federal and state efforts 

are culminating in plans and projects to help devastated parishes recover 

from the storms, and to be better prepared for future storms. Plans and 

projects vary from parish to parish, depending upon the most pressing 

needs in a given location. 

Ongoing– 

Future 

Sabine Pass LNGa

Project 

Construction of three LNG tanks along the Sabine Ship Channel with a 

nominal output of up to 2.6 Bcfd and a new 16-mile-long natural gas 

pipeline originating at the Sabine LNG Terminal and terminating near 

Johnsons Bayou in Cameron Parish, Louisiana. 

2005-2007 

Sabine Pass LNGa

Project Expansion 

(Phase II) 

Expansion of Sabine Pass LNG Project (Phase I) to include construction 

and operation of three additional LNG tanks to increase sendout output 

up to 4.0 Bcfd. 

2006-2008 

Golden Pass LNGa

Project 

Construction of up to five LNG storage tanks with a nominal output of 1 

Bcfd for the first phase (three LNG tanks), increasing to 2 Bcfd in the 

second phase (five tanks) in Jefferson County, Texas, and about 122 

miles of pipelines located in Jefferson, Orange, and Newton Counties, 

Texas, and Calcasieu Parish, Louisiana. 

2006-2008 

Trunkline LNGa

Terminal Expansion 

Expansion of an existing LNG terminal in Lake Charles, Louisiana. 

Includes an infrastructure enhancement project and a natural gas liquids 

extraction plant. 

2005-2008 
 4-101 Environmental Analysis

TABLE 4.11-1 (cont’d) 

Existing, Approved, or Proposed Projects and Activities that 

Could Contribute to Cumulative Impacts with the KMLP Project 

Activity/Project Description

Timing/ 

Construction

Schedule

Cameron (Hackberry) 

LNG Project 

Construction and operation of an LNG terminal along the Calcasieu Ship 

Channel and associated 35.4-mile natural gas pipeline in Louisiana. 

2005-2008 

Liberty Gas Storage 

Project 

Construction and operation of two natural gas storage caverns, four 

injection wells, and associated 24.6-mile pipeline in Louisiana. 

2006-2007 

Reasonably Foreseeable Future Activities/Projects 

Louisiana Long-Term 

Community Recovery 

Plan 

See description for these projects under Ongoing Activities/Projects. Ongoing– 

Future 

Creole Trail Pipeline 

Segment 1 

Amendment 

Construction and operation of 18.1 miles of 42-inch-diameter highpressure natural gas pipeline to interconnect the previously certificated 

Creole Trail and Sabine Pass pipeline systems in Cameron Parish, 

Louisiana. 

2008-2009 

Creole Trail LNG 

Project 

Construction and operation of an LNG terminal at the mouth of the 

Calcasieu Ship Channel and an associated natural gas pipeline in 

Louisiana. 

2007-2009 

Cameron LNG 

Expansion Project 

Expansion of Cameron (Hackberry) LNG Project (described above) to 

construct and operate one additional LNG storage tank and other 

modifications to increase sendout capacity to 2.65 Bcfd. 

2007-2008 

Port Arthur LNGb

Project 

Port Arthur LNG proposes to construct and operate an LNG terminal 

along the Sabine-Neches Canal and associated natural gas pipeline in 

Texas and Louisiana. 

2007-2010 

Starks Gas Storageb

Pipeline Project 

Construction of about 35.6 miles of 16-inch and 30-inch-diameter natural 

gas pipeline and about 1.9 miles of 10-inch-diameter brine pipeline in 

Calcasieu and Beauregard Parishes, Louisiana. 

2006-2008 

_______________ 

a

 Projects have been approved by the FERC and are under construction. b

 Projects have been approved by the FERC but construction is pending.
 4-102 Environmental Analysis

TABLE 4.11-2 

Resources of Concern that Could be Affected by Construction or Development of Existing, 

Approved, or Proposed Projects or Activities in the Vicinity of the KMLP Project 

Primary Environmental Impact 

Activity/Project

Water Resources Wetlands Wildlife/Vegetation Aquatic Resources Recreation Socioeconomics Land Use Ship Traffic Transportation Air Quality/Noise 

Present Projects or Activities

Manufacturing/Refining X X X X X X X 

Dredging X X X X X X X X 

Recreation X X X X X 

Shipping X X X X X 

Transportation Infrastructure X X X X X X X X X 

Utility Infrastructure X X X X X X X X 

Commercial/Residential Development X X X X X X 

Agriculture and Silviculture X X X X X X X 

Environmental Restoration X X X X X X X 

Louisiana Long-Term Community Recovery Plan Projects X X X X X X X X X X 

Sabine Pass LNG Project X X X X X X X X X X 

Sabine Pass LNG Project Expansiona X X X X X 

Golden Pass LNG Project X X X X X X X X X X 

Trunkline LNG Terminal Expansion X X X X 

Cameron (Hackberry) LNG Expansion Project X X X X X X X X X X 

Liberty Gas Storage Project X X X X X X X 

Reasonably Foreseeable Future Projects or Activities

Louisiana Long-Term Community Recovery Plan X X X X X X X X X X 

Creole Trail Pipeline Segment 1 Amendment X X X X X X X 

Creole Trail LNG Project X X X X X X X X X X 

Cameron LNG Expansion Project X X X X X X 

Port Arthur LNG Project X X X X X X X X X X 

Starks Gas Storage Pipeline Project X X X X X X X 

_______________ 

a

 No other sources were considered regarding the Sabine Pass LNG Project Expansion because it would be within the same 

boundaries as the existing facility. 

included in the Long-Term Community Recovery Plan include environmental restoration activities that 

would improve the quality of water resources within the project area. 
 4-103 Environmental Analysis

4.11.2 Wetlands 

From a wetlands perspective, the KMLP Project would be within the Western Gulf Coastal Plain 

ecoregion, which historically contained vast areas of freshwater and tidal wetlands, intermixed with 

upland prairie and forest. This ecoregion has undergone significant alterations in the last several decades. 

In particular, the area of freshwater wetlands has significantly decreased due to saltwater intrusion caused 

by development, dredging, channelization, land subsidence, and other factors (Ruth 2006). The presence 

and ongoing spread of non-native vegetation species have reduced the vegetative diversity and wildlife 

habitat quality of freshwater and tidal wetlands in this region. 

The projects listed in table 4.11-3 would disturb a total of about 2,285 acres of wetlands during 

construction. The KMLP Project would disturb approximately 22% of the total wetlands impacted during 

construction. Including the KMLP Project, pipelines account for approximately 77% of the total acres of 

wetlands that would be disturbed during construction. To provide perspective, SNWR, which comprises 

a small portion of the project area, encompasses 124,511 acres of fresh, intermediate, and brackish 

marshes (FWS 2006c). The combined projects would result cumulatively in a short-term and minor 

impact associated with construction through emergent or scrub-shrub wetlands, which would revegetate 

quickly (generally within 1 to 3 years) after construction and right-of-way restoration. Construction 

through forested wetlands would contribute cumulatively to the long- term or permanent alteration of 

forested wetlands in southwest Louisiana and southeast Texas to shrub or emergent wetlands (although 

the KMLP Project would not contribute to wetland alteration in Texas). 

The construction and operation of the Project, along with the other potential projects and 

activities, could result in a cumulative reduction in the amount of wetlands within the project area. 

However, mitigation for wetlands affected by the Project and the other projects listed would be required 

by the COE and could result in a net increase and/or improvement in the regional coastal marsh resource. 

4.11.3 Biological Resources 

When projects are constructed at or near the same time, the combination of construction activities 

could have a cumulative impact on vegetation, wildlife, and aquatic organisms living in the immediate 

area. Clearing, grading, and other construction activities associated with pipeline construction and other 

similar activities in the vicinity (e.g., road and transmission line construction, silvicultural practices) 

would result in the removal of vegetation, alteration of wildlife habitat, displacement of wildlife, and 

other secondary effects such as increased population stress, predation, forest fragmentation, and 

establishment of invasive plant species. Similarly, the construction of multiple large industrial projects at 

or near the same time can result in a significant amount of land clearing activities that could have a 

cumulative impact on forest resources in the immediate area of the projects. However, most of the large 

industrial sites proposed or currently under construction in the project area (e.g., LNG terminals) are 

largely devoid of large stands of trees other than Chinese Tallow, an invasive species. 

About 598.9 miles of pipeline would be constructed for the projects listed in table 4.11-3 and 

would result in a total of about 9,074 acres of vegetation disturbance assuming a right-of-way width of 

125 feet. The construction of the LNG terminals would add to the total area of vegetation disturbance. 

Although the total amount of vegetation that would be affected by the KMLP Project and other potential 

projects in the area may be considered substantial, much of this would occur in areas that have been 

previously disturbed by existing rights-of-way. Also, this disturbance, alteration, or loss of habitat would 

be relatively small compared to the abundance of similar resources in the project area, the majority of it 

would be allowed to return to pre-construction conditions. 
 4-104 Environmental Analysis

TABLE 4.11-3 

Cumulative Impacts to Environmental Resources Resulting from the Construction and 

Operation of Projects in the Vicinity of the KMLP Project 

Dredging Required 

(cubic yards) 

Total Wetlands 

Disturbed During 

Construction 

(acres) 

Forest Cleared 

(acres)a

Project 

Pipeline 

Length 

(miles)b

Number of 

Open-Cut 

Waterbody 

Crossings 

Berth 

Area Lakec LNG 

Terminal Pipeline 

LNG 

Terminal Pipeline 

KMLP Projectd

Construction 135.5 133 NA NA NA 504.2 NA 150.6 

Operations NA NA NA NA NA NA NA 58.7 

Cameron (Hackberry) LNG Projecte 

Construction 35.4 97 4,900,000 NA 67.7 148.1 0.0 148.3 

Operations NA NA NA NA NA NA 0.0 74.2 

Cameron LNG Expansiond 

Construction NA 0 20,000 NA 1.8 NA 0.0 0.0 

Operations NA NA NA NA NA NA 0.0 0.0 

Creole Trail Projectf 

Construction 116.8 81 4,100,000 2,575,596 102.9 106.8 54.1 552.5 

Operations NA NA NA NA NA NA 22.9 299.7 

Creole Trail Segment 1 Pipeline Projectd 

Construction 18.1 7 NA NA NA 216.9 NA 0.0 

Operations NA NA NA NA NA NA NA 0.0 

Golden Pass LNG Projecte

Construction 122.4 54 5,700,000 NA 108.8 290.2 0.0 451.3 

Operations NA NA NA NA NA NA 0.0 238.7 

Liberty Pipeline Projecte

Construction 24.6 10 NA NA NA 40.9 NA 155.5 

Operations NA NA NA NA NA NA NA 82.4 

Port Arthur LNG Projectf 

Construction 73.0 34 820,000 310,088 82.5 308.3 0.0 201.0 

Operations NA NA NA NA NA NA 0.0 87.2 

Sabine Pass LNG and Pipeline Projecte 

Construction 16.0 5 4,569,000 NA 56.4 99.4 0.7 2.3 

Operations NA NA NA NA NA NA 0.7 0.8 

Sabine Pass LNG Project Expansion

Construction NA 0 NA NA 100.3 NA 0.0 0.0 

Operations NA NA NA NA NA NA 0.0 0.0 
 4-105 Environmental Analysis

TABLE 4.11-3 (cont’d) 

Cumulative Impacts to Environmental Resources Resulting from the Construction and 

Operation of Projects in the Vicinity of the KMLP Project 

Dredging Required 

(cubic yards) 

Total Wetlands 

Disturbed During 

Construction 

(acres) 

Forest Cleared 

(acres)a

Project 

Pipeline 

Length 

(miles)b

Number of 

Open-Cut 

Waterbody 

Crossings 

Berth 

Area Lakec LNG 

Terminal Pipeline 

LNG 

Terminal Pipeline 

Starks Gas Storage Pipeline Projectf 

Construction 34.7 6 NA NA NA 49.8 NA 149.2 

Operations NA NA NA NA NA NA NA 90.3 

Trunkline LNG Terminal Expansione 

Construction 22.2 0 70,000 NA 0.0 NA 0.0 NA 

Operations NA NA NA NA NA NA 0.0 NA 

Cumulative Totals 

Construction 598.9 427 20,179,000 2,885,684 520.4 1764.6 54.8 1,810.7 

Operations NA NA NA NA NA NA 23.6 932.0 

_______________ 

a

 Includes forested wetlands. 

b

 Includes mainlines, looplines, and laterals associated with the project. c

 Dredging required in Sabine Lake (Port Arthur) and Calcasieu Lake (Creole Trail) for pipeline construction. d

 Projects are currently under review by the FERC. 

e

 Projects have been approved by the FERC and are under construction. f

 Projects have been approved by the FERC but construction has not begun. g

 Includes dual pipeline. 

NA Not Applicable 

Construction of the projects in table 4.11-3 would affect a total of about 1,865.5 acres of forested 

land (including forested wetlands), of which about 956 acres would be maintained in a non-forested 

condition during project operations. Some of these forest lands consist of stands of planted timber grown 

for commercial use. Landowners would be compensated for raw timber removed from construction work 

areas, and would be allowed to replant areas outside of the permanent right-of-way following completion 

of construction. 

Although the total amount of forested land that would be affected by the KMLP Project and other 

potential projects in the project area may be considered substantial, the linear nature of the pipelines 

would not require clear cutting of large areas of timber. Additionally, where the pipelines would be 

parallel and adjacent to one another, additional forest impacts would be cumulative, but minimized by the 

overlapping rights-of-way. The loss of forested land in this area due to all of these projects would be 

relatively small compared to the abundance of similar resources in the project area. 
 4-106 Environmental Analysis

4.11.4 Land Use, Recreation, and Visual Resources 

Along the Project and other pipeline routes, most land uses would revert to prior uses following 

construction. Some land uses would be restricted or prohibited on the new permanent pipeline rights-ofway, to accommodate permanent aboveground structures and recurring maintenance activities. 

Recreational activities, such as fishing, boating, and bird watching occur throughout the coastal 

marsh, Sabine Lake, and the Sabine River in the vicinity of the KMLP Project. Other projects included in 

this analysis would contribute to effects on users of Sabine Lake and the Sabine River and could 

negatively affect recreation, primarily during periods of active construction. The presence and movement 

of construction equipment, materials, and workers may be disruptive temporarily to users of the local 

recreation areas, particularly if more than one project is under construction at any one time in the project 

area. Recreation-related cumulative impacts are expected to be localized, short-term, and minor. 

Construction and operation of the KMLP Project and other projects in the area may affect visual 

resources by altering the terrain and vegetation patterns during construction or right-of-way maintenance 

and through the installation of new aboveground facilities that change land use. However, the KMLP 

Project would result in minimal land use changes and would therefore not contribute significantly to 

adverse impacts on visual resources within the project area. 

4.11.5 Socioeconomics 

Present and reasonably foreseeable future projects and activities could cumulatively impact 

socioeconomic conditions in the project area. There may be both beneficial and detrimental effects on 

employment, housing, infrastructure, and public services. The Project would make a negligible 

contribution to these impacts. 

Employment and Housing 

In general, natural gas-related projects have a beneficial impact on local employment during the 

short construction period. Since the construction of the KMLP Project would overlap with the 

construction of other projects, the demand for workers could exceed the local supply of appropriately 

skilled labor. The increased demand for workers could reduce current unemployment and perhaps lead to 

higher wages for the duration of construction. Other indirect employment benefits could include 

temporary jobs in the local area (e.g., restaurants, motels, and convenience stores). 

Damage caused by Hurricane Rita in 2005 increased the need for construction workers in the 

project area. Prior to the hurricane, the project area would have been able to accommodate temporary 

construction workers who preferred to live there. However, as a result of the hurricane, accommodating 

temporary construction workers is likely to be a regional priority for several years. Nevertheless, given 

the vacancy rates in the area and the number of hotel/motel rooms in larger population centers in the 

project area, construction crews should not encounter difficulties in finding temporary housing. The 

degree of cumulative impacts on housing resources would depend upon the number of other projects 

being constructed simultaneously and the season, specifically when construction coincides with periods of 

peak recreation and tourism activity. If construction occurs concurrently with other projects and during 

the peak recreation and tourism periods, temporary housing would still be available but may be more 

difficult to find and/or more expensive to secure. Regardless, these effects would be temporary, lasting 

only for the duration of construction, and there would be no long-term cumulative effect on housing. 
 4-107 Environmental Analysis

Vehicular Traffic 

Since the construction of the KMLP Project would overlap with the construction of other 

projects, there could be increased congestion on local roads during the construction period. Kinder 

Morgan plans to cross most paved roads and railroads using the boring or HDD method to mitigate traffic 

disruptions and direct surface impacts. Alternatively, unpaved roads and one abandoned railroad would 

be crossed using the open cut method. This method can cause temporary traffic delays. However, the use 

of adequate signs, safety barriers, and pre-established detours would minimize these interruptions to road 

traffic. Pipe installation at road crossings typically takes a day to complete and includes construction 

practices that keep one lane of traffic open where no reasonable detours are feasible or during peak traffic 

hours. To the extent that construction occurs simultaneously in a given area, traffic impacts would be 

localized and short-term. 

Infrastructure and Public Services 

The cumulative impact of the KMLP Project and other activities in the project area on 

infrastructure and public services would depend on the number of projects under construction at one time. 

The small incremental demands of several projects occurring at the same time could become difficult for 

police, fire, and emergency service personnel to address. This problem would be temporary, and occur 

only for the length of construction. No long-term effects on infrastructure and public services are 

expected. 

Marine Traffic 

Once completed, other projects within the project area would cause an increase in marine traffic. 

The KMLP Project would cross Sabine Lake, enter the mouth of the Sabine River, and cross the GIWW 

and the Calcasieu River. Construction would temporarily impact commercial and recreational boats in 

these areas due to project-related marine traffic, including pipe and material delivery barges and 

construction barges. Project-related impacts would primarily affect barges and smaller recreational 

vessels and would only occur during periods of active construction in these areas. These impacts would 

result in a negligible contribution to the cumulative impacts on marine traffic when added to impacts of 

other projects in the area. 

4.11.6 Shoreline Erosion 

Average coastal erosion rates are 4.2 meters per year in Louisiana and 1.8 meters per year along 

the northern Gulf of Mexico shoreline. The most serious erosion and land loss are occurring in the eastern 

part of the coastal area, east of Atchafalaya Bay (USGS 2003). Marine traffic and the potential for 

shoreline erosion would increase as a result of other projects in the project area. Marine vessels 

associated with the KMLP Project would include barges used for material delivery and construction. The 

use of these vessels would be limited to periods of active construction. The KMLP Project would add 

negligible, if any, impacts to eroding shorelines within the area. 

4.11.7 Air Quality and Noise 

Ambient air quality in the project area is acceptable. The parishes crossed by the Project are in 

attainment for all criteria pollutants. 

Construction of the KMLP Project and other projects in the area would involve the use of heavy 

equipment that produces noise, air contaminants, and dust. Use of the access roads for maintenance of the 

pipeline and appurtenances would generate occasional, minor, and short-term increases in dust similar to 
 4-108 Environmental Analysis

that generated on other unpaved roads in the area. Construction of the KMLP Project and other projects 

in the project area would cause localized declines in ambient air quality. 

During operations, the KMLP Project would result in fugitive emissions at the aboveground 

meter stations and block valves. Such emissions would be below any established regulatory thresholds 

and therefore would not require any type of permit. Other sources of air pollutants within the project area 

include new LNG terminals and ships using those terminals, refineries, etc. These sources emit PM10, 

SO2, NOx, CO, and VOCs. In turn, NOx and VOC emissions contribute to regional ozone 

concentrations. Ambient air quality could decline as a result of the operation of other projects located 

within the project area. However, a decline in ambient air quality would be minimal and the project area 

is anticipated to remain in attainment for all criteria pollutants. 

Aside from noise associated with construction, pipeline projects do not typically result in elevated 

noise levels. Construction of the KMLP Project would increase sound levels in the vicinity of Project 

activities, and the sound levels would vary during the construction period, depending on the level of 

construction activity at any given time. Additional noise produced during construction of the KMLP 

Project and other projects could create short-term annoyances to nearby residences and could disrupt 

nesting birds and other wildlife in the project area. These noise impacts would be localized and would 

attenuate quickly as the distance from the noise source increases. Operation of the KMLP Project would 

not contribute to any increases in ambient noise levels within the project area. 

4.11.8 Cumulative Impacts Conclusions 

Environmental resources within the project area have experienced adverse impacts from oil and 

gas development, agriculture, silviculture, and a number of other human activities for decades. Human 

activity has resulted in a loss of ecologically significant habitat including coastal marsh and forested 

wetlands; introduced pesticides and other contaminants into surface water bodies and sediments; altered 

the hydrologic regime through channelization of surface water bodies and heavy groundwater 

withdrawals; and introduced invasive plants into the ecosystem. To mitigate the effects of these adverse 

impacts, many environmental restoration projects have been implemented within the project area (see 

section 4.8). Such projects have provided beneficial environmental effects such as restoring the functions 

and values of thousands of acres of wetlands and stabilizing eroding shorelines. 

The KMLP Project and other projects and activities within the project area would cumulatively 

impact water resources, wetlands, biological resources, land use, air quality, and other environmental 

resources. However, we believe that impacts associated with the KMLP Project would be relatively 

minor, and we have included numerous recommendations in this draft EIS to further reduce the 

environmental impacts associated with the Project. The environmental impacts associated with the Project 

would be minimized by careful project routing, utilization of HDD techniques to avoid and minimize 

impacts to sensitive resources, and implementation of appropriate mitigation measures. Based on the 

analysis conducted in this draft EIS, the impacts of the KMLP Project, when added to the impacts of other 

projects and activities, would not be expected to alter any environmental resource beyond its ability to 

return to a near-baseline condition. 
 4-109 Environmental Analysis

4.12 AIR QUALITY AND NOISE 

4.12.1 Air Quality 

4.12.1.1 Affected Environment 

The region between Cameron Parish, Louisiana and Evangeline Parish, Louisiana is characteristic 

of subtropical regions, with short mild winters and warm humid summers. The Gulf of Mexico plays an 

important part in moderating the local weather by producing a pronounced sea breeze effect in the 

summer and tempering the effects of polar outbreaks. Tropical cyclones (hurricanes) are not unusual for 

the Project area. 

The prevailing winds are generally from offshore to onshore from the south to south-southwest, 

except during winter months when passing cold fronts bring prevailing winds from the north to northnortheast. Wind speeds average 9 miles per hour throughout the year. 

Rainfall in Saint Charles, Louisiana, located at approximately the midpoint of the pipeline route, 

averages 57.19 inches annually. June is the wettest month averaging 6.07 inches, and February is the 

driest month averaging 3.28 inches. The warmest months are July and August with an average high 

temperature of 91o

F and average low temperature of 74oF. January is the coldest month with an average 

high temperature of 61o

F and average low temperature of 41oF. 

4.12.1.2 Regulatory Requirements 

The Clean Air Act of 1970 (CAA) designates six pollutants as criteria pollutants for which the 

National Ambient Air Quality Standards (NAAQS) are promulgated. The NAAQS for sulfur dioxide 

(SO2), nitrogen dioxide (NO2), particulate matter with an aerodynamic diameter less than 10 microns 

(PM10), particulate matter with an aerodynamic diameter less than 2.5 microns (PM2.5), carbon monoxide 

(CO), ozone (O3), and lead were set to protect human health (primary standards) and human welfare 

(secondary standards). State air quality standards cannot be less stringent than the NAAQS. Louisiana 

has adopted the NAAQS, as defined in 40 CFR 50; these standards are summarized in table 4.12.1.2-1. In 

addition to the NAAQS shown in table 4.12.1.2-1, Louisiana has adopted secondary CO standards that are 

equal to the primary NAAQS for CO. Areas where the ambient air quality is better than the NAAQS are 

designated as attainment areas and areas exceeding the NAAQS are designated non-attainment. The 

parishes in which the Project would be located are in attainment for all criteria pollutants. 

The CAA, 42 USC 7401 et seq. amended in 1977 and 1990, is the basic federal statute governing 

air pollution. The provisions of the CAA that are potentially relevant to the Project include the following 

and are discussed further below: 

• New source review (NSR); 

• Prevention of significant deterioration (PSD); 

• New source performance standards (NSPS); 

• Maximum achievable control technology (MACT) standards; and 

• Title V operating permits. 

In addition, the Project would be subject to applicable Louisiana state regulations that are more 

stringent than federal regulations. 
 4-110 Environmental Analysis

TABLE 4.12.1.2-1 

National Ambient Air Quality Standards 

Pollutant Time Frame Primary Secondary 

Annuala Particulate matter less than 10 microns in 50 μg/m3 50 μg/m3 

diameter 24-hourb

 150 μg/m3 150 μg/m3

Annualc 15 μg/m3 15 μg/m3 Particulate matter less than 2.5 microns in 

diameter 24-hourd

 65 μg/m3 65 μg/m3

Annual 0.030 ppm (80 μg/m3) N/A 

24-hourb 0.014 ppm (365 μg/m3) N/A 

Sulfur dioxide 

3-hourb

 N/A 0.5 ppm (1,300 μg/m3) 

8-hourb 9 ppm (10,000 μg/m3 Carbon monoxide ) None 

1-hourb

 35 ppm (40,000 μg/m3) None 

Nitrogen dioxide Annual 0.053 ppm (100 μg/m3) 0.053 ppm 

Ozone 8-houre 0.08 ppm (157 μg/m3) 0.08 ppm 

Lead Quarterly 1.5 μg/m3 1.5 μg/m3

_______________ 

μg = Microgram(s). 

m3

 = Cubic meter(s). 

NA = Not applicable. 

ppm = Part(s) per million. 

a

 To attain this standard, the 3-year average of the weighted annual mean particulate matter less than 10 microns in diameter 

concentration at each monitor within an area must not exceed 50 μg/m3

. b

 Not to be exceeded more than once per year. 

c

 To attain this standard, the 3-year average of the weighted annual mean particulate matter less than 2.5 microns in diameter 

concentrations from single or multiple community-oriented monitors must not exceed 15 μg/m3

. d

 To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor 

within an area must not exceed 65 μg/m3

. e

 To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations, 

measured at each monitor within an area over each year, must not exceed 0.08 ppm. 

New Source Review 

NSR refers to the preconstruction permitting programs under Parts C and D of the CAA that must 

be satisfied before construction can begin on new major sources or major modifications to existing major 

sources. The PSD program is the NSR permitting program for sources located in attainment areas and in 

areas for which there is insufficient information to determine attainment status (unclassified areas). For 

sources located in non-attainment areas, the applicable permitting program is the Nonattainment New 

Source Review (NNSR) program. NNSR is required for major sources locating or expanding in nonattainment areas. Since the Project would be located in an attainment area, NNSR is not applicable to the 

Project. 

Prevention of Significant Deterioration 

The PSD review regulations apply to proposed new major sources or major modifications to 

existing major sources located in an attainment area. The PSD regulations (40 CFR 52.21) define a major 

source as any source type belonging to a list of named source categories that emit or have the potential to 
 4-111 Environmental Analysis

emit 100 tons per year (tpy) or more of any regulated pollutant. A major source under PSD also can be 

defined as any source not on the list of named source categories with the potential to emit such pollutants 

in amounts equal to or greater than 250 tpy. Modifications to existing major sources have lower emission 

thresholds, called significant emission increases; amounts over any of these thresholds trigger PSD 

review. 

The PSD review evaluates existing ambient air quality and the potential impacts of the proposed 

source on ambient air quality (noting in particular whether the source would contribute to any violation of 

the NAAQS), and reviews the best available control technology (BACT) in order to minimize emissions. 

The PSD regulations contain restrictions on the degree of ambient air quality deterioration that would be 

allowed. These increments for criteria pollutants are based on the PSD review classification of the area. 

Air Quality Control Regions (AQCRs) are categorized as Class I, Class II, or Class III. Class I areas are 

designated specifically as pristine natural areas or areas of natural significance. Class III designations, 

intended for heavily industrialized zones, can be made only on request and must meet all requirements 

outlined in 40 CFR 51.166. The remainder of the United States is classified as Class II. The Project 

would be located in a Class II area. The nearest Class I area is the Breton National Wildlife Refuge 

located in the Gulf of Mexico east of New Orleans, Louisiana approximately 218 miles east of the 

Project.

The Project would not include facilities or operations included on the list of named source 

categories to which the 100-tpy trigger applies. The Project would have only negligible fugitive 

emissions and would not exceed emissions of 250 tpy of any criteria pollutant. Therefore, PSD 

permitting is not applicable to the Project. 

New Source Performance Standards 

NSPS regulations, which are codified at 40 CFR 60 and incorporated by reference in the 

Louisiana Administrative Code (LAC) 33.III.3303, establish requirements for new, modified, or 

reconstructed units in specific source categories. NSPS requirements include emission limits, monitoring, 

reporting, and record keeping. There are no NSPS requirements identified as potentially applicable to the 

Project. 

Maximum Achievable Control Technology Standards 

MACT standards are intended to reduce emissions of air toxics or hazardous air pollutants 

(HAPs) through installation of control equipment rather than enforcement of risk-based emission limits. 

Applicability is triggered if potential emissions are greater than 10 tpy of any single listed HAP or greater 

than 25 tpy combined total of listed HAPs. As potential HAP emissions resulting from the Project would 

be well below these thresholds, the MACT is not applicable. The Project would not have sources of HAP 

emissions so MACT is not applicable. 

Title V Permitting 

The Title V permit program, as described in 40 CFR 70, requires sources of air emissions with 

criteria pollutant emissions that reach or exceed major source levels to obtain federal operating permits. 

These permits list all applicable air regulations and include a compliance demonstration for each 

applicable requirement. The major source threshold level in attainment areas is 100 tpy of NOx, SO2, CO, 

PM10, PM2.5, and volatile organic compound (VOC). The Project would have only negligible fugitive 

emissions and would not exceed the 100-tpy criterion pollutant threshold. Therefore, the Project would 

not require a Title V permit. 
 4-112 Environmental Analysis

State Regulations 

In addition to the Federal regulations described above, Louisiana also has state air quality 

regulations. The LDEQ manages air quality issues in Louisiana. Subject to EPA approval, these agencies 

manage the statewide air permitting, compliance, and enforcement programs. The Project would be 

authorized under a LDEQ minor source permit or exemption. 

LDEQ regulates emissions of particulate matter arising from unpaved streets, access roads, 

construction, and similar facilities through LAC33.III.1305, which requires application of water or dust 

retardant chemicals or paving of roadways. KMLP indicates that if fugitive dust becomes a problem, it 

would employ LDEQ required practices, such as water sprays, to control fugitive dust. Water sprays have 

provided sufficient control to ensure protection of air quality during construction of similar pipeline 

projects. 

4.12.1.3 General Impacts and Mitigation 

Construction Emissions 

Construction of the pipeline and access roads would generate air emissions during grading, 

trenching, and backfilling, and while driving construction vehicles along unpaved areas. Use of existing 

roads would be maximized and facilities would be constructed adjacent to existing roads. New road 

construction would be limited to driveways from existing roads to new facilities. Where possible, 

permanent roadways would be avoided by installing temporary, removable wooden mats to protect the 

underlying surface. These activities could generate dust and particulate emissions from earth moving 

activities and construction equipment engine exhaust. Construction would be expected to cause a minor 

and temporary reduction in local ambient air quality as a result of fugitive dust and combustion emissions 

generated by construction equipment. Criteria pollutant emissions during the operation of the fossilfueled construction equipment would occur from combustion products resulting from use of gasoline and 

diesel fuels, primarily NO2, CO, VOCs, PM10, small amounts of SO2 and small amounts of HAPs (e.g., 

formaldehyde, benzene, toluene, and xylene) produced by the construction equipment engines. Impacts 

from construction equipment would be temporary, would be distributed along the length of the pipeline, 

and would be expected to result in an insignificant impact on air quality. Emissions of criteria pollutants 

during construction are shown in table 4.12.1.3-1. 

TABLE 4.12.1.3-1 

Emission from Construction Activities 

NOx Emissions 

(tpy) 

CO Emissions 

(tpy) 

VOC Emissions 

(tpy) 

PM10 Emissions 

(tpy) 

SO2 Emissions 

(tpy) 

319.62 169.91 42.78 33.55 25.12 

Operations Emissions 

Heaters would be installed to raise the temperature of the transported gas at 14 interconnect sites. 

The capacities of the heaters would range from 10 MMBtu/hour to 70 MMBtu/hour. Emissions from the 

heaters were calculated based on AP-42 chapter 1.4 factors and for NOx, CO, and VOC emission factors 

more conservative than AP-42 were used. Table 4.12.1.3-2 shows calculated emissions at each 

interconnect site. These sites will be permitted as minor sources as allowed under LAC 33 III:503(B). 
 4-113 Environmental Analysis

TABLE 4.12.1.3-2 

Emission from Heaters Located at Interconnect Sites 

Site 

NOx Emissions 

(tpy) 

CO Emissions 

(tpy) 

VOC Emissions

(tpy) 

PM10 Emissions 

(tpy) 

SO2 Emissions

(tpy) 

MP 1.23 36.06 34.32 17.74 2.28 0.18 

MP 2.30 7.73 7.36 3.80 0.49 0.04 

MP 28.24 10.30 9.81 5.07 0.65 0.05 

MP 61.35 5.15 4.90 2.53 0.33 0.03 

MP 87.48 7.73 7.36 3.80 0.49 0.04 

MP 91.45 7.73 7.36 3.80 0.49 0.04 

MP 110.04 12.88 12.26 6.34 0.82 0.06 

MP111.30 7.73 7.36 3.80 0.49 0.04 

MP 112.02 10.30 9.81 5.07 0.65 0.05 

MP 116.95 5.15 4.90 2.53 0.33 0.03 

MP 122.08 10.30 9.81 5.07 0.65 0.05 

MP 132 16 10.30 9.81 5.07 0.65 0.05 

Bridgeline 7.73 7.36 3.80 0.49 0.04 

SW Loop JB 7.73 7.36 3.80 0.49 0.04 

Operation of the above ground meter stations and block valves would not result in substantial air 

emissions under normal operating conditions. Typically, only minor emissions of natural gas, called 

fugitive emissions, occur from small connections at meter station and valve sites. Because such 

emissions are very small, they are not regulated by permit or source-specific requirements. Use of the 

access roads for maintenance would generate occasional, minor, and short term increases in dust similar 

to that generated on other unpaved roads in the area. Use of these roads by maintenance and operation 

personnel would have a negligible effect on air quality. Overall, operation of the Project would not result 

in significant impacts to air quality. 

4.12.2 Noise 

Construction, modification, and operation of the Project would affect the local noise environment. 

The ambient sound level of a region is defined by the total noise generated within the specific 

environment, and is usually comprised of sounds emanating from natural and artificial sources. At any 

location, both the magnitude and frequency of environmental noise may vary considerably over the 

course of a day and throughout the week. This variation is caused in part by changing weather conditions 

and the effect of seasonal vegetative cover. 

Two measurements used by some federal agencies to relate the time-varying quality of 

environmental noise to its known effects on people are the equivalent sound level (Leq) and the day-night 

sound level (Ldn). The Leq is an A-weighted sound level containing the same sound energy as the 

instantaneous sound levels measured over a specific time period. Noise levels are perceived differently, 

depending on length of exposure and time of day. The Ldn takes into account the duration and time the 

noise is encountered. Late night and early morning (10:00 pm to 7:00 am ) noise exposures are penalized 

+10 decibels, to account for people’s greater sensitivity to sound during the nighttime hours. 
 4-114 Environmental Analysis

In 1974, the EPA published its Information on Levels of Environmental Noise Requisite to 

Protect Public Health and Welfare with an Adequate Margin of Safety. This document provides 

information for state and local governments to use in developing their own ambient noise standards. The 

EPA has indicated that an Ldn of 55 decibels on the A-weighted scale (dBA) protects the public from 

indoor and outdoor activity interference. We have adopted this criterion and use it to evaluate the 

potential noise impact from operation of the compressor facilities. 

Louisiana does not regulate noise at the state level, however individual parishes have specific 

noise control ordinances. Calcasieu Parish and Cameron Parish prohibit operating construction 

equipment within 165 feet of a Noise Sensitive Area (NSA) between sunset and sunrise Monday through 

Saturday, and 9 pm to 8 am Sundays and holidays. Operation of vehicles including offroad vehicles 

without a muffler is also prohibited. (Calcasieu Parish Ordinances 18, VII, 18-100 and Cameron Parish 

Ordinances 15, III, 15-32). Cameron Parish also prohibits operating machinery within 300 feet of a place 

of worship that causes loud sounds that will interfere with worship services (Cameron Parish Ordinances, 

15, III, 15-33). Acadia Parish prohibits operating internal combustion engines and air compressors 

without a muffler and prohibits operation of construction equipment within 500 feet of a residential area 

from 10 pm to 7 am (Acadia Parish Ordinances, 13, V, 13-82 and 13-87). 

4.12.2.1 Affected Environment 

No compressor stations would be used for the Project, therefore no existing noise level surveys 

were performed. Existing noise levels in areas near Project facilities are expected to be similar to other 

pipeline projects in rural areas of Louisiana, which typically have ambient noise levels between 40 and 60 

dBA depending on proximity to area roadways. 

4.12.2.2 Impacts and Mitigation 

Construction Noise 

Construction of the Project is expected to be typical of other pipeline projects in terms of 

schedule, equipment used, and types of activities. Sound levels would increase in the vicinity of 

construction activities, and would vary depending on the construction phase. Pipeline construction 

generally would proceed at rates ranging from several hundred feet to one mile per day. However, due to 

the assembly-line method of construction, construction activities in any one area could last from several 

weeks to six months on an intermittent basis. Construction equipment would be operated as needed 

during those periods and would be maintained to manufacturers’ specifications to minimize noise 

impacts. 

Although individuals in the immediate vicinity of the construction activities could experience 

annoyance, the impact on the noise environment at any specific location along the route would be short 

term. Night-time noise levels would normally be unaffected since most construction would take place 

only during daylight hours. The possible exceptions would be at the HDD sites. At HDD locations, 

drilling equipment may operate on a 24-hour per day basis over a short period of time. Predicted noise 

impacts on NSAs near three HDD sites indicate that sound levels would exceed 55 dBA, as discussed 

below. 

An HDD entry pit near MP 44.5 on the west side of John Brannon Road is close to three NSAs, 

which are residences built in 2006. These residences are more than 50 feet away, but are less than 165 

feet from the proposed workspace. Given the Calcasieu Parish noise requirements defined above, KMLP 

has stated that it would request an exception from the Calcasieu Parish Police Jury to allow operation of 
 4-115 Environmental Analysis

the HDD equipment near MP 44.5 for 24 hours per day, and offer the residents temporary lodging at a 

nearby hotel for the duration of the HDD activities. 

The other two sites of concern are an HDD exit pit at MP 49.6, which is located 400 feet from the 

nearest NSA, and the HDD entry pit at MP 99.8, which is located 500 feet from the nearest NSA. 

Predicted sound levels due to HDD operations at these two sites are 72 dBA and 70 dBA, respectively. 

There are no applicable noise ordinances at MP 49.6 in Calcasieu Parish because the distance from the 

HDD site to the NSA, which is a fishing camp, exceeds 165 feet. The HDD site at MP 99.8 is located in 

Acadia Parish and is within 500 feet of a residence. Acadia Parish Ordinance 13-87 prohibits operation of 

construction equipment within 500 feet of a residential area between 10 pm and 7 am. KMLP has not 

specified what mitigation measures it would take to comply with all applicable rules and regulations at 

these two HDD sites. 

To ensure that no NSAs are exposed to excessive noise during drilling operations, we 

recommend that: 

• Prior to construction, KMLP file with the Secretary for review and written approval by 

the Director of OEP a noise mitigation and compliance plan for HDD operations at MP 

44.5, MP 49.6, and MP 99.8. This plan should identify mitigation measures such as 

noise barriers, temporary housing, etc. to be implemented prior to the start of drilling 

operations to reduce noise from HDD activities to below 55 dBA at these NSAs. 

Operational Noise 

During operation of the Project, the potential noise impacts would be limited to the vicinity of the 

new valve and metering stations. Principal noise sources would include gas flow through valves and 

metering equipment. Such gas flow noise is typically not noticeable more than a short distance from the 

equipment. Underground sections of the pipeline are not a substantial source of noise. 

If the recommended mitigation at MP 44.5, MP 49.6, and MP 99.8 occurs, we believe that 

project-related noise impacts at the nearest NSAs would not be significant. 
 4-116 Environmental Analysis

4.13 RELIABILITY AND SAFETY 

The transportation of natural gas by pipeline involves some risk to the public in the event of an 

accident and subsequent release of gas. The greatest hazard is a fire or explosion following a major 

pipeline rupture. 

Methane, the primary component of natural gas, is colorless, odorless, and tasteless. It is nontoxic but, possessing a slight inhalation hazard, is classified as a simple asphyxiate. If breathed in high 

concentration, oxygen deficiency can result in serious injury or death. 

Methane has an ignition temperature of 1,000°F and is flammable at concentrations between 

5.0 percent and 15.0 percent in air. Unconfined mixtures of methane in air are not explosive. However, a 

flammable concentration within an enclosed space in the presence of an ignition source can explode. 

Having a specific gravity of 0.55, it is buoyant at atmospheric temperatures and disperses rapidly in air. 

In 2005, Hurricanes Rita and Katrina dramatically illustrated the susceptibility of southern 

Louisiana to the devastation that can be caused by major storms. Much of the aboveground utility 

infrastructure and offshore oil and gas facilities were seriously affected. Most of the onshore damage was 

caused by high winds, with some storm surge damage near the coast. The offshore damage was primarily 

a result of high winds, waves, and currents. Heavy rainfall also caused localized inshore flooding. The 

Project would be located onshore, eliminating the storm-related hazards found in the Gulf of Mexico. 

The pipeline would be buried at depths equal to or exceeding DOT requirements, eliminating concerns 

from wind or surface flooding. In areas where the soils are, or could become, saturated, including Sabine 

Lake, the pipeline would be concrete coated to eliminate positive buoyancy. High rainfall rates 

associated with hurricanes would increase the volume and velocity of stream flows, elevating the risk of 

erosion and scour and the resulting exposure of the pipeline. For this reason, the Project would be 

installed by HDD under major waterbodies, providing at least 20 feet of cover between the pipeline and 

the bottom of the channel; at least 5 feet of cover will be provided at minor waterbodies. Sabine Lake 

does not have the water depth or fetch to generate the size of waves that were observed in the Gulf of 

Mexico, but some increased wave action and movement of bottom sediments would occur during storms. 

The depth of cover over the Project would be increased to at least 4 feet in Sabine Lake as added 

protection against exposure. Aboveground facilities would be limited to meter stations, each of which 

could be isolated from the pipeline if damaged, eliminating the potential for substantial releases of natural 

gas. These aboveground facilities, as well as the pipeline, would be continuously monitored and could be 

shut down remotely in the event of an emergency. It is also likely that the Sabine Pass LNG Terminal 

would be shut down, or at least it would no longer receive ships, upon detection of an approaching storm, 

substantially reducing the amount of gas that would be delivered by the pipeline during the storm. 

Finally, the pipeline right-of-way would be inspected immediately following the passage of a storm to 

ensure the pipeline had not been exposed or otherwise damaged. 

4.13.1 Safety Standards 

The DOT is mandated to provide pipeline safety under Title 49, USC Chapter 601. The Pipeline 

and Hazardous Materials Safety Administration’s (PHMSA’s), Office of Pipeline Safety (OPS), 

administers the national regulatory program to ensure the safe transportation of natural gas and other 

hazardous materials by pipeline. It develops safety regulations and other approaches to risk management 

that ensure safety in the design, construction, testing, operation, maintenance, and emergency response of 

pipeline facilities. Many of the regulations are written as performance standards that set the level of 

safety to be attained and allow the pipeline operator to use various technologies to achieve safety. 

PHMSA ensures that people and the environment are protected from the risk of pipeline incidents. This 
 4-117 Environmental Analysis

work is shared with state agency partners and others at the federal, state, and local level. Section 5(a) of 

the Natural Gas Pipeline Safety Act (NGPSA) provides for a state agency to assume all aspects of the 

safety program for intrastate facilities by adopting and enforcing the federal standards, while Section 5(b) 

permits a state agency that does not qualify under Section 5(a) to perform certain inspection and 

monitoring functions. A state may also act as DOT’s agent to inspect interstate facilities within its 

boundaries; however, the DOT is responsible for enforcement action. The majority of the states have 

either 5(a) certifications or 5(b) agreements, while nine states act as interstate agents. The DOT pipeline 

standards are published in Parts 190-199 of Title 49 of the CFR. Part 192 of 49 CFR specifically 

addresses natural gas pipeline safety issues. 

Under a Memorandum of Understanding on Natural Gas Transportation Facilities (Memorandum) 

dated January 15, 1993 between DOT and the FERC, DOT has the exclusive authority to promulgate 

federal safety standards used in the transportation of natural gas. Section 157.14(a)(9)(vi) of the FERC’s 

regulations require that an Applicant certify that it will design, install, inspect, test, construct, operate, 

replace, and maintain the facility for which a certificate is requested in accordance with federal safety 

standards and plans for maintenance and inspection, or shall certify that it has been granted a waiver of 

the requirements of the safety standards by DOT in accordance with Section 3(e) of the NGPSA. The 

FERC accepts this certification and does not impose additional safety standards other than the DOT 

standards. If the Commission becomes aware of an existing or potential safety problem, there is a 

provision in the Memorandum to promptly alert DOT. The Memorandum also provides for the referral of 

complaints and inquiries made by state and local governments and the general public involving safety 

matters related to pipelines under the Commission’s jurisdiction. 

The FERC also acts as a member of DOT’s Technical Pipeline Safety Standards Committee, 

which determines if proposed safety regulations are reasonable, feasible, and practicable. 

The pipeline and aboveground facilities associated with the Project must be designed, 

constructed, operated, and maintained in accordance with the DOT Minimum Federal Safety Standards in 

49 CFR Part 192. These regulations are intended to ensure adequate protection for the public and to 

prevent natural gas facility accidents and failures. Part 192 specifies material selection and qualification, 

minimum design requirements, and protection from internal, external, and atmospheric corrosion. 

Part 192 also defines area classifications, based on population density in the vicinity of the 

pipeline, and specifies more rigorous safety requirements for populated areas. The class location unit is 

an area that extends 220 yards on either side of the centerline of any continuous 1-mile length of pipeline. 

The four area classifications are defined as follows: 

• Class 1 locations include 10 or fewer buildings intended for human occupancy; 

• Class 2 locations include more than 10 but less than 46 buildings intended for human 

occupancy; 

• Class 3 locations include 46 or more buildings intended for human occupancy or where the 

pipeline lies within 100 yards of any building, or small well-defined outside areas occupied 

by 20 or more people on at least 5 days in a week for 10 weeks in any 12-month period; and 

• Class 4 locations where buildings with four or more stories aboveground are prevalent. 

Class locations representing more populated areas require higher safety factors in pipeline design, 

testing, and operation. Pipelines constructed on land in Class 1 locations must be installed with a 
 4-118 Environmental Analysis

minimum depth of cover of 30 inches in normal soil and 18 inches in consolidated rock. Class 2, 3, and 4 

locations, as well as drainage ditches of public roads and railroad crossings, require a minimum cover of 

36 inches in normal soil and 24 inches in consolidated rock. All pipelines installed in navigable rivers, 

streams, and harbors must have a minimum cover of 48 inches in soil or 24 inches in consolidated rock. 

Class locations also specify the maximum distance to a sectionalizing block valve (e.g., 

10.0 miles in Class 1, 7.5 miles in Class 2, 4.0 miles in Class 3, and 2.5 miles in Class 4). Pipe wall 

thickness and pipeline design pressures, hydrostatic test pressures, maximum allowable operating 

pressure (MAOP), inspection and testing of welds, and frequency of pipeline patrols and leak surveys 

must also conform to higher standards in more populated areas. 

The Project would be designed to account for planned population development. Table 4.13.1-1 

shows the area classifications for the Project. 

TABLE 4.13.1-1 

Area Classifications 

Parish MP Start MP End Area Classifications Reasons for Class 2 or 3 

Leg 1 

Cameron 0.00 1.5 3 Commercial/Industrial 

Cameron 1.5 24.6 1 

Calcasieu 24.6 47.6 1 

Calcasieu 47.6 48.9 2 Houses 

Calcasieu 48.9 50.5 1 

Calcasieu 50.5 51.3 3 Marina (HDD) 

Calcasieu 51.3 51.8 1 

Calcasieu 51.8 52.4 3 Industrial (HDD) 

Calcasieu 52.4 74.9 1 

Jefferson Davis 74.9 99.4 1 

Acadia 99.4 110.0 1 

Acadia 110.0 112.4 2 Houses/Industrial 

Acadia 112.4 112.5 1 

Evangeline 112.5 121.4 1 

Evangeline 121.4 123.3 2 Houses 

Evangeline 123.3 128.3 1 

Evangeline 128.3 129.9 2 Houses 

Evangeline 129.9 132.1 1 

Leg 2 

Cameron 0.00 1.2 3 Commercial/Industrial 

FGT Lateral 

Acadia 0.00 2.3 1 

If a subsequent increase in population density adjacent to the right-of-way indicates a change in 

Class location for a segment of pipeline, Sections 192.609 and 192.611 require that the pipeline operator 

confirm or revise the MAOP commensurate with the current Class location. If physical revisions are 

required, these revisions may be accomplished by reducing operating pressure, or replacing the segment 

with pipe of sufficient grade and wall thickness to comply with the DOT code requirements for the new 

Class location. 
 4-119 Environmental Analysis

In 2002, Congress passed an act to strengthen the Nation’s pipeline safety laws. The Pipeline 

Safety Improvement Act of 2002 (HR 3609) was passed by Congress on November 15, 2002, and signed 

into law by the President in December 2002. Gas transmission operators must develop and follow a 

written integrity management program that contains all the elements described in Section 192.911 and 

addresses the risks on each covered transmission pipeline segment. Specifically, the law establishes an 

integrity management program, which applies to all high-consequence areas (HCAs). DOT (68 FR 

69778, 69 FR 18228, and 69 FR 29903) defines HCAs as they relate to the different class zones, potential 

impact circles, or areas containing an identified site as defined in Section 192.903 of the DOT regulations. 

OPS published a series of rules from August 6, 2002 to May 26, 2004 (69 FR 29903) that define 

HCAs where a gas pipeline accident would do considerable harm to people and their property and 

requires an integrity management program to minimize the potential for an accident. This definition 

satisfies, in part, the Congressional mandate in 49 USC 60109 for OPS to prescribe standards that 

establish criteria for identifying each gas pipeline facility in a high-density population area. 

The HCAs may be defined in one of two ways. In the first method an HCA includes: 

• Current Class 3 and 4 locations; 

• Any area in Class 1 or 2 where the potential impact radius1

 is greater than 660 feet and there 

are 20 or more buildings intended for human occupancy within the potential impact circle;2

 or 

• Any area in Class 1 or 2 where the potential impact circle includes an identified site.3

In the second method, an HCA includes any area within a potential impact circle that contains: 

• 20 or more buildings intended for human occupancy ; or 

• An identified site. 

Once a pipeline operator has determined the HCAs on its pipeline, it must apply the elements of 

its integrity management program to those segments of the pipeline within HCAs. The DOT regulations 

specify the requirements for the integrity management plan at Section 192.911. The HCAs have been 

determined based on the relationship of the pipeline centerline to other nearby structures and identified 

sites. Of the approximately 135.5 miles of pipeline route, KMLP has identified approximately 0.8 mile 

that would be classified as an HCA. The pipeline integrity management rule for HCAs requires 

inspection of the entire pipeline for HCAs every 7 years. 

Part 192 prescribes the minimum standards for operating and maintaining pipeline facilities, 

including the requirement to establish a written plan governing these activities. Under 192.615, each 

 

1

 The potential impact is calculated as the product of 0.69 and the square root of the MAOP of the pipeline in psi 

multiplied by the pipeline diameter in inches. Based on an MAOP of 1,440 PSIG and a nominal diameter of 

42 inches, the calculated potential impact radius for Leg 1 of the Project would be about 1,100 feet. The 

potential impact radius for Leg 2 and the 24-inch FGT Lateral would be 943 feet and 628 feet, respectively. 

2

 The potential impact circle is a circle of radius equal to the potential impact radius. 

3

 An identified site is an outside area or open structure that is occupied by 20 or more persons on at least 50 days 

in any 12-month period; a building that is occupied by 20 or more persons on at least 5 days a week for any 10 

weeks in any 12-month period; or a facility that is occupied by persons who are confined, are of impaired 

mobility, or would be difficult to evacuate. 
 4-120 Environmental Analysis

pipeline operator must also establish an emergency plan that includes procedures to minimize the hazards 

in a natural gas pipeline emergency. Key elements of the plan include procedures for: 

• Receiving, identifying, and classifying emergency events, gas leakage, fires, explosions, and 

natural disasters; 

• Establishing and maintaining communications with local fire, police, and public officials, and 

coordinating emergency response; 

• Emergency shutdown of system and safe restoration of service; 

• Making personnel, equipment, tools, and materials available at the scene of an emergency; 

• Protecting people first and then property, and making them safe from actual or potential 

hazards; and 

• Safely restoring any service outage. 

Each operator must establish and maintain liaison with appropriate fire, police, and public 

officials to identify the resources and responsibilities of each organization that may respond to a gas 

pipeline emergency, and coordinate mutual assistance in responding to emergencies. The operator must 

also establish a continuing education program to enable customers, the public, government officials, and 

those engaged in excavation activities to recognize a gas pipeline emergency and report it to appropriate 

public officials. KMLP would provide the appropriate training to local emergency service personnel 

before the pipeline is placed in service. No additional specialized local fire protection equipment would 

be required to handle pipeline emergencies. KMLP would develop an Emergency Plan for the Project 

that incorporates these procedures as required by Part 192. 

4.13.2 Pipeline Accident Data 

Since February 9, 1970, 49 CFR Part 191 has required all operators of transmission and gathering 

systems to notify DOT of any reportable incident and to submit a report on form F7100.2 within 20 days. 

Reportable incidents are defined as any leaks that: 

• Caused a death or personal injury requiring hospitalization; 

• Required taking any segment of transmission line out of service; 

• Resulted in gas ignition; 

• Caused estimated damage to the property of the operator, or others, or both, of a total of 

$5,000 or more; 

• Required immediate repair on a transmission line; 

• Occurred while testing with gas or another medium; or 

• In the judgment of the operator was significant, even though it did not meet the above 

criteria. 

Since 1984, DOT has required operators to report within 20 days incidents that involve property 

damage of more than $50,000, injury requiring in-patient hospitalization, death, release of gas, or those 

considered significant by the operator. Table 4.13.2-1 presents a summary of incident data for the period 
 4-121 Environmental Analysis

TABLE 4.13.2-1 

Natural Gas Service Incidents by Cause 

Incidents per 1,000 miles of Pipeline (percentage) 

Cause 1970-1984 1986-2005 

Outside force 0.70 (53.8) 0.10 (38.5) 

Corrosion 0.22 (16.9) 0.06 (23.1) 

Construction or material defect 0.27 (20.8) 0.04 (15.4) 

Other 0.11 ( 8.5) 0.06 (23.1)

Total 1.30 (100) 0.26 (100) 

1970 to 1984, as well as more recent incident data for 1986 through 2005, recognizing the difference in 

reporting requirements. The 14.5-year period from 1970 through June 1984, which provides a larger 

universe of data and more basic report information than subsequent years, has been subject to detailed 

analysis, as discussed in the following sections (Jones et al. 1986). 

During the 14.5-year period, 5,862 service incidents were reported over the more than 300,000 

total miles of natural gas transmission and gathering systems nationwide. Service incidents, defined as 

failures that occur during pipeline operation, have remained fairly constant over this period with no clear 

upward or downward trend in annual totals. In addition, 2,013 test failures were reported. Correction of 

test failures removed defects from the pipeline before operation. 

Additional insight into the nature of service incidents may be found by examining the primary 

factors that caused the failures. Table 4.13.2-1 provides a percentage distribution of the causal factors as 

well as the annual frequency of each factor per 1,000 miles of pipeline in service. 

The dominant incident cause is outside forces, constituting 53.8 percent of all service incidents. 

Outside forces incidents result from the encroachment of mechanical equipment such as bulldozers and 

backhoes; earth movements due to soil settlement, washouts, or geologic hazards; weather effects such as 

winds, storms, and thermal strains; and willful damage. Table 4.13.2-2 shows that human error in 

equipment usage was responsible for approximately 75 percent of outside forces incidents. Since April 

1982, operators have been required to participate in "One Call" public utility programs in populated areas 

to minimize unauthorized excavation activities in the vicinity of pipelines. The "One Call" program is a 

service used by public utilities and some private sector companies (e.g., oil pipelines and cable television) 

to provide preconstruction information to contractors or other maintenance workers on the underground 

location of pipes, cables, and culverts. The 1986 through 2005 data show that the portion of incidents 

caused by outside forces has decreased to 38.5 percent. 

The pipelines included in the data set in table 4.13.2-1 vary widely in terms of age, pipe diameter, 

and level of corrosion control. Each variable influences the incident frequency that may be expected for a 

specific segment of pipeline. 

The frequency of service incidents is strongly dependent on pipeline age. While pipelines 

installed since 1950 exhibit a fairly constant level of service incident frequency, pipelines installed before 

that time have a significantly higher rate, partially due to corrosion. Older pipelines have a higher 

frequency of corrosion incidents, since corrosion is a time-dependent process. Further, new pipe 

generally uses more advanced coatings and cathodic protection to reduce corrosion potential. 
 4-122 Environmental Analysis

TABLE 4.13.2-2 

Outside Forces Incidents by Cause (1970-1984)

Cause Percent 

Equipment operated by outside party 67.1 

Equipment operated by or for operator 7.3 

Earth movement 13.3 

Weather 10.8 

Other 1.5 

Older pipelines have a higher frequency of outside forces incidents partly because their location 

may be less well known and less well marked than newer lines. In addition, the older pipelines contain a 

disproportionate number of smaller diameter pipelines, which have a greater rate of outside forces 

incidents. Small diameter pipelines are more easily crushed or broken by mechanical equipment or earth 

movements. 

Table 4.13.2-3 clearly demonstrates the effectiveness of corrosion control in reducing the 

incidence of failures caused by external corrosion. The use of both an external protective coating and a 

cathodic protection system, required on all pipelines installed after July 1971, significantly reduces the 

rate of failure compared to unprotected or partially protected pipe. The data show that bare, cathodically 

protected pipe actually has a higher corrosion rate than unprotected pipe. This anomaly reflects the 

retrofitting of cathodic protection to actively corroding spots on pipes. 

TABLE 4.13.2-3 

External Corrosion by Level of Control (1970-1984) 

Corrosion Control Incidents per 1,000 miles per Year 

None-bare pipe 0.42 

Cathodic protection only 0.97 

Coated only 0.40 

Coated and cathodic protection 0.11 

4.13.3 Impact on Public Safety 

The service incident data summarized in table 4.13.2-1 include pipeline failures of all magnitudes 

with widely varying consequences. Approximately two-thirds of the incidents were classified as leaks, 

and the remaining third classified as ruptures, implying a more serious failure. 

Table 4.13.3-1 presents the average annual fatalities that occurred on natural gas transmission and 

gathering lines from 1970 to 2005. Fatalities between 1970 and June 1984 have been separated into 

employees and nonemployees, to better identify a fatality rate experienced by the general public. Of the 

total 5.0 nationwide average, fatalities among the public averaged 2.6 per year over this period. The 

simplified reporting requirements in effect after June 1984 do not differentiate between employees and 

nonemployees. However, the data show that the total annual average for the period 1984 through 2005 
 4-123 Environmental Analysis

TABLE 4.13.3-1 

Annual Average Fatalities - Natural Gas Transmission and Gathering Systemsa,b

Year Employees Nonemployees Total 

1970-June 1984 2.4 2.6 5.0 

1984-2005c - - 3.6 

1984-2005c - - 2.8d

_______________ 

a

 1970 through June 1984 – Jones et al,1986. 

b

 Pipeline and Hazardous Materials Administration, 2005. 

c

 Employee/nonemployee breakdown not available after June 1984. 

d

 Without 18 offshore fatalities occurring in 1989 - 11 fatalities resulted from a fishing vessel striking an offshore pipeline and 7 

fatalities resulted from explosion on an offshore production platform.

decreased to 3.6 fatalities per year. Subtracting two major offshore incidents in 1989, which do not 

reflect the risk to the onshore public, yields a total annual rate of 2.8 fatalities per year for this period. 

The nationwide totals of accidental fatalities from various manmade and natural hazards are listed 

in table 4.13.3-2 in order to provide a relative measure of the industry-wide safety of natural gas 

pipelines. Direct comparisons between accident categories should be made cautiously, however, because 

individual exposures to hazards are not uniform among all categories. Nevertheless, the average 2.6 

public fatalities per year is relatively small considering the more than 300,000 miles of transmission and 

gathering lines in service nationwide. Furthermore, the fatality rate is approximately two orders of 

magnitude (100 times) lower than the fatalities from natural hazards such as lightning, tornados, floods, 

earthquakes, etc. 

TABLE 4.13.3-2 

Nationwide Accidental Deathsa

Type of Accident Fatalities 

All accidents 90,523 

Motor vehicles 43,649 

Falls 14,985 

Drowning 3,488 

Poisoning 9,510 

Fires and burns 3,791 

Suffocation by ingested object 3,206 

Tornado, flood, earthquake, etc. (1984-93 average) 181 

All liquid and gas pipelines (1978-87 average)b 27 

Gas transmission and gathering lines, nonemployees only (1970-84 average)c 2.6 

_______________ 

a

 All data, unless otherwise noted, reflects 1996 statistics from the U.S. Department of Commerce, Bureau of the Census, 

"Statistical Abstract of the United States 118th Edition." 

b

 U.S. Department of Transportation, "Annual Report on Pipeline Safety - Calendar Year 1987." 

c

 Jones et al 1986. 

The available data show that natural gas pipelines continue to be a safe, reliable means of energy 

transportation. Based on approximately 301,000 miles in service, the rate of public fatalities for the 
 4-124 Environmental Analysis

nationwide mix of transmission and gathering lines in service is 0.01 per year per 1,000 miles of pipeline. 

Using this rate, the KMLP Project might result in a public fatality every 738-plus years. This would 

represent a slight increase in risk to the nearby public. 
5.0 CONCLUSIONS AND RECOMMENDATIONS 

5.1 SUMMARY OF THE STAFF’S ENVIRONMENTAL ANALYSIS 

We have determined that construction and operation of the KMLP Project would result in limited 

adverse environmental impacts. If the Project is constructed and operated in accordance with 

recommended mitigation measures, it would be an environmentally acceptable action. Our conclusion is 

based on information provided by KMLP and data developed from data requests; field investigations by 

Commission staff; literature research; alternatives analysis; comment from federal, state, and local 

agencies; and input from the public. 

As part of our review, we developed measures that we believe would appropriately and 

reasonably avoid, minimize, or mitigate environmental impacts resulting from construction and operation 

of the Project. We are, therefore, recommending that our mitigation measures be attached as conditions 

to any authorization issued by the Commission. 

5.1.1 Geology 

Construction and operation of the Project would have minimal impact on geological resources. 

No bedrock blasting is anticipated for the Project. The Project would be located in a region with a low 

risk of seismic activity, soil liquefaction, landslide susceptibility, and subsidence. Oil and natural gas 

extraction is common in the project area, but construction and operation of the Project is not expected to 

have an impact on exploitable oil or natural gas resources. The Project pipeline would HDD under a 

current sand and gravel pit. KMLP reports that the owner of this pit intends to begin filling the pit and 

there would not be any further excavation. We are recommending that KMLP file documentation of its 

consultation with the owner of the borrow pit prior to the close of the comment period on the draft EIS. 

KMLP proposed an alternative measure to item V.A.5 of our Plan, which requires land surfaces 

to be restored to pre-construction contours, unless such contours threaten the integrity of the pipeline. We 

are not approving this proposal because KMLP did not provide sufficient site-specific justification. 

However, if KMLP identifies a location where it cannot comply with item V.A.5, we are recommending 

that KMLP file with the Secretary any alternative measures that it would use to ensure pre-construction 

contours are restored without compromising pipeline integrity. 

5.1.2 Soils 

The Project would traverse a variety of soil types and conditions, and approximately 79 percent of 

the soils that would be affected by the proposed pipeline are classified as prime farmland. Construction 

activities associated with the Project, such as clearing, grading, trenching, and backfilling, would 

adversely affect soil resources by resulting in erosion, compaction, and the loss of soil productivity and 

fertility by mixing of topsoil and subsoil horizons and changing drainage patterns. KMLP would 

implement the mitigation measures contained in our Plan to control erosion, ensure successful 

revegetation, and minimize any potential adverse impacts to soil resources. In addition, potential soil 

impacts to rice fields and crawfish ponds would be mitigated by attempting to schedule construction 

during dry periods, re-installing and testing the underlying low-permeability layer needed to hold water, 

and other measures. 

There are no known contaminated soils in the project area. In case contaminated soils are 

encountered, we are recommending that KMLP file a Plan for the Discovery and Management of 

Contaminated Soils and Groundwater. To further reduce the potential for contamination from an 

 5-1 Conclusions and Recommendations 
accidental release of petroleum hydrocarbons or other hazardous materials, we are recommending that 

KMLP develop and file a project-specific SWPPP and SPRP. 

5.1.3 Water Resources 

Groundwater 

Construction and operation of the Project would not have a significant impact on groundwater 

resources in the project area, including the Chicot Aquifer. Based on current information, 28 wells would 

be located within 150 feet of the construction right-of-way, including eight domestic supply wells (two of 

which are either abandoned or plugged), two industrial wells, nine irrigation wells, four monitoring wells 

(all four are plugged), and five rig supply wells (three of which are plugged). Landowners in the general 

vicinity of the construction right-of-way would be notified about their ability to request well testing and 

monitoring. In case water quality or well yield is affected, we are recommending KMLP file a statement 

agreeing to provide a temporary water supply and well re-testing, and replacement of the potable water 

supply system if water capacity and quality cannot be restored. 

The greatest potential for impact on groundwater would be from spills, leaks, or other releases of 

hazardous substances during project construction or operation. We are recommending KMLP develop 

and implement a project-specific SWPPP and SPRP that would conform to the guidelines in our 

Procedures to prevent and minimize accidental or inadvertent chemical spills. Based on land use 

activities in the project area, the potential exists for contaminated groundwater to occur in the area. We 

are recommending KMLP develop a Plan for the Discovery of Contaminated Soil and Groundwater that 

would specify measures for protecting the environment in the event an unanticipated encounters with 

contaminated groundwater. With the implementation of the proposed construction measures, our Plan 

and Procedures, and our recommendations, we believe that there would be no impacts on groundwater 

resources as a result of construction and operation of the Project. 

Surface Water 

The Project would cross a total of 310 waterbodies. To minimize impacts on these water bodies, 

KMLP would implement our Procedures, its project-specific SPRP and SWPPP, site-specific waterbody 

crossing plans (appendix G), and an HDD Contingency Plan (appendix I), as well as requirements in the 

permits issued by other federal and state agencies. 

KMLP proposes to use the HDD crossing method in 18 locations to avoid impacts to 24 

waterbodies (some HDDs would cross more than one waterbody). The use of the HDD method would 

avoid or minimize in-stream disturbance and impacts on aquatic resources. We are recommending that 

KMLP file a site-specific construction plan for each of these HDD crossings. In response to comments 

from FWS, COE, and LDWF, we are also recommending KMLP evaluate the feasibility of using the 

HDD method to cross the Tiger Point Gulley (MP 113.3) and Bayou Barwick (MP 109.2) along Leg 1, 

and Bayou des Cannes (MP 1.57) along the FGT Lateral to avoid impacts to adjacent riparian and wetland 

areas. 

KMLP proposes to cross Sabine Lake by HDD at the lake’s southern and northern shorelines and 

it would use the open-cut construction method with spud barges across the lake’s open water. KMLP 

would use the open-cut construction method from MP 4.8 to MP 17.9 of Leg 1. The use of HDD would 

resume at MP 17.9 within Sabine Lake, exiting on land at MP 18.6, to avoid shoreline erosion. By 

implementing the HDD crossing method at the northern and southern banks of Sabine Lake, it would 

avoid impacts to the shoreline, oyster reefs, EFH wetlands, and aquatic resources. Open-cut construction 

would affect water quality during construction, causing sediment resuspension and related impacts in the 

 5-2 Conclusions and Recommendations 
water column. To minimize impacts, KMLP would utilize BMPs as part of the SWPPP to address 

hazardous materials handling and storage, as well as spill prevention and response. 

KMLP would install the pipeline across Calcasieu River between MP 49.6 and MP 51.1 with a 

series of HDDs. One of the HDD pull strings would lie across a COE dredge spoil area. We are 

recommending KMLP complete consultation with COE regarding the related impacts and file 

documentation of its consultations with the Secretary prior to construction. Crossing the Calcasieu River 

by HDD would minimize impacts to the river and associated riparian vegetation. 

KMLP proposed to construct/modify Access Roads 15, 19, and FGT-2 across drainage ditches, 

which according to the COE, qualify as flowing waters that must be protected. Therefore, we are 

recommending that KMLP evaluate the feasibility of rerouting these access roads to minimize impacts to 

the drainage ditches. 

5.1.4 Wetlands 

The Project would be constructed in areas of extensive estuarine and palustrine wetlands, 

affecting a total of 352 wetlands covering approximately 504.2 acres. Temporary impacts resulting from 

installation of the Project would include approximately 28.3 acres of forested wetlands and 475.9 acres of 

non-forested wetlands. These temporary impacts include 99.5 acres of EFH wetlands and 179.4 acres of 

two CWPPRA projects crossed by the pipeline. Operation of the pipeline facilities would result in the 

permanent conversion of 14.9 acres of forested wetlands to emergent or scrub-shrub wetlands. The COE 

has not yet verified the KMLP wetland delineation for the Project; therefore, the acreage of wetlands 

affected by the Project may change. 

KMLP has requested the use of a 125-foot-wide construction right-of-way in wetlands where the 

crossing length is greater than 100 feet. KMLP has also requested that various access roads, extra work 

spaces, and interconnect sites be constructed within wetlands. We are approving the requested alternative 

measures based on soil stability issues, necessary access to HDD work spaces, and lack of practicable 

alternatives. 

To minimize impacts to wetlands, KMLP would implement our Procedures, with accepted 

alternative measures, which include measures to minimize sediment runoff into wetlands and minimize 

impacts from construction equipment. Use of HDD construction methods along the pipeline route would 

avoid the need to clear or otherwise disturb 7.0 acres of forested wetlands and 100.8 acres of non-forested 

wetlands. We are also recommending that KMLP evaluate alternative routes for Access Road 4-5 to 

avoid impacts to wetlands. 

KMLP would also implement its Aquatic Resources Mitigation Plan (see appendix J) to ensure 

no net loss of wetland functions and values. KMLP is still developing its draft Aquatic Resources 

Mitigation Plan in consultation with COE, FWS, NOAA Fisheries Service, and LDWF and we are 

recommending that the final Aquatic Resources Mitigation Plan be filed with the Secretary prior to 

construction. 

5.1.5 Vegetation 

Construction of the pipeline, aboveground facilities, access roads, pipe storage and contractor 

yards, and extra workspaces would require the clearing of 1,843.3 acres of upland vegetative lands, 

including 115.4 acres of upland forest. Upon completion of construction approximately 43.8 acres of 

upland forest would be converted to a permanent pipeline right-of-way and maintained in an herbaceous 

 5-3 Conclusions and Recommendations 
state. Additionally, 16.5 acres of upland vegetation would be permanently converted to aboveground 

facilities or permanent access roads. 

KMLP has requested a construction right-of-way width for Leg 1 through upland habitats that 

would range from 125 feet to 165 feet, depending on construction methods; a construction right-of-way 

for the FGT Lateral through upland habitats that would range from 100 feet to 130 feet wide, depending 

on construction methods; and maintenance across the entire 50-foot-wide permanent right-of-way on an 

annual basis. We are only approving the use of a 125-foot-wide construction right-of-way for Leg 1 in 

uplands and a 100-foot-wide construction right-of-way for the FGT Lateral in uplands due to the large 

diameter of the pipe and local soil conditions, and to accommodate right-of-way topsoil segregation. We 

are denying the requested annual maintenance of the permanent right-of-way to avoid excessive and 

continuous disruption of upland habitats. Construction and operation of the Project would not 

significantly affect vegetation. 

5.1.6 Wildlife and Aquatic Resources 

Wildlife 

The impact of construction and operation of the Project on wildlife would be the temporary 

alteration of wildlife habitat. Initial clearing and construction activities would result in the disruption of 

wildlife habitat. Once construction is completed, wildlife would re-occupy the temporarily disturbed 

habitat along the Project corridor. The areas disturbed by construction, excluding areas occupied by 

aboveground facilities, would be revegetated after construction has been completed. Although temporary 

and permanent impacts on food, cover, and water sources may occur, none of the species identified within 

the project area are specialized in such a way that construction of a pipeline would inhibit the overall 

fitness or reproductive viability of the populations as a whole. Many of the mammal, bird, reptile, and 

amphibian species are adaptive to changing habitat conditions and have the capability of temporarily 

expanding or shifting their home ranges to find alternative sources of food, water, and shelter until the 

right-of-way habitats become re-established. The impact on wildlife would be temporary and short-term. 

We believe, with the implementation of our Plan and Procedures and recommended measures, impact on 

wildlife would be minimal. 

Approximately the first 50 miles of the Project consists of emergent marsh and coastal 

prairie/grassland that provide habitat for wintering waterfowl and rookeries. Given the abundant adjacent 

areas that can provide alternative habitat, we conclude that there would be no significant impact on 

migratory waterfowl. The Project route could include suitable nesting habitat for various species of 

colonial wading birds, including the roseate spoonbill. To avoid impacts to these species, KMLP has 

stated that they would employ a qualified biologist to survey the proposed work area during the 2007 

nesting season, and again immediately prior to construction scheduled during the nesting season to 

determine the presence of colonial waterbird rookeries. KMLP would further consult with FWS and the 

NHP of LDWF in order to determine mitigation measures to minimize potential impacts to these nesting 

areas, should they be found. 

Aquatic Resources 

The pipeline would cross 310 waterbodies, including Sabine Lake, the GIWW, and Calcasieu 

River. Potential impacts on aquatic resources from project construction and operation include those 

associated with pipeline construction across waterbodies and through wetlands. 

Impacts on fisheries resources resulting from pipeline construction activities at waterbody 

crossings may include sedimentation and turbidity, alteration or removal of instream and stream bank fish 

 5-4 Conclusions and Recommendations 
cover, introduction of water pollutants, or entrainment of small organisms during hydrostatic testing. 

Studies generally have indicated that pipeline construction through waterbodies results in temporary 

impacts on streams and rivers, and that there are no long-term effects on water temperature, pH, dissolved 

oxygen, benthic invertebrate populations, or fish populations. KMLP would implement the measures in 

our Procedures, which include the use of screening on intake hoses, to minimize entrainment or 

impingement of fish when withdrawing water for hydrostatic testing. 

The primary impacts on aquatic resources would be associated with open-cut construction in 

Sabine Lake. This would include entrainment of organisms by construction machinery and increased 

turbidity due to the re-suspension of bottom sediments. Incidental take of benthic organisms due to 

entrainment during the offshore construction process would not be extensive enough to have a significant 

impact on the fishery resources of the area. The LDWF is mandated under Louisiana law to protect 

oyster resources. Sabine Lake contains a public tonging area for oysters, and was surveyed to determine 

the extent of oyster resources in the project area. Although no oyster reefs would be directly impacted by 

the construction of the Project, suitable substrate would be within the construction right-of-way and 

potentially lost. KMLP has stated that it would compensate LDWF for each bottom substrate directly 

impacted by pipeline construction and also for oysters lost due to sedimentation on the reefs within 1,500 

feet of the HDD exit pit at MP 4.82. 

Direct spills of petroleum or other toxic products into waterbodies during construction could be 

harmful to aquatic organisms, depending on the type, quantity, and concentration of the spill. To reduce 

the potential for direct surface water contamination, KMLP would develop and implement the procedures 

in a project-specific SWPPP and SPRP. KMLP requested an alternative measure to items IV.A.1.d and e 

of our Procedures to allow refueling and storage of hazardous materials near a waterbody. We are 

approving this measure only for construction in Sabine Lake and the Sabine River, where there is no 

practicable alternative to refueling from barges. 

Post-construction or operational impacts of the pipeline would be minimal. Restoration of the 

vegetation along the pipeline construction work areas would minimize erosion potential relative to 

waterbodies. Minimal impact on fisheries is expected from maintenance mowing or manual removal of 

woody vegetation in the vicinity of the pipeline right-of-way as maintenance would be in accordance with 

our Plan and Procedures. 

Essential Fish Habitat 

Construction of the Project is not expected to have a significant impact on EFH. Impacts on EFH 

from the construction of the Project are associated with loss or alteration of habitat. These impacts can be 

further divided into those that result in temporary or permanent effects on EFH and species. The primary 

impact of construction and operation of the Project would be the alteration and, to a lesser extent, direct 

loss of habitat types that could function as EFH for the various species. 

NOAA Fisheries Service identified aquatic and tidally influenced wetland habitats in the project 

area as designated EFH for postlarval, juvenile, and subadult life stages of two species of shellfish (brown 

and white shrimp); postlarval, juvenile, and subadult life stages of red drum; and the late juvenile, 

subadult, and adult life stages of bonnethead shark. Construction through the first 50 miles of the 

proposed pipeline route would impact approximately 99.5 acres of EFH wetlands along the northern and 

southern banks of Sabine Lake, Shell Island, the Sabine and Calcasieu Rivers, and the GIWW. 

Construction through Sabine Lake would result in a temporary loss of soft bottom habitat due to 

the excavation of the floatation channel and pipe trench, as well as the placement of the spoil piles, which 

would cover the habitat at that location. These activities would also cause an increase in turbidity and 

 5-5 Conclusions and Recommendations 
sedimentation. Managed mobile species utilizing soft bottoms or the water column would be temporarily 

displaced; however, less mobile stages of managed species that utilize soft bottom habitat could be 

smothered and experience mortality through placement of the spoil pile. Oyster reefs do not occur within 

the construction right-of-way for the pipeline in Sabine Lake. Impacts to these oyster reefs would be 

limited to increased turbidity and sedimentation. 

Operation of the pipeline facilities would have minimal impacts on EFH since the pipeline would 

be buried and the existing EFH would become reestablished in the construction corridor. KMLP 

proposes to monitor the created or restored tidal wetlands annually for at least 3 years and to consult with 

appropriate agencies if monitoring indicates poor plant survival or insufficient coverage. Monitoring 

protocols were developed in consultation with NOAA Fisheries Service and are included in the draft 

Aquatic Resources Mitigation Plan (appendix J). 

5.1.7 Threatened and Endangered Species 

Agency consultations resulted in the identification of 12 federally listed threatened or endangered 

species that potentially occur in the project area. These include: five sea turtles (the green, leatherback, 

loggerhead, Kemp’s ridley, and hawksbill sea turtles); one marine mammal (the West Indian manatee); 

four bird species (the bald eagle, brown pelican, RCW, and piping plover), and two fish species (the Gulf 

sturgeon and smalltooth sawfish). 

The FWS stated that the Project would not affect the West Indian manatee, four bird species, the 

two fish species, and four of the five sea turtle species. NOAA Fisheries Service has joint jurisdiction 

over the Gulf sturgeon, smalltooth sawfish, and the five species of sea turtle. NOAA Fisheries Service 

agreed that the project would not affect the Gulf sturgeon or smalltooth sawfish, and requested that 

Project impacts be assessed for the five species of sea turtles. 

The construction impacts to sea turtles would include noise disturbance, alteration or loss of 

habitat, effects on prey species, and changes in water quality. These impacts are expected to be 

temporary, localized, and minor. KMLP would implement NOAA Fisheries Service’s “Sea Turtle and 

Smalltooth Sawfish Construction Conditions” and “Vessel Strike Avoidance Measures and Injured or 

Dead Species Reporting” guidelines (see appendix K). 

KMLP has not completed surveys for RCW due to lack of access to certain private properties. 

Therefore, we are recommending that KMLP consult further with the FWS to identify the need for 

additional RCW field surveys and file documentation of its consultation, including any survey reports and 

FWS comments on the surveys, as soon as they become available. 

NHP of LDWF has identified 10 state-listed species of concern that may occur in the project area. 

Seven species of plants were eliminated from concern because none of them are located within 0.5 miles 

of the Project. However, the Roseate Spoonbill (colonial waterbirds), Crested Caracara, and Old Prairie 

Crawfish, may be located in the project area. KMLP has committed to engaging a qualified biologist to 

perform surveys during the 2007 nesting season and immediately prior to construction to determine the 

presence or absence of colonial waterbird nesting areas. If any nesting areas are found, KMLP would 

consult further with FWS and the NHP of LDWF to determine mitigation measures and BMPs to 

minimize potential impacts to the Roseate Spoonbill and Crested Caracara. KMLP also would implement 

our Plan and Procedures, which include measures to minimize impacts to the general habitats used by 

these species. These measures would reduce the loss of vegetated habitats, minimize impacts to water 

quality, and result in restoration of areas temporarily disturbed during construction. In its letter, LDWF 

requested that measures be taken to protect Old Prairie Crawfish habitat, including roadside ditches. We 

 5-6 Conclusions and Recommendations 
are recommending KMLP file documentation of consultations with LDWF to develop mitigation 

measures for the crossing of roadside ditches. 

We have not completed consultation with the FWS and NOAA Fisheries Service. Therefore, we 

are recommending that KMLP not begin construction activities until we complete any necessary 

consultations with the FWS and NOAA Fisheries Service, and KMLP receives written notification from 

the Director of OEP that construction and/or implementation of conservation measures may begin. 

5.1.8 Land Use, Recreation, and Visual Resources 

Construction of the Project would affect approximately 3,030.7 acres of land, including 2,274.1 

acres for the pipeline construction right-of-way; 12.3 acres for the aboveground facilities; and 744.4 acres 

for extra workspaces, pipe storage and contractor yards, and access roads. Agricultural land comprises 

about 49 percent of the project area and about 19 percent is open water. Beaches, forestland, developed 

land, open land, and other land (including strip mines, quarries, and gravel pits) account for the remaining 

32 percent of this acreage. Following construction, all affected areas outside the permanent pipeline 

right-of-way and aboveground facility sites would be restored and allowed to revert to preconstruction 

conditions and uses. During operation of the Project, the permanent pipeline right-of-way would consist 

of approximately 822 acres, and the aboveground facility sites and permanent access roads would 

permanently convert about 19 acres to developed land. 

KMLP identified 14 structures within 50 feet of the construction right-of-way. None of these 

structures were identified as residences. However, 9 of the 14 structures have been generically identified 

as “buildings.” We are recommending that KMLP revise table 4.8.3.6-1 in this draft EIS to explicitly 

identify all structures within 50 feet of the construction work area and file this information with the 

Secretary prior to the end of this draft EIS comment period. 

The Project would potentially affect several recreational and special interest areas, including CRP 

lands administered by the NRCS and FSA; FWS-administered conservation easement areas; two wetland 

and hydrologic restoration projects, the Black Bayou Hydrologic Restoration Project sponsored by 

NOAA Fisheries Service and the LDNR and the Perry Ridge Shore Protection Project sponsored by 

NRCS and the LDNR; and one scenic by-way, the Creole Nature Trail. According to local FSA offices, 

the Project would not cross any CRP lands with the possible exception of such lands in Jefferson Davis 

Parish, where consultations are still ongoing. Therefore, we are recommending that KMLP continue 

consultations with FSA and NRCS to identify the extent and location of any CRP lands within Jefferson 

Davis Parish that would be affected by the project. We are also recommending that KMLP consult with 

FWS to determine if FWS conservation easement properties are crossed by the Project. In addition, we 

are recommending that KMLP consult with LDNR, NOAA Fisheries Service, and FWS, and develop sitespecific construction and restoration plans for crossing the Black Bayou Hydrologic Restoration Project 

and the Perry Ridge Shore Protection Project. 

Commercial and recreational activities, such as boating, fishing, and oyster harvesting would 

potentially be impacted by pipeline installation through Sabine Lake. KMLP would utilize special 

construction methods and sequencing to help mitigate such impacts, as well as provide project-specific 

details to the U.S. Coast Guard. 

No known hazardous waste sites occur within 0.25 miles of the Project right-of-way. We are 

including a recommendation for KMLP to develop a Plan for the Discovery and Management of 

Contaminated Soils and Groundwater that identifies the procedures that would be implemented during 

construction to identify, test, treat, and dispose of such materials, if found, in accordance with the 

appropriate state and federal regulations. 

 5-7 Conclusions and Recommendations 
The Project would cross numerous foreign pipelines. The KMLP pipeline would be installed by 

horizontal bore under most single pipelines, but in areas where foreign pipelines are highly congested or 

near waterbodies or wetlands, HDD would be used. To ensure KMLP’s plans for HDDs under foreign 

pipelines are complete, we are recommending that KMLP file a site-specific construction plan for the 

crossing of foreign pipeline corridors between MP 25.3 and MP 26.8. 

Visual resources along the Project route would not be adversely affected. There are several 

existing pipelines in the vicinity of the Project, and the KMLP pipeline would parallel some of these 

existing rights-of-way. Many areas along the Project are either inaccessible or do not provide long-range 

unobstructed views, but public viewpoints are present along some of the roadways in the area. The 

Transco interconnect site would be within 0.5 mile of several residences that would likely have a direct 

view. Therefore, we are recommending that KMLP develop and file a site-screening plan for this facility 

prior to construction. 

Portions of the Project lie within Louisiana’s coastal zone that is managed by the CMD of the 

LDNR. KMLP has consulted with the CMD and is in the process of preparing and filing a Coastal Use 

Permit application as part of the Joint Permit Application with the COE. Upon receipt and review of that 

document, CMD will determine if the Project is consistent with Louisiana’s Coastal Zone Management 

Program. We are recommending that KMLP file a copy of the CZMP consistency determination issued 

by the LDNR before construction begins. 

5.1.9 Socioeconomics 

Construction of the Project would not have a significant impact on local populations, housing, 

employment, or the provision of community services. Construction of the Project would temporarily 

increase the demand for public services such as emergency response, medical, and traffic control but 

these effects would be offset by increases in local government revenues. Operation of the project would 

have stimulatory effects on local spending, employment, and government revenues but such effects would 

be minor. 

5.1.10 Cultural Resources 

KMLP consulted with the Louisiana SHPO and performed cultural resource investigations for the 

APE for the proposed pipeline corridor and ancillary facilities. A total of 15 cultural resources were 

discovered within the terrestrial portion of the pipeline route and five additional cultural resource 

locations were identified at ancillary sites. None of the properties identified to date have been determined 

eligible for the NHRP, though KMLP proposed to use HDDs to avoid four previously recorded sites 

along the pipeline corridor. 

Underwater surveying of Sabine Lake revealed 15 targets along the proposed pipeline corridor. 

However, only one of these identified targets was designated as a potential submerged cultural resource 

after consultation with archaeologists. KMLP would either avoid this site or complete further 

investigation in consultation with regulatory authorities. Gaps in data are present along the proposed 

submerged route due to difficulty in obtaining sensory data in shallow waters, but significant underwater 

cultural resources are not anticipated in these shallow waters. 

Present evidence suggests that no historic properties eligible for the NRHP would be affected by 

the construction of the project. However, surveys have not been conducted for about 9.9 miles of the 

proposed pipeline route and a few ancillary facilities where permission from landowners is pending, and 

the Louisiana SHPO’s comments are awaited. 

 5-8 Conclusions and Recommendations 
In order to assure that the ACHP would have the opportunity to comment on any historic 

properties that might be identified by these studies, we are recommending that KMLP not be allowed to 

construct any facilities, use any staging, storage, or temporary work areas, or use any access roads, until it 

files the survey reports, required treatment plans, and the SHPO comments with the Commission, and is 

given written authorization to proceed by the Director of the OEP. 

5.1.11 Cumulative Impacts 

We identified three types of past, present, and reasonably foreseeable future projects that would 

potentially result in a cumulative impact when considered with the proposed Project. These include other 

natural gas transmission pipelines in the area, nonjurisdictional facilities associated with the Project, and 

transportation and other infrastructure projects in the vicinity of the proposed pipeline route. The 

potential impacts associated with these projects that are most likely to be cumulatively significant are 

related to wetlands and waterbodies, vegetation and wildlife, federally and state-listed endangered and 

threatened species, land use, air quality, and noise. We believe that, overall, impacts associated with the 

Project would be relatively minor, and we included recommendations in this draft EIS to further reduce 

the environmental impacts associated with the Project. Similarly, each of the projects considered in our 

analysis has been or would be designed to avoid or minimize impacts to sensitive environmental 

resources. Additionally, it is anticipated that any significant unavoidable impacts to sensitive resources 

resulting from these projects would be mitigated. Consequently, only a small cumulative effect is 

anticipated when the impacts of the KMLP Project are added to past, present, or reasonably foreseeable 

future projects in the area. 

5.1.12 Air Quality and Noise 

Construction of the Project is expected to have short-term minor impacts on air quality from 

fugitive dust and emissions from construction equipment. Operation of the Project is expected to have 

long-term minor impacts on air quality from emissions from heaters installed at interconnect locations. 

Construction activities are expected to have a short-term minor impact on the noise environment 

provided that mitigation measures are employed during HDD operations. Recommended mitigation 

measures include the development of a noise mitigation and compliance plan that would address potential 

mitigation measures such as sound barriers or temporary housing to ensure the NSAs at MPs 44.5, 49.6, 

and 99.8 are not exposed to noise greater than 55 dBA. Operation of the project is not expected to have 

an impact on the noise environment. 

5.1.13 Reliability and Safety 

The proposed Project would be designed, constructed, operated, and maintained to meet or 

exceed all DOT safety standards for natural gas pipelines. Following construction, KMLP would also 

initiate a pipeline integrity management plan to ensure public safety during operation. The Project would 

result in only a slight increase in risk to the nearby public. 

5.1.14 Alternatives 

We evaluated the no action or postponed action alternatives, which would involve not building or 

deferring construction of the proposed Project facilities. While the no action or postponed action 

alternative would eliminate the short- and long-term environmental impacts identified in this draft EIS, 

the objectives of the Project would not be met, and KMLP would not be able to deliver re-gasified LNG 

to markets in Louisiana and the rest of the United States as proposed. 

 5-9 Conclusions and Recommendations 
We evaluated system alternatives, including alternatives involving the approved Sabine Pass 

Pipeline, to examine whether other existing or proposed natural gas pipeline systems would meet the 

proposed Project objectives while offering an environmental advantage over the Project. Currently, there 

is no existing pipeline system that could be used to move vaporized LNG from the Sabine Pass LNG 

Terminal location to the existing interstate and intrastate natural gas pipeline systems. Within 3 miles of 

the LNG Terminal in the Sabine Pass area, there are two 30-inch-diameter NGPL pipelines and two 24- 

and one 16-inch-diameter Transco pipelines. The combined capacity of these existing pipeline systems 

are inadequate to meet the objectives of the KMLP Project. We identified two proposed pipeline systems 

that, with significant additional construction and adaptation, could potentially meet the KMLP Project’s 

objectives in terms of take-away capacity from the Sabine Pass LNG Terminal and downstream 

interconnecting capacity to other pipelines that serve the same markets proposed to be served by KMLP’s 

shippers. Based on our analysis, however, we do not believe that the system alternatives offer substantial 

environmental benefits relative to the proposed action. 

We also evaluated four major route alternatives to the Project route. However, none of these 

would offer significant environmental advantages over the proposed route, and we eliminated them from 

further consideration. Lastly, we considered route variations to resolve or reduce construction impacts to 

localized, specific resources. We evaluated a total of 15 route variations and considered their associated 

environmental consequences as part of our environmental analysis of the Project. Variations that lessened 

environmental impacts were adopted by KMLP as part of the proposed Project route. 

In summary, with KMLP’s proposed mitigation and our recommendations, the proposed route is 

environmentally least damaging and we are recommending use of the proposed route as the preferred 

alternative. 

5.2 FERC STAFF’S RECOMMENDED MITIGATION 

If the Commission issues a Certificate for the proposed Project, we recommend that the 

Commission’s Order include the following specific conditions. We believe that these measures would 

further mitigate the environmental impacts associated with the construction and operation of the Project: 

1. KMLP shall follow the construction procedures and mitigation measures described in its 

application, supplemental filings (including responses to staff information requests), and as 

identified in the EIS, unless modified by the Order. KMLP must: 

a. request any modification to these procedures, measures, or conditions in a filing with the 

Secretary; 

b. justify each modification relative to site-specific conditions; 

c. explain how that modification provides an equal or greater level of environmental 

protection than the original measure; and 

d. receive approval in writing from the Director of OEP before using that modification. 

2. The Director of OEP has delegated authority to take whatever steps are necessary to ensure 

the protection of life, health, property, and the environment during construction and operation 

of the project. This authority shall allow: 

a. the modification of conditions of the Order; and 

b. design and implementation of any additional measures deemed necessary (including stop 

work authority) to assure continued compliance with the intent of the environmental 

 5-10 Conclusions and Recommendations 
conditions as well as the avoidance or mitigation of adverse environmental impact 

resulting from project construction and operation. 

3. Prior to any construction, KMLP shall file an affirmative statement with the Secretary, 

certified by a senior company official, that all company personnel, environmental inspectors 

(EIs), and contractor personnel will be informed of the EIs’ authority and have been or will 

be trained on the implementation of the environmental mitigation measures appropriate to 

their jobs before becoming involved with construction and restoration activities. 

4. The authorized facility locations shall be as shown in the EIS, as supplemented by filed 

alignment sheets, and shall include all of the staff's recommended facility locations. As soon 

as they are available, and before the start of construction, KMLP shall file with the 

Secretary any revised detailed survey alignment maps/sheets at a scale not smaller than 

1:6,000 with station positions for all facilities approved by the Order. All requests for 

modifications of environmental conditions of the Order or site-specific clearances must be 

written and must reference locations designated on these alignment maps/sheets. 

KMLP’s exercise of eminent domain authority granted under Natural Gas Act (NGA) section 

7(h) in any condemnation proceedings related to the Order must be consistent with these 

authorized facilities and locations. KMLP’s right of eminent domain granted under NGA 

section 7(h) does not authorize it to increase the size of its natural gas pipeline to 

accommodate future needs or to acquire a right-of-way for a pipeline to transport a 

commodity other than natural gas. 

5. KMLP shall file with the Secretary detailed alignment maps/sheets and aerial photographs at 

a scale not smaller than 1:6,000 identifying all route realignments or facility relocations, and 

staging areas, pipe storage yards, new access roads, and other areas that would be used or 

disturbed and have not been previously identified in filings with the Secretary. Approval for 

each of these areas must be explicitly requested in writing. For each area, the request must 

include a description of the existing land use/cover type, and documentation of landowner 

approval, whether any cultural resources or federally listed threatened or endangered species 

would be affected, and whether any other environmentally sensitive areas are within or 

abutting the area. All areas shall be clearly identified on the maps/sheets/aerial photographs. 

Each area must be approved in writing by the Director of OEP before construction in or near 

that area.

This requirement does not apply to extra workspace allowed by the Upland Erosion Control, 

Revegetation, and Maintenance Plan, minor field realignments per landowner needs and 

requirements which do not affect other landowners or sensitive environmental areas such as 

wetlands. 

Examples of alterations requiring approval include all route realignments and facility location 

changes resulting from: 

a. implementation of cultural resources mitigation measures; 

b. implementation of endangered, threatened, or special concern species mitigation 

measures; 

c. recommendations by state regulatory authorities; and 

d. agreements with individual landowners that affect other landowners or could affect 

sensitive environmental areas.

 5-11 Conclusions and Recommendations 
6. Within 60 days of the acceptance of this certificate and prior to construction, KMLP 

shall file an initial Implementation Plan with the Secretary for review and written approval by 

the Director of OEP describing how KMLP would implement the mitigation measures 

required by the Order. KMLP must file revisions to the plan as schedules change. The plan 

shall identify: 

a. how KMLP will incorporate these requirements into the contract bid documents, 

construction contracts (especially penalty clauses and specifications), and construction 

drawings so that the mitigation required at each site is clear to onsite construction and 

inspection personnel; 

b. the number of EIs assigned per spread, and how the company will ensure that sufficient 

personnel are available to implement the environmental mitigation; 

c. company personnel, including EIs and contractors, who will receive copies of the 

appropriate material; 

d. the training and instructions KMLP will give to all personnel involved with construction 

and restoration (initial and refresher training as the project progresses and personnel 

change), with the opportunity for OEP staff to participate in the training session; 

e. the company personnel (if known) and specific portion of KMLP's organization having 

responsibility for compliance; 

f. the procedures (including use of contract penalties) KMLP will follow if noncompliance 

occurs; and 

g. for each discrete facility, a Gantt or PERT chart (or similar project scheduling diagram), 

and dates for: 

(1) the completion of all required surveys and reports; 

(2) the mitigation training of onsite personnel; 

(3) the start of construction; and 

(4) the start and completion of restoration.

7. KMLP shall develop and implement an environmental complaint resolution procedure. The 

procedure shall provide landowners with clear and simple directions for identifying and 

resolving their environmental mitigation problems/concerns during construction of the 

Project and restoration of the right-of-way. Prior to construction, KMLP shall mail the 

complaint procedures to each landowner whose property would be crossed by the Project. 

a. In its letter to affected landowners, KMLP shall: 

(1) provide a local contact that the landowners should call first with their concerns; the 

letter should indicate how soon a landowner should expect a response; 

(2) instruct the landowners that, if they are not satisfied with the response, they should 

call KMLP’s Hotline; the letter should indicate how soon to expect a response; and 

(3) instruct the landowners that, if they are still not satisfied with the response from 

KMLP’s Hotline, they should contact the Commission's Enforcement Hotline at 

(888) 889-8030. 

b. In addition, KMLP shall include in its weekly status report a copy of a table that contains 

the following information for each problem/concern: 

(1) the date of the call; 

(2) the identification number from the certificated alignment sheets of the affected 

property; 

(3) the description of the problem/concern; and 

(4) an explanation of how and when the problem was resolved, will be resolved, or 

why it has not been resolved. 

 5-12 Conclusions and Recommendations 
8. KMLP shall employ a team of EIs (at least two per construction spread). The EIs shall be: 

a. responsible for monitoring and ensuring compliance with all mitigation measures 

required by the Order and other grants, permits, certificates, or other authorizing 

documents; 

b. responsible for evaluating the construction contractor's implementation of the 

environmental mitigation measures required in the contract (see condition 6 above) and 

any other authorizing document; 

c. empowered to order correction of acts that violate the environmental conditions of the 

Order, and any other authorizing document; 

d. a full-time position, separate from all other activity inspectors; 

e. responsible for documenting compliance with the environmental conditions of the Order, 

as well as any environmental conditions/permit requirements imposed by other federal, 

state, or local agencies; and 

f. responsible for maintaining status reports. 

9. KMLP shall file updated status reports prepared by the EI with the Secretary on a weekly 

basis until all construction and restoration activities are complete. On request, these 

status reports will also be provided to other federal and state agencies with permitting 

responsibilities. Status reports shall include: 

a. the current construction status of the Project, work planned for the following reporting 

period, and any schedule changes for stream crossings or work in other environmentally 

sensitive areas; 

b. a listing of all problems encountered and each instance of noncompliance observed by the 

EIs during the reporting period (both for the conditions imposed by the Commission and 

any environmental conditions/permit requirements imposed by other federal, state, or 

local agencies); 

c. corrective actions implemented in response to all instances of noncompliance, and their 

cost; 

d. the effectiveness of all corrective actions implemented; 

e. a description of any landowner/resident complaints which may relate to compliance with 

the requirements of the Order, and the measures taken to satisfy their concerns; and 

f. copies of any correspondence received by KMLP from other federal, state or local 

permitting agencies concerning instances of noncompliance, and KMLP’s response.

10. KMLP must receive written authorization from the Director of OEP before commencing 

service of the Project. Such authorization will only be granted following a determination 

that rehabilitation and restoration of the right-of-way and other areas affected by the Project 

are proceeding satisfactorily. 

11. Within 30 days of placing the certificated facilities in service, KMLP shall file an 

affirmative statement with the Secretary, certified by a senior company official: 

a. that the facilities have been constructed in compliance with all applicable conditions, and 

that continuing activities will be consistent with all applicable conditions; or 

b. identifying which of the certificate conditions KMLP has complied with or will comply 

with. This statement shall also identify any areas affected by the Project where 

compliance measures were not properly implemented, if not previously identified in filed 

status reports, and the reason for noncompliance.

 5-13 Conclusions and Recommendations 
12. KMLP shall limit its nominal construction right-of-way width for Leg 1 and the FGT Lateral 

in upland areas to 125 feet and 100 feet, respectively. If additional right-of-way width is 

necessary, KMLP shall file with the Secretary a site-specific construction plan and written 

justification for any additional right-of-way width for review and written approval by the 

Director of OEP prior to construction. (page 2-9) 

13. KMLP shall file its project-specific SWPPP, including an ES&C Plan and SPRP, with the 

Secretary for review and written approval by the Director of OEP prior to construction. 

(page 2-10) 

14. KMLP shall file with the Secretary a site-specific construction plan for the crossing of 

foreign pipeline corridors between MP 25.3 and MP 26.8. These site-specific plans shall 

include scaled drawings identifying all areas that would be disturbed by construction. KMLP 

shall file these plans for review and written approval by the Director of OEP prior to 

construction. (page 2-40) 

15. Prior to the close of comment period on the draft EIS, KMLP shall file with the Secretary 

a letter from the owner of the borrow pit at MP 52.7 addressing the existing and future use of 

this resource. (page 4-6) 

16. KMLP shall restore the contours in accordance with the requirements of item V.A.5 of our 

Plan. If KMLP identifies a location(s) where it can not implement item V.A.5 of our Plan, 

KMLP shall file with the Secretary for review and written approval by the Director of OEP, 

any alternative measures that it would use to ensure preconstruction contours are restored 

without compromising pipeline integrity. (page 4-8) 

17. Prior to construction, KMLP shall file with the Secretary for review and written approval by 

the Director of OEP, a Plan for the Discovery and Management of Contaminated Soils and 

Groundwater. (page 4-14) 

18. Prior to construction, KMLP shall file with the Secretary a statement that if water quality or 

yield were found to be impaired due to the Project, KMLP would provide a temporary water 

supply and re-test the well within 30 days. In addition, KMLP shall replace any potable 

water supply system that it damages during construction and cannot repair to its former 

capacity and quality. KMLP shall identify in its report to the Secretary all potable water 

supply systems damaged by construction and how they were repaired. (page 4-19) 

19. KMLP shall file with the Secretary a site-specific construction plan for the crossing of each 

waterbody proposed as a HDD crossing. These site-specific plans shall include scaled 

drawings identifying all areas that would be disturbed by construction. KMLP shall file these 

plans for review and written approval by the Director of the OEP along with the COE permit 

prior to construction across those waterbodies. (page 4-22) 

20. KMLP shall evaluate the feasibility of using the HDD method to cross Tiger Point Gulley at 

MP 113.3 and Bayou Barwick at MP 109.2 along Leg 1 and Bayou des Cannes along the 

FGT Lateral at MP 1.57, and develop a site-specific construction plan for each of these 

crossings in coordination with FWS and LDWF that clearly identifies all construction work 

areas including the laydown area for the pipe string if the HDD method is determined to be 

feasible. KMLP shall file the results of its evaluation, the site-specific construction plans, 

and any agreed-upon mitigation measures to minimize impacts on riparian areas and the 

 5-14 Conclusions and Recommendations 
associated forested wetlands with the Secretary for review and written approval by the 

Director of OEP prior to the close of the comment period on the draft EIS. (page 4-22) 

21. Prior to construction of Access Roads 15, 19, and FGT-2, KMLP shall evaluate the 

feasibility to reroute these access roads to avoid crossing drainage ditches at MPs 52.3 and 

61.4 of Leg 1, and avoid crossing Bayou des Cannes Tributary at MP 2.3 of the FGT Lateral. 

KMLP shall file with the Secretary the reroutes for these access roads, copies of the revised 

alignment sheets, and necessary environmental information for review and written approval 

by the Director of OEP. 

If any of these access roads can not be rerouted, KMLP shall provide: 

a. justification why rerouting is infeasible; 

b. documentation of consultation with COE, including proposed mitigation measures; 

c. construction plans for these access roads; 

d. copies of necessary permits/approvals; and 

e. landowner concurrences. 

KMLP shall not use/construct these access roads until the Director or OEP notifies KMLP in 

writing that it may proceed. (page 4-23) 

22. Prior to construction, KMLP shall file the following environmental information with the 

Secretary for review and written approval by the Director of OEP: 

a. site-specific construction plan for the HDD crossing of the Calcasieu River and marina 

between MP 49.6 and MP 51.1 along Leg 1; and 

b. documentation of consultation with COE for the HDD crossing of the Calcasieu River 

and the use of COE dredge spoil area located at MP 50.0. (page 4-28) 

23. KMLP shall use hand clearing methods for clearing vegetation in the path of HDDs in 

wetland areas. (page 4-32) 

24. KMLP shall evaluate alternative routes for Access Road 4-5 or provide justification for the 

wetland impacts associated with its construction in wetlands. Any revision to the route of 

Access Road 4-5 shall be shown on revised alignment sheets. KMLP shall file with the 

Secretary results of its evaluation and copies of the revised alignment sheets for review and 

written approval by the Director of OEP prior to construction. (page 4-35) 

25. KMLP shall consult with LDNR, NOAA Fisheries Service, and FWS, and develop sitespecific construction and restoration plans for crossing the Black Bayou Hydrologic 

Restoration Project and Perry Ridge Shore Protection Project. KMLP shall file with the 

Secretary copies of its consultation, along with construction and restoration plans, for review 

and written approval by the Director of OEP prior to the completion of the final EIS. (page 

4-37) 

26. KMLP shall continue consultations with the FSA and NRCS to identify the extent and 

location of all CRP lands within Jefferson Davis Parish that would be affected by 

construction and operation of the Project. In addition, KMLP shall file with the Secretary 

prior to construction, copies of its consultation and documentation of any stipulations or 

recommendations to avoid and minimize impacts to any CRP lands that would be affected. 

(page 4-38) 

 5-15 Conclusions and Recommendations 
27. Prior to construction, KMLP shall file with the Secretary a copy of the finalized Aquatic 

Resources Mitigation Plan developed in consultation with COE, NOAA Fisheries Service, 

FWS, LDNR, and LDWF. (page 4-41) 

28. KMLP shall consult with the FWS to determine the need for and methodology of additional 

surveys for RCW along the pipeline route or provide concurrence from the FWS that the 

Project is not likely to adversely affect the RCW. The results of consultation with the FWS, 

any additional survey reports, and FWS comments on the survey shall be filed with the 

Secretary as soon as they become available before close of the comment period on the 

draft EIS. Survey reports shall include the following information: 

a. name(s) and qualifications of the person(s) conducting the survey; 

b. method(s) used to conduct the survey; 

c. date(s) of the survey; 

d. area surveyed (include the mileposts surveyed); and 

e. proposed mitigation that would substantially minimize or avoid the potential impacts. 

(page 4-70) 

29. KMLP shall consult with the NHP of LDWF and develop mitigation measures to protect the 

old prairie crawfish during construction through roadside ditches. KMLP shall file with the 

Secretary copies of its consultation prior to construction. (page 4-72) 

30. KMLP shall not begin construction activities until: 

a. the FERC completes any necessary consultations with the FWS and NOAA Fisheries 

Service; and 

b. KMLP receives written notification from the Director of OEP that construction and/or 

implementation of conservation measures may begin. (page 4-73) 

31. KMLP shall revise table 4.8.3.6-1 of the draft EIS and explicitly identify all structures and 

residences within 50 feet of the construction work areas. KMLP shall file the revised table 

with the Secretary prior to the close of the comment period on the draft EIS. (page 4-80) 

32. KMLP shall consult with the FWS to determine if FWS conservation easement properties are 

crossed by the Project. KMLP shall file with the Secretary documentation of its consultation 

with FWS, including any recommended mitigation measures, for review and written approval 

by the Director of OEP prior to construction. (page 4-83) 

33. KMLP shall develop a site-screening plan for the Transco Interconnect site (MP 122.1) and 

file that plan with the Secretary for review and written approval by the Director of OEP prior 

to the close of the comment period on the draft EIS. (page 4-85)

34. KMLP shall not begin construction on any facilities associated with the KMLP Project until

it files with the Secretary a copy of the CZM Program consistency determination issued by 

the LDNR. (page 4-85) 

35. KMLP shall defer construction and use of facilities and staging, storage, and temporary work 

areas and new or to be improved access until it files with the Secretary cultural resource 

reports, as appropriate, and the SHPO's comments; and the Director of OEP reviews and 

approves all reports and notifies KMLP in writing that it may proceed. 

 5-16 Conclusions and Recommendations 
All material filed with the Commission containing location, character, and ownership

information about cultural resources must have the cover and any relevant pages therein 

clearly labeled in bold lettering: “CONTAINS PRIVILEGED INFORMATION—DO 

NOT RELEASE.” (page 4-96) 

36. Prior to construction, KMLP shall file with the Secretary for review and written approval by 

the Director of OEP a noise mitigation and compliance plan for HDD operations at MP 44.5, 

MP 49.6, and MP 99.8. This plan shall identify mitigation measures such as noise barriers, 

temporary housing, etc. to be implemented prior to the start of drilling operations to reduce 

noise from HDD activities to below 55 dBA at NSAs. (page 4-115) 

 5-17 Conclusions and Recommendations 
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APPENDIX A 

DISTRIBUTION LIST
[This page intentionally left blank.] 
APPENDIX A 

DRAFT EIS DISTRIBUTION LIST

Federal Agencies

Army Corps of Engineers 

 New Orleans District 

 Ronnie Duke 

 James Little 

Department of Agriculture 

 Natural Resources Conservation Service 

Coastal Wetlands Planning, Protection, and Restoration Act (CWPPRA), CS-24, Perry 

Ridge Shore Protection 

CWPPRA, CS-25, Plowed Terraces Demonstration 

CWPPRA, CS-27, Black Bayou Hydrologic Restoration Program 

CWPPRA, CS-30, Perry Ridge West Bank Stabilization 

CWPPRA, CS-32, East Sabine Lake Hydrologic Restoration 

Department of Commerce 

National Oceanic and Atmospheric Administration, National Marine Fisheries Services 

 John Foret 

 Richard Hartman 

Kelly Shotts 

Department of Energy 

 Energy Information Administration 

 Barbara Mariner-Volpe, Gas Fields 

Department of the Interior 

 Fish and Wildlife Service 

Cameron Prairie National Wildlife Refuge, Lake Charles, LA 

Sabine National Wildlife Refuge, Bell City, LA 

 Kelly Perky 

Brigette Firmin, Lafayette, LA 

Angela Trahan, Lafayette, LA 

Environmental Protection Agency 

 Barbara Keeler 

 Rob Lawrence 

Federal Representatives and Senators

Representative Rodney Alexander 

Representative Charles Boustany 

Senator Mary Landrieu 

Senator David Vitter 

State Representatives and Senators

Representative Clara G. Boudoin 

Representative Don Cravins, Jr. 

 A-1 Appendix A 
Representative Mickey Frith 

Representative Brett Geymann 

Representative Elcie Guillory 

Representative Mickey J. Guillory 

Representative Ronnie Johns 

Representative Chuck Kleckley 

Representative Eric LaFleur 

Representative Dan Morrish 

Representative Gil Pinac 

Senator James David Cain 

Senator Donald Cravins 

Senator Nick Gautreaux 

Senator Don Hines 

Senator Willie L. Mount 

Senator Gerald Theunissen 

Native American Tribes

Earl Barbry, Jr., Tunica-Biloxi Indians of Louisiana, Marksville, LA 

Robert Cast, Caddo Nation, Binger, OK 

Phillip Martin, Mississippi Band of Choctaw Indians, Philadelphia, MS 

Christine Norris, Jena Band of Choctaw Indians, Jena, LA 

Lovelin Poncho, Coushatta Tribe of Louisiana, Elton, LA 

Debbie Thomas, Alabama Coushatta Tribe of Texas, Livingston, TX 

Kimberly Walden, Chitimacha Tribe of Louisiana, Charenton, LA 

Carrie Wilson, Quapaw Tribe of Oklahoma, Quapaw, OK 

State Agencies

Louisiana

Agriculture Finance Authority 

 Commissioner of Agriculture 

Department of Culture, Recreation, and Tourism 

 Duke Rivet 

 Rachel Watson 

Department of Natural Resources 

Coastal Management Division 

 Ontario James 

 Chris Melton 

Department of Transportation and Development 

 Leslie Mix 

 Dale Touchet, District 03 

Department of Wildlife and Fisheries 

 Kyle Balkum 

 Rick Kasprzak, Artificial Reef Program Supervisor 

 Venise Ortego 

Geological Services 

 John Johnston 

 A-2 Appendix A 
Office of Conservation 

 Clear Marias Field 

 James Welsh 

State Land Office 

 Sonya Boudreaux 

 John Evans 

County/Parish Agencies 

Acadia Parish 

 Acadia/Evangeline Fire Protection District 

 Acadia Fire Protection District No. 3 

 Acadia Parish Police Jury 

 Acadia Parish School Board 

 Robert T. Barousse, Acadia Parish Clerk of Court 

Russell L. Benoit, Acadia Parish Assessor 

 Thomas Benoit, Acadia Parish Police Jury, District 7 

 A.J. Broussard, Acadia Parish Police Jury, District 2 

 Cecelia Broussard, Acadia Parish Police Jury, District 4 

 A.J. Credeur, Acadia Parish Police Jury, District 6 

 John W. Humble, Sr., Acadia Parish Police Jury Vice President, District 3 

 Marietta W. James, Acadia Parish School Board Superintendent 

 Katry Martin, Acadia Parish Police Jury, Secretary-Treasurer 

 Wayne Melancon, Acadia Parish Sheriff 

 Felton Moreau, Acadia Parish Police Jury President, District 8 

 Jimmie Pellerin, Acadia Parish Police Jury, District 5 

 Alton Stevenson, Acadia Parish Police Jury, District 1 

Calcasieu Parish 

 Francis Andrepont, Calcasieu Parish Police Jury, District 13 

Guy Brame, Calcasieu Parish Police Jury, District 8 

Calcasieu Parish Sheriff’s Department Substation 

Calcasieu Police Jury 

 Calcasieu Sherriff’s Prison 

 Brent Clement, Calcasieu Parish Police Jury, District 12 

 Richard Cole, Jr., Calcasieu Parish Assessor 

 Calvin Collins, Calcasieu Parish Police Jury, District 2 

 Mike Danahay, Calcasieu Parish Police Jury, District 15 

 Elizabeth Griffin, Calcasieu Parish Police Jury, District 3 

Kevin Guidry, Calcasieu Parish Police Jury, District 9 

 Tony Guillory, Calcasieu Parish Police Jury, District 4 

 Horace Lynn Jones, II, Calcasieu Parish Clerk of Court 

 Chris Landry, Calcasieu Parish Police Jury, District 7 

 Charles S. Mackey, Calcasieu Parish Police Jury, District 5 

 Don Manuel, Calcasieu Parish Police Jury, District 1 

 Hal McMillin, Calcasieu Parish Police Jury, District 14 

 Cornelius Moon, Calcasieu Parish Police Jury, District 6 

 Wayne Savoy, Calcasieu Parish School Board Superintendent 

 Tony Stelly, Calcasieu Parish Police Jury, District 10 

 Sandy Treme, Calcasieu Parish Police Jury, District 11 

 A-3 Appendix A 
 Jimmy Vickers, Calcasieu Parish Planning and Development Director 

 West Calcasieu Managing Board, Southland Field 

Cameron Parish 

 Carl E. Broussard, Cameron Parish Clerk of Court 

 Doug Chance, Cameron Parish School Board Superintendent 

 Douaine Conner, Cameron Parish Police Jury, District 4 

 R.E. Conner, Cameron Parish Assessor 

 James Doxey, Cameron Parish Police Jury, District 6 

Darryl Farque, Cameron Parish Police Jury, District 7 

Magnus McGee, Cameron Parish Police Jury, District 1 

Charles Precht, III, Cameron Parish Police Jury, District 3 

Scott Trahan, Cameron Parish Police Jury, District 5 

Steve Trahan, Cameron Parish Police Jury, District 2 

Evangeline Parish 

 Mitchell Ardoin, Evangeline Parish Police Jury, District 3 

 Dirk Deville, Evangeline Parish Assessor 

 Ronald Doucet, Evangeline Parish Police Jury, District 8 

 Evangeline Parish Police Jury 

 Rayford J. Fontenot, Evangeline Parish School Board Superintendent 

Sidney Fontenot, Evangeline Parish Police Jury, District 2 

William Guidry, Evangeline Parish Police Jury, District 7 

Hill Johnson, Evangeline Parish Police Jury, District 4 

Walter Lee, Evangeline Parish Clerk of Court 

“Bob” Manuel, Evangeline Parish Police Jury, District 5 

Davis Manuel, Evangeline Parish Police Jury, District 1 

Wayne Morein, Evangeline Parish Sheriff 

Eric Soileau, Evangeline Parish Police Jury, District 6 

Richard Thomas, Evangeline Parish Police Jury, District 9 

Dale Touchet, Department of Transportation and Development, District 3 

Jefferson Davis Parish 

 Melton Alfred, Jefferson Davis Parish Police Jury, District 3 

 Robert J. Broussard, Jefferson Davis Parish Police Jury, District 8 

Don Davis, Jefferson Davis Parish Police Jury, District 10 

Carlton L. Duhon, Jefferson Davis Parish Clerk of Court 

Bradley Eastman, Jefferson Davis Parish Police Jury, District 4 

Steve Eastman, Jefferson Davis Parish Police Jury, District 7 

Richard Edwards, Jr., Jefferson Davis Parish Sheriff 

Leroy A. Faul, Jefferson Davis Parish Police Jury Vice President, District 11 

Larry James Fontenot, Jefferson Davis Parish Police Jury, District 9 

Pierre J. Galley, Jefferson Davis Parish Police Jury, District 13 

Johnny Guinn, Jefferson Davis Parish Police Jury, District 5 

Jefferson Davis Parish Police Jury 

 Jefferson Davis Sherriff’s Office 

 Donald G. Kratzer, Jefferson Davis Parish Assessor 

 Harry B. Levy, Jefferson Davis Parish Police Jury, District 6 

 John P. Marceaux, Jefferson Davis Parish Police Jury, District 2 

 Tommy L. Smith, Jefferson Davis Parish School Board Superintendent 

 A-4 Appendix A 
 Bill Wild, Jefferson Davis Parish Police Jury, District 12 

 Donald Woods, Jefferson Davis Parish Police Jury President, District 1 

St. Landry Parish 

 Wayne Ardoin, St. Landry Parish Council, District 9 

 Bruce Boudreaux, St. Landry Parish Council, District 1 

 Dexter Q. Brown, St. Landry Parish Council, District 10 

Ronald Buschel, St. Landry Parish Council, District 5 

Gary Courville, St. Landry Parish Council, District 13 

Ronald Dugas, St. Landry Parish Council, District 8 

 Rhyn Duplechain, St. Landry Parish Assessor 

 Huey Dupre, St. Landry Parish Council, District 4 

 Hurlin Dupre, St. Landry Parish Council, District 6 

 James Eaglin, St. Landry Parish Council, District 2 

William Gil, St. Landry Parish Council, District 12 

Albert Hollier, St. Landry Parish Council, District 7 

Charles Jagneaux, St. Landry Parish Clerk of Court 

Donald Menard, St. Landry Parish, President 

Keith O. Miller, St. Landry Parish Council, District 11 

Pat Miller, St. Landry Parish Council, District 3 

 Larry Moreau, St. Landry Parish, School Board Superintendent 

Howard Zerangue, St. Landry Parish Sheriff 

Town Agencies

Chaderick Hebert, Town of Arnaudville Alderman, Arnaudville, LA 

Elsie H. Lagrange, Town of Arnaudville Alderman, Arnaudville, LA 

Ricky J. Lagrange, Town of Arnaudville Alderman, Arnaudville, LA 

Remi Olivier, Town of Arnaudville Alderman, Arnaudville, LA 

Kathy M. Richard, Mayor, Town of Arnaudville, Arnaudville, LA 

John Ray Taylor, Town of Arnaudville Alderman, Arnaudville, LA 

Basile Police Station, Basile, LA 

Rodney J. Bellon, Town of Basile Alderman, District 1, Basile, LA 

Berline Boone, Mayor, Town of Basile, Basile, LA 

Frank Ceasar, Town of Basile Alderman, District 3, Basile, LA 

Jessica G. Denette, Town of Basile Alderman, District 4, Basile, LA 

Ronnie Denette, Town of Basile Alderman, At Large, Basile, LA 

John Jenkins, Town of Basile Alderman, District 2, Basile, LA 

Bart Daigle, Village of Cankton Alderman, Cankton, LA 

Camile J.R. Menard, Village of Cankton Alderman, Cankton, LA 

Susan Menard, Mayor, Village of Cankton, Cankton, LA 

Gladys Myers Soileau, Village of Cankton Alderman, Cankton, LA 

Daniel Brasseaux, Village of Chataignier Alderman, Chataignier, LA 

Chataignier Volunteer Fire Department, Chataignier, LA 

Lucy Jones Green, Village of Chataignier Alderman, Chataignier, LA 

Herman Malveaux, Mayor, Village of Chataignier, Chataignier, LA 

Alton Thomas, Jr., Village of Chataignier Alderman, Chataignier, LA 

 A-5 Appendix A 
Roger Boudreaux, Mayor, Town of Church Point, Church Point, LA 

Theresa R. Carey, Town of Church Point Alderman, Ward 4, Church Point, LA 

Errol “SLU” Comeaux, Town of Church Point Alderman, Ward 5, Church Point, LA 

Gary J. Duplechin, Town of Church Point Alderman, Ward 3, Church Point, LA 

Mel Green, Town of Church Point Alderman, Ward 1, Church Point, LA 

Amber Higginbotham, Town Clerk, Town of Church Point, Church Point, LA 

Alexis Jagneaux, Town of Church Point Alderman, Ward 2, Church Point, LA 

James M. Buatt, Jr., City of Crowley Alderman, Ward 2, Division A, Crowley, LA 

Isabella DelaHoussaye, Mayor, City of Crowley, Crowley, LA 

Anthony Istre, City of Crowley Alderman, Ward 1, Division A, Crowley, LA 

Judy Istre, City Clerk, City of Crowley, Crowley, LA 

Vernon Martin, City of Crowley Alderman, Ward 3, Division A, Crowley, LA 

Mary Melancon, City of Crowley Alderman, Ward 4, Division B, Crowley, LA 

Laurita D. Pete, City of Crowley Alderman, Ward 3, Division B, Crowley, LA 

Steven C. Premeaux, City of Crowley Alderman, At Large, Crowley, LA 

Ira G. Thomas, City of Crowley Alderman, Ward 2, Division B, Crowley, LA 

“Kitty” Valdetero, City of Crowley Alderman, Ward 1, Division B, Crowley, LA 

Jerry Bell, Mayor, City of DeQuincy, DeQuincy, LA 

W. Tracey Brown, City Council, District 2, City of DeQuincy, DeQuincy, LA 

Andrea Coleman-Williams, City Council, District 4, City of DeQuincy, DeQuincy, LA 

Lawrence Henagan, City Council, District 3, City of DeQuincy, DeQuincy, LA 

Denise W. Maddox, City Council, At Large, City of DeQuincy, DeQuincy, LA 

Tammy Pinder, Town Clerk, City of DeQuincy, DeQuincy, LA 

Lynne Treme, City Council, District 1, City of DeQuincy, DeQuincy, LA 

Gerald Alleman, Town of Duson Alderman, Duson, LA 

Dwayne Bowers, Town of Duson Alderman, Duson, LA 

Eugene Cahanin, Town of Duson Alderman, Duson, LA 

Jimmy A. Champagne, Town of Duson Alderman, Duson, LA 

Alvin Felix, Town of Duson Alderman, Duson, LA 

John E. Lagneaux, Mayor, Town of Duson, Duson, LA 

Avella Ackless, Town Clerk, Town of Elton, Elton, LA 

Durffey J. Fontenot, Jr., Town of Elton Council, Elton, LA 

Kim Guidry, Town of Elton Council, Elton, LA 

Alphonse Guillory, Town of Elton Council, Elton, LA 

Cathy Hollingsworth, Mayor, Town of Elton, Elton, LA 

Margaret G. Langley, Town of Elton Council, Elton, LA 

Town of Elton, Elton, LA 

Tracey Doescher Treme, Town of Elton Council, Elton, LA 

Winford Guillory, Village of Estherwood Alderman, Estherwood, LA 

Bill Maples, Mayor, Village of Estherwood, Estherwood, LA 

John Monceaux, Village of Estherwood Alderman, Estherwood, LA 

Emily W. Roy, Village of Estherwood Alderman, Estherwood, LA 

Sandy S. Sarver, Town Clerk, Village of Estherwood, Estherwood, LA 

Nolton Anderson, City of Eunice Alderman, Ward 2, Eunice, LA 

Charles Atchison, City of Eunice Alderman, Ward 4, Eunice, LA 

 A-6 Appendix A 
Jackson Burson, Jr., City of Eunice Alderman, At Large, Eunice, LA 

Eunice Community Medical Center, Eunice, LA 

Eunice Fire Department, Eunice, LA 

Eunice Police Department, Eunice, LA 

Chawna V. Fontenot, City of Eunice Alderman, Ward 3, Eunice, LA 

E. Lynn Lejeune, Mayor, City of Eunice, Eunice, LA 

Louis A. Pavur, City of Eunice Alderman, Ward 1, Eunice, LA 

C. Dale Sittig, Public Service Commission, District 4, Eunice, LA 

Eddie B. Alfred, Village of Fenton Alderman, Fenton, LA 

Darla Kirklin, Town Clerk, Village of Fenton, Fenton, LA 

Wilfred J. LeMelle, Village of Fenton Alderman, Fenton, LA 

Janet Manuel, Mayor, Village of Fenton, Fenton, LA 

Mark S. Reed, Village of Fenton Alderman, Fenton, LA 

Wallace Belson, Jr., Town of Grand Coteau Alderman, Grand Coteau, LA 

Jean Jone Coco, Mayor, Town of Grand Coteau, Grand Coteau, LA 

Wilton Guidry, Town of Grand Coteau Alderman, Grand Coteau, LA 

Robert Landry, Town of Grand Coteau Alderman, Grand Coteau, LA 

David T. Richard, Town of Grand Coteau Alderman, Grand Coteau, LA 

Russell Richard, Jr., Town of Grand Coteau Alderman, Grand Coteau, LA 

R.B. Fontenot, Town of Iota Alderman, Iota, LA 

Iota Fire Department, Iota, LA 

Iota Police Department, Iota, LA 

Troy Lantz, Town of Iota Alderman, Iota, LA 

Cody Leckelt, Town of Iota Alderman, Iota, LA 

Raleigh Miller, Town of Iota Alderman, Iota, LA 

Warren C. Pousson, Town of Iota Alderman, Iota, LA 

Dolores Pousson, Town Clerk, Town of Iota, Iota, LA 

John D. Sittig, Mayor, Town of Iota, Iota, LA 

 

Gerald Guidry, Town of Iowa Council, District E, Iowa, LA 

Larry Hardy, Town of Iowa Council, District B, Iowa, LA 

Iowa Police Department, Iowa, LA 

Iowa Volunteer Fire Department, Iowa, LA 

Jerry R. Lapearous, Town of Iowa Council, District A, Iowa, LA 

Manchester Fire Station, Iowa, LA 

O’Brien Flying Service Airport, Iowa, LA 

Amanda Racca, Mayor, Town of Iowa, Iowa, LA 

Thomas Talbot, Town of Iowa Council, District D, Iowa, LA 

Sandra Turley, Town Clerk, Town of Iowa, Iowa, LA 

Zelia C. Washington, Town of Iowa Council, District C, Iowa, LA 

Johnny Armentor, City of Jennings Council, District B, Jennings, LA 

R. Arthur Berry, City of Jennings Council, District C Jennings, LA 

Norman J. Cain, City Clerk, City of Jennings, Jennings, LA 

City of Jennings Fire Department, Jennings, LA 

City of Jennings Parks and Recreation Department, Jennings, LA 

City of Jennings Police Department, Jennings, LA 

City of Jennings Street Department (Public Works), Jennings, LA 

 A-7 Appendix A 
Jeremy K. Doucet, City of Jennings Council, District E, Jennings, LA 

Terry W. Duhon, Mayor, City of Jennings, Jennings, LA 

Wilbert L. Gilbeaux, City of Jennings Council, District D, Jennings, LA 

Rogeous Lawdins, City of Jennings Council, District A, Jennings, LA 

Keith Ardoin, Town of Krotz Springs Alderman, Krotz Springs, LA 

William H. Bryson, Town of Krotz Springs Alderman, Krotz Springs, LA 

Tony Collette, Town of Krotz Springs Alderman, Krotz Springs, LA 

Mary Lou Lacassin, Town of Krotz Springs Alderman, Krotz Springs, LA 

Gary G. Soileau, Mayor, Town of Krotz Springs Alderman, Krotz Springs, LA 

Donald Williams, Town of Krotz Springs Alderman, Krotz Springs, LA 

Dorothy Charles, Town of Lake Arthur Council, Lake Arthur, LA 

Kirk J. Conner, Town of Lake Arthur Council, Lake Arthur, LA 

Ellsworth Duhon, Town of Lake Arthur Council, Lake Arthur, LA 

E.R. Giles, Mayor, Town of Lake Arthur, Lake Arthur, LA 

David Hanks, Town of Lake Arthur Council, Lake Arthur, LA 

Cindy LaPoint, Town of Lake Arthur Council, Lake Arthur, LA 

Cynthia Mallett, Town of Lake Arthur Council, Lake Arthur, LA 

A.B. Franklin, City of Lake Charles Council, District B, Lake Charles, LA 

Rodney Geyen, City of Lake Charles Council, District C, Lake Charles, LA 

Mike Huber, City of Lake Charles Council, District G, Lake Charles, LA 

Dana Carl Jackson, City of Lake Charles Council, District F, Lake Charles, LA 

Lake Charles Harbor and Terminal District, Lake Charles, LA 

Lake Charles Memorial Hospital, Lake Charles, LA 

Lake Charles Police Department, Lake Charles, LA 

Lake Charles Regional Airport, Lake Charles, LA 

Billy Lofton, City of Lake Charles Attorney, Lake Charles, LA 

David R. Perry, City of Lake Charles Council, District D, Lake Charles, LA 

Randy Roach, Mayor, City of Lake Charles, Lake Charles, LA 

Marshall Simien, City of Lake Charles Council, District A, Lake Charles, LA 

Lynn Thibodeaux, Town Clerk, City of Lake Charles, Lake Charles, LA 

Stuart Weatherford, City of Lake Charles Council, District E, Lake Charles, LA 

Joseph Davis, Town of Leonville Council, Leonville, LA 

Nick Degueyter, Town of Leonville Council, Leonville, LA 

Gayle Hebert, Town of Leonville Council, Leonville, LA 

Joel Lanclos, Jr., Mayor, Town of Leonville, Leonville, LA 

Dorothy L. Meche, Town of Leonville Council, Leonville, LA 

Kerry J. Willingham, Town of Leonville Council, Leonville, LA 

Wilda Chamberlain, Mayor, Town of Mamou, Mamou, LA 

Ricky Fontenot, Town of Mamou Alderman, District 1, Mamou, LA 

Essie Rose Holland, Town of Mamou Alderman, At Large, Mamou, LA 

Mamou City Gas and Water Development, Mamou, LA 

Mamou Fire Department, Mamou, LA 

Mamou Police Department, Mamou, LA 

J.L. Saucier, Town of Mamou Alderman, District 4, Mamou, LA 

Savoy Medical Center, Mamou, LA 

 A-8 Appendix A 
Jody Soileau, Town of Mamou Alderman, District 3, Mamou, LA 

Randall Young, Town of Mamou Alderman, District 2, Mamou, LA 

James W. Fontenot, Town of Melville Council, Melville, LA 

Tony Foret, Town of Melville Council, Melville, LA 

George Guillory, Town of Melville Council, Melville, LA 

Willie Haynes, III, Mayor, Town of Melville, Melville, LA 

Esther M. Anthony Johnson, Town of Melville Council, Melville, LA 

Denise Lee Oliney, Town of Melville Council, Melville, LA 

Peggy Bergeaux, Village of Mermentau Alderman, Mermentau, LA 

Bonnie Dugas, Village of Mermentau Clerk, Mermentau, LA 

Myrtis A. Gautreaux, Mayor, Village of Mermentau, Mermentau, LA 

Gerald Godeaux, Village of Mermentau Alderman, Mermentau, LA 

Darla Istre, Village of Mermentau Alderman, Mermentau, LA 

Leon Clement, Mayor, Village of Morse, Morse, LA 

Wade Clement, Village of Morse Alderman, Morse, LA 

Donlean J. Gary, Village of Morse Alderman, Morse, LA 

Jacob Touchet, Village of Morse Alderman, Morse, LA 

Shella Villejoin, Village of Morse Clerk, Morse, LA 

Gregory T. Castain, City of Opelousas Alderman, District B, Opelousas, LA 

Joe Charles, City of Opelousas Alderman, District E, Opelousas, LA 

Joseph A. Guillory, City of Opelousas Alderman, District A, Opelousas, LA 

Huey Hawkins, City of Opelousas Alderman, District D, Opelousas, LA 

LeRoy R. Payne, City of Opelousas Alderman, At Large, Opelousas, LA 

Dale Pefferkorn, City of Opelousas Alderman, District C, Opelousas, LA 

Judy S. Dupre, Village of Palmetto Alderman, Palmetto, LA 

Nelene Guidroz, Village of Palmetto Alderman, Palmetto, LA 

Lavonya Malveaux, Village of Palmetto Alderman, Palmetto, LA 

Greg Ardoin, Village of Pine Prairie Alderman, Pine Prairie, LA 

Tammy McCauley Hammond, Village of Pine Prairie Alderman, Pine Prairie, LA 

Terry L. Savant, Mayor, Village of Pine Prairie, Pine Prairie, LA 

Quint West, Village of Pine Prairie Alderman, Pine Prairie, LA 

Johnny Ardoin, Town of Port Barre Alderman, Port Barre, LA 

John B. Fontenot, Mayor, Town of Port Barre, Port Barre, LA 

Richard Mobile, Town of Port Barre Alderman, Port Barre, LA 

Polly Pickney, Town of Port Barre Alderman, Port Barre, LA 

Gil Savoy, Jr., Town of Port Barre Alderman, Port Barre, LA 

Bobby Soileau, Town of Port Barre Alderman, Port Barre, LA 

Jude Abshire, City of Rayne Alderman, Ward 2, Rayne, LA 

Gerard L. Arceneaux, City of Rayne Alderman, Ward 3, Rayne, LA 

Gerald Foreman, City of Rayne Alderman, Ward 4, Rayne, LA 

Robert Hebert, City of Rayne Clerk, Rayne, LA 

Paul Molbert, City of Rayne Alderman, At Large, Rayne, LA 

 A-9 Appendix A 
James J. Petitjean, Mayor, City of Rayne, Rayne, LA 

Ann Domingue Washington, City of Rayne Alderman, Ward 1, Rayne, LA 

Arlene Blanchard, Town Clerk, City of Sulphur, Sulphur, LA 

Wilmer Dugas, Town of Sulphur Council Member, District 1, Sulphur, LA 

Chris Duncan, City of Sulphur Council, District 3, Sulphur, LA 

Donna Emmons, City of Sulphur Council, District 2, Sulphur, LA 

Lance Hernandez, City of Sulphur Council, District 5, Sulphur, LA 

Ron LeLeux, Mayor, Town of Sulphur, Sulphur, LA 

Nancy Tower, City of Sulphur Council, District 4, Sulphur, LA 

Dalton Belson, Jr., Town of Sunset Alderman, District 2, Sunset, LA 

Lonnie J. Cormier, Town of Sunset Alderman, District 4, Sunset, LA 

Joseph C. Guidry, Jr., Town of Sunset Alderman, District 3, Sunset, LA 

Bernice R. Lavergne, Town of Sunset Alderman, At Large, Sunset, LA 

Danny J. Louviere, Mayor, Town of Sunset, Sunset, LA 

Joseph Meche, Town of Sunset Alderman, District 1, Sunset, LA 

Bert Keith Campbell, Village of Turkey Creek Council, Turkey Creek, LA 

W.L. Chapelle, Village of Turkey Creek Council, Turkey Creek, LA 

Blaine Jude Janet, Mayor, Village of Turkey Creek, Turkey Creek, LA 

Billy King, Jr., Village of Turkey Creek Council, Turkey Creek, LA 

Carol Alfred, City of Ville Platte Alderman, District B, Ville Platte, LA 

James D. Bordelon, City of Ville Platte Alderman, District C, Ville Platte, LA 

C.J. Dardeau, City of Ville Platte Alderman, District A, Ville Platte, LA 

Earl Edward, City of Ville Platte Alderman, District E, Ville Platte, LA 

Romeo Hargrove, III, City of Ville Platte Chief of Police, Ville Platte, LA 

Freddie J. Jack, City of Ville Platte Alderman, District D, Ville Platte, LA 

Bill Jeanmard, City of Ville Platte Alderman, District F, Ville Platte, LA 

Phil Lemoine, Mayor, City of Ville Platte, Ville Platte, LA 

Ville Platte City Hall, Ville Platte, LA 

Ville Platte Fire Department, Ville Platte, LA 

Ville Platte Medical Center, Ville Platte, LA 

Ville Platte Police Department, Ville Platte, LA 

Ville Platte Utilities Department, Ville Platte, LA 

Karen Douglass, Town of Vinton Council, Vinton, LA 

B.B. Loyd, Jr., Town of Vinton Council, Vinton, LA 

Kevin Merchant, Town of Vinton Council, Vinton, LA 

David T. Riggins, Mayor, Town of Vinton, Vinton, LA 

Edward Vice, Town of Vinton Council, Vinton, LA 

Mary Vice, Town of Vinton Clerk, Vinton, LA 

Wilson Doomes, Sr., Town of Washington Alderman, District 2, Washington, LA 

Wilbert Ledet, Town of Washington Alderman, District 4, Washington, LA 

Joseph Pitre, Mayor, Town of Washington, Washington, LA 

Mark Tompkins, Town of Washington Alderman, District 3, Washington, LA 

Gary J. Wilson, Town of Washington Alderman, District 1, Washington, LA 

Mona C. Wilson, Town of Washington Alderman, At Large, Washington, LA 

 A-10 Appendix A 
Allen Ardoin, Town of Welsh Alderman, Welsh, LA 

Charles Drake, Town of Welsh Alderman, Welsh, LA 

Becky Hudson, Town of Welsh Alderman, Welsh, LA 

Linda LeBlanc, Town of Welsh Clerk, Welsh, LA 

Carolyn Louviere, Mayor, Town of Welsh, Welsh, LA 

Leona M. Vanicor, Town of Welsh Alderman, Welsh, LA 

Gloria Viney, Town of Welsh Alderman, Welsh, LA 

Wally Anderson, City of Westlake Council, Westlake, LA 

Danny Cupit, City of Westlake Council, Westlake, LA 

Dudley Dixon, Mayor, City of Westlake, Westlake, LA 

Holly Fontenot, City of Westlake Clerk, Westlake, LA 

Bob Hardey, City of Westlake Council, Westlake, LA 

Dan Racca, City of Westlake Council, Westlake, LA 

Gerald Washington, City of Westlake Council, Westlake, LA 

Libraries

Evangeline Parish Basile Branch Library, Basile, LA 

Cameron Parish Library, Cameron, LA 

Acadia Parish Churchpoint Branch Library, Churchpoint, LA 

Acadia Parish Library, Crowley, LA 

Acadia Parish Evangeline Branch Library, Evangeline, LA 

Acadia Parish Iota Branch Library, Iota, LA 

Calcasieu Parish Iowa Branch Library, Iowa, LA 

Jefferson Davis Parish Library, Jennings, LA 

Jennings Carnegie Public Library, Jennings, LA 

Calcasieu Parish Public Library, Lake Charles, LA 

Evangeline Parish Mamou Branch Library, Mamou, LA 

Calcasieu Parish Sulphur Branch Library, Sulphur, LA 

Evangeline Parish Library, Ville Platte, LA 

 

Jefferson County Library, Beaumont, TX 

Orange Public Library, Orange, TX 

Media

Basile Weekly, Basile, LA 

Church Point News, Church Point, LA 

Crowley Post-Signal, Crowley, LA 

KSIG-AM, Crowley, LA 

Barry Thompson, KAJN-FM, Crowley, LA 

Cameron Parish Pilot, DeQuincy, LA 

DeQuincy News, DeQuincy, LA 

Eunice News, Eunice, LA 

 Bob Giroir, Editor 

 Jerry Hoffpauir, Press Release Contact 

KEUN-AM/KJJB-FM, Eunice, LA 

Jennings Daily News, Jennings, LA 

Lake Arthur Sun-Times, Lake Arthur, LA 

 A-11 Appendix A 
K13VG, Apex Broadcasting-Ind, Lake Charles, LA 

 Mila Brignac, Press Release Contact 

 Sara Cormier, General Manager 

KAOK-AM, Lake Charles, LA 

KBIU-FM/KXZZ-FM/KYKZ-FM/KXZZ-AM, Lake Charles, LA 

KHLA-FM/KLCL-AM, Lake Charles, LA 

KVHP-TV, FOX, Lake Charles, LA 

 Kerry Anderson, Press Release Contact 

 Eric Zartler, Assignments Editor 

Lagniappe, Lake Charles, LA 

Lake Charles American Press, Lake Charles, LA 

James Serra, KPLC-TV (NBC), Lake Charles, LA 

Shelletta Smith, KPLC-TV (NBC), Lake Charles, LA 

Times of Southwest Louisiana, Lake Charles, LA 

Wandell Allegood, KSLO-AM, Opelousas, LA 

KDCG-TV, PAX, Opelousas, LA 

 Thom Daly, General Manager, Vice President, Press Release Contact 

 Melanie Zerangue, Assignments Editor 

Harlan Kirgan, Daily World, Opelousas, LA 

Johnny Wright, KOGM-FM, Opelousas, LA 

Rayne Acadian-Tribune, Rayne, LA 

Rayne Independent, Rayne, LA 

KEZM-AM, Sulphur, LA 

Southwest Daily News, Sulphur, LA 

Vinton News, Sulphur, LA 

Westlake/Moss Bluff News, Sulphur, LA 

Cleco, Ville Platte, LA 

KVPI-AM and FM, Ville Platte, LA 

Ville Platte Gazette, Ville Platte, LA 

Welsh Citizen, Welsh, LA 

Intervenors

William D. Rapp, Senior Counsel, Sempra Energy, San Diego, CA 

Stacy Van Goor, Director, Federal Regulatory Policy, Sempra Energy, San Diego, CA 

David T. Andril, Vinson & Elkins, LLP, Washington, DC 

Pete W. Frost, Director, Regulatory Affairs, ConocoPhillips Company, Washington, DC 

Joseph W. Lowell, Morgan Lewis & Bockius, LLP, Washington, DC 

Karol Lyn Newman, Morgan Lewis & Bockius, LLP, Washington, DC 

James E. Olson, Vinson & Elkins, LLP, Washington, DC 

Willard J. Evans, Jr., Vice President, The Peoples Gas Light & Coke Company, North Shore Gas 

Company, Chicago, IL 

Gerald T. Fox, The Peoples Gas Light & Coke Company, North Shore Gas Company, Chicago, IL 

Leonard M. Gilmore, General Manager, Supply, Nicor Gas, Aurora, IL 

Bridget E. Shahan, Chief Compliance Officer & Assistant General Counsel, Nicor Gas, Aurora, IL 

Kenneth C. Dothage, Manager, Gas Supply Division, Ameren Energy Fuels and Services Company, St. 

Louis, MO 

Joseph H. Raybuck, Managing Associate General Counsel, Ameren Services Company, St. Louis, MO 

 A-12 Appendix A 
Tania S. Perez, King & Spalding, LLP, New York, NY 

Lisa M. Tonery, King & Spalding, LLP, New York, NY 

Donna Bailey, Managing Counsel, Chevron Global Gas, A Division of Chevron U.S.A. Inc., Houston, TX 

Chuck Cook, Manager, Regulatory Affairs, Chevron Global Gas, A Division of Chevron U.S.A. Inc., 

Houston, TX 

Bruce E. Henderson, Vice President, Finance and Legal, TOTAL GAS & POWER, Houston, TX 

Tim Janisse, Director, Targa Louisiana Field Services LLC, Houston, TX 

Michael L. Jones, Senior Attorney, Plains All American Pipeline, LP, Houston, TX 

Jason F. Leif, Jones Day, Houston, TX 

Cheryl V. Longuet, Co-General Partner, W.L. Vincent Limited Partnership, Houston, TX 

Cary Loughman, Counsel, Targa Louisiana Field Services LLC, Houston, TX 

J. Jeannie Myers, Senior Counsel, Chevron Global Gas, A Division of Chevron U.S.A. Inc., Houston, TX 

Patricia Outtrim, Vice President, Government Affairs, Cheniere LNG, Inc., Houton, TX 

Richard S. Tomaski, Vice President, Pine Prairie Energy Center, LLC, Houston, TX 

Organizations and Individuals

Estate of Phoebe Shoemaker, Eufaula, AL 

Eric R. Leboeuf, Anchorage, AK 

Helen Clooney Humphrey, Mountain View, AK 

Vernon W. Humphrey, Mountain View, AK 

Brandon Fontenot, POA Robert Jason Cleveland, Concord, CA 

Trust of Mary Ball Gassaway, Corte Madera, CA 

Helena Houssiere, Fallbrook, CA 

D’arcy Michael Cashin, Menlo Park, CA 

Emmet J. Cashin, III, Menlo Park, CA 

Bonnie C. Englert, Menlo Park, CA 

Mary Geraldine Lowery Cirello, Newport Beach, CA 

Margaret A. Garlinghouse, San Francisco, CA 

D’arcy J. Owens, San Francisco, CA 

David W. Pettus, San Francisco, CA 

Packett Energy Partnership, Stonington, CT 

Helena Hawthorn, Jacksonville, FL 

Anne E. Edwards, Ocala, FL 

Colonial Pipeline, Alpharetta, GA 

Chemical Waste Management, Inc., Chicago, IL 

Milo C. Albrecht, Morton, IL 

Alice Norinne Winter, Murray, KY 

Ruby A. G. Guillory, Alexandria, LA 

Martin Roy O. Lumber Co. LLC, Alexandria, LA 

 A-13 Appendix A 
Mena J. Bourgeois, Basile, LA 

Cornell P. Fontenot, Basile, LA 

Arista Guidry, Basile, LA 

Joseph L. Johnson, Basile, LA 

Mary Klumpp Johnson, Basile, LA 

William J. Johnson, Basile, LA 

Lottie Rose Y. Keith, Basile, LA 

Rapheal H. & Rebecca C. Klump, Basile, LA 

Felix Klumpp, Basile, LA 

James Ronald & Candace F. Klumpp, Basile, LA 

Marshall D. Klumpp, Basile, LA 

Lejeune Living Trust of 1997, Basile, LA 

Mamou Prarie Farms, Inc., Basile, LA 

Edna S. Redlich, Basile, LA 

Elvin & Theresa F. Vidrine, Basile, LA 

Ethel Klumpp Young, Basile, LA 

John A. Young, Basile, LA 

Russell M. Young, Basile, LA 

Choupique and Sulphur, LLC, Baton Rouge, LA 

Coastal Conservation Association, Baton Rouge, LA 

Donald Ray & Sarah Ann Cowick, Baton Rouge, LA 

Bennett A. Ellender, Baton Rouge, LA 

Paul T. Ellender, Baton Rouge, LA 

Eunice Country Club, Baton Rouge, LA 

Excalibur Land Company, Inc. (The Powell Group), Baton Rouge, LA 

Mary Hamilton, Baton Rouge, LA 

Sara Lang, Baton Rouge, LA 

Louisiana Charter Boat Society, Baton Rouge, LA 

Irma K. Moore, Baton Rouge, LA 

Charles and Debra Montgomery, Bell City, LA 

Charlinda, Inc., Cameron, LA 

J.P. Constance, Cameron, LA 

Charles F. Hebert, Cameron, LA 

Howard Romero, Cameron, LA 

Virginia C. Landry, Carencro, LA 

Sabine Outback North, LLC, Carenco, LA 

CCC Holding Co., Carlyss, LA 

Trust of Kevin Pole, Church Point, LA 

Barbara N. Primeaux, Creole, LA 

George W. Guillory Family, LLC, Crowley, LA 

Jeff Davis Farms, Inc., Crowley, LA 

Penny Unverzagt Stefanski, Crowley, LA 

Mary C. Box, DeQuincy, LA 

Frank R. Clifton, DeQuincy, LA 

Thedas Freeman, DeQuincy, LA 

Clifton A. Lee, DeQuincy, LA 

J.W. Patterson, DeQuincy, LA 

Thedas Clifton Robertson, DeQuincy, LA 

Judith A. McClelland Porter, Deville, LA 

Estate of T.O. Allen, Egan, LA 

 A-14 Appendix A 
Dosie Farms, Inc. & Michael & Rousella Dosie, Elton, LA 

Kathleen C. Gorbel, Elton, LA 

4-T Investments, Inc., Eunice, LA 

Rogers Allison, Eunice, LA 

Lindsey J. Aucoin, Eunice, LA 

Bayou State Investment Corp., Eunice, LA 

Pamela Berzas, Eunice, LA 

Michael Dale Bihm, Eunice, LA 

Evana Marie K. Cart, Eunice, LA 

Robert & Shirley Read & Ethelyn Loris Cooper, Eunice, LA 

Derouen Farms, Eunice, LA 

Randy Estes, Eunice, LA 

Darry J. Feucht, Eunice, LA 

Francene A. Fontenot, Eunice, LA 

Patrick Fontenot & Wilda Rose Klumpp Fontenot, Eunice, LA 

Terry G. Fontenot, Eunice, LA 

Warren Frey, Eunice, LA 

Winston J. Frey, Eunice, LA 

Fuselier-Thibodeaux Farms, Inc., Eunice, LA 

Edward L. Gil, Eunice, LA 

Edna K. Granger, Eunice, LA 

Curley Joseph Godeaux & Ruby Ann G. Guillory, Eunice, LA 

Jerry Dale Guidry, Eunice, LA 

W.E. Heinen Farms, Inc., Eunice, LA 

John P. Higgins, Eunice, LA 

Hilary Memorial Trust, Eunice, LA 

Pamela F. Joubert, Eunice, LA 

Harry J. Lafleur, Eunice, LA 

A. Neil Lejeune, Eunice, LA 

J. B. Lewis, Jr. & Lois Lewis, Eunice, LA 

Liberty Six Community Home, Inc., Eunice, LA 

Margaret Loewer, Eunice, LA 

Ruth M. Manuel, Eunice, LA 

Lowell C. McClelland, Eunice, LA 

Douglas A. Medux, Eunice, LA 

Calvin J. Ortego, Jr. & Diane Ortego Brown, Eunice, LA 

Jo Ann Ortego, Eunice, LA 

R. S. Parrott & Pamela Parrott Quirk Estate, Eunice, LA 

Terry J. Pitre, Eunice, LA 

Raymond Klumpp Farms, Inc., Eunice, LA 

Robert & Shirley Read & Ethlyn Loris Cooper, Eunice, LA 

Dulance Reed, Eunice, LA 

Clifton Seale, Eunice, LA 

Michael Simon, Eunice, LA 

Ken Sonnier, Eunice, LA 

Vivian Sonnier, Eunice, LA 

Chester Thibodeaux, Eunice, LA 

Alina Dell Vidrine, Eunice, LA 

Valley Vidrine, Jr., Eunice, LA 

Harvey P. Vigee, Eunice, LA 

Michael S. Ward, Eunice, LA 

 A-15 Appendix A 
Jacob D. Young, Eunice, LA 

Warner G. Duhon, Florien, LA 

Carl Broussard, Grand Chenier, LA 

Butch’s Properties, LLC, Grand Chenier, LA 

Crain Lands, LLC, Grand Chenier, LA 

Curtis Paul Richard, Grand Chenier, LA 

David Y. Doland, Jr., Grand Chenier, LA 

Patrick A. Doland, Grand Chenier, LA 

Leslie Griffith, Grand Chenier, LA 

Lonnie G. Harper, Grand Chenier, LA 

Frances L. Perry, Grand Chenier, LA 

J.C. Reina, Grand Chenier, LA 

Benjamin C. Welch, Grand Chenier, LA 

Dora Mudd Welch, Grand Chenier, LA 

Bishop Geishier Group, Inc., Gretna, LA 

Clara Marie Hebert Olsen Estate, Gretna, LA 

J.E. Vezina, Gretna, LA 

Baja Farms, LLC, Gueydan, LA 

Velma Lowery, Hackberry, LA 

Robert Lee Trajan, Jr., Hackberry, LA 

Gregory & Perri Bourgeois, Iota, LA 

Walter T. & Eula B. Garber, Iota, LA 

Wayne T. & Glenda S. Garber, Iota, LA 

Margaret Guidroz, Iota, LA 

Cindy R. & Joseph C. Joseph, Iota, LA 

Patrick P. Ardoin, Iowa, LA 

Gregory & Perri Bourgeois, Iowa, LA 

Charles D. Bourne, Iowa, LA 

Larry J. Daigle, Iowa, LA 

Paul E. Daigle, Iowa, LA 

John C. Guidry, Iowa, LA 

Mary Ann Spears Guidry, Iowa, LA 

Victor Wayne Guidry, Iowa, LA 

Ralph Paul & Gertrude Hardy, Iowa, LA 

Ray Joseph & Laura Hardy, Iowa, LA 

Wayne A. McVicker, Iowa, LA 

Darren Miller, Iowa, LA 

Phillip W. Miller, Iowa, LA 

Miller & Associates, Iowa, LA 

Michael R. Mott, Iowa, LA 

Arnold Natali, JATKY, Iowa, LA 

Melton D. O’Brien, Iowa, LA 

O’Brien's Flying Service, Iowa, LA 

Philmar, Inc., Iowa, LA 

Michael L. Richard, Iowa, LA 

Southwest Land & Title Co., LLC, Iowa, LA 

Robert & Peggy Stollsteimer, Iowa, LA 

Scott Stollsteimer, Iowa, LA 

Charles D. Thomas, Iowa, LA 

Charles E. Thomas, Iowa, LA 

Kip O. Webb, Iowa, LA 

 A-16 Appendix A 
Linda L. Spears Webb, Iowa, LA 

R. L. Webb, Jr., Iowa, LA 

John A. Weishampel, Iowa, LA 

David & Dawn Augustine, Jennings, LA 

Maurice & Tabatha Benoit, Jennings, LA 

Julie G. Berry, Jennings, LA 

Trudy and Paul Born, Jennings, LA 

Carol P. Bourque, Jennings, LA 

Robert J. & Theresa Broussard, Jennings, LA 

Harold E. Brown, Jennings, LA 

Julie G. Buisson, Jennings, LA 

Daniel R. & Mary Lou Doucet, Jennings, LA 

R. Jean & Elmer Doucet, Jennings, LA 

Sharon Dean Miller Duhon, Jennings, LA 

Douglas P. & Denise L. Dunn, Jennings, LA 

Ronald & Christina Fontenot, Jennings, LA 

William & Theresa P. Habetz, Jennings, LA 

Barbara L. Houssier, Jennings, LA 

Virginia H. Houssier, Jennings, LA 

Anthony Koonce, Jennings, LA 

Larry T. & Patricia Koonce, Jennings, LA 

Larry P. & Marie L. Lacomb, Jennings, LA 

Frank E. Landry, Jennings, LA 

David M. & Joy LeBleu, Jennings, LA 

James F. Lyons, Jennings, LA 

Andree H. Macaluso, Jennings, LA 

Linda Faye Manuel, Jennings, LA 

Richard Farms, Inc., Jennings, LA 

Charles A. Klumpp, Kinder, LA 

Bourgeois Farms, Inc., Lacassine, LA 

Claude & Diana Gotreaux, Lacassine, LA 

Lawrence E., Jr. & Shari R. Kozelski, Lacassine, LA 

Robert & Karen S. Priola, Lacassine, LA 

Margaret Ealin F. Borden, Lafayette, LA 

Brown & Rozas Farms LTD, Lafayette, LA 

Ernest F. Clooney, Jr., Lafayette, LA 

John Sherman and Susan Fallis, Lafayette, LA 

Dawn Ismarie Herrington, Lafayette, LA 

James P. Herrington, Lafayette, LA 

Hilary Memorial Trust, Lafayette, LA 

Harriet M. Landry, Lafayette, LA 

Douglas R. & Janice H. Matte, Lafayette, LA 

Mary Leonise Broussard Perrin, Lafayette, LA 

Joseph B. Powell, Lafayette, LA 

James N. Prather, Lafayette, LA 

Riceland Petro Company, Lafayette, LA 

Shannon E. Stefanski, Lafayette, LA 

R. Allen Benoit, Lake Arthur, LA 

Warner D. Miller, Lake Arthur, LA 

Leona B. Sonnier, Lake Arthur, LA 

3N75 Trust, Lake Charles, LA 

 A-17 Appendix A 
Arrozal, L.L.C., Lake Charles, LA 

Patricia Baggett, Lake Charles, LA 

Belarbor Timber L.L.C., Lake Charles, LA 

Bel-Krause Properties, Lake Charles, LA 

Murphy Bellard and Gregory Rosette, Lake Charles, LA 

Bennett Oil Corporation, Lake Charles, LA 

Harold H. Born, Lake Charles, LA 

Sara Lou Greathouse Brasher, Lake Charles, LA 

Caltrax, Inc., Lake Charles, LA 

Edward M. Carmouche, Jr., Lake Charles, LA 

Clark Real Estate Enterprises, Inc., Lake Charles, LA 

Claudia Bard Trust, Lake Charles, LA 

Katherine K. Blake Trust, Lake Charles, LA 

James Ray Clooney, III, Lake Charles, LA 

Coastal Conservation Association, Lake Charles, LA 

Barbara Coatney, Lake Charles, LA 

Oscar Colletta, Lake Charles, LA 

Francis Coltrin, Lake Charles, LA 

William A. Coltrin, Lake Charles, LA 

Mary Ellen Aucoin Comier, Lake Charles, LA 

C.O. Noble Heirs, Lake Charles, LA 

Joseph K. Cooper, Lake Charles, LA 

Clarence Richmond Corley, Jr., DDS, Lake Charles, LA 

Fay Craft, Lake Charles, LA 

Neil R. Crain, Lake Charles, LA 

Nancy S. Crowe, Lake Charles, LA 

Cypress of Iowa, LLC, Lake Charles, LA 

Simon David Davidson and Sonya Jean Harris, Lake Charles, LA 

Dolores McClelland Duplechin, Lake Charles, LA 

East Ridge Baptist Church, Lake Charles, LA 

Edwin Heirs, Inc., Lake Charles, LA 

Rena Marie Faulk, Lake Charles, LA 

Carol Lavonne Taylor Fraser & Ronald Dale Taylor, Lake Charles, LA 

Phillip Anthony Gayle, Lake Charles, LA 

W.J. Gayle and Sons, Inc., Lake Charles, LA 

Carol M. Gerard, Lake Charles, LA 

Matilda G. Gray, Lake Charles, LA 

Opal Gray Trust, Lake Charles, LA 

Matilda Geddings Gray Trust, Lake Charles, LA 

Arlen L. Greathouse, Lake Charles, LA 

Carroll L. Greathouse, Lake Charles, LA 

Laurence Ray Greathouse, Lake Charles, LA 

Greathouse Living Trust of 1998, Lake Charles, LA 

Richard D. Griffith, Lake Charles, LA 

C.E. Guidry, Lake Charles, LA 

L.R. Henry Estate, Lake Charles, LA 

Allan C. House, Lake Charles, LA 

Kerry A. House, Lake Charles, LA 

Ernest C. Hunt, Jr., Lake Charles, LA 

JAPER, INC., Lake Charles, LA 

JATS Real Estate LLC, Lake Charles, LA 

 A-18 Appendix A 
J. S. Broussard Farms, LLC, Lake Charles, LA 

King Minerals, LLC, Lake Charles, LA 

Robert Sere Kleinschmidt, Lake Charles, LA 

Gary G. Klumpp, Lake Charles, LA 

Mary A. Kohnke, Lake Charles, LA 

LA Farm and Livestock Co., Inc., Lake Charles, LA 

Lisa Ann Lacomb, Lake Charles, LA 

Zoe B. Lassman, Lake Charles, LA 

William B. Lawton, L.P., Lake Charles, LA 

Louis Milton LeBleu, Lake Charles, LA 

Janet S. Leboeuf, Lake Charles, LA 

Lejeune Family Trust, Lake Charles, LA 

LMD Investments Ltd. Partnership, Lake Charles, LA 

Louisiana Farm and Livestock Company, Inc., Lake Charles, LA 

Louisiana State University Agricultural Center, Lake Charles, LA 

Ernest Lawrence Lowery, Jr., Lake Charles, LA 

Sue N. McCardle, Lake Charles, LA 

Merlin Joseph McFarlain, Jr., Lake Charles, LA 

McNeese State University, Lake Charles, LA 

Olan Menard, Lake Charles, LA 

Warner D. Miller, Lake Arthur, LA 

Randall Moorehead, Lake Charles, LA 

North American Land Co. LLC, Lake Charles, LA 

James Nunez, Lake Charles, LA 

Leo Pierre Olivier, Jr., Lake Charles, LA 

Open A-1 Ranch, Inc., Lake Charles, LA 

Joseph D. Painter, Lake Charles, LA 

PBA Properties, L.L.C., Lake Charles, LA 

Powell Land Holdings, LLC, Lake Charles, LA 

Prairie Land Company, Lake Charles, LA 

R.L.P. Land Enterprises, Inc., Lake Charles, LA 

Clint Simien Estate, Lake Charles, LA 

Leona B. Sonnier, Lake Arthur, LA 

Gordon E. Steen, Lake Charles, LA 

Todd A. Stein, Lake Charles, LA 

Stream Family Ltd. Partnership, Lake Charles, LA 

Stream Land Title Co. Inc., Lake Charles, LA 

Thomas Randolph Swayzee III, Ed. Trust, Lake Charles, LA 

Sweetlake Land & Oil, LLC, Lake Charles, LA 

Thomas Cecil Steen, Jr., Lake Charles, LA 

TLC Trust, Lake Charles, LA 

Ricky Tommasi P&E, LLC, Lake Charles, LA 

Tower Land Company, Inc., Lake Charles, LA 

Raymond Wayne Vincent, Lake Charles, LA 

White Lake Preservation, Inc., Lake Charles, LA 

Willis Noland Testamentary Trust, Lake Charles, LA 

Wise Land and Title Co. Inc., Lake Charles, LA 

WKT Properties, Lake Charles, LA 

Evelyn Elaine Young Schultz, Lake Charles, LA 

Donald A. Young, Lake Charles, LA 

Merrill B. Ardoin, Mamou, LA 

 A-19 Appendix A 
Murphy P. Decou, Mamou, LA 

Kerney J. Doucet, Mamou, LA 

Jason R. Fontenot, Mamou, LA 

Ozeman J. Fontenot, Mamou, LA 

Billy Fusilier & John H. McClelland, Jr., Mamou, LA 

Bruce & Gladys Guillory Farms LLC, Mamou, LA 

Raymond E. Landreneau, Mamou, LA 

Clifton W. Lemoine, Mamou, LA 

Michael S. Manuel, Mamou, LA 

Tiqua J. Manuel, Mamou, LA 

Clancy D. Moliter, Mamou, LA 

Kathrine T. Ortego, Mamou, LA 

Charles Reed & Wesley Reed, Mamou, LA 

Wiston C. Reed, Mamou, LA 

Shannon Blake Richard, Mamou, LA 

David Chad West, Mamou, LA 

Harry L. West, Mamou, LA 

Errol J. Young, Mamou, LA 

Robert C. Waltrip, Mandeville, LA 

Rodney Douglas Vincent, Metairie, LA 

Thibodeaux Land Co., Midland, LA 

James L. Negley, Monroe, LA 

George L. Winter, Monroe, LA 

Garbarino Trust #1, New Orleans, LA 

Helena Houssiere, New Orleans, LA 

Showalter A. Knight, Jr., New Orleans, LA 

Timothy W. Giles, Oakdale, LA 

Rex Odoin, Oakdale, LA 

E.M. Boagni Heirs, Opelousas, LA 

N.H. Hirsch Trust for Wienstien Children, Opelousas, LA 

Opelousas St. Landry Realty Co., Inc., Opelousas, LA 

Katherine Tolladay-Gingher, Prescott-Valley, LA 

Carolyn Bruner Trust, Rayne, LA 

Randall K. & Martha M.B. Johnson, Rayne, LA 

Freddie Miller, Rayne, LA 

Johnny R. & Judith A.G. Miller, Rayne, LA 

Rodie Ann F. Thibodeaux, Rayne, LA 

E. Norman Garbarino, Jr., Roanoke, LA 

Eva Garbarino, Jr., Roanoke, LA 

Chris B. & Yvone H. Krielow, Roanoke, LA 

James M. Lessard, Roanoke, LA 

James E. Clark, Shreveport, LA 

Donner Properties, Shreveport, LA 

Jerry Scott Lewis, Shreveport, LA 

Leatha C. Monk, Shreveport, LA 

Cameron B. Barr, Slidell, LA 

Shirley R. Richert, Slidell, LA 

Edward B. Baty, Sulphur, LA 

Steven & Angela D. Belshe, Sulphur, LA 

Philip Benoit, Sulphur, LA 

Margaret B. Black, Sulphur, LA 

 A-20 Appendix A 
Lynwood Burkhalter, Sulphur, LA 

Dennis Clyde Carruth, Sulphur, LA 

C.E. Beckenstein Living Trust, Sulphur, LA 

Judith Clifton Bennett, Sulphur, LA 

Kenneth Len and Theresa Diana Broussard, Sulphur, LA 

Robert E. Broussard & Sarah O. Broussard, Sulphur, LA 

David Chreitien, Sulphur, LA 

Rita Sarver Clement, Sulphur, LA 

George G. Corbello, Sr. & Mary Ruth Corbello, Sulphur, LA 

Richard S. Dowden, Sulphur, LA 

Paul Drounette, Jr., Sulphur, LA 

Sam P. Dugas, Sulphur, LA 

Matthew D Duhon, Sulphur, LA 

Michael A Farque, Sulphur, LA 

Barbara Marie Bahnsen Ford, Sulphur, LA 

Global Industries, Ltd., Sulphur, LA 

Mary S. Granger, Sulphur, LA 

J. Lawton Company, Sulphur, LA 

J.E. Trust, Sulphur, LA 

Alton Joseph and Marlene Manuel, Sulphur, LA 

Llewellyn Edward Kyle, Jr. and Jerlene, Sulphur, LA 

Estelle Walker Lovejoy, Sulphur, LA 

Alton J. Manuel, Sulphur, LA 

David L, Miller, Sulphur, LA 

Mark L. Mitchell, Sulphur, LA 

Robert E. Moss, Jr., Sulphur, LA 

Palermo Co., Sulphur, LA 

Arthur Planchard, Sulphur, LA 

Phillip Quinn, Sulphur, LA 

Barry E. Russell, Sulphur, LA 

James Monroe Stark, Jr. & Kala Stark, Sulphur, LA 

Raymond J. Stein, Sulphur, LA 

Todd Anthony Stein, Sulphur, LA 

Agnes Gary Stutes, Sulphur, LA 

Brenda Sue Sumpter, Sulphur, LA 

Roger Allen Sumpter, Sulphur, LA 

Winnie L. Sumpter, Sulphur, LA 

Winnie Marie Vincent Sumpter, Sulphur, LA 

Thomas-Perkins LLC, Sulphur, LA 

John Rudy Trahan, Sulphur, LA 

Robert Lee Trajan, Jr., Sulphur, LA 

James Calvin Vallette, Sulphur, LA 

Steven K. Vallette, Sulphur, LA 

Martha Ann Clifton Vasquez, Sulphur, LA 

Terry Lee Veillon, Sulphur, LA 

Charles W. Vincent, Sulphur, LA 

W. L. Vincent, LP, Sulphur, LA 

Linda L. West, Sulphur, LA 

Marion L. West, Sulphur, LA 

Rupert Elton West, Sulphur, LA 

James T. Williams, Sulphur, LA 

 A-21 Appendix A 
Margaret L. Williams, Sulphur, LA 

Cephus Mitchell Estate, Ventress, LA 

Cephus R. Duhon, Ventress, LA 

Darryl Wayne Attales, Ville Platte, LA 

Joseph M. Belleau, Ville Platte, LA 

Lawrence E. Buller, Ville Platte, LA 

Lucas Buller, Ville Platte, LA 

Harold L. Charlie, Ville Platte, LA 

Haudry Douget, Ville Platte, LA 

Charles Dupre, Ville Platte, LA 

Christopher J. Fontenot, Ville Platte, LA 

James V. Fontenot, Ville Platte, LA 

Donald W. Fuselier, Ville Platte, LA 

Margaret Theresa P. Johnson, Ville Platte, LA 

Johnson Living Trust, Ville Platte, LA 

Mary P. Ortego, Ville Platte, LA 

Willie E. Oslen, Ville Platte, LA 

Adam T. Reed, Ville Platte, LA 

Claude Rozas Farm, Inc., Ville Platte, LA 

J.D. Solieau & Leroy Solieau, Ville Platte, LA 

Joseph L. Soileau, Ville Platte, LA 

Jeffery Viznat, Ville Platte, LA 

John Thomas Lagrone, Vinton, LA 

Gale A. Leger, Vinton, LA 

Costanza Brothers Partnership, Washington, LA 

Benoit Farms, Inc., Welsh, LA 

Christine B. Benoit, Welsh, LA 

Delores Conner, Welsh, LA 

Diamond-W. Inc., Welsh, LA 

Diamond W Ranch, Welsh, LA 

Timothy & Lisa Duplechain, Welsh, LA 

E. Richard Farms, Inc., Welsh, LA 

Fear Farms, Inc., Welsh, LA 

Sue C. Hebert, Welsh, LA 

Elizabeth Meche, et al, Welsh, LA 

Ella M. Meche, Welsh, LA 

Jeffry J. Meche, Welsh, LA 

Kenneth R. Menard, Welsh, LA 

Wayne G. Phenice, Welsh, LA 

Robert B. Ramagos, Welsh, LA 

John T. Richard, Welsh, LA 

Thomas J. Sr. & Mary D. Schexnider, Welsh, LA 

Turf Grass Farms, Inc. & EKS, Inc., Welsh, LA 

Mayo Realty Co. Inc., Westlake, LA 

T.F. Monroe Heirs, Westlake, LA 

 

Jennie S. Pearson, Frederick, MD 

Barbara Jean Stevenson Levine, Potomac, MD 

Sally L. Hammett, Carriere, MS 

Jane M. Tyner, Starkville, MS 

 A-22 Appendix A 
Smith Family Trust, Raleigh, NC 

Union Pacific Railroad, Omaha, NE 

S.A. Mayo Estate, Brooklyn, NY 

Natalie R. Murphy, Camillus, NY 

Thomas Barr, IV, Sag Harbor, NY 

Ivolee Nash, Bethany, OK 

Justin William Darphin, Carney, OK 

Leboueuf Land and Investments, LLC, Idabel, OK 

Renee Tuthill Trusts, Tulsa, OK 

Elazabeth Burkhalter, Clarksville, TN 

Andree H. Macaluso, Austin, TX 

Joan Donaldson Watkins, Austin, TX 

Carl W. Winters, Austin, TX 

Gerald M. Tate Revocable Trust, Baytown, TX 

David W. and Laura Blacksher, Bridge City, TX 

Albin J. and Michelle Judice, Bridge City, TX 

Larry J. Louellen Judice, Bridge City, TX 

Paul M. and Debbie Roy, Bridge City, TX 

Winnie L. Hebert, Canyon Lake, TX 

Barbara Alice G. Bounds, Carthage, TX 

Winifred Vetha Adkins Hutchinson, Dallas, TX 

RR-Northern Burlington-Santa Fe, Fort Worth, TX 

Richard E. and Joanna Jones, Grove, TX 

Tillman Sylvester, Highlands, TX 

Tillman Sylvester Living Trust, Highlands, TX 

Amoco Production Company, BP Amoco Production Company, Houston, TX 

Frank M. Brown, Houston, TX 

Malloy B. Brown, Houston, TX 

Karen Gwen Hill Carnes, Houston, TX 

Clarence L. Cooper, Houston, TX 

H.D. Cox Estate, Houston, TX 

Domatti Family Living Trust, Houston, TX 

Nanette Clooney Edwards, Houston, TX 

Mildred M. Farley, Houston, TX 

Florida Gas Transmission Company, Property Tax Department, Houston, TX 

Byng Hall, Houston, TX 

Earl W. Horne Jr., Houston, TX 

Charles R. Houssier, III, Houston, TX 

Dorothy C. Kerr, Houston, TX 

Henry Little Estate, Jeanne Jard, Houston, TX 

Callie Attales Martin, Houston, TX 

Propylene Pipeline Partnership LP, Houston TX 

John C. Russell, Houston, TX 

Sabine Pipeline LLC, Houston, TX 

TEPI, Chevron Texaco, Houston, TX 

 A-23 Appendix A 
Transco Gas Pipeline Corp., Houston, TX 

Vintage Petroleum Inc., Houston, TX 

Charles M. Welch, Houston, TX 

William L. Welch, Houston, TX 

S.A. Fairchild Heirs, Jasper, TX 

John B. Daigle Estate, Kerrville, TX 

Roy H. Donaldson, Jr., et al, Kerrville, TX 

Brenda E. Bell Roberts, Kerrville, TX 

J.C. Tracy Estate, Lake Jackson, TX 

Clyde Kilpatrick, Matagorda, TX 

Eunice R. Beckenstein, Orange, TX 

David B. Brown, Orange, TX 

E.W. Brown, Jr., Orange, TX 

Michael Slade Brown, Orange, TX 

Lee Ann Coulter, Orange, TX 

Barbara Lucille Brown Ewing, Orange, TX 

Mary Robbins Brown Jones, Orange, TX 

John S. Brown LA Trust, Orange, TX 

R.E. Odom, Orange, TX 

Joe V. Duhon, Pearland, TX 

C.C.C. Holding Company, Plano, TX 

Lady Ellen Clark, San Antonio, TX 

Elaine Clooney Whitehead, San Antonio, TX 

E.W. Brown, IV, Seabrook, TX 

Robert E. Houssiere, Seguin, TX 

Mary Henderson, Silsbee, TX 

Marjorie W. Fann, Spring, TX 

C.L. Beckenstein, Jr., Land & Royalty Trust, Stafford, TX 

J.H. Minton, Tyler, TX 

Elmer L. Ellender, Vidor, TX 

 

John F. Hennessey, Carlsborg, WA 

Linn M. Gassaway, Poulsbo, WA 

Lehman Farms, LLC, New Berlin, WI 

Ellen L. Thewis, Cartigny, Switzerland 

 A-24 Appendix A 
APPENDIX B 

FACILITY LOCATION MAPS
[This page intentionally left blank] 
 B-1 

Non-Internet Public 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

KINDER MORGAN LOUISIANA PIPELINE PROJECT 

Docket No. CP06-449-000 

Pages B-1 to B-27 

Maps 

Public access for this Non-Internet Public information is available only thr

Reference Room, or by e-mail at public.referenceroom@ferc.g
[This page intentionally left blank]
APPENDIX C 

LAND REQUIREMENTS FOR EXTRA WORKSPACES, ACCESS ROADS, AND 

PIPE STORAGE AND CONTRACTOR YARDS 
 [This page intentionally left blank.] 
 C-1 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

Leg 1 and Leg 2

0.4 Transportation, Communications, 

and Utilities 

0.6 Industrial 637 Cameron 0.00 0.02 Staging Area, Tie-In & Fabrication 

Area 

0.2 Nonforested Wetland 

0.1 Industrial

638 Cameron 0.01 0.04 Fabrication Area & P.I. 

0.1 Nonforested Wetland 

639 Cameron 0.09 0.12 Waterbody Crossing 0.2 Nonforested Wetland 

640 Cameron 0.09 0.12 Waterbody Crossing 0.2 Nonforested Wetland 

641 Cameron 0.21 0.24 Waterbody Crossing & P.I. 0.2 Industrial 

642 Cameron 0.27 0.29 Waterbody Crossing 0.1 Forested Wetland 

0.3 Nonforested Wetland 

643 Cameron 0.52 0.60 Fabrication Area, Access & P.I. 

0.1 Transportation, Communications, 

and Utilities 

0.3 Nonforested Wetland 

644 Cameron 0.54 0.57 Fabrication Area & P.I. 

0.1 Transportation, Communications, 

and Utilities 

645 Cameron 0.85 0.95 Foreign Line Crossing, Crossover & 

P.I. 0.6 Nonforested Wetland 

0.1 Nonforested Wetland 

647 Cameron 0.95 1.02 Fabrication Area, P.I. & Crossover 

0.3 Mixed Urban or Built-up Land 

646 Cameron 0.99 1.02 P.I. 0.2 Mixed Urban or Built-up Land 

648 Cameron 1.00 1.07 Road Crossing & Foreign Line 

Crossing 0.1 Nonforested Wetland 

0.3 Nonforested Wetland 

0.1 Transportation, Communications, 

and Utilities 649 Cameron 1.07 1.15 Road Crossing, Fabrication Area, 

Access & P.I. 

0.1 Mixed Urban or Built-up Land 
 C-2 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

0.1 Industrial 

0.4 Nonforested Wetland 650 Cameron 1.16 1.27 Fabrication Area, Foreign Line 

Crossing, P.I. & Road Crossing 

0.0 Transportation, Communications, 

and Utilities 

0.1 Transportation, Communications, 

and Utilities 

0.9 Nonforested Wetland 651 Cameron 1.23 1.31 Road Crossing, Staging Area & 

Fabrication Area 

0.1 Industrial 

0.4 Nonforested Wetland 

652 Cameron 1.34 1.44 Road Crossing, Foreign Line 

Crossing, Access & Fabrication Area 0.1 Deciduous Forest Land 

653 Cameron 1.37 1.42 Road Crossing & Foreign Line 

Crossing 0.3 Nonforested Wetland 

655 Cameron 1.44 1.51 Road Crossing & Fabrication Area 0.3 Nonforested Wetland 

0.1 Deciduous Forest Land 

654 Cameron 1.46 1.50 Road Crossing 

0.2 Nonforested Wetland 

25 

HDD Cameron 3.89 3.94 HDD Site -Entry Hole 1.1 Nonforested Wetland 

24 

HDD Cameron 4.82 4.87 HDD Site -Exit Hole 2.1 Lakes 

537 Cameron 5.54 5.81 Pull String 1.5 Lakes 

536 Cameron 17.15 17.89 Pull String 4.1 Lakes 

23 

HDD Cameron 17.86 17.97 HDD Site -Exit Hole 5.7 Lakes 

670 Orange 

County, TX 17.92 18.18 Fabricate Pull String 4.8 Bays and Estuaries 

535 Orange 

County, TX 18.09 18.56 Pull String 7.2 Bays and Estuaries 

535 Cameron 18.51 18.57 Pull String 0.5 Bays and Estuaries 
 C-3 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

0.0 Shrub and Brush Rangeland 22 

HDD Cameron 18.55 18.66 HDD Site -Entry & Exit Hole 

2.9 Bays and Estuaries 

21 

HDD Cameron 19.36 19.5 HDD Site -Entry Holes 4.0 Bays and Estuaries 

20 

HDD Cameron 20.00 20.04 HDD Site -Exit Hole 1.1 Deciduous Forest Land 

1.3 Bays and Estuaries 

534 Cameron 20.00 20.04 HDD & Work Corridor Access 

0.1 Deciduous Forest Land 

0.0 Deciduous Forest Land 

557 Cameron 20.04 20.98 Pull String 

5.7 Bays and Estuaries 

0.4 Bays and Estuaries 

531 Cameron 20.90 21.04 Pull String Access 

0.5 Nonforested Wetland 

0.1 Nonforested Wetland 

532 Cameron 21.02 21.07 P.I. 

0.1 Shrub and Brush Rangeland 

0.5 Nonforested Wetland 

19 

HDD Cameron 21.14 21.19 HDD Site -Exit Hole 

0.6 Shrub and Brush Rangeland 

0.2 Nonforested Wetland 

574 Cameron 21.14 21.19 HDD & Work Corridor Access 1.1 Bays and Estuaries 

0.1 Shrub and Brush Rangeland 

577 Cameron 21.68 22.11 Pull String 3.8 Nonforested Wetland 

575 Cameron 22.05 22.17 HDD & Work Corridor Access 1.7 Bays and Estuaries 

0.1 Bays and Estuaries 576 Cameron 22.08 22.14 Access 

0.2 Forested Wetland 

0.1 Forested Wetland 

18 

HDD Cameron 22.08 22.14 HDD Site -Entry Hole 1.1 Nonforested Wetland 
 C-4 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

26 

HDD Cameron 22.69 22.74 HDD Site -Entry Holes 1.1 Nonforested Wetland 

1.2 Bays and Estuaries 

578 Cameron 22.69 22.74 HDD & Work Corridor Access 

0.5 Nonforested Wetland 

27 

HDD Cameron 23.43 23.49 HDD Site -Exit & Entry Hole 1.4 Shrub and Brush Rangeland 

0.4 Shrub and Brush Rangeland 

579 Cameron 23.44 23.48 HDD & Work Corridor Access 

1.7 Bays and Estuaries 

0.1 Bays and Estuaries 

580 Cameron 23.48 23.56 Pull String 

0.9 Shrub and Brush Rangeland 

0.9 Streams and Canals 

581 Cameron 23.82 23.86 Access 

0.1 Nonforested Wetland 

582 Cameron 23.86 24.48 Pull String 3.7 Bays and Estuaries 

0.9 Shrub and Brush Rangeland 28 

HDD Cameron 23.91 23.96 HDD Site -Exit Hole 

0.2 Nonforested Wetland 

530 Cameron 24.21 24.26 Foreign Line Crossing 0.3 Nonforested Wetland 

582 Calcasieu 24.47 24.59 Pull String 0.9 Bays and Estuaries 

529 Cameron 24.57 24.62 P.I. 0.2 Nonforested Wetland 

0.7 Nonforested Wetland 

29 

HDD Calcasieu 25.22 25.28 HDD Site -Exit Hole 

0.4 Deciduous Forest Land 

583 Calcasieu 25.80 25.86 HDD Access & Loading Area 0.7 Streams and Canals 

0.2 Deciduous Forest Land 

0.1 Transportation, Communications, 

and Utilities 584 Calcasieu 25.80 25.83 Access & Loading Area 

0.0 Streams and Canals 

30 

HDD Calcasieu 26.00 26.05 HDD Site -Entry Holes 1.4 Deciduous Forest Land 
 C-5 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

0.0 Cropland and Pasture 31 

HDD Calcasieu 26.78 26.83 HDD Site -Exit Hole 

1.1 Deciduous Forest Land 

585 Calcasieu 27.58 27.64 Access & Loading Area 0.7 Streams and Canals 

0.0 Streams and Canals 

0.1 Transportation, Communications, 

and Utilities 586 Calcasieu 27.58 27.60 Access & Loading Area 

0.3 Shrub and Brush Rangeland 

0.1 Nonforested Wetland 

0.1 Cropland and Pasture 

0.0 Transportation, Communications, 

and Utilities 

0.1 Forested Wetland 

587 Calcasieu 27.81 27.86 Foreign Line Crossing 

0.1 Deciduous Forest Land 

0.1 Cropland and Pasture 

0.3 Nonforested Wetland 

0.1 Deciduous Forest Land 

588 Calcasieu 28.26 28.33 Foreign Line Crossing 

0.1 Forested Wetland 

0.4 Nonforested Wetland 

523 Cameron 29.46 29.90 Pull String 

2.5 Bays and Estuaries 

2.0 Bays and Estuaries 

523 Calcasieu 29.88 30.33 Pull String 

0.9 Nonforested Wetland 

16 

HDD Calcasieu 30.32 30.38 HDD Site -Exit Hole 1.1 Nonforested Wetland 

522 Calcasieu 31.37 31.43 Work Corridor Access 0.7 Streams and Canals 

0.1 Streams and Canals 

521 Calcasieu 31.39 31.42 Loading & Unloading Area 

0.1 Deciduous Forest Land 
 C-6 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

15 

HDD Calcasieu 31.43 31.50 HDD Site -Entry Holes 1.8 Nonforested Wetland 

13 

HDD Calcasieu 32.41 32.46 HDD Site -Exit Hole 1.1 Nonforested Wetland 

0.6 Streams and Canals 

518 Calcasieu 32.43 32.50 Work Corridor Access 

0.1 Deciduous Forest Land 

517 Calcasieu 32.45 32.49 Loading & Unloading Area 0.2 Deciduous Forest Land 

514 Calcasieu 35.15 35.19 Fabrication Area, Access & P.I. 0.7 Nonforested Wetland 

513 Calcasieu 36.17 36.21 Waterbody Crossing & Fabrication 

Area 0.2 Cropland and Pasture 

512 Calcasieu 36.24 36.28 Waterbody Crossing & Access 0.2 Cropland and Pasture 

0.5 Cropland and Pasture 

0.1 Nonforested Wetland 511 Calcasieu 36.50 36.60 

Waterbody Crossing, Road Crossing, 

Foreign Line Crossing, Fabrication 

Area & Access 

0.1 Transportation, Communications, 

and Utilities 

0.3 Cropland and Pasture 

510 Calcasieu 37.29 37.36 Waterbody Crossing & Access

0.0 Nonforested Wetland 

509 Calcasieu 37.84 37.87 Waterbody Crossing 0.1 Nonforested Wetland 

1.0 Nonforested Wetland 

508 Calcasieu 37.89 37.98 0.0 Streams and Canals 

Road Crossing, Waterbody Crossing, 

Fabrication Area, Access & Truck 

Turnaround 

0.1 Transportation, Communications, 

and Utilities 

507 Calcasieu 37.98 38.01 Waterbody Crossing & Road Crossing 0.2 Nonforested Wetland 

506 Calcasieu 38.11 38.23 Drag Section 0.7 Nonforested Wetland 

505 Calcasieu 38.34 38.40 Waterbody Crossing, Road Crossing 

& Access 0.0 Nonforested Wetland 

0.1 Nonforested Wetland 

503 Calcasieu 38.86 38.90 Waterbody Crossing 

0.1 Cropland and Pasture 

0.1 Nonforested Wetland 

504 Calcasieu 38.94 38.96 Waterbody Crossing 0.0 Cropland and Pasture 

0.6 Cropland and Pasture 
 C-7 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

0.1 Nonforested Wetland 

0.2 Cropland and Pasture 

0.0 Streams and Canals 502 Calcasieu 39.06 39.14 Waterbody Crossing, Road Crossing 

& Access 

0.1 Transportation, Communications, 

and Utilities 

501 Calcasieu 39.44 39.46 Waterbody Crossing 0.1 Cropland and Pasture 

500 Calcasieu 39.47 39.49 Waterbody Crossing 0.1 Cropland and Pasture 

589 Calcasieu 39.82 40.04 Pull Section & Access 1.4 Cropland and Pasture 

0.4 Cropland and Pasture 

499 Calcasieu 39.90 39.98 Access & Waterbody Crossing 

0.0 Nonforested Wetland 

498 Calcasieu 40.02 40.09 

Waterbody Crossing, Truck 

Turnaround, P.I. & Foreign Line 

Crossing 

0.5 Cropland and Pasture 

0.0 Nonforested Wetland 

593 Calcasieu 40.29 40.33 Waterbody Crossing, Truck 

Turnaround & Foreign Line Crossing 0.3 Cropland and Pasture 

0.0 Nonforested Wetland 

590 Calcasieu 40.29 40.35 Foreign Line Crossing & P.I. 0.2 Cropland and Pasture 

592 Calcasieu 40.37 40.46 Foreign Line Crossing & Fabrication 

Area 0.6 Cropland and Pasture 

591 Calcasieu 40.43 40.47 Access & P.I. 0.1 Cropland and Pasture 

492 Calcasieu 41.40 41.45 Waterbody Crossing & Fabrication 

Area 0.3 Cropland and Pasture 

491 Calcasieu 41.42 41.44 Waterbody Crossing 0.1 Cropland and Pasture 

490 Calcasieu 41.47 41.49 Waterbody Crossing 0.1 Cropland and Pasture 

617 Calcasieu 41.76 41.81 Fabrication Area & P.I. 0.3 Cropland and Pasture 

594 Calcasieu 41.90 41.96 Fabrication Area & P.I. 0.3 Cropland and Pasture 

489 Calcasieu 41.97 42.01 Staging Area 0.1 Transportation, Communications, 

and Utilities 
 C-8 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

0.8 Cropland and Pasture 

663 Calcasieu 42.01 42.08 Fabrication Area & P.I. 0.4 Cropland and Pasture 

657 Calcasieu 42.18 42.21 Fabrication Area & P.I. 0.2 Cropland and Pasture 

658 Calcasieu 42.18 42.22 Waterbody Crossing & P.I. 0.1 Cropland and Pasture 

488 Calcasieu 42.45 42.47 Waterbody Crossing 0.1 Cropland and Pasture 

487 Calcasieu 42.48 42.50 Waterbody Crossing 0.1 Cropland and Pasture 

0.2 Nonforested Wetland 

659 Calcasieu 42.72 42.76 Waterbody Crossing 

0.0 Cropland and Pasture 

660 Calcasieu 42.79 42.81 Road Crossing & Waterbody Crossing 0.1 Cropland and Pasture 

4.7 Cropland and Pasture 

597 Calcasieu 43.13 43.67 Pull String 

0.1 Streams and Canals 

661 Calcasieu 43.16 43.20 Waterbody Crossing & Fabrication 

Area 0.3 Cropland and Pasture 

662 Calcasieu 43.22 43.25 Waterbody Crossing 0.2 Cropland and Pasture 

596 Calcasieu 43.59 43.66 Fabrication Area, P.I. & Truck 

Turnaround 0.9 Cropland and Pasture 

595 Calcasieu 43.60 43.67 Access 0.2 Cropland and Pasture 

11 

HDD Calcasieu 43.65 43.72 HDD Site -Exit Hole 1.3 Cropland and Pasture 

32 

HDD Calcasieu 44.45 44.51 HDD Site -Entry Hole 1.4 Cropland and Pasture 

598 Calcasieu 44.51 44.54 Truck Turnaround & Fabrication Area 0.9 Cropland and Pasture 

0.0 Streams and Canals 

599 Calcasieu 45.25 45.27 Fabrication Area & P.I. 

0.2 Cropland and Pasture 

476 Calcasieu 45.52 45.53 Waterbody Crossing 0.1 Nonforested Wetland 

475 Calcasieu 45.52 45.54 Waterbody Crossing 0.1 Nonforested Wetland 

473 Calcasieu 45.56 45.58 Waterbody Crossing 0.1 Nonforested Wetland 
 C-9 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

474 Calcasieu 45.56 45.58 Waterbody Crossing 0.1 Nonforested Wetland 

471 Calcasieu 45.76 45.79 Waterbody Crossing & P.I. 0.2 Nonforested Wetland 

472 Calcasieu 45.76 45.80 Waterbody Crossing, Fabrication 

Area, Truck Turnaround & P.I. 0.9 Nonforested Wetland 

470 Calcasieu 45.87 45.90 Waterbody Crossing 0.1 Herbaceous Rangeland 

0.1 Nonforested Wetland 

469 Calcasieu 45.88 45.93 Waterbody Crossing & Truck 

Turnaround 

0.5 Herbaceous Rangeland 

468 Calcasieu 45.93 45.96 Fabrication Area & Waterbody 

Crossing 0.2 Herbaceous Rangeland 

0.4 Nonforested Wetland 

0.0 Transportation, Communications, 

and Utilities 

467 Calcasieu 46.19 46.26 Access 

0.0 Streams and Canals 

466 Calcasieu 46.65 46.67 Waterbody Crossing 0.1 Nonforested Wetland 

465 Calcasieu 46.66 46.68 Waterbody Crossing 0.1 Nonforested Wetland 

464 Calcasieu 46.69 46.71 Waterbody Crossing 0.1 Nonforested Wetland 

463 Calcasieu 46.70 46.73 Waterbody Crossing 0.1 Nonforested Wetland 

0.8 Nonforested Wetland 

0.1 Streams and Canals 460 Calcasieu 46.93 46.98 Waterbody Crossing, Access & 

Staging Area 

0.0 Transportation, Communications, 

and Utilities 

462 Calcasieu 46.94 46.96 Waterbody Crossing 0.1 Nonforested Wetland 

0.2 Nonforested Wetland 

0.0 Streams and Canals 459 Calcasieu 46.96 47.01 Waterbody Crossing & Access 

0.1 Transportation, Communications, 

and Utilities 
 C-10 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

0.0 Transportation, Communications, 

and Utilities 

461 Calcasieu 46.97 47.00 Waterbody Crossing & Access 

0.1 Nonforested Wetland 

458 Calcasieu 47.03 47.05 Waterbody Crossing 0.1 Nonforested Wetland 

558 Calcasieu 47.03 47.05 Waterbody Crossing 0.1 Nonforested Wetland 

457 Calcasieu 47.33 47.35 Waterbody Crossing 0.1 Nonforested Wetland 

456 Calcasieu 47.33 47.35 Waterbody Crossing 0.1 Nonforested Wetland 

0.0 Nonforested Wetland 

454 Calcasieu 47.37 47.39 Waterbody Crossing 

0.1 Herbaceous Rangeland 

0.0 Nonforested Wetland 

455 Calcasieu 47.37 47.39 Waterbody Crossing 

0.1 Herbaceous Rangeland 

453 Calcasieu 47.69 47.74 Road Crossing & Fabrication Area 0.3 Nonforested Wetland 

452 Calcasieu 47.72 47.75 Road Crossing 0.1 Nonforested Wetland 

450 Calcasieu 47.76 47.87 Road Crossing, Fabrication Area & 

P.I. 0.3 Nonforested Wetland 

451 Calcasieu 47.77 47.87 Road Crossing & P.I. 0.3 Nonforested Wetland 

0.1 Cropland and Pasture 

448 Calcasieu 48.23 48.30 P.I. 0.0 Nonforested Wetland 

0.1 Residential 

449 Calcasieu 48.24 48.29 P.I. 0.2 Cropland and Pasture 

0.1 Residential 

447 Calcasieu 48.42 48.49 P.I. 

0.1 Cropland and Pasture 

446 Calcasieu 48.46 48.50 P.I. 0.1 Cropland and Pasture 

0.3 Cropland and Pasture 

562 Calcasieu 49.45 49.51 Access 

0.0 Transportation, Communications, 

and Utilities 
 C-11 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

10 

HDD Calcasieu 49.52 49.58 HDD Site -Exit Hole 1.1 Cropland and Pasture 

444 Calcasieu 49.69 49.72 Equipment Area 0.2 Nonforested Wetland 

443 Calcasieu 49.71 50.44 Pull String 4.7 Nonforested Wetland 

9 

HDD Calcasieu 50.42 50.5 HDD Site -Entry & Exit Hole 1.9 Nonforested Wetland 

442 Calcasieu 51.18 51.19 Equipment Area & Access 0.1 Industrial 

441 Calcasieu 51.19 51.28 Pull String 0.6 Industrial 

8 

HDD Calcasieu 51.28 51.33 HDD Site -Entry Hole 1.4 Industrial 

440 Calcasieu 51.33 51.37 Truck Turnaround 0.9 Industrial 

439 Calcasieu 51.37 51.53 Pull String 0.4 Industrial 

438 Calcasieu 51.71 51.74 Staging Area 0.9 Industrial 

1.1 Industrial 

7 

HDD Calcasieu 51.74 51.79 HDD Site -Exit Hole 

0.1 Transportation, Communications, 

and Utilities 

1.3 Evergreen Forest Land 6 

HDD Calcasieu 52.35 52.41 HDD Site -Entry Holes 0.1 Forested Wetland 

0.1 Streams and Canals 

5 

HDD Calcasieu 53.04 53.08 HDD Site -Exit Hole 

1.0 Cropland and Pasture 

436 Calcasieu 53.48 53.52 Road Crossing, Staging Area & 

Fabrication Area 0.9 Cropland and Pasture 

435 Calcasieu 53.53 53.56 Road Crossing 0.2 Forested Wetland 

434 Calcasieu 53.70 53.72 Waterbody Crossing 0.1 Cropland and Pasture 

433 Calcasieu 53.73 53.75 Waterbody Crossing 0.1 Cropland and Pasture 

432 Calcasieu 53.96 53.98 Waterbody Crossing 0.1 Nonforested Wetland 

431 Calcasieu 54.04 54.08 Waterbody Crossing & Truck 

Turnaround 0.2 Cropland and Pasture 
 C-12 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

0.1 Streams and Canals 

430 Calcasieu 54.06 54.12 Waterbody Crossing, Fabrication Area 

& Truck Turnaround 

0.1 Cropland and Pasture 

0.0 Streams and Canals 

671 Calcasieu 54.14 54.18 Foreign Line Crossing 

0.1 Cropland and Pasture 

672 Calcasieu 54.16 54.21 Foreign Line Crossing 0.1 Cropland and Pasture 

429 Calcasieu 54.50 54.53 Road Crossing & Fabrication Area 0.2 Cropland and Pasture 

427 Calcasieu 54.54 54.57 Road Crossing 0.1 Cropland and Pasture 

428 Calcasieu 54.54 54.57 Road Crossing 0.1 Cropland and Pasture 

425 Calcasieu 55.04 55.08 Waterbody Crossing, Truck 

Turnaround & Fabrication Area 0.8 Cropland and Pasture 

426 Calcasieu 55.04 55.11 Waterbody Crossing & Truck 

Turnaround 0.2 Cropland and Pasture 

424 Calcasieu 55.51 55.54 Road Crossing 0.2 Cropland and Pasture 

422 Calcasieu 55.55 55.58 Road Crossing 0.1 Transitional Areas 

423 Calcasieu 55.55 55.58 Road Crossing 0.1 Transitional Areas 

421 Calcasieu 55.70 55.76 Waterbody Crossing & Fabrication 

Area 0.3 Transitional Areas 

420 Calcasieu 55.73 55.75 Waterbody Crossing 0.1 Transitional Areas 

418 Calcasieu 55.80 55.82 Waterbody Crossing 0.1 Cropland and Pasture 

419 Calcasieu 55.81 55.83 Waterbody Crossing 0.1 Cropland and Pasture 

0.1 Cropland and Pasture 

417 Calcasieu 55.96 56.00 Spread Flop 

0.3 Herbaceous Rangeland 

0.2 Herbaceous Rangeland 

415 Calcasieu 55.97 56.02 Spread Flop 0.1 Cropland and Pasture 

673 Calcasieu 56.31 56.34 

Waterbody Crossing, Foreign Line 

Crossing, Fabrication Area & Truck 

Turnaround 

0.9 Herbaceous Rangeland 
 C-13 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

413 Calcasieu 56.62 56.65 Road Crossing 0.2 Herbaceous Rangeland 

0.0 Nonforested Wetland 

412 Calcasieu 56.67 56.70 Road Crossing, Staging Area & 

Fabrication Area 

0.9 Cropland and Pasture 

0.7 Cropland and Pasture 

563 Calcasieu 56.70 56.94 Waterbody Crossing & P.I. 

0.0 Streams and Canals 

410 Calcasieu 57.62 57.66 Road Crossing & Fabrication Area 0.2 Cropland and Pasture 

0.2 Herbaceous Rangeland 

409 Calcasieu 57.66 57.70 Road Crossing 

0.0 Forested Wetland 

0.1 Herbaceous Rangeland 

408 Calcasieu 57.85 57.92 Road Crossing & Fabrication Area 

0.3 Forested Wetland 

407 Calcasieu 57.92 57.96 Road Crossing 0.2 Cropland and Pasture 

406 Calcasieu 58.35 58.42 Fabrication Area & P.I. 0.3 Cropland and Pasture 

405 Calcasieu 58.51 58.55 Waterbody Crossing & Fabrication 

Area 0.2 Cropland and Pasture 

0.1 Cropland and Pasture 

404 Calcasieu 58.58 58.60 Waterbody Crossing 0.1 Cropland and Pasture 

403 Calcasieu 59.01 59.06 Road Crossing & Fabrication Area 0.3 Cropland and Pasture 

402 Calcasieu 59.07 59.10 Road Crossing 0.2 Cropland and Pasture 

0.7 Nonforested Wetland 

401 Calcasieu 59.66 59.73 Fabrication Area, Spread Flop & 

Foreign Line Crossing 0.1 Transportation, Communications, 

and Utilities 

400 Calcasieu 59.70 59.77 Foreign Line Crossing & P.I. 0.3 Nonforested Wetland 

399 Calcasieu 59.96 60.01 Fabrication Area & P.I. 0.1 Nonforested Wetland 

392 Calcasieu 60.01 60.05 Waterbody Crossing, Fabrication 

Area, Access & P.I. 0.7 Nonforested Wetland 
 C-14 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

391 Calcasieu 60.06 60.08 Waterbody Crossing 0.1 Nonforested Wetland 

390 Calcasieu 60.07 60.14 Waterbody Crossing, Fabrication Area 

& Access 0.8 Nonforested Wetland 

0.1 Nonforested Wetland 

386 Calcasieu 60.19 60.21 Road Crossing 

0.0 Cropland and Pasture 

0.1 Nonforested Wetland 

387 Calcasieu 60.19 60.21 Road Crossing 0.0 Cropland and Pasture 

388 Calcasieu 60.23 60.25 Road Crossing 0.1 Cropland and Pasture 

389 Calcasieu 60.23 60.25 Road Crossing 0.1 Cropland and Pasture 

383 Calcasieu 60.37 60.39 Waterbody Crossing 0.1 Cropland and Pasture 

384 Calcasieu 60.37 60.39 Waterbody Crossing 0.1 Cropland and Pasture 

382 Calcasieu 60.42 60.46 Waterbody Crossing, Fabrication 

Area, Access & Truck Turnaround 0.9 Cropland and Pasture 

64 Calcasieu 60.65 60.76 Fabrication Area & P.I. 0.4 Cropland and Pasture 

556 Calcasieu 60.81 60.86 Foreign Line Crossing 0.3 Cropland and Pasture 

381 Calcasieu 60.92 60.95 Road Crossing & Waterbody Crossing 0.2 Cropland and Pasture 

0.3 Nonforested Wetland 

62 Calcasieu 60.97 60.99 Road Crossing, Fabrication Area & 

P.I. 

0.0 Cropland and Pasture 

674 Calcasieu 61.28 61.33 Foreign Line Crossing 0.3 Cropland and Pasture 

59 Calcasieu 61.45 61.50 Road Crossing & Fabrication Area 0.3 Cropland and Pasture 

58 Calcasieu 61.52 61.55 Road Crossing 0.2 Cropland and Pasture 

380 Calcasieu 61.94 61.97 Waterbody Crossing & Truck 

Turnaround 0.4 Cropland and Pasture 

379 Calcasieu 61.98 62.04 Waterbody Crossing, Fabrication Area 

& Access 0.4 Cropland and Pasture 

57 Calcasieu 62.45 62.56 Fabrication Area & P.I. 0.4 Cropland and Pasture 
 C-15 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

0.1 Nonforested Wetland 

398 Calcasieu 63.00 63.02 Waterbody Crossing 

0.0 Cropland and Pasture 

0.0 Cropland and Pasture 

397 Calcasieu 63.03 63.05 Waterbody Crossing 

0.1 Nonforested Wetland 

0.1 Nonforested Wetland 

396 Calcasieu 63.22 63.24 Waterbody Crossing 

0.0 Cropland and Pasture 

395 Calcasieu 63.26 63.28 Waterbody Crossing 0.1 Cropland and Pasture 

373 Calcasieu 63.45 63.48 Road Crossing & Waterbody Crossing 0.2 Cropland and Pasture 

376 Calcasieu 63.50 63.54 Road Crossing, Fabrication Area & 

Waterbody Crossing 0.3 Cropland and Pasture 

371 Calcasieu 64.19 64.23 Waterbody Crossing & Truck 

Turnaround 0.2 Cropland and Pasture 

675 Calcasieu 64.22 64.26 Waterbody Crossing & Access 0.2 Cropland and Pasture 

370 Calcasieu 64.25 64.32 Waterbody Crossing & Fabrication 

Area 0.4 Cropland and Pasture 

0.1 Cropland and Pasture 

0.2 Transportation, Communications, 

and Utilities 676 Calcasieu 64.45 64.49 Foreign Line Crossing 

0.1 Evergreen Forest Land 

42 Calcasieu 64.67 64.71 Road Crossing 0.2 Evergreen Forest Land 

Staging Area, Road Crossing & 

Fabrication Area 0.0 Streams and Canals 

43 Calcasieu 64.72 64.77 

Staging Area, Road Crossing & 

Fabrication Area 0.9 Cropland and Pasture 

369 Calcasieu 65.33 65.35 Waterbody Crossing 0.1 Cropland and Pasture 

368 Calcasieu 65.37 65.39 Waterbody Crossing 0.1 Cropland and Pasture 

616 Calcasieu 65.45 65.50 Foreign Line Crossing 0.3 Cropland and Pasture 
 C-16 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

365 Calcasieu 65.94 65.97 Road Crossing 0.2 Cropland and Pasture 

367 Calcasieu 65.99 66.00 Road Crossing & Waterbody Crossing 0.1 Herbaceous Rangeland 

366 Calcasieu 66.02 66.04 Waterbody Crossing 0.1 Cropland and Pasture 

364 Calcasieu 66.18 66.24 Truck Turnaround & Foreign Line 

Crossing 0.6 Cropland and Pasture 

363 Calcasieu 66.25 66.31 

Road Crossing, Waterbody Crossing, 

Foreign Line Crossing, Fabrication 

Area & P.I. 

1.3 Cropland and Pasture 

362 Calcasieu 66.33 66.41 Road Crossing & Fabrication Area 0.5 Nonforested Wetland 

361 Calcasieu 66.67 66.69 Waterbody Crossing 0.1 Nonforested Wetland 

360 Calcasieu 66.70 66.72 Waterbody Crossing 0.1 Nonforested Wetland 

359 Calcasieu 66.83 66.87 

Railroad Crossing, Waterbody 

Crossing, Truck Turnaround & 

Fabrication Area 

0.5 Nonforested Wetland 

0.5 Nonforested Wetland 

315 Calcasieu 67.03 67.09 Railroad Crossing, Waterbody 

Crossing & Truck Turnaround 0.0 Mixed Rangeland 

0.2 Nonforested Wetland 

316 Calcasieu 67.09 67.15 Waterbody Crossing & Fabrication 

Area 

0.1 Forested Wetland 

317 Calcasieu 67.17 67.19 Waterbody Crossing 0.1 Nonforested Wetland 

318 Calcasieu 67.26 67.28 Waterbody Crossing 0.1 Nonforested Wetland 

0.4 Nonforested Wetland 

319 Calcasieu 67.29 67.37 Waterbody Crossing & Access 

0.0 Herbaceous Rangeland 

0.0 Cropland and Pasture 

320 Calcasieu 67.38 67.44 Waterbody Crossing, Fabrication Area 

& Access 

0.3 Nonforested Wetland 

321 Calcasieu 67.53 67.59 Road Crossing & Fabrication Area 0.3 Nonforested Wetland 
 C-17 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

0.1 Shrub and Brush Rangeland 322 Calcasieu 67.62 67.65 Road Crossing 

0.1 Nonforested Wetland 

323 Calcasieu 67.96 68.03 Waterbody Crossing, Fabrication Area 

& Truck Turnaround 0.8 Herbaceous Rangeland 

0.4 Cropland and Pasture 

324 Calcasieu 68.07 68.11 Waterbody Crossing & Truck 

Turnaround 

0.1 Herbaceous Rangeland 

325 Calcasieu 68.30 68.33 Road Crossing & Waterbody Crossing 0.2 Herbaceous Rangeland 

326 Calcasieu 68.34 68.35 Road Crossing & Waterbody Crossing 0.1 Deciduous Forest Land 

327 Calcasieu 68.36 68.52 Road Crossing, Waterbody Crossing 

& Fabrication Area 0.9 Cropland and Pasture 

328 Calcasieu 68.52 68.59 

Road Crossing, Railroad Crossing, 

Waterbody Crossing & Truck 

Turnaround 

0.7 Cropland and Pasture 

329 Calcasieu 68.70 68.75 Road Crossing, Railroad Crossing & 

Waterbody Crossing 0.5 Herbaceous Rangeland 

0.8 Herbaceous Rangeland 

330 Calcasieu 68.97 69.07 0.1 Nonforested Wetland Waterbody Crossing, Fabrication Area 

& Truck Turnaround 

0.1 Cropland and Pasture 

331 Calcasieu 69.08 69.10 Waterbody Crossing 0.1 Cropland and Pasture 

334 Calcasieu 69.15 69.22 Waterbody Crossing & Truck 

Turnaround 1.1 Cropland and Pasture 

335 Calcasieu 69.36 69.41 Road Crossing, Fabrication Area & 

P.I. 0.3 Cropland and Pasture 

336 Calcasieu 69.42 69.43 Road Crossing & Waterbody Crossing 0.1 Herbaceous Rangeland 

337 Calcasieu 69.45 69.50 Waterbody Crossing, Fabrication Area 

& Access 0.4 Cropland and Pasture 

338 Calcasieu 69.83 69.90 

Waterbody Crossing, Fabrication 

Area, Foreign Line Crossing & Truck 

Turnaround 

0.7 Cropland and Pasture 
 C-18 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

339 Calcasieu 69.94 69.99 Waterbody Crossing, Fabrication 

Area, P.I. & Access 0.2 Cropland and Pasture 

340 Calcasieu 70.28 70.30 Waterbody Crossing & Access 0.1 Cropland and Pasture 

341 Calcasieu 70.32 70.37 Waterbody Crossing, Fabrication 

Area, Access & Foreign Line Crossing 0.4 Cropland and Pasture 

0.4 Cropland and Pasture 

342 Calcasieu 70.63 70.68 Waterbody Crossing, Fabrication Area 

& Access 

0.0 Streams and Canals 

343 Calcasieu 70.72 70.74 Waterbody Crossing 0.1 Nonforested Wetland 

344 Calcasieu 71.62 71.63 Waterbody Crossing 0.0 Cropland and Pasture 

346 Calcasieu 71.67 71.76 Waterbody Crossing & Fabrication 

Area 0.5 Cropland and Pasture 

345 Calcasieu 71.76 71.83 Waterbody Crossing & Truck 

Turnaround 1.2 Cropland and Pasture 

347 Calcasieu 71.85 71.92 Waterbody Crossing, Fabrication Area 

& Truck Turnaround 1.2 Nonforested Wetland 

56 Calcasieu 72.52 72.61 Fabrication Area, Foreign Line 

Crossing & P.I. 0.6 Nonforested Wetland 

0.1 Nonforested Wetland 

348 Calcasieu 72.69 72.72 Road Crossing 0.0 Cropland and Pasture 

0.0 Streams and Canals 

0.5 Nonforested Wetland 

349 Calcasieu 72.74 72.84 Road Crossing, Waterbody Crossing 

& Fabrication Area 

0.1 Cropland and Pasture 

350 Calcasieu 72.87 72.98 Road Crossing, Waterbody Crossing 

& Fabrication Area 0.6 Nonforested Wetland 

0.1 Nonforested Wetland 

261 Calcasieu 73.77 73.80 Road Crossing 0.1 Cropland and Pasture 

0.0 Streams and Canals 

262 Calcasieu 73.82 73.88 Road Crossing & Fabrication Area 0.4 Herbaceous Rangeland 
 C-19 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

555 Calcasieu 73.98 74.03 Foreign Line Crossing 0.3 Herbaceous Rangeland 

264 Calcasieu 74.71 74.79 Airstrip Crossing & Fabrication Area 0.5 Cropland and Pasture 

263 Calcasieu 74.79 74.84 

Airstrip Crossing, Waterbody 

Crossing, Fabrication Area & Truck 

Turnaround 

1.1 Cropland and Pasture 

265 Jefferson 

Davis 74.92 74.97 Railroad Crossing, Waterbody Crossing, Fabrication Area & P.I. 0.2 Nonforested Wetland 

266 Jefferson 

Davis 75.21 75.25 Road Crossing 0.2 Nonforested Wetland 

266 Jefferson 

Davis 75.23 75.26 Road Crossing 0.1 Cropland and Pasture 

267 Jefferson 

Davis 75.30 75.34 Road Crossing & Staging Area 0.9 Cropland and Pasture 

268 Jefferson 

Davis 75.34 75.37 Fabrication Area 0.2 Cropland and Pasture 

554 Jefferson 

Davis 75.50 75.55 Foreign Line Crossing 0.3 Cropland and Pasture 

553 Jefferson 

Davis 75.60 75.65 Foreign Line Crossing 0.3 Cropland and Pasture 

270 Jefferson 

Davis 75.83 75.95 Foreign Line Crossing, Fabrication Area & P.I. 0.8 Cropland and Pasture 

269 Jefferson 

Davis 75.95 75.99 Waterbody Crossing, P.I. & Truck Turnaround 0.9 Cropland and Pasture 

271 Jefferson 

Davis 76.11 76.14 Waterbody Crossing, P.I. & Truck Turnaround 1.0 Cropland and Pasture 

272 Jefferson 

Davis 76.14 76.35 Waterbody Crossing & Fabrication Area 1.3 Cropland and Pasture 

677 Jefferson 

Davis 76.22 76.27 Foreign Line Crossing 0.3 Cropland and Pasture 

274 Jefferson 

Davis 76.66 76.82 Railroad Crossing, P.I. & Fabrication 

Area 1.4 Cropland and Pasture 

275 Jefferson 

Davis 76.70 76.82 Railroad Crossing, P.I. & Access 0.8 Cropland and Pasture 
 C-20 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

276 Jefferson 

Davis 76.85 76.93 Foreign Line Crossing, Railroad Crossing, P.I. & Fabrication Area 0.9 Cropland and Pasture 

277 Jefferson 

Davis 76.86 76.95 Foreign Line Crossing, P.I. & Railroad Crossing 0.3 Cropland and Pasture 

279 Jefferson 

Davis 76.90 76.96 HDD Pullstring 0.6 Cropland and Pasture 

278 Jefferson 

Davis 76.94 77.00 Foreign Line Crossing, P.I., Fabrication Area & Truck Turnaround 1.3 Cropland and Pasture 

280 Jefferson 

Davis 77.10 77.15 Foreign Line Crossing 0.3 Nonforested Wetland 

285 Jefferson 

Davis 77.52 77.54 Access, P.I. & Fabrication Area 0.1 Other Agricultural Land 

286 Jefferson 

Davis 77.52 77.61 P.I. 0.3 Cropland and Pasture 

285 Jefferson 

Davis 77.54 77.61 Access, P.I. & Fabrication Area 0.3 Cropland and Pasture 

4 

HDD 

Jefferson 

Davis 77.61 77.66 HDD Site -Exit Hole 1.1 Cropland and Pasture 

287 Jefferson 

Davis 78.33 78.38 Staging Area 1.1 Cropland and Pasture 

3 

HDD 

Jefferson 

Davis 78.39 78.43 HDD Site -Entry Hole 1.1 Cropland and Pasture 

288 Jefferson 

Davis 78.69 78.71 Waterbody Crossing 0.1 Cropland and Pasture 

289 Jefferson 

Davis 78.73 78.77 Waterbody Crossing & Fabrication Area 0.2 Cropland and Pasture 

290 Jefferson 

Davis 78.96 78.98 Waterbody Crossing 0.1 Nonforested Wetland 

291 Jefferson 

Davis 79.00 79.02 Waterbody Crossing & Fabrication Area 0.2 Cropland and Pasture 

292 Jefferson 

Davis 79.40 79.45 Road Crossing & Foreign Line Crossing 0.3 Cropland and Pasture 
 C-21 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

293 Jefferson 

Davis 79.53 79.59 Road Crossing & Fabrication Area 0.4 Cropland and Pasture 

294 Jefferson 

Davis 79.89 79.94 Waterbody Crossing & Truck Turnaround 0.7 Cropland and Pasture 

295 Jefferson 

Davis 79.96 80.03 Waterbody Crossing & Fabrication Area 0.4 Cropland and Pasture 

615 Jefferson 

Davis 80.15 80.19 Foreign Line Crossing 0.3 Cropland and Pasture 

296 Jefferson 

Davis 80.31 80.39 Waterbody Crossing & Access 0.5 Cropland and Pasture 

297 Jefferson 

Davis 80.41 80.47 Waterbody Crossing & Fabrication Area 0.4 Cropland and Pasture 

298 Jefferson 

Davis 80.68 80.71 Waterbody Crossing & Access 0.2 Cropland and Pasture 

299 Jefferson 

Davis 80.72 80.84 Waterbody Crossing, Foreign Line Crossing, Fabrication Area & Access 0.7 Cropland and Pasture 

300 Jefferson 

Davis 80.84 80.89 Truck Turnaround, Foreign Line Crossing & Waterbody Crossing 1.1 Cropland and Pasture 

301 Jefferson 

Davis 80.91 80.97 Truck Turnaround, Foreign Line Crossing & Waterbody Crossing 1.1 Cropland and Pasture 

314 Jefferson 

Davis 80.97 81.01 Waterbody Crossing & Fabrication Area 0.2 Cropland and Pasture 

302 Jefferson 

Davis 81.23 81.28 Access 0.3 Cropland and Pasture 

303 Jefferson 

Davis 81.68 81.75 Truck Turnaround, Waterbody Crossing & Road Crossing 0.8 Cropland and Pasture 

304 Jefferson 

Davis 81.84 81.92 Road Crossing, Waterbody Crossing & Fabrication Area 0.5 Cropland and Pasture 

305 Jefferson 

Davis 82.24 82.28 Road Crossing 0.2 Cropland and Pasture 

306 Jefferson 

Davis 82.31 82.36 Road Crossing & Fabrication Area 0.3 Nonforested Wetland 
 C-22 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

307 Jefferson 

Davis 82.74 82.77 Waterbody Crossing 0.2 Nonforested Wetland 

308 Jefferson 

Davis 82.78 82.82 Waterbody Crossing 0.2 Nonforested Wetland 

309 Jefferson 

Davis 82.96 82.99 Road Crossing 0.2 Nonforested Wetland 

310 Jefferson 

Davis 83.00 83.04 Road Crossing 0.2 Cropland and Pasture 

311 Jefferson 

Davis 84.20 84.24 Road Crossing 0.2 Nonforested Wetland 

0.1 Herbaceous Rangeland 

312 Jefferson 

Davis 84.24 84.31 Waterbody Crossing, Fabrication Area & Road Crossing 0.3 Nonforested Wetland 

0.0 Cropland and Pasture 

136 0.4 Nonforested Wetland Jefferson 

Davis 84.32 84.40 Road Crossing, Waterbody Crossing & Fabrication Area 

0.1 Herbaceous Rangeland 

135 Jefferson 

Davis 84.43 84.48 Road Crossing & Fabrication Area 0.3 Cropland and Pasture 

137 Jefferson 

Davis 84.66 84.70 Waterbody Crossing 0.2 Cropland and Pasture 

138 Jefferson 

Davis 84.70 84.75 Waterbody Crossing & Fabrication 

Area 0.3 Cropland and Pasture 

356 Jefferson 

Davis 84.90 84.93 Waterbody Crossing 0.2 Cropland and Pasture 

140 Jefferson 

Davis 84.97 85.03 Waterbody Crossing & Fabrication Area 0.3 Cropland and Pasture 

564 Jefferson 

Davis 85.36 85.41 Access 0.3 Cropland and Pasture 

573 Jefferson 

Davis 86.08 86.13 Foreign Line Crossing 0.3 Cropland and Pasture 
 C-23 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

142 Jefferson 

Davis 86.47 86.53 Road Crossing & Staging Area 0.8 Cropland and Pasture 

143 Jefferson 

Davis 86.58 86.66 Road Crossing & Fabrication Area 0.5 Cropland and Pasture 

614 Jefferson 

Davis 87.14 87.19 Foreign Line Crossing 0.3 Cropland and Pasture 

613 Jefferson 

Davis 87.43 87.46 Foreign Line Crossing 0.2 Nonforested Wetland 

0.1 Nonforested Wetland 

0.1 Cropland and Pasture 

0.0 Transportation, Communications, 

and Utilities 

144 Jefferson 

Davis 87.67 87.71 Road Crossing 

0.0 Streams and Canals 

146 Jefferson 

Davis 87.76 87.78 Fabrication Area 0.1 Cropland and Pasture 

147 Jefferson 

Davis 88.45 88.48 Waterbody Crossing 0.1 Cropland and Pasture 

148 Jefferson 

Davis 88.50 88.52 Waterbody Crossing 0.1 Cropland and Pasture 

149 Jefferson 

Davis 88.58 88.65 Fabrication Area & P.I. 0.4 Cropland and Pasture 

150 Jefferson 

Davis 88.75 88.78 Road Crossing 0.1 Cropland and Pasture 

151 Jefferson 

Davis 88.77 88.80 Road Crossing 0.1 Cropland and Pasture 

152 Jefferson 

Davis 88.79 88.88 Road Crossing, Fabrication Area & P.I. 0.3 Cropland and Pasture 

153 Jefferson 

Davis 88.81 88.88 Waterbody Crossing & P.I. 0.2 Cropland and Pasture 

154 Jefferson 

Davis 88.89 88.92 Road Crossing 0.1 Cropland and Pasture 
 C-24 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

155 Jefferson 

Davis 88.89 88.92 Road Crossing 0.1 Cropland and Pasture 

156 Jefferson 

Davis 89.94 89.97 Road Crossing 0.1 Cropland and Pasture 

158 Jefferson 

Davis 89.94 89.97 Road Crossing 0.1 Cropland and Pasture 

157 Jefferson 

Davis 89.98 90.01 Road Crossing 0.1 Cropland and Pasture 

159 Jefferson 

Davis 89.98 90.01 Road Crossing 0.1 Cropland and Pasture 

163 Jefferson 

Davis 90.54 90.56 Waterbody Crossing & Foreign Line Crossing 0.1 Cropland and Pasture 

161 Jefferson 

Davis 90.55 90.57 Waterbody Crossing & Foreign Line Crossing 0.1 Cropland and Pasture 

164 Jefferson 

Davis 90.57 90.59 Waterbody Crossing & Foreign Line Crossing 0.1 Cropland and Pasture 

162 Jefferson 

Davis 90.58 90.62 Waterbody Crossing & Fabrication Area 0.1 Cropland and Pasture 

168 Jefferson 

Davis 90.98 91.00 Road Crossing 0.1 Cropland and Pasture 

165 Jefferson 

Davis 90.98 91.01 Road Crossing 0.1 Cropland and Pasture 

167 Jefferson 

Davis 91.01 91.04 Road Crossing 0.1 Cropland and Pasture 

166 Jefferson 

Davis 91.02 91.05 Road Crossing 0.1 Cropland and Pasture 

699 Jefferson 

Davis 91.06 91.11 Foreign Line Crossing 0.1 Cropland and Pasture 

700 Jefferson 

Davis 91.06 91.11 Foreign Line Crossing 0.1 Cropland and Pasture 

612 Jefferson 

Davis 91.29 91.38 Fabrication Area, Waterbody Crossing & Foreign Line Crossing 0.6 Cropland and Pasture 
 C-25 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

678 Jefferson 

Davis 91.34 91.38 Waterbody Crossing & Foreign Line Crossing 0.2 Cropland and Pasture 

169 Jefferson 

Davis 91.61 91.63 Waterbody Crossing 0.1 Cropland and Pasture 

171 Jefferson 

Davis 91.62 91.64 Waterbody Crossing 0.1 Cropland and Pasture 

172 Jefferson 

Davis 91.65 91.67 Waterbody Crossing 0.1 Cropland and Pasture 

170 Jefferson 

Davis 91.65 91.68 Waterbody Crossing & Fabrication Area 0.2 Cropland and Pasture 

0.1 Cropland and Pasture 

175 Jefferson 

Davis 92.00 92.03 Road Crossing 

0.0 Streams and Canals 

0.1 Cropland and Pasture 173 Jefferson 

Davis 92.01 92.04 Road Crossing 0.0 Streams and Canals 

174 Jefferson 

Davis 92.04 92.07 Road Crossing 0.1 Herbaceous Rangeland 

176 Jefferson 

Davis 92.05 92.11 Road Crossing & Fabrication Area 0.3 Herbaceous Rangeland 

178 Jefferson 

Davis 92.13 92.16 Waterbody Crossing 0.1 Herbaceous Rangeland 

177 Jefferson 

Davis 92.15 92.18 Waterbody Crossing 0.1 Herbaceous Rangeland 

180 Jefferson 

Davis 92.20 92.23 Waterbody Crossing 0.1 Nonforested Wetland 

179 Jefferson 

Davis 92.22 92.26 Waterbody Crossing & Fabrication Area 0.2 Nonforested Wetland 

0.3 Cropland and Pasture 

0.0 Streams and Canals 183 Jefferson 

Davis 93.02 93.08 Road Crossing & Spread Flop 

0.1 Transportation, Communications, 

and Utilities 
 C-26 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

181 Jefferson 

Davis 93.04 93.09 Road Crossing & Staging Area 1.0 Cropland and Pasture 

0.3 Cropland and Pasture 

182 0.0 Streams and Canals Jefferson 

Davis 93.08 93.14 Road Crossing & Spread Flop 

0.1 Transportation, Communications, 

and Utilities 

0.0 Streams and Canals 

184 Jefferson 

Davis 93.08 93.14 Road Crossing, Staging Area & Fabrication Area 0.7 Cropland and Pasture 

185 Jefferson 

Davis 93.64 93.70 Fabrication Area & P.I. 0.3 Cropland and Pasture 

188 Jefferson 

Davis 94.06 94.09 Waterbody Crossing 0.2 Cropland and Pasture 

187 Jefferson 

Davis 94.11 94.17 Road Crossing & Waterbody Crossing 0.3 Cropland and Pasture 

186 Jefferson 

Davis 94.18 94.21 Road Crossing 0.2 Cropland and Pasture 

189 Jefferson 

Davis 94.61 94.67 Waterbody Crossing, Fabrication Area & Truck Turnaround 0.7 Cropland and Pasture 

681 Jefferson 

Davis 94.72 94.76 Waterbody Crossing & Access 0.1 Cropland and Pasture 

190 Jefferson 

Davis 94.72 94.78 Waterbody Crossing & Fabrication Area 0.3 Cropland and Pasture 

682 Jefferson 

Davis 94.94 94.97 Access 0.1 Cropland and Pasture 

191 Jefferson 

Davis 95.07 95.10 Waterbody Crossing 0.2 Cropland and Pasture 

683 Jefferson 

Davis 95.07 95.10 Waterbody Crossing & Access 0.1 Cropland and Pasture 
 C-27 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

1.0 Cropland and Pasture 

0.1 Transportation, Communications, 

and Utilities 192 Jefferson 

Davis 95.14 95.33 

Road Crossing, Fabrication Area, 

Waterbody Crossing, Spread Flop & 

P.I. 

0.0 Streams and Canals 

0.3 Cropland and Pasture 

0.1 Transportation, Communications, 

and Utilities 679 Jefferson 

Davis 95.20 95.27 Road Crossing, Access & Spread Flop 

0.0 Streams and Canals 

680 Jefferson 

Davis 95.26 95.33 Road Crossing, Spread Flop, Fabrication Area & P.I. 0.4 Cropland and Pasture 

684 Jefferson 

Davis 95.54 95.62 Fabrication Area & P.I. 0.4 Cropland and Pasture 

685 Jefferson 

Davis 95.55 95.60 P.I. 0.2 Cropland and Pasture 

686 Jefferson 

Davis 95.80 95.83 Access 0.2 Cropland and Pasture 

687 Jefferson 

Davis 96.14 96.19 Foreign Line Crossing 0.3 Cropland and Pasture 

688 Jefferson 

Davis 96.31 96.34 Road Crossing & Fabrication Area 0.2 Cropland and Pasture 

690 Jefferson 

Davis 96.38 96.41 Road Crossing & Waterbody Crossing 0.2 Cropland and Pasture 

689 Jefferson 

Davis 96.38 96.43 Waterbody Crossing, Fabrication Area, Road Crossing, & Access 0.3 Cropland and Pasture 

701 Jefferson 

Davis 97.30 97.36 Road Crossing & Fabrication Area 0.3 Cropland and Pasture 

550 Jefferson 

Davis 97.33 97.36 Road Crossing 0.1 Cropland and Pasture 

547 Jefferson 

Davis 97.38 97.41 Road Crossing 0.1 Cropland and Pasture 
 C-28 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

548 Jefferson 

Davis 97.38 97.41 Road Crossing 0.1 Cropland and Pasture 

691 Jefferson 

Davis 97.59 97.62 Road Crossing 0.2 Cropland and Pasture 

0.2 Cropland and Pasture 

692 Jefferson 

Davis 97.60 97.64 Road Crossing 

0.1 Other Agricultural Land 

0.3 Cropland and Pasture 693 Jefferson 

Davis 97.72 97.78 Access 

0.1 Deciduous Forest Land 

546 Jefferson 

Davis 97.75 97.81 P.I. 0.2 Cropland and Pasture 

694 Jefferson 

Davis 97.80 97.87 Fabrication Area & P.I. 0.4 Cropland and Pasture 

203 Jefferson 

Davis 98.82 98.94 Fabrication Area & Access 0.7 Cropland and Pasture 

205 Jefferson 

Davis 98.94 99.03 Truck Turnaround 1.1 Cropland and Pasture 

2 

HDD 

Jefferson 

Davis 98.98 99.03 HDD Site -Exit Hole 1.1 Cropland and Pasture 

1 

HDD Acadia 99.76 99.81 HDD Site -Entry Hole 1.1 Cropland and Pasture 

209 Acadia 99.76 99.88 Fabrication Area & Truck Turnaround 1.3 Cropland and Pasture 

210 Acadia 99.81 99.87 P.I. 0.2 Cropland and Pasture 

0.3 Cropland and Pasture 

208 Acadia 100.01 100.07 Access 

0.1 Streams and Canals 

40 Acadia 100.39 100.42 Road Crossing 0.1 Other Agricultural Land 

0.1 Cropland and Pasture 

38 Acadia 100.40 100.43 Road Crossing 

0.1 Other Agricultural Land 

39 Acadia 100.43 100.46 Road Crossing 0.1 Cropland and Pasture 

37 Acadia 100.44 100.47 Road Crossing 0.1 Cropland and Pasture 
 C-29 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

35 Acadia 100.72 100.74 Waterbody Crossing 0.1 Cropland and Pasture 

36 Acadia 100.72 100.74 Waterbody Crossing 0.1 Cropland and Pasture 

34 Acadia 100.75 100.77 Waterbody Crossing 0.2 Cropland and Pasture 

571 Acadia 100.87 100.93 Access 0.3 Cropland and Pasture 

211 Acadia 101.08 101.12 Waterbody Crossing & Truck 

Turnaround 0.9 Cropland and Pasture 

213 Acadia 101.22 101.24 Waterbody Crossing 0.1 Cropland and Pasture 

212 Acadia 101.23 101.26 Waterbody Crossing, Truck 

Turnaround & Fabrication Area 0.9 Cropland and Pasture 

216 Acadia 101.45 101.56 Road Crossing, Staging Area & Pull 

Section 0.9 Cropland and Pasture 

214 Acadia 101.46 101.49 Road Crossing 0.2 Cropland and Pasture 

215 Acadia 101.51 101.52 P.I. & Road Crossing 0.1 Cropland and Pasture 

217 Acadia 101.51 101.60 Fabrication Area, P.I. & Road 

Crossing 0.6 Cropland and Pasture 

218 Acadia 102.31 102.34 Road Crossing 0.2 Cropland and Pasture 

219 Acadia 102.36 102.40 Road Crossing & Fabrication Area 0.2 Cropland and Pasture 

220 Acadia 102.80 102.82 Waterbody Crossing 0.1 Cropland and Pasture 

221 Acadia 102.85 102.91 Waterbody Crossing & Fabrication 

Area 0.3 Cropland and Pasture 

222 Acadia 103.13 103.16 Waterbody Crossing 0.1 Cropland and Pasture 

223 Acadia 103.17 103.21 Waterbody Crossing & Fabrication 

Area 0.2 Cropland and Pasture 

224 Acadia 104.16 104.21 Road Crossing 0.2 Cropland and Pasture 

225 Acadia 104.22 104.28 Road Crossing & Waterbody Crossing 0.3 Cropland and Pasture 

226 Acadia 104.29 104.32 Waterbody Crossing 0.2 Cropland and Pasture 

227 Acadia 104.55 104.61 Access 0.3 Cropland and Pasture 
 C-30 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

229 Acadia 104.70 104.72 Waterbody Crossing 0.1 Cropland and Pasture 

230 Acadia 104.73 104.75 Waterbody Crossing 0.1 Cropland and Pasture 

231 Acadia 105.07 105.09 Waterbody Crossing 0.1 Cropland and Pasture 

232 Acadia 105.14 105.17 Waterbody Crossing 0.1 Cropland and Pasture 

233 Acadia 105.23 105.27 Waterbody Crossing & Fabrication 

Area 0.3 Cropland and Pasture 

570 Acadia 105.27 105.36 Fabrication Area & P.I. 0.2 Cropland and Pasture 

234 Acadia 105.56 105.59 Road Crossing 0.2 Cropland and Pasture 

235 Acadia 105.60 105.68 Road Crossing, Fabrication Area & 

P.I. 0.6 Cropland and Pasture 

236 Acadia 106.15 106.19 Road Crossing 0.2 Cropland and Pasture 

237 Acadia 106.19 106.23 Road Crossing 0.2 Cropland and Pasture 

238 Acadia 106.58 106.68 Road Crossing, Fabrication Area & 

Foreign Line Crossing 0.6 Cropland and Pasture 

239 Acadia 106.70 106.75 Road Crossing 0.2 Cropland and Pasture 

240 Acadia 106.77 106.81 Road Crossing 0.2 Cropland and Pasture 

0.2 Cropland and Pasture 

241 Acadia 106.81 106.85 Road Crossing 

0.1 Other Agricultural Land 

0.1 Cropland and Pasture 

242 Acadia 107.22 107.27 Foreign Line Crossing 

0.2 Shrub and Brush Rangeland 

243 Acadia 107.37 107.40 Road Crossing & Fabrication Area 0.2 Cropland and Pasture 

245 Acadia 107.56 107.58 Waterbody Crossing 0.2 Cropland and Pasture 

246 Acadia 107.84 107.89 Truck Turnaround, Waterbody 

Crossing & Fabrication Area 1.0 Cropland and Pasture 

247 Acadia 107.94 107.98 Truck Turnaround, Waterbody 

Crossing, Fabrication Area & P.I. 0.9 Cropland and Pasture 

248 Acadia 108.05 108.07 Waterbody Crossing 0.1 Cropland and Pasture 
 C-31 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

249 Acadia 108.10 108.15 Waterbody Crossing & Foreign Line 

Crossing 0.3 Cropland and Pasture 

251 Acadia 108.15 108.21 Staging Area & Access 1.2 Cropland and Pasture 

544 Acadia 108.39 108.51 Foreign Line Crossing, P.I. & 

Fabrication Area 0.7 Cropland and Pasture 

0.3 Cropland and Pasture 

543 Acadia 108.54 108.59 Foreign Line Crossing & Fabrication 

Area 

0.0 Mixed Forest Land 

611 Acadia 109.00 109.04 Foreign Line Crossing 0.3 Mixed Forest Land 

696 Acadia 109.64 109.69 Access 0.3 Cropland and Pasture 

697 Acadia 110.00 110.02 Fabrication Area 0.3 Cropland and Pasture 

0.9 Cropland and Pasture 

542 Acadia 110.09 110.25 Fabrication Area Access, P.I., & 

Foreign Line Crossing 0.1 Streams and Canals 

1.1 Cropland and Pasture 

569 Acadia 110.32 110.38 Staging Area 

0.1 Transportation, Communications, 

and Utilities 

255 Acadia 110.32 110.45 Road Crossing & Fabrication Area 1.0 Cropland and Pasture 

669 Acadia 110.60 110.79 Foreign Line Crossing, Fabrication 

Area & Tie-In 1.1 Cropland and Pasture 

256 Acadia 111.19 111.22 Road Crossing 0.1 Cropland and Pasture 

258 Acadia 111.21 111.24 Road Crossing 0.1 Cropland and Pasture 

259 Acadia 111.25 111.36 Road Crossing & Foreign Line 

Crossing 0.3 Cropland and Pasture 

541 Acadia 111.26 111.32 Road Crossing & Foreign Line 

Crossing 0.4 Cropland and Pasture 

313 Acadia 111.45 111.50 Foreign Line Crossing & P.I. 0.3 Cropland and Pasture 

87 Acadia 112.36 112.47 Road Crossing, Fabrication Area & 

P.I. 0.5 Evergreen Forest Land 
 C-32 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

0.1 Evergreen Forest Land 

87 Evangeline 112.47 112.51 Road Crossing, Fabrication Area & 

P.I. 

0.2 Cropland and Pasture 

93 Evangeline 112.91 112.94 Access 0.2 Cropland and Pasture 

0.9 Cropland and Pasture 

355 Evangeline 113.09 113.13 Truck Turnaround, Fabrication Area & 

P.I. 

0.0 Mixed Forest Land 

0.2 Cropland and Pasture 

90 Evangeline 113.09 113.14 P.I. 

0.0 Evergreen Forest Land 

0.5 Mixed Forest Land 

53 Evangeline 113.41 113.61 Railroad Crossing & Foreign Line 

Crossing 0.1 Herbaceous Rangeland 

0.1 Mixed Forest Land 

54 Evangeline 113.52 113.57 Railroad Crossing & Foreign Line 

Crossing 0.1 Herbaceous Rangeland 

94 Evangeline 113.63 113.69 Truck Turnaround, Fabrication Area, 

Railroad Crossing & P.I. 1.1 Cropland and Pasture 

Railroad Crossing, Foreign Line 

Crossing & P.I. 0.0 Mixed Forest Land 

55 Evangeline 113.65 113.74 Railroad Crossing, Foreign Line 

Crossing & P.I. 0.2 Cropland and Pasture 

95 Evangeline 113.69 113.77 Railroad Crossing & P.I. 0.2 Cropland and Pasture 

32 Evangeline 114.78 114.82 Staging Area, Fabrication Area & P.I. 0.9 Cropland and Pasture 

0.1 Cropland and Pasture 

97 Evangeline 114.80 114.87 Road Crossing & P.I. 

0.1 Residential 

31 Evangeline 114.84 114.88 Road Crossing 0.1 Cropland and Pasture 

0.0 Cropland and Pasture 

30 Evangeline 114.89 114.92 Road Crossing 

0.1 Nonforested Wetland 
 C-33 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

0.0 Cropland and Pasture 

96 Evangeline 114.89 114.92 Road Crossing 

0.1 Nonforested Wetland 

354 Evangeline 115.25 115.34 Fabrication Area & P.I. 0.3 Herbaceous Rangeland 

50 Evangeline 115.26 115.33 P.I. 0.2 Herbaceous Rangeland 

99 Evangeline 115.64 115.70 Road Crossing & Fabrication Area 0.2 Herbaceous Rangeland 

98 Evangeline 115.67 115.70 Road Crossing 0.1 Herbaceous Rangeland 

100 Evangeline 115.71 115.76 Road Crossing, Fabrication Area & 

P.I. 0.5 Cropland and Pasture 

101 Evangeline 115.72 115.75 Road Crossing & P.I. 0.2 Cropland and Pasture 

111 Evangeline 116.33 116.36 Road Crossing 0.1 Cropland and Pasture 

112 Evangeline 116.36 116.39 Road Crossing 0.1 Cropland and Pasture 

110 Evangeline 116.37 116.41 Road Crossing 0.1 Cropland and Pasture 

113 Evangeline 116.40 116.44 Road Crossing 0.1 Cropland and Pasture 

108 Evangeline 116.51 116.54 Road Crossing 0.1 Cropland and Pasture 

107 Evangeline 116.54 116.57 Road Crossing 0.1 Cropland and Pasture 

109 Evangeline 116.56 116.59 Road Crossing 0.1 Cropland and Pasture 

106 Evangeline 116.58 116.61 Road Crossing 0.1 Cropland and Pasture 

104 Evangeline 116.69 116.73 Road Crossing 0.1 Cropland and Pasture 

105 Evangeline 116.72 116.76 Road Crossing 0.1 Cropland and Pasture 

102 Evangeline 116.74 116.77 Road Crossing 0.1 Cropland and Pasture 

103 Evangeline 116.77 116.83 Road Crossing & Fabrication Area 0.3 Cropland and Pasture 

567 Evangeline 116.94 116.99 Foreign Line Crossing 0.3 Cropland and Pasture 

568 Evangeline 116.97 117.02 Foreign Line Crossing 0.3 Cropland and Pasture 

29 Evangeline 117.19 117.27 Road Crossing & P.I. 0.2 Cropland and Pasture 
 C-34 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

27 Evangeline 117.20 117.27 Road Crossing, Fabrication Area & 

P.I. 0.2 Cropland and Pasture 

26 Evangeline 117.28 117.31 Road Crossing 0.1 Cropland and Pasture 

28 Evangeline 117.28 117.31 Road Crossing 0.1 Cropland and Pasture 

115 Evangeline 117.99 118.07 Waterbody Crossing & Fabrication 

Area 0.5 Cropland and Pasture 

0.5 Evergreen Forest Land 

114 Evangeline 118.27 118.36 Fabrication Area, Access & P.I. 

0.1 Transportation, Communications, 

and Utilities 

0.1 Nonforested Wetland 

120 Evangeline 118.82 118.84 Waterbody Crossing 

0.0 Forested Wetland 

0.1 Deciduous Forest Land 

119 Evangeline 118.85 118.87 Waterbody Crossing 

0.1 Shrub and Brush Rangeland 

117 Evangeline 119.25 119.27 Waterbody Crossing 0.1 Cropland and Pasture 

116 Evangeline 119.28 119.30 Waterbody Crossing 0.1 Cropland and Pasture 

0.3 Cropland and Pasture 

24 Evangeline 119.47 119.53 Access 

0.1 Transportation, Communications, 

and Utilities 

23 Evangeline 119.70 119.74 Road Crossing 0.2 Cropland and Pasture 

22 Evangeline 119.74 119.78 Road Crossing 0.2 Cropland and Pasture 

129 Evangeline 120.12 120.17 Truck Turnaround & Waterbody 

Crossing 1.1 Cropland and Pasture 

130 Evangeline 120.20 120.24 Truck Turnaround, Fabrication Area & 

Waterbody Crossing 0.9 Cropland and Pasture 

1.3 Cropland and Pasture 

131 Evangeline 120.35 120.42 Fabrication Area, Road Crossing, & 

Foreign Line Crossing 0.0 Streams and Canals 

121 Evangeline 120.47 120.54 Fabrication Area, Road Crossing & 

Foreign Line Crossing 0.6 Cropland and Pasture 
 C-35 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

21 Evangeline 120.60 120.68 P.I. 0.5 Cropland and Pasture 

0.2 Cropland and Pasture 

19 Evangeline 120.74 120.77 Road Crossing 

0.1 Streams and Canals 

20 Evangeline 120.78 120.82 Road Crossing 0.2 Cropland and Pasture 

123 Evangeline 121.45 121.48 Waterbody Crossing 0.1 Cropland and Pasture 

122 Evangeline 121.49 121.52 Waterbody Crossing 0.1 Cropland and Pasture 

124 Evangeline 121.83 121.85 Waterbody Crossing 0.1 Cropland and Pasture 

18 Evangeline 121.86 122.06 Spread Flop, Fabrication Area, P.I., 

Road Crossing & Waterbody Crossing 1.1 Cropland and Pasture 

125 Evangeline 121.95 122.09 Spread Flop, Road Crossing, 

Fabrication Area & P.I. 0.6 Cropland and Pasture 

664 Evangeline 122.06 122.10 Foreign Line Crossing & Fabrication 

Area 0.3 Cropland and Pasture 

665 Evangeline 122.18 122.25 Fabrication Area & Foreign Line 

Crossing 0.4 Cropland and Pasture 

666 Evangeline 123.07 123.12 Road Crossing 0.2 Cropland and Pasture 

126 Evangeline 123.13 123.22 

Spread Flop, Fabrication Area, 

Foreign Line Crossing, P.I. & Road 

Crossing 

0.6 Cropland and Pasture 

0.5 Cropland and Pasture 

16 Evangeline 123.16 123.28 

Spread Flop, Fabrication Area, 

Foreign Line Crossing, P.I. & Road 

Crossing 0.2 Residential 

127 Evangeline 123.66 123.70 Road Crossing 0.2 Shrub and Brush Rangeland 

128 Evangeline 123.70 123.74 Road Crossing 0.2 Cropland and Pasture 

698 Evangeline 124.75 124.84 Waterbody Crossing & Fabrication 

Area 0.5 Cropland and Pasture 

566 Evangeline 125.00 125.05 Staging Area 1.7 Cropland and Pasture 

540 Evangeline 125.81 125.84 Road Crossing 0.2 Cropland and Pasture 

539 Evangeline 125.85 125.88 Road Crossing 0.2 Cropland and Pasture 
 C-36 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

14 Evangeline 126.19 126.24 Road Crossing 0.2 Cropland and Pasture 

351 Evangeline 126.25 126.38 Road Crossing & Fabrication Area 0.7 Cropland and Pasture 

15 Evangeline 126.39 126.42 Road Crossing 0.2 Cropland and Pasture 

13 Evangeline 127.65 127.70 Road Crossing & Access 0.5 Cropland and Pasture 

12 Evangeline 127.71 127.74 Road Crossing & Access 0.2 Cropland and Pasture 

0.3 Cropland and Pasture 

0.1 Streams and Canals 565 Evangeline 128.04 128.12 Access 

0.1 Transportation, Communications, 

and Utilities 

9 Evangeline 128.34 128.39 P.I. 0.2 Cropland and Pasture 

10 Evangeline 128.45 128.51 Road Crossing & Fabrication Area 0.4 Cropland and Pasture 

11 Evangeline 128.53 128.57 Road Crossing 0.2 Cropland and Pasture 

600 Evangeline 129.54 129.60 Road Crossing, Foreign Line 

Crossing, P.I. & Fabrication Area 0.5 Cropland and Pasture 

601 Evangeline 129.69 129.79 Topsoil Segregation 0.2 Residential 

602 Evangeline 129.71 129.84 Fabrication Area & P.I. 0.7 Residential 

603 Evangeline 129.99 130.05 Waterbody Crossing & Fabrication 

Area 0.3 Cropland and Pasture 

604 Evangeline 130.12 130.15 Waterbody Crossing 0.1 Cropland and Pasture 

605 Evangeline 130.55 130.60 Road Crossing & Fabrication Area 0.3 Cropland and Pasture 

606 Evangeline 130.61 130.64 Road Crossing 0.2 Cropland and Pasture 

607 Evangeline 130.75 130.78 Waterbody Crossing 0.1 Cropland and Pasture 

608 Evangeline 130.80 130.86 Waterbody Crossing & Fabrication 

Area 0.4 Cropland and Pasture 

609 Evangeline 131.67 131.70 Road Crossing 0.2 Cropland and Pasture 

610 Evangeline 131.70 131.75 Staging Area & Road Crossing 1.0 Cropland and Pasture 

667 Evangeline 131.88 131.92 P.I. 0.2 Cropland and Pasture 
 C-37 Appendix C 

TABLE C-1 

Extra Workspaces

MP 

ID Parisha Begin End Purpose 

Acreage of

Workspace Land Use Type 

668 Evangeline 132.11 132.15 Fabrication Area 0.3 Cropland and Pasture 

FGT Lateral 

- Acadia 0.00 0.04 Tie-In & Fabrication Area 0.2 Cropland and Pasture 

- Acadia 0.11 0.13 Waterbody Crossing 0.1 Cropland and Pasture 

- Acadia 0.14 0.16 Waterbody Crossing 0.1 Cropland and Pasture 

- Acadia 0.47 0.50 Road Crossing 0.2 Cropland and Pasture 

- Acadia 0.51 0.54 Road Crossing 0.2 Cropland and Pasture 

0.7 Shrub and Brush Rangeland 

0.1 Transportation, Communications, 

and Utilities - Acadia 1.18 1.26 Waterbody Crossing, Fabrication Area 

& Access 

0.1 Nonforested Wetland 

- Acadia 1.66 1.78 Waterbody Crossing, Fabrication Area 

& Truck Turnaround 1.4 Herbaceous Rangeland 

- Acadia 2.16 2.21 P.I. 0.3 Cropland and Pasture 

0.1 Cropland and Pasture 

- Acadia 2.28 2.30 Fabrication Area & P.I. 

0.0 Herbaceous Rangeland 

Total 292.2 

a

 All are parishes in Louisiana, except for # extra workspaces in Orange County, TX. 
 C-38 

TABLE C-2 

Land Requirements for Access Roads

Access 

Road 

No. Parish

Approx. 

MP Status

Use 

(Permanent

or 

Temporary)

Approx.

Length

(feet)

Average

Width 

(feet)

Surface

Type Condition

Proposed 

Improvement 

or 

Modification

Land 

Affect

Durin

Cons

(acre

1 Cameron 3.89 Existing Temporary 12,626 33 Gravel Unknown Add gravel and maintain 8.6 

0.4 

2 Calcasieu 31.40 New Temporary 704 50 New Unknown Construct with gravel and maintain 0.4 

0.2 

3 Calcasieu 32.45 New Temporary 524 50 New Unknown Construct with gravel and maintain 0.4 4 Calcasieu 37.13 Existing Temporary 4,037 25 Paved Good Maintain 2.3 

4-1 Calcasieu 37.32 Existing Temporary 3,956 27 Dirt Fair Add gravel and maintain 2.4 4-2 Calcasieu 36.54 Existing Temporary 8,861 22 Paved Good Maintain 4.9 4-3 Calcasieu 36.29 Existing Temporary 1,170 32 Gravel Fair Add gravel and maintain 0.84 4-4 Calcasieu 35.20 Existing Temporary 6,567 18 Gravel Fair Add gravel and maintain 2.26 

0.06 

4-5 Calcasieu 35.15 New Temporary 309 14 New Unknown Construct with gravel and maintain 0.04 4-6 Calcasieu 36.39 Existing Temporary 24 24 Dirt Unknown Add gravel and maintain 0.01 

5 Calcasieu 38.36 Existing Temporary 5,564 19 Dirt Good Add gravel and maintain 2.54 

5-1 Calcasieu 37.98 Existing Temporary 2,727 22 Dirt Fair Add gravel and maintain 1.25 
 C-39 

TABLE C-2 

Land Requirements for Access Roads

Access 

Road 

No. Parish

Approx. 

MP Status

Use 

(Permanent

or 

Temporary)

Approx.

Length

(feet)

Average

Width 

(feet)

Surface

Type Condition

Proposed 

Improvement 

or 

Modification

Land 

Affect

Durin

Cons

(acre

6 Calcasieu 39.10 Existing Temporary 3,565 12 Dirt Good Add gravel and maintain 1.00 7 Calcasieu 40.18 Existing Temporary 2,517 12 Dirt Good Add gravel and maintain 0.7 

7-1 Calcasieu 39.96 Existing Temporary 2,399 12 Dirt Unknown Add gravel and maintain 0.6 7-2 Calcasieu 40.44 Existing Temporary 2,238 22 Dirt Unknown Add gravel and maintain 1.1 

8 Calcasieu 42.48 Existing Temporary 17 16 Dirt Good Add gravel and maintain 0.0 9 Calcasieu 42.79 Existing Temporary 39 18 Dirt Good Add gravel and maintain 0.0 

10 Calcasieu 46.49 Existing Temporary 1,227 15 Dirt Unknown Add gravel and maintain 0.4 

10-1 Calcasieu 46.23 Existing Temporary 1,406 14 Dirt Unknown Add gravel and maintain 0.5 

11 Calcasieu 46.98 Existing Temporary 1,518 16 Gravel Unknown Maintain 0.5 12 Calcasieu 49.47 Existing Temporary 380 15 Dirt Good Add gravel and maintain 0.1 13 Calcasieu 50.31 Existing Temporary 10,499 18 Dirt Fair Add gravel and maintain 5.1 

13-1 Calcasieu 50.31 Existing Temporary 2,049 30 Dirt Unknown Add gravel and maintain 1.5 

14 Calcasieu 51.18 Existing Temporary 1,229 12 Dirt Fair Add gravel and maintain 0.4 15 Calcasieu 52.34 New Temporary 100 15 New Unknown Construct with gravel and maintain 0.1 
 C-40 

TABLE C-2 

Land Requirements for Access Roads

Access 

Road 

No. Parish

Approx. 

MP Status

Use 

(Permanent

or 

Temporary)

Approx.

Length

(feet)

Average

Width 

(feet)

Surface

Type Condition

Proposed 

Improvement 

or 

Modification

Land 

Affect

Durin

Cons

(acre

16 Calcasieu 53.61 Existing Temporary 2,470 12 Gravel Fair Add gravel and maintain 0.7 17 Calcasieu 60.05 Existing Temporary 1,411 19 Dirt Unknown Add gravel and maintain 0.6 18 Calcasieu 60.42 Existing Temporary 1,211 12 Dirt Unknown Add gravel and maintain 0.3 19 Calcasieu 61.37 New Permanent 110 20 New Unknown Construct with gravel and maintain 0.1 20 Calcasieu 61.98 Existing Temporary 58 16 Dirt Unknown Add gravel and maintain 0.0 21 Calcasieu 64.31 Existing Temporary 86 23 Dirt Unknown Add gravel and maintain 0.1 22 Calcasieu 65.98 Existing Temporary 137 23 Dirt Unknown Add gravel and maintain 0.1 23 Calcasieu 67.36 Existing Temporary 553 15 Dirt Unknown Add gravel and maintain 0.2 24 Calcasieu 67.38 Existing Temporary 479 15 Dirt Unknown Add gravel and maintain 0.2 25 Calcasieu 69.44 Existing Temporary 592 19 Dirt Unknown Add gravel and maintain 0.2 26 Calcasieu 69.94 Existing Temporary 6,504 12 Dirt Unknown Add gravel and maintain 1.8 

26-1 Calcasieu 70.32 Existing Temporary 1,851 11 Dirt Unknown Add gravel and maintain 0.5 26-2 Calcasieu 70.39 Existing Temporary 1,964 18 Dirt Unknown Add gravel and maintain 0.6 26-3 Calcasieu 70.68 Existing Temporary 71 22 Dirt Unknown Add gravel and maintain 0.1 
 C-41 

TABLE C-2 

Land Requirements for Access Roads

Access 

Road 

No. Parish

Approx. 

MP Status

Use 

(Permanent

or 

Temporary)

Approx.

Length

(feet)

Average

Width 

(feet)

Surface

Type Condition

Proposed 

Improvement 

or 

Modification

Land 

Affect

Durin

Cons

(acre

27 Calcasieu 71.81 Existing Temporary 3,963 10 Dirt Unknown Add gravel and maintain 0.9 28 Jefferson Davis 75.98 Existing Temporary 1,784 12 Dirt Unknown Add gravel and maintain 0.5 29 Jefferson Davis 76.05 Existing Temporary 1,700 18 Dirt Unknown Add gravel and maintain 0.7 30 Jefferson Davis 76.82 Existing Temporary 3,844 20 Dirt Unknown Add gravel and maintain 1.8 31 Jefferson Davis 77.54 Existing Temporary 1,307 10 Dirt Unknown Add gravel and maintain 0.3 32 Jefferson Davis 80.31 Existing Temporary 3,653 9 Dirt Fair Add gravel and maintain 0.7 33 Jefferson Davis 80.72 Existing Temporary 4,236 18 Dirt Unknown Add gravel and maintain 1.7 

33-1 Jefferson Davis 80.73 Existing Temporary 1,574 29 Dirt Unknown Add gravel and maintain 1.0 

34 Jefferson Davis 81.25 Existing Temporary 3,882 19 Dirt Unknown Add gravel and maintain 1.2 

34-1 Jefferson Davis 80.91 Existing Temporary 3,344 11 Dirt Unknown Add gravel and maintain 0.8 

35 Jefferson Davis 85.37 Existing Temporary 2,259 14 Dirt Unknown Add gravel and maintain 0.7 36 Jefferson Davis 97.60 Existing Temporary 3,445 12 Dirt Unknown Add gravel and maintain 1.0 

36-1 Jefferson Davis 97.74 Existing Temporary 743 14 Dirt Unknown Add gravel and maintain 0.2 

37 Jefferson Davis 98.86 Existing Temporary 5,289 26 Dirt Unknown Add gravel and maintain 2.8 
 C-42 

TABLE C-2 

Land Requirements for Access Roads

Access 

Road 

No. Parish

Approx. 

MP Status

Use 

(Permanent

or 

Temporary)

Approx.

Length

(feet)

Average

Width 

(feet)

Surface

Type Condition

Proposed 

Improvement 

or 

Modification

Land 

Affect

Durin

Cons

(acre

38 Acadia 100.05 Existing Temporary 2,769 15 Dirt Fair Add gravel and maintain 0.9 39 Acadia 100.90 Existing Temporary 1,291 11 Dirt Unknown Add gravel and maintain 0.3 41 Acadia 109.68 Existing Temporary 4,166 15 Gravel Good Maintain 1.2 

41-1 Acadia 110.06 Existing Temporary 680 9 Dirt Good Maintain 0.1 

42 Acadia 112.93 Existing Temporary 1,143 11 Dirt Poor Add gravel and maintain 0.3 43 Acadia 114.35 Existing Temporary 2,492 14 Gravel Good Add gravel and maintain 0.6 44 Evangeline 118.35 Existing Temporary 784 12 Gravel Good Maintain 0.2 45 Evangeline 119.50 Existing Temporary 880 10 Dirt Good Maintain 0.2 46 Evangeline 124.61 Existing Temporary 1,197 12 Dirt Fair Add gravel and maintain 0.3 47 Evangeline 127.73 Existing Temporary 2,752 15 Gravel Good Maintain 0.8 48 Evangeline 128.10 Existing Temporary 1,467 12 Dirt Fair Maintain 0.4 49 Calcasieu 25.81 Existing Temporary 1,017 18 Dirt Poor Add gravel and maintain 0.4 50 Calcasieu 27.59 Existing Temporary 2,247 20 Dirt Poor Add gravel and maintain 1.0 51 Calcasieu 41.98 Existing Temporary 1,431 19 Gravel Good Maintain 0.7 
 C-43 

TABLE C-2 

Land Requirements for Access Roads

Access 

Road 

No. Parish

Approx. 

MP Status

Use 

(Permanent

or 

Temporary)

Approx.

Length

(feet)

Average

Width 

(feet)

Surface

Type Condition

Proposed 

Improvement 

or 

Modification

Land 

Affect

Durin

Cons

(acre

52 Acadia 112.02 Existing Permanent 2,046 12 Dirt Poor Add gravel and maintain 0.6 

FGT-1 Acadia 1.25 Existing Temporary 4,812 20 Dirt Fair Add gravel and maintain 1.1 FGT-2 Acadia 2.30 New Permanent 1,927 12 New Unknown Construct with gravel and maintain 0.5 

L1 Cameron 0.00 Existing Permanent 7,723 30 Gravel Good Maintain 4.4 L2 Cameron 0.53 Existing Temporary 67 33 Gravel Good Maintain 0.1 L3 Cameron 0.23 Existing Temporary 203 20 Gravel Good Maintain 0.1 L4 Cameron 1.11 Existing Permanent 2,154 30 Gravel Good Maintain 1.4 

Total 66.0 
 C-44 

TABLE C-3 

Land Requirements for Pipe Storage and Contractor Yards 

Yard 

No. 

Approx. 

Milepost Parish 

Land Affected 

During 

Construction 

(acres) Current Land Use Location 

1 36.51 Calcasieu 38.8 Non-forested Wetland Off Gulf Intracoastal Waterway 

9.2 Cropland and Pasture 

2 47.96 Calcasieu 

19.9 Non-forested Wetland 

Highway 27 and Burton Shipyard Road 

3 46.86 Calcasieu 14.5 Cropland and Pasture Intersection of Highway 27 and Highway 108 

14.6 Cropland and Pasture 

4 64.55 Calcasieu 

4.0 Non-forested Wetland 

Southeast corner of the intersection of Highway 397 and Highway 14 

5 64.87 Calcasieu 38.8 Cropland and Pasture 

Northwest corner of the intersection of Highway 397 and Highway 14 

6 78.85 Jefferson Davis 38.8 Herbaceous Rangeland Intersection of Highway 101 and I-10 frontage road 7 85.89 Jefferson Davis 29.8 Cropland and Pasture Intersection of Highway 99 and Cormier Village Road 
 C-45 

TABLE C-3 

Land Requirements for Pipe Storage and Contractor Yards 

Yard 

No. 

Approx. 

Milepost Parish 

Land Affected 

During 

Construction 

(acres) Current Land Use Location 

8 96.46 Jefferson Davis 20.9 Cropland and Pasture 

Northeast corner of the intersection of Highway 26 and Lantz Road 

9 96.52 Jefferson Davis 32.1 Cropland and Pasture 

Southeast corner of the intersection of Highway 26 and Highway 102 

10 112.79 Evangeline 35.8 Cropland and Pasture Morning Glory Road 11 115.30 Evangeline 62.5 Cropland and Pasture North side of Highway 190 on west side of Eunice 

18.6 Cropland and Pasture 

12 120.79 Evangeline 

0.4 Other Agricultural Land 

Corner of Highway 13 and Highway 374 

Total 378.7 
[This page left intentionally blank.] 
APPENDIX D 

LOCATIONS OF REQUESTED ALTERNATIVE MEASURES 
[This page intentionally left blank.]
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

1.01 1.12 Cameron Upland 

1.12 1.15 Cameron Wetland 

1.15 1.36 Cameron Upland 

1.36 1.42 Cameron Wetland 

1.42 1.47 Cameron Upland 

1.47 1.48 Cameron Wetland 

1.48 1.51 Cameron Upland 

20.04 20.21 Cameron Upland 

20.21 20.23 Cameron Wetland 

20.23 20.30 Cameron Upland 

20.30 20.31 Cameron Wetland 

20.31 20.38 Cameron Upland 

20.38 20.39 Cameron Wetland 

20.39 20.57 Cameron Upland 

20.57 20.65 Cameron Wetland 

20.65 20.77 Cameron Upland 

20.77 20.78 Cameron Wetland 

20.78 20.80 Cameron Upland 

20.80 20.81 Cameron Wetland 

20.81 20.84 Cameron Upland 

20.84 20.87 Cameron Wetland 

20.87 20.91 Cameron Upland 

20.91 20.97 Cameron Wetland 

D-1 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

20.97 20.99 Cameron Upland 

20.99 21.04 Cameron Wetland 

21.04 21.07 Cameron Upland 

21.07 21.10 Cameron Wetland 

21.10 21.12 Cameron Upland 

21.12 21.14 Cameron Wetland 

23.96 23.97 Cameron Upland 

23.97 24.02 Cameron Wetland 

24.02 24.06 Cameron Upland 

24.06 24.08 Cameron Wetland 

24.08 24.14 Cameron Upland 

24.14 24.25 Cameron Wetland 

24.25 24.28 Cameron Upland 

24.28 24.56 Cameron Wetland 

24.56 24.63 Cameron Upland 

24.63 24.87 Calcasieu Wetland 

24.87 24.89 Calcasieu Upland 

24.89 25.23 Calcasieu Wetland 

26.83 27.03 Calcasieu Upland 

27.03 27.42 Calcasieu Wetland 

27.42 27.55 Calcasieu Upland 

27.55 27.83 Calcasieu Wetland 

27.83 27.84 Calcasieu Upland 

D-2 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

27.84 27.85 Calcasieu Wetland 

27.85 27.88 Calcasieu Upland 

27.88 28.31 Calcasieu Wetland 

28.31 28.32 Calcasieu Upland 

28.32 30.04 Calcasieu Wetland 

30.04 30.09 Calcasieu Upland 

30.09 30.33 Calcasieu Wetland 

35.15 35.64 Calcasieu Wetland 

35.64 35.72 Calcasieu Upland 

35.72 35.74 Calcasieu Wetland 

35.74 35.88 Calcasieu Upland 

35.88 35.89 Calcasieu Wetland 

35.89 35.91 Calcasieu Upland 

35.91 35.92 Calcasieu Wetland 

35.92 35.94 Calcasieu Upland 

35.94 35.99 Calcasieu Wetland 

35.99 36.57 Calcasieu Upland 

36.57 36.59 Calcasieu Wetland 

36.59 36.70 Calcasieu Upland 

36.70 36.71 Calcasieu Wetland 

36.71 36.87 Calcasieu Upland 

36.87 36.88 Calcasieu Wetland 

36.88 36.89 Calcasieu Upland 

D-3 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

36.89 36.94 Calcasieu Wetland 

36.94 37.12 Calcasieu Upland 

37.12 37.17 Calcasieu Wetland 

37.17 37.29 Calcasieu Upland 

37.29 37.32 Calcasieu Wetland 

37.32 37.33 Calcasieu Upland 

37.33 37.34 Calcasieu Wetland 

37.34 37.36 Calcasieu Upland 

37.36 37.37 Calcasieu Wetland 

37.37 37.43 Calcasieu Upland 

37.43 37.44 Calcasieu Wetland 

37.44 37.49 Calcasieu Upland 

37.49 37.50 Calcasieu Wetland 

37.50 37.51 Calcasieu Upland 

37.51 37.56 Calcasieu Wetland 

37.56 37.57 Calcasieu Upland 

37.57 37.58 Calcasieu Wetland 

37.58 37.61 Calcasieu Upland 

37.61 37.62 Calcasieu Wetland 

37.62 37.63 Calcasieu Upland 

37.63 37.88 Calcasieu Wetland 

37.88 37.89 Calcasieu Upland 

D-4 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

37.89 37.96 Calcasieu Wetland 

37.96 37.97 Calcasieu Upland 

37.97 38.23 Calcasieu Wetland 

38.34 38.35 Calcasieu Wetland 

38.35 38.40 Calcasieu Upland 

38.40 38.44 Calcasieu Wetland 

38.44 38.45 Calcasieu Upland 

38.45 38.46 Calcasieu Wetland 

38.46 38.47 Calcasieu Upland 

38.48 38.51 Calcasieu Wetland 

38.51 38.54 Calcasieu Upland 

38.54 38.56 Calcasieu Wetland 

38.56 38.57 Calcasieu Upland 

38.57 38.61 Calcasieu Wetland 

38.61 38.66 Calcasieu Upland 

38.66 38.69 Calcasieu Wetland 

38.69 38.70 Calcasieu Upland 

38.70 38.73 Calcasieu Wetland 

38.73 38.74 Calcasieu Upland 

38.74 38.78 Calcasieu Wetland 

38.78 38.79 Calcasieu Upland 

38.79 38.83 Calcasieu Wetland 

38.83 38.84 Calcasieu Upland 

D-5 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

38.84 38.89 Calcasieu Wetland 

38.89 38.90 Calcasieu Upland 

38.90 38.92 Calcasieu Wetland 

38.92 38.94 Calcasieu Upland 

38.94 39.06 Calcasieu Wetland 

39.06 39.10 Calcasieu Upland 

39.10 39.20 Calcasieu Wetland 

39.20 39.45 Calcasieu Upland 

39.45 39.46 Calcasieu Wetland 

39.46 39.65 Calcasieu Upland 

39.65 39.66 Calcasieu Wetland 

39.66 39.67 Calcasieu Upland 

39.67 39.80 Calcasieu Wetland 

39.80 40.12 Calcasieu Upland 

40.12 40.17 Calcasieu Wetland 

40.17 40.19 Calcasieu Upland 

40.19 40.24 Calcasieu Wetland 

40.24 40.25 Calcasieu Upland 

40.25 40.29 Calcasieu Wetland 

40.29 42.74 Calcasieu Upland 

42.74 42.76 Calcasieu Wetland 

42.76 43.00 Calcasieu Upland 

D-6 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

43.00 43.10 Calcasieu Wetland 

43.10 43.42 Calcasieu Upland 

43.42 43.43 Calcasieu Wetland 

43.43 43.66 Calcasieu Upland 

44.54 44.57 Calcasieu Upland 

44.57 44.96 Calcasieu Wetland 

44.96 45.36 Calcasieu Upland 

45.36 45.86 Calcasieu Wetland 

45.86 45.87 Calcasieu Upland 

45.87 45.88 Calcasieu Wetland 

45.88 46.05 Calcasieu Upland 

46.05 46.68 Calcasieu Wetland 

46.68 46.69 Calcasieu Upland 

46.69 46.96 Calcasieu Wetland 

46.96 46.97 Calcasieu Upland 

46.97 47.01 Calcasieu Wetland 

47.01 47.02 Calcasieu Upland 

47.02 47.38 Calcasieu Wetland 

47.38 47.48 Calcasieu Upland 

47.48 47.51 Calcasieu Wetland 

47.51 47.54 Calcasieu Upland 

47.54 47.75 Calcasieu Wetland 

47.75 47.76 Calcasieu Upland 

D-7 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

47.76 48.06 Calcasieu Wetland 

48.06 48.14 Calcasieu Upland 

48.14 48.23 Calcasieu Wetland 

48.23 48.35 Calcasieu Upland 

48.35 48.46 Calcasieu Wetland 

48.46 48.63 Calcasieu Upland 

48.63 48.66 Calcasieu Wetland 

48.66 48.71 Calcasieu Upland 

48.71 48.90 Calcasieu Wetland 

48.90 49.12 Calcasieu Upland 

49.12 49.13 Calcasieu Wetland 

49.13 49.33 Calcasieu Upland 

49.33 49.34 Calcasieu Wetland 

49.34 49.40 Calcasieu Upland 

49.40 49.42 Calcasieu Wetland 

49.42 49.53 Calcasieu Upland 

51.33 51.74 Calcasieu Upland 

53.08 53.53 Calcasieu Upland 

53.53 53.60 Calcasieu Wetland 

53.60 53.91 Calcasieu Upland 

53.91 54.02 Calcasieu Wetland 

54.02 54.91 Calcasieu Upland 

54.91 55.03 Calcasieu Wetland 

D-8 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

55.03 55.15 Calcasieu Upland 

55.15 55.18 Calcasieu Wetland 

55.18 55.79 Calcasieu Upland 

55.79 55.80 Calcasieu Wetland 

55.80 55.96 Calcasieu Upland 

56.00 56.54 Calcasieu Upland 

56.54 56.55 Calcasieu Wetland 

56.55 57.15 Calcasieu Upland 

57.15 57.23 Calcasieu Wetland 

57.23 57.73 Calcasieu Upland 

57.73 57.92 Calcasieu Wetland 

57.92 58.57 Calcasieu Upland 

58.57 58.59 Calcasieu Wetland 

58.59 59.65 Calcasieu Upland 

59.65 60.02 Calcasieu Wetland 

60.02 60.06 Calcasieu Upland 

60.06 60.21 Calcasieu Wetland 

60.21 60.98 Calcasieu Upland 

60.98 61.26 Calcasieu Wetland 

61.26 62.65 Calcasieu Upland 

62.65 63.02 Calcasieu Wetland 

63.02 63.04 Calcasieu Upland 

63.04 63.23 Calcasieu Wetland 

D-9 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

63.23 66.32 Calcasieu Upland 

66.32 66.68 Calcasieu Wetland 

66.68 66.69 Calcasieu Upland 

66.69 66.91 Calcasieu Wetland 

66.91 66.95 Calcasieu Upland 

66.95 67.36 Calcasieu Wetland 

67.36 67.37 Calcasieu Upland 

67.37 67.62 Calcasieu Wetland 

67.62 67.69 Calcasieu Upland 

67.69 67.82 Calcasieu Wetland 

67.82 68.33 Calcasieu Upland 

68.33 68.34 Calcasieu Wetland 

68.34 68.91 Calcasieu Upland 

68.91 68.98 Calcasieu Wetland 

68.98 69.03 Calcasieu Upland 

69.03 69.06 Calcasieu Wetland 

69.06 69.91 Calcasieu Upland 

69.91 69.93 Calcasieu Wetland 

69.93 70.69 Calcasieu Upland 

70.69 70.85 Calcasieu Wetland 

70.85 71.60 Calcasieu Upland 

71.60 71.66 Calcasieu Wetland 

71.66 71.82 Calcasieu Upland 

D-10 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

71.82 72.16 Calcasieu Wetland 

72.16 72.19 Calcasieu Upland 

72.19 72.71 Calcasieu Wetland 

72.71 72.73 Calcasieu Upland 

72.73 72.86 Calcasieu Wetland 

72.86 72.92 Calcasieu Upland 

72.92 73.02 Calcasieu Wetland 

73.02 73.06 Calcasieu Upland 

73.06 73.26 Calcasieu Wetland 

73.26 73.28 Calcasieu Upland 

73.28 73.29 Calcasieu Wetland 

73.29 73.30 Calcasieu Upland 

73.30 73.79 Calcasieu Wetland 

73.79 73.81 Calcasieu Upland 

73.81 73.84 Calcasieu Wetland 

73.84 74.89 Calcasieu Upland 

74.89 74.99 Jefferson Davis Wetland 

74.99 75.00 Jefferson Davis Upland 

75.00 75.02 Jefferson Davis Wetland 

75.02 75.06 Jefferson Davis Upland 

75.06 75.28 Jefferson Davis Wetland 

75.28 76.84 Jefferson Davis Upland 

76.84 76.85 Jefferson Davis Wetland 

D-11 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

76.85 77.00 Jefferson Davis Upland 

77.00 77.26 Jefferson Davis Wetland 

77.26 77.61 Jefferson Davis Upland 

78.43 78.94 Jefferson Davis Upland 

78.94 78.99 Jefferson Davis Wetland 

78.99 79.97 Jefferson Davis Upland 

79.97 79.98 Jefferson Davis Wetland 

79.98 82.34 Jefferson Davis Upland 

82.34 82.98 Jefferson Davis Wetland 

82.98 83.38 Jefferson Davis Upland 

83.38 84.22 Jefferson Davis Wetland 

84.22 84.24 Jefferson Davis Upland 

84.24 84.33 Jefferson Davis Wetland 

84.33 84.34 Jefferson Davis Upland 

84.34 84.43 Jefferson Davis Wetland 

84.43 87.41 Jefferson Davis Upland 

87.41 87.68 Jefferson Davis Wetland 

87.68 89.20 Jefferson Davis Upland 

89.20 89.40 Jefferson Davis Wetland 

89.40 92.20 Jefferson Davis Upland 

92.20 92.25 Jefferson Davis Wetland 

92.25 97.44 Jefferson Davis Upland 

97.44 97.48 Jefferson Davis Wetland 

D-12 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

97.48 97.52 Jefferson Davis Upland 

97.52 98.42 Jefferson Davis Upland 

98.42 98.56 Jefferson Davis Wetland 

98.56 98.57 Jefferson Davis Upland 

98.57 98.98 Jefferson Davis Upland 

99.81 103.44 Acadia Upland 

103.44 103.51 Acadia Wetland 

103.51 107.27 Acadia Upland 

107.27 107.29 Acadia Wetland 

107.29 107.92 Acadia Upland 

107.92 107.94 Acadia Wetland 

107.94 108.71 Acadia Upland 

108.71 108.72 Acadia Wetland 

108.72 109.14 Acadia Upland 

109.14 109.25 Acadia Wetland 

109.25 109.26 Acadia Upland 

109.26 109.33 Acadia Wetland 

109.33 110.65 Acadia Upland 

110.65 110.68 Acadia Wetland 

110.68 113.52 Acadia and Evangeline Upland 

113.52 113.54 Evangeline Wetland 

113.54 113.60 Evangeline Upland 

113.60 113.61 Evangeline Wetland 

D-13 Appendix D
TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

113.61 114.90 Evangeline Upland 

114.90 114.92 Evangeline Wetland 

114.92 115.06 Evangeline Upland 

115.06 115.22 Evangeline Wetland 

115.22 117.84 Evangeline Upland 

117.84 117.85 Evangeline Wetland 

117.85 117.93 Evangeline Upland 

117.93 117.95 Evangeline Wetland 

117.95 117.98 Evangeline Upland 

117.98 117.99 Evangeline Wetland 

117.99 118.69 Evangeline Upland 

118.69 118.84 Evangeline Wetland 

118.84 118.85 Evangeline Upland 

118.85 118.86 Evangeline Wetland 

118.86 119.00 Evangeline Upland 

119.00 119.01 Evangeline Wetland 

119.01 122.10 Evangeline Upland 

122.16 123.40 Evangeline Upland 

123.40 123.41 Evangeline Wetland 

123.41 124.56 Evangeline Upland 

124.56 124.59 Evangeline Wetland 

124.59 129.12 Evangeline Upland 

129.12 129.14 Evangeline Wetland 

D-14 Appendix D
D-15 Appendix D

TABLE D-1 Pipeline Segments with a Temporary ROW Width of 125 Feet 

Milepost 

Begin End 

Parish Upland or Wetland Area 

129.14 129.61 Evangeline Upland 

129.67 132.15 Evangeline Upland 

TABLE D-2 Wetlands Affected by Aboveground Facilities 

Permanent Impacts 

Facility Approx. 

MP 

Facility 

Size 

(acres) Cowardin 

Class 

Habitat 

description

NRCS 

Class1 Size (acres) 

Leg 1 and Leg 2 

PEM1C Herbaceous 

Wetland N 0.3 

Southwest Loop 

Delivery Point 28.24 0.9 

PSS1C 

Scrub 

Shrub 

Wetland 

N 0.6 

TGTPL Interconnect 

Site 87.48 1.0 PEM1C Herbaceous Wetland PC 1.0 

NGPL Interconnect 1.23 0.8 E2EM1P5 Herbaceous 

Wetland N 0.8 

FGT Lateral 

The FGT Interconnect on proposed FGT Lateral will not affect any Wetlands
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost 

EWS ID Parish 

Begin End 

EWS Purpose 

Rationale for Alter

and Waterbody 

Leg 1 and Leg 2 

EWS is needed for inmainline valves; the 42” and 36” pipelines Pas LNG Terminal. Wdominate the area of The configuration of defines the layout of site. 

637 Cameron 0.00 0.02 Staging Area, Tie-In & Fabrication Area 

EWS is needed to sufacilitate installation o

638 Cameron 0.01 0.04 Fabrication Area & P.I. 639 Cameron 0.09 0.12 Waterbody Crossing 

EWS is needed to sucrossing. EWS locatwaterbody, but only barea. Wetlands and the Sabine Pass LNG the terminal site in lapipeline corridor in th

D-16 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS is needed to sucrossing. EWS locatwaterbody, but only barea. Wetlands and the Sabine Pass LNG the terminal site in lapipeline corridor in th

640 Cameron 0.09 0.12 Waterbody Crossing 

EWS is needed to faPIs and to support incrossings. EWS locawaterbody, but only bwetland area. Wetlathe area of the Sabinconfiguration of the tthe layout of the pipe

641 Cameron 0.21 0.24 Waterbody Crossing & P.I. 642 Cameron 0.27 0.29 Waterbody Crossing 

EWS is needed to su36” canal crossings. setback from waterbopartially in wetland adominate the area of The configuration of defines the layout of site. 

D-17 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS is needed to faWetlands and waterbSabine Pass LNG Tewetland area cannot configuration of the tthe layout of the pipe

643 Cameron 0.52 0.60 Fabrication Area, Access & P.I. 

EWS is needed to faWetlands and waterbSabine Pass LNG Tewetland area cannot configuration of the tthe layout of the pipe

644 Cameron 0.54 0.57 Fabrication Area & P.I. 

EWS is needed to sucrossover of existing waterbodies dominatLNG Terminal; locaticannot be reasonably the terminal site in lapipeline corridor in th

645 Cameron 0.85 0.95 Foreign Line Crossing, Crossover & P.I. 647 Cameron 0.95 1.02 Fabrication Area, P.I. & Crossover 

EWS is needed to sucrossover of existing waterbodies dominatLNG Terminal; locatiwetland area cannot configuration of the tthe layout of the pipe

D-18 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS is needed to suof an existing road anWetlands and waterbSabine Pass LNG Tewetland area cannot configuration of the tthe layout of the pipe

648 Cameron 1.00 1.07 Road Crossing & Foreign Line Crossing 

EWS is needed to sucrossing of an existinInterconnect. Wetlanthe area of the SabinEWS partially within reasonably avoided aconfiguration of the tthe layout of the pipe

649 Cameron 1.07 1.15 Road Crossing, Fabrication Area, Access & P.I. 650 Cameron 1.16 1.27 Fabrication Area, Foreign Line Crossing, P.I. & Road Crossing 

EWS is needed to sucrossing of an existinwaterbodies dominatLNG Terminal; locatiwetland area cannot location. The configupart defines the layouplant site. 

D-19 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS is needed to suof an existing road siInterconnect. Wetlanthe area of the SabinEWS partially within reasonably avoided aof the terminal site in the pipeline corridor plant site. 

651 Cameron 1.23 1.31 Road Crossing, Staging Area & Fabrication Area 

EWS is needed to suline crossings and a Wetlands and waterbSabine Pass LNG Tewetland area cannot location. The configupart defines the layouplant site. 

652 Cameron 1.34 1.44 Road Crossing, Foreign Line Crossing, Access & Fabrication Area 653 Cameron 1.37 1.42 Road Crossing & Foreign Line Crossing 

EWS is needed to suline crossings and a Wetlands and waterbSabine Pass LNG Tewithin wetland area cthis location. The colarge part defines the the plant site. 

D-20 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS is needed to suexisting plant road anWetlands and waterbSabine Pass LNG Tewithin wetland area cthis location. The colarge part defines the the plant site. 

655 Cameron 1.44 1.51 Road Crossing & Fabrication Area 

EWS is needed to suexisting plant road anWetlands and waterbSabine Pass LNG Tewetland area cannot location. The configupart defines the layouplant site. 

654 Cameron 1.46 1.50 Road Crossing 

25 HDD Cameron 3.89 3.94 HDD Site - Entry Hole 

EWS is needed to sushoreline of Sabine Lavoid wetlands or at waterbodies dominatSabine Lake. The reprovided by HDD inslocation in this previo

D-21 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS is needed to sulocation and must be reduction in shoreline installation easily offstemporary HDD-relat

24 HDD Cameron 4.82 4.87 HDD Site - Exit Hole 

EWS is needed for fapullback string and mThe reduction in shoinstallation easily offspullback string fabriclake bottom or water 

537 Cameron 5.54 5.81 Pull String 

EWS is needed for fapullback string and mThe reduction in shoinstallation easily offspullback string fabriclake bottom or water 

536 Cameron 17.15 17.89 Pull String 

23 HDD Cameron 17.86 17.97 HDD Site - Exit Hole 

EWS is needed to sushoreline crossing anHDD segments. EWLake. The reduction HDD installation easitemporary HDD-relat

D-22 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS is needed for fapullback strings and The reduction in shoinstallation easily offspullback string fabriclake bottom or water 

670 Orange County 17.92 18.18 Fabricate Pull String 

EWS is needed for faHDD pullback string Lake. The reduction provided by HDD inslocation in the lake; phave few impacts on 

535 Orange County 18.09 18.56 Pull String 535 Cameron 18.51 18.57 Pull String 

EWS is needed for faHDD pullback string Sabine River. The reimpacts provided by the EWS location in tfabrication will have fbottom, or water qua

D-23 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS supporting 42” points in Sabine Riveand adjacent wetlandwetland impacts provoffsets dredging and impacts in the river. subject to previous doperations for the GIdominate the area in and the Sabine River

22 HDD Cameron 18.55 18.66 HDD Site - Entry & Exit Hole 

EWS supporting 42” Sabine River avoids adjacent wetlands; thwetland impacts provoffsets dredging and impacts in the river. 

21 HDD Cameron 19.36 19.50 HDD Site - Entry Holes 20 HDD Cameron 20.00 20.04 HDD Site - Exit Hole 

EWS supporting 42” adjacent to Sabine Rpullback string, 50’ sepractical. Further, acsupported by barge. impacts provided by dredging and other tethe river bottom. Baroperations on the bareduces impacts by eaccess road construc

D-24 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS is needed to prlocated in EWS 20 HEWS and adjacent osupported by barge freduces construction for temporary access 

534 Cameron 20.00 20.04 HDD & Work Corridor Access 

EWS is needed for faHDD pullback strings Sabine River. The reby HDD installations the river; pullback strimpacts on river bank

557 Cameron 20.04 20.98 Pull String 

EWS is needed to acEWS 557and must bSabine River; 50’ setwetlands is not possiinstallation will greatlimmediately east of t

531 Cameron 20.90 21.04 Pull String Access 532 Cameron 21.02 21.07 P.I. 

EWS is needed to fathe riverbank and cato Sabine River. PI wfor HDD exit in EWS 

D-25 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS supporting 42” upland adjacent to Sof pullback string, 50practical. Further, acsupported by barge f

19 HDD Cameron 21.14 21.19 HDD Site - Exit Hole 

EWS is needed to prlocated in EWS 19 HEWS and adjacent osupported by barge freduces construction for temporary access 

574 Cameron 21.14 21.19 HDD & Work Corridor Access 

EWS is needed for fastring and must align Due to alignment at bavoid wetlands south bank impacts provideoffsets the temporary wetlands. 

577 Cameron 21.68 22.11 Pull String 575 Cameron 22.05 22.17 HDD & Work Corridor Access 

EWS in the Sabine Rto 42” HDD entry and Further, access to HDthe Sabine River greby eliminating the neconstruction. 

D-26 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS on the bank of connect EWS 575 wiEWS cannot avoid whowever, access to Hfrom the Sabine Riveby reducing overall celiminating the need construction. 

576 Cameron 22.08 22.14 Access 

EWS supporting 42” upland adjacent to SEWS must be suppo576. 

18 HDD Cameron 22.08 22.14 HDD Site – Entry/Exit Holes 

EWS supporting 42” upland adjacent to SEWS must be suppo

26 HDD Cameron 22.69 22.74 HDD Site - Entry Holes 

EWS in and on the bneeded to support EWEWS cannot avoid whowever, access to Hthe Sabine River grereducing overall consthe need for tempora

578 Cameron 22.69 22.74 HDD & Work Corridor Access 

27 HDD Cameron 23.43 23.49 HDD Site - Exit & Entry Hole 

EWS supporting 42” upland adjacent to Smust be supported b

D-27 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

579 Cameron 23.44 23.48 HDD & Work Corridor Access 

EWS in and on the bneeded to support EWEWS avoids wetlandsetback 50’ from the HDD entry EWS by bgreatly offsets waterbeliminating the need construction. 

D-28 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS is needed to acEWS 582 and is locaRiver; 50’ setback frothe purpose of this Estring. 

580 Cameron 23.48 23.56 Pull String Access 

EWS is needed to prlocated in EWS 28 HEWS and adjacent osupported by barge fBurton Shell Slip greby eliminating the neconstruction. 

581 Cameron 23.82 23.86 Access 582 Cameron 23.86 24.48 Pull String 

EWS is needed for fapullback string and mRiver. The reduction HDD installations easthe river; pullback strimpacts on river bank(Continues into Calca

D-29 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS supporting 42” upland adjacent to SCanal. Access to HDbarge from EWS 581

28 HDD Cameron 23.91 23.96 HDD Site - Exit Hole 

EWS needed to suppcrossing located in wRiver; no other locaticonsidering the proxi

530 Cameron 24.21 24.26 Foreign Line Crossing 

(Continuation of EWS needed for fabricatioand must be located reduction in bank impinstallations easily ofriver; pullback string on river banks, botto

582 Calcasieu 24.47 24.59 Pull String 

EWS is needed to fathe riverbank and cato Sabine River/GIWpractical considering lines. 

529 Cameron 24.57 24.62 P.I. 

29 HDD Calcasieu 25.22 25.28 HDD Site - Exit Hole 

EWS supporting 42” upland adjacent to SHDD EWS must be s583. 

D-30 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS in the GIWW is HDD exit located in EEWS 30 HDD. Accebarge from the GIWW impacts by eliminatinroad construction. 

583 Calcasieu 25.80 25.86 HDD Access & Loading Area 

EWS on the bank of EWS 29 HDD and EWto EWS 583 in the GEWS avoids wetlandbe setback 50’ from tto HDD EWS by bargwaterbody and wetlaneed for temporary a

584 Calcasieu 25.80 25.83 Access & Loading Area 

EWS supporting 42” adjacent to GIWW. Asupported by barge f

30 HDD Calcasieu 26.00 26.05 HDD Site - Entry Holes 31 HDD Calcasieu 26.78 26.83 HDD Site - Exit Hole 

EWS supporting 42” adjacent to GIWW. Asupported by barge f

D-31 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS in the GIWW is HDD exit located in Eexit EWS and onshofrom the GIWW greaby eliminating the neconstruction. 

585 Calcasieu 27.58 27.64 Access & Loading Area 

EWS on the bank of EWS 31 HDD and onproviding access to EGIWW access to EWbank, but cannot be However, access to Hconstruction corridor offsets waterbody anthe need for tempora

586 Calcasieu 27.58 27.60 Access & Loading Area 587 Calcasieu 27.81 27.86 Foreign Line Crossing 

EWS needed to suppcrossing partially localocation of EWS is prsurrounding wetland foreign lines and elec

D-32 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppLoop Interconnect anpartially located in weEWS is practical conareas and proximity oelectric transmission 

588 Calcasieu 28.26 28.33 Foreign Line Crossing 

EWS is needed for fapullback string for GIcrossings. Fabricatiowetland and shallow alignment for pullbacthe channel and banBay Cutoff provided the temporary wetlanEWS. 

523 Cameron, Calcasieu 29.46 29.90 Pull String 

EWS supporting 42” adjacent to GIWW. Asupported by barge f

16 HDD Calcasieu 30.32 30.38 HDD Site - Exit Hole 

522 Calcasieu 31.37 31.43 Work Corridor Access 

EWS in the GIWW is HDD entries located entries EWS by bargconstruction impacts temporary access ro

D-33 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS on the bank of EWS 15 HDD by proGIWW. The GIWW awetlands adjacent to setback 50’ from the HDD EWS by barge waterbody and wetlaneed for temporary a

521 Calcasieu 31.39 31.42 Loading & Unloading Area 

EWS supporting 42” adjacent to GIWW. Asupported by barge fother location of the surrounding wetland foreign lines and elec

15 HDD Calcasieu 31.43 31.50 HDD Site - Entry Holes 13 HDD Calcasieu 32.41 32.46 HDD Site - Exit Hole 

EWS supporting 42” adjacent to GIWW. Asupported by barge fother location of the surrounding wetland foreign lines and elec

D-34 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS in the GIWW is HDD exit located in Econstruction corridoronshore construction GIWW greatly reduceeliminating the need construction. 

518 Calcasieu 32.43 32.50 Work Corridor Access 

EWS on the bank of EWS 13 HDD and onproviding access to EGIWW access to EWbank, but cannot be However, access to Hconstruction corridor offsets waterbody anthe need for tempora

517 Calcasieu 32.45 32.49 Loading & Unloading Area 514 Calcasieu 35.15 35.19 Fabrication Area, Access & P.I. 

EWS needed to suppcrossing and PIs; EWareas; no other locatconsidering the surroproximity of foreign lilines. 

D-35 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppand foreign line crosslocated in wetland arpractical considering waterbody, foreign lin

511 Calcasieu 36.50 36.60 

Waterbody Crossing, Road Crossing, Foreign Line Crossing, Fabrication Area & Access 

EWS needed to suppforeign line crossingswaterbody and wetlalocation for the EWS proximity the waterboline, and other wetlan

510 Calcasieu 37.29 37.36 Waterbody Crossing & Access 

EWS needed to suppcrossings; EWS is selocated in wetland arthe EWS is practical wetland areas. 

509 Calcasieu 37.84 37.87 Waterbody Crossing 508 Calcasieu 37.89 37.98 

Road Crossing, Waterbody Crossing, Fabrication Area, Access & Truck Turnaround 

EWS needed to supproad crossings and trin wetland area; howEWS is practical conwetland areas. 

D-36 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppditch crossing; EWS waterbody but is locaother location for the proximity of other we

507 Calcasieu 37.98 38.01 Waterbody Crossing & Road Crossing 

EWS needed to suppfor installation in redustructure. EWS is selocated in wetland arthe EWS is practical wetland areas. 

506 Calcasieu 38.11 38.23 Drag Section 

EWS needed to suppditch crossing; EWS and ditch; however, npractical considering areas. 

505 Calcasieu 38.34 38.40 Waterbody Crossing, Road Crossing & Access 503 Calcasieu 38.86 38.90 Waterbody Crossing 

EWS needed to suppcrossing; EWS is locwetland area; howevis practical considerinareas. 

D-37 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing; EWS is locwetland area; howevis practical considerinareas. 

504 Calcasieu 38.94 38.96 Waterbody Crossing 

EWS needed to suppditch crossing; EWS and ditch; however, npractical considering areas. 

502 Calcasieu 39.06 39.14 Waterbody Crossing, Road Crossing & Access 

EWS needed to suppcrossing; EWS is locditch; however, no otpractical considering waterbody and the p

501 Calcasieu 39.44 39.46 Waterbody Crossing 

EWS needed to suppcrossing; EWS is locditch; however, no otpractical considering waterbody and the p

500 Calcasieu 39.47 39.49 Waterbody Crossing 589 Calcasieu 39.82 40.04 Crossing Section & Access 

EWS needed for fabrcrossings of multiple canals. No other locconsidering the align

D-38 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to supproad crossing; EWS however, no other loconsidering the charathe proximity of other 

499 Calcasieu 39.90 39.98 Access & Waterbody Crossing 

EWS needed to suppmultiple foreign lines located within 50’ welocation for the EWS and complexity of the 

593 Calcasieu 40.29 40.33 Waterbody Crossing, Truck Turnaround & Foreign Line Crossing 

EWS needed to suppmultiple foreign lines located within 50’ welocation for the EWS and complexity of the 

590 Calcasieu 40.29 40.35 Foreign Line Crossing & P.I. 

EWS needed to suppcrossing; EWS is lochowever, no other loconsidering the charathe proximity of other 

490 Calcasieu 41.47 41.49 Waterbody Crossing 488 Calcasieu 42.45 42.47 Waterbody Crossing 

EWS needed to suppcrossing; EWS is lochowever, no other loconsidering the chara

D-39 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing; EWS is lochowever, no other loconsidering the chara

487 Calcasieu 42.48 42.50 Waterbody Crossing 

EWS needed to suppcrossing; EWS is setlocated in a wetland for the EWS is practicharacteristics of the other wetlands. 

659 Calcasieu 42.72 42.76 Waterbody Crossing 

EWS is needed for fapullback string for BaFabrication EWS is lo(upland or converted more irrigation canalsproper alignment for EWS 11 HDD. The pmore irrigation canals reduction in impacts associated with Bayoinstallation easily offsfabrication EWS. 

597 Calcasieu 43.13 43.67 Pull String 662 Calcasieu 43.22 43.25 Waterbody Crossing 

EWS needed to suppcrossing; EWS is lochowever, no other loconsidering the chara

D-40 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS supporting 42” wetland area (upland included for referencrequested). Pull strin

11 HDD Calcasieu 43.65 43.72 HDD Site - Exit Hole 

EWS supporting 42” wetland area (upland included for referencrequested). Pull strin

32 HDD Calcasieu 44.45 44.51 HDD Site - Entry Hole 

EWS needed to suppcrossing. EWS is selocated within 50’ of wlocation for the EWS characteristics of the wetlands. 

476 Calcasieu 45.52 45.53 Waterbody Crossing 

EWS needed to suppcrossing. EWS is selocated within 50’ of wlocation for the EWS characteristics of the wetlands. 

475 Calcasieu 45.52 45.54 Waterbody Crossing 473 Calcasieu 45.56 45.58 Waterbody Crossing 

EWS needed to suppcrossing. EWS is selocated in wetland arthe EWS is practical the waterbody and p

D-41 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is selocated in wetland arthe EWS is practical the waterbody and p

474 Calcasieu 45.56 45.58 Waterbody Crossing 

EWS needed to suppcrossing and PI. EWwaterbody, and is locno other location for the characteristics of adjacent wetlands. 

471 Calcasieu 45.76 45.79 Waterbody Crossing & P.I. 

EWS needed to suppcrossing, PI and trucfrom waterbody, and however, no other loconsidering the charaproximity of adjacent 

472 Calcasieu 45.76 45.80 Waterbody Crossing, Fabrication Area, Truck Turnaround & P.I. 470 Calcasieu 45.87 45.90 Waterbody Crossing 

EWS needed to suppcrossing. EWS is selocated within 50’ of wwaterbody. Setback to provide protection soil/spoil transfer and installation of the cro

D-42 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing and to allow 50’ from waterbody, wetland adjacent to twaterbody is sufficienminimizing distance fthis will expedite inst

469 Calcasieu 45.88 45.93 Waterbody Crossing & Truck Turnaround 

EWS needed for trucpartially located in wethe EWS is practical characteristics of adjthe access road. 

467 Calcasieu 46.19 46.26 Access 

EWS needed to suppcrossing. EWS is selocated in wetland arthe EWS is practical the waterbody and p

464 Calcasieu 46.69 46.71 Waterbody Crossing 463 Calcasieu 46.70 46.73 Waterbody Crossing 

EWS needed to suppcrossing. EWS is selocated in wetland arthe EWS is practical the waterbody and p

D-43 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is selocated in wetland arthe EWS is practical adjacent wetlands. 

460 Calcasieu 46.93 46.98 Waterbody Crossing, Access & Staging Area 

EWS needed to suppcrossing. EWS is selocated in wetland arthe EWS is practical adjacent wetlands. 

462 Calcasieu 46.94 46.96 Waterbody Crossing 

EWS needed to suppcrossing. EWS is selocated in wetland arthe EWS is practical adjacent wetlands anand waterbody. 

459 Calcasieu 46.96 47.01 Waterbody Crossing & Access 461 Calcasieu 46.97 47.00 Waterbody Crossing & Access 

EWS needed to suppcrossing. EWS is selocated in wetland arthe EWS is practical adjacent wetlands anand waterbody. 

D-44 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is separtially located in welocation for the EWS proximity of adjacent 

457 Calcasieu 47.33 47.35 Waterbody Crossing 

EWS needed to suppcrossing. EWS is separtially located in welocation for the EWS proximity of adjacent 

456 Calcasieu 47.33 47.35 Waterbody Crossing 

EWS needed to suppcrossing. EWS is selocated within 50’ of wwaterbody. Setback to provide protection soil/spoil transfer and installation of the cro

454 Calcasieu 47.37 47.39 Waterbody Crossing 455 Calcasieu 47.37 47.39 Waterbody Crossing 

EWS needed to suppcrossing. EWS is selocated within 50’ of wwaterbody. Setback to provide protection soil/spoil transfer and installation of the cro

D-45 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing and PI. EWhowever, no other loconsidering the proxi

450 Calcasieu 47.76 47.87 Road Crossing, Fabrication Area & P.I. 

EWS needed to suppcrossing and PI. EWhowever, no other loconsidering the proxi

451 Calcasieu 47.77 47.87 Road Crossing & P.I. 

EWS needed to suppof in wetland area; hoEWS is determined bwetland features in th

447 Calcasieu 48.42 48.49 P.I. 

EWS needed to suppof wetland area; howEWS is determined bwetland features in th

446 Calcasieu 48.46 48.50 P.I. 

EWS supporting 42” area adjacent to Calcreference only, no altPullback is to EWS 9 construction corridor

10 HDD Calcasieu 49.52 49.58 HDD Site - Exit Hole 

444 Calcasieu 49.69 49.72 Equipment Area EWS is need for equ

pull string fabrication 

D-46 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS is needed for fapullback string for Cacrossings. Pullback Fabrication EWS mudredged material disCalcasieu River to prpullback. The reductbanks of the river anby HDD installation ewetland impacts of th

443 Calcasieu 49.71 50.44 Pull String 

EWS supporting 42” wetland adjacent to Cimpacts to the channRiver and LNG Terminstallation easily offsimpacts of HDD entry Access is from the nodisposal area. 

9 HDD Calcasieu 50.42 50.5 HDD Site - Entry & Exit Hole 

441 Calcasieu 51.19 51.28 Pull String 

EWS is needed for fapullback string. PullbEWS 441 located eninformation only, no aHDD will eliminate wHDD and EWS 6 HS

D-47 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS supporting 42” area on west side of Henry Puglet Blvd (inalternative measure 

8 HDD Calcasieu 51.28 51.33 HDD Site - Entry Hole 

EWS supporting 42” area on west side of Henry Puglet Blvd (inalternative measure 

7 HDD Calcasieu 51.74 51.79 HDD Site - Exit Hole 

EWS supporting 42” wetland adjacent to Cimpacts to wetlands peasily offsets the tementry construction acHwy 384. 

6 HDD Calcasieu 52.35 52.41 HDD Site - Entry Holes 5 HDD Calcasieu 53.04 53.08 HDD Site - Exit Hole 

EWS supporting 42” wetland area on consEWS 5 HDD from Joneed to prevent impareduction in impacts installation easily offsimpacts of access to construction activity. construction corridor 

D-48 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is locno other location for the proximity of adjac

435 Calcasieu 53.53 53.56 Road Crossing 

EWS needed to suppcrossing. EWS is selocated within wetlanlocation for the EWS proximity of adjacent 

432 Calcasieu 53.96 53.98 Waterbody Crossing 

EWS needed to suppcrossing and for trucfrom waterbody, but area. EWS is locatewaterbody crossing wRelocating EWS to eadjacent wetland are

425 Calcasieu 55.04 55.08 Waterbody Crossing, Truck Turnaround & Fabrication Area 426 Calcasieu 55.04 55.11 Waterbody Crossing & Truck Turnaround 

EWS needed to suppcrossing. EWS is senot setback 50’ from close possible to watwetland area. Relocencroach on another 

D-49 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is senot set back 50’ from waterbody. Setback to provide protection soil/spoil transfer and installation of the cro

419 Calcasieu 55.81 55.83 Waterbody Crossing 

EWS needed to suppclose to the highwayprobably associated and would be isolatestrip or silt fence. 

412 Calcasieu 56.67 56.70 Road Crossing, Staging Area & Fabrication Area 

EWS needed to suppRoad crossing. EWS area; however, no otpractical considering wetlands. 

409 Calcasieu 57.66 57.70 Road Crossing 408 Calcasieu 57.85 57.92 Road Crossing & Fabrication Area 

EWS needed to suppHouse Road crossingwetland area; howevis practical considerinwetlands. 

D-50 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppchannelized Black Baand change in workinsetback 50’ from watsedimentation featurcorridor from the watpipeline construction associated with cultiv

401 Calcasieu 59.66 59.73 Fabrication Area, Spread Flop & Foreign Line Crossing 

EWS needed to suppforeign line crossing, previously cultivated EWS is not practical designed to parallel ecanals, pipelines, etcconstruction will likely with previous cultivat

62 Calcasieu 60.97 60.99 Road Crossing, Fabrication Area & P.I. 

361 Calcasieu 66.67 66.69 Waterbody Crossing 

EWS needed to suppcrossing. EWS is senot set back 50’ from waterbody. Setback to provide protection soil/spoil transfer and installation of the cro

D-51 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is senot set back 50’ from waterbody. Setback to provide protection soil/spoil transfer and installation of the cro

360 Calcasieu 66.70 66.72 Waterbody Crossing 

EWS needed to suppcrossing, adjacent to turning. EWS is locaother location for the proximity of adjacent 

315 Calcasieu 67.03 67.09 Railroad Crossing, Waterbody Crossing & Truck Turnaround 

EWS needed to suppcrossing. EWS is senot set back 50’ from waterbody; however, practical considering wetlands. 

316 Calcasieu 67.09 67.15 Waterbody Crossing & Fabrication Area 317 Calcasieu 67.17 67.19 Waterbody Crossing 

EWS needed to suppcrossing. EWS is senot set back 50’ from waterbody; however, practical considering wetlands. 

D-52 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is senot set back 50’ from waterbody; however, practical considering wetlands. 

318 Calcasieu 67.26 67.28 Waterbody Crossing 

EWS needed to suppcrossing. EWS is senot set back 50’ from waterbody; however, practical considering wetlands. 

319 Calcasieu 67.29 67.37 Waterbody Crossing & Access 

EWS needed to suppcrossing. EWS is noagricultural wetland lhowever, no other loconsidering the proxi

322 Calcasieu 67.62 67.65 Road Crossing 325 Calcasieu 68.30 68.33 Road Crossing & Waterbody Crossing 

EWS needed to suppcrossing. EWS is noand wetland located no other location for the characteristics of wetlands. 

D-53 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is noand wetland located no other location for the characteristics of wetlands. 

326 Calcasieu 68.34 68.35 Road Crossing & Waterbody Crossing 

EWS needed to suppcrossing and to proviback 50’ from waterbwetland area; howevis practical considerinproximity of adjacent 

330 Calcasieu 68.97 69.07 Waterbody Crossing, Fabrication Area & Truck Turnaround 338 Calcasieu 69.83 69.90 

Waterbody Crossing, Fabrication Area, Foreign Line Crossing & Truck Turnaround 

EWS needed to suppand foreign line crossEWS is not set back located adjacent to wlocation for the EWS of the foreign line anwaterbody and adjac

D-54 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is nohowever, no other loconsidering charactefor field road access 

342 Calcasieu 70.63 70.68 Waterbody Crossing, Fabrication Area & Access 

EWS needed to suppcrossing. EWS is selocated in fallow agriwaterbody; however, practical considering agricultural wetlands

343 Calcasieu 70.72 70.74 Waterbody Crossing 

EWS needed to suppwaterbody crossing. waterbody, but is locadjacent to road; howEWS is practical confallow agricultural we

350 Calcasieu 72.87 72.98 Road Crossing, Waterbody Crossing & Fabrication Area 261 Calcasieu 73.77 73.80 Road Crossing 

EWS needed to suppcrossing. EWS is locwetland adjacent to rfor the EWS is practiadjacent fallow agric

D-55 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing of Thompsowetland area. Installagricultural wetland; EWS is practical confallow agricultural weMLV adjacent to road 

262 Calcasieu 73.82 73.88 Road Crossing & Fabrication Area 

EWS needed to supp(inactive) and waterbback 50’ from waterbadjacent to waterbodfor the EWS is practirailroad and the locatwaterbodies and adja

265 Jefferson Davis 74.92 74.97 Railroad Crossing, Waterbody Crossing, Fabrication Area & P.I. 

EWS supporting 42” crossing is located in prior-converted croplno alternative measufabrication in constru

2 HDD Jefferson Davis 98.98 99.03 HDD Site - Exit Hole 1 HDD Acadia 99.76 99.81 HDD Site – Entry Hole 

EWS supporting 42” crossing is located in prior-converted croplno alternative measu

D-56 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is noHowever, considerinwaterbody, setback fprovide protection whsoil/spoil transfer and installation of the cro

35 Acadia 100.72 100.74 Waterbody Crossing 

EWS needed to suppcrossing. EWS is noHowever, considerinwaterbody, setback fprovide protection whsoil/spoil transfer and installation of the cro

36 Acadia 100.72 100.74 Waterbody Crossing 34 Acadia 100.75 100.77 Waterbody Crossing 

EWS needed to suppcrossing. EWS is noHowever, considerinwaterbody, setback fprovide protection whsoil/spoil transfer and installation of the cro

D-57 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is noHowever, considerinwaterbody, setback fprovide protection whsoil/spoil transfer and installation of the cro

226 Acadia 104.29 104.32 Waterbody Crossing 

EWS needed to suppcrossing. EWS is noHowever, considerinwaterbody, setback fprovide protection whsoil/spoil transfer and installation of the cro

229 Acadia 104.70 104.72 Waterbody Crossing 230 Acadia 104.73 104.75 Waterbody Crossing 

EWS needed to suppcrossing. EWS is noHowever, considerinwaterbody, setback fprovide protection whsoil/spoil transfer and installation of the cro

D-58 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is nowetland on foreign linHowever, considerinisolated wetlands, reproposed pipeline) is in increased clearing 

53 Evangeline 113.41 113.61 Railroad Crossing & Foreign Line Crossing 

EWS needed to suppcrossing. EWS is noand wetland located no other location for proximity of other adjareas. EWS location while minimizing diststorage; this will expesegment. 

120 Evangeline 118.82 118.84 Waterbody Crossing 119 Evangeline 118.85 118.87 Waterbody Crossing 

EWS needed to suppcrossing. EWS is noand wetland located no other location for proximity of other adjareas. EWS location while minimizing diststorage; this will expesegment. 

D-59 
Table D-3 Rationale for Extra Workspaces Within 50 feet of Waterbodies and W

Milepost Rationale for Alter

and Waterbody 

EWS ID Parish 

Begin End 

EWS Purpose 

EWS needed to suppcrossing. EWS is noHowever, considerinwaterbody, setback fprovide protection whsoil/spoil transfer and installation of the cro

124 Evangeline 121.83 121.85 Waterbody Crossing 

FGT Lateral 

EWS needed to suppCannes crossing. EWarea; however, EWS areas. No other locaconsidering location EWS. 

- Acadia 1.18 1.26 Waterbody Crossing, Fabrication Area & Access 

D-60 
APPENDIX E 

PIPELINE CONSTRUCTION METHODS BY MILEPOST 
[This page intentionally left blank.] 
Pipeline Construction Methods by Milepost 

The anticipated primary construction methods that will be used along the KMLP Project 

are listed by milepost in the following tables (minor construction methods, such as road, 

railroad, and pipeline crossings are not listed). The construction method numbers used in 

the table correspond to the construction method descriptions as follows: 

• Typical Submerged Marsh (Push-Pull); 

• Typical HDD Waterbody Crossing; 

• Typical Inland Open Water <8’ Depth; 

• Saturated Wetland Crossing without Topsoil Segregation; 

• Typical Cross Section with 42” Pipe Adjacent to Foreign Pipeline without Topsoil 

Segregation; 

• Upland without Topsoil Segregation; 

• Typical Cross Section with 24” Pipe Adjacent to Foreign Pipeline without Topsoil 

Segregation; 

• Unsaturated Wetland Crossing with Topsoil Segregation; 

• 42” Typical Cross Section with Full Width Topsoil Segregation; 

• Typical Cross Section with 42” Pipe Adjacent to Foreign Pipe with Ditch Plus 

Spoil Side Topsoil Segregation; 

• 42” & 36” Typical Cross Section without Topsoil Segregation; 

• 36” Typical Cross Section without Topsoil Segregation; and 

• Inland Open Water ≥8’ Depth. 

E-1 Appendix I 
TABLE E-1 Pipeline Construction Method by Milepost 

Milepost 

Begin End 

Primary Construction Method 

Description Figure Number

0.00 0.92 42” & 36” Typical Cross Section without 

Topsoil Segregation (LNG Terminal) 2.3.1.1-6 

0.92 1.51 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

1.51 3.93 Typical Submerged Marsh (Push-Pull) 2.3.1.2-5 

3.93 4.83 Typical HDD Waterbody Crossing 2.3.1.3-1 

4.83 9.93 Typical Inland Open Water <8’ Depth 2.3.1.3-4 

9.93 11.94 Typical Inland Open Water ≥8’ Depth 2.3.1.3-5 

11.94 12.21 Typical Inland Open Water <8’ Depth 2.3.1.3-4 

12.21 13.50 Typical Inland Open Water ≥8’ Depth 2.3.1.3-5

13.50 13.82 Typical Inland Open Water <8’ Depth 2.3.1.3-4 

13.82 14.23 Typical Inland Open Water ≥8’ Depth 2.3.1.3-5

14.23 17.96 Typical Inland Open Water <8’ Depth 2.3.1.3-4 

17.96 18.62 Typical HDD Waterbody Crossing 2.3.1.3-1 

18.62 19.41 Typical HDD Waterbody Crossing 2.3.1.3-1 

19.41 20.01 Typical HDD Waterbody Crossing 2.3.1.3-1 

20.01 20.57 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

20.57 21.17 Saturated Wetland Crossing without Topsoil 

Segregation 

2.3.1.2-3 and 

2.3.1.2-4

21.17 22.11 Typical HDD Waterbody Crossing 2.3.1.3-1 

22.11 22.71 Typical HDD Waterbody Crossing 2.3.1.3-1 

22.71 23.45 Typical HDD Waterbody Crossing 2.3.1.3-1 

23.45 23.95 Typical HDD Waterbody Crossing 2.3.1.3-1 

E-2 Appendix I 
TABLE E-1 Pipeline Construction Method by Milepost 

Milepost 

Begin End 

Primary Construction Method 

Description Figure Number

23.95 25.26 Saturated Wetland Crossing without Topsoil 

Segregation 

2.3.1.2-3 and 

2.3.1.2-4

25.26 26.03 Typical HDD Waterbody Crossing 2.3.1.3-1 

26.03 26.80 Typical HDD Waterbody Crossing 2.3.1.3-1 

26.80 30.36 Saturated Wetland Crossing without Topsoil 

Segregation 

2.3.1.2-3 and 

2.3.1.2-4

30.36 31.46 Typical HDD Waterbody Crossing 2.3.1.3-1 

31.46 32.42 Typical HDD Waterbody Crossing 2.3.1.3-1 

32.42 35.15 Typical Submerged Marsh (Push-Pull) 2.3.1.2-5 

35.15 35.64 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

35.64 37.40 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

37.40 38.59 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

38.59 37.24 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

37.24 39.10 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

39.10 40.29 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

40.29 42.50 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

42.50 42.72 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

42.72 43.36 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

E-3 Appendix I 
TABLE E-1 Pipeline Construction Method by Milepost 

Milepost 

Begin End 

Primary Construction Method 

Description Figure Number

43.36 43.44 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

43.44 43.69 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

43.69 44.48 Typical HDD Waterbody Crossing 2.3.1.3-1 

44.48 44.82 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

44.82 45.00 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

45.00 45.55 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

45.55 46.23 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

46.23 46.70 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

46.70 47.00 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

47.00 47.76 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

47.76 48.04 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

48.04 48.70 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

48.70 49.15 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

49.15 49.57 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

49.57 50.45 Typical HDD Waterbody Crossing 2.3.1.3-1 

50.45 51.30 Typical HDD Waterbody Crossing 2.3.1.3-1 

51.30 51.78 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

E-4 Appendix I 
TABLE E-1 Pipeline Construction Method by Milepost 

Milepost 

Begin End 

Primary Construction Method 

Description Figure Number

51.78 52.37 Typical HDD Waterbody Crossing 2.3.1.3-1 

52.37 53.05 Typical HDD Waterbody Crossing 2.3.1.3-1 

53.05 53.52 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

53.52 53.60 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

53.60 53.90 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

53.90 54.02 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

54.02 54.91 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

54.91 55.03 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

55.03 56.06 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

56.06 57.64 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

57.64 57.94 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

57.94 59.73 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

59.73 61.00 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

61.00 62.70 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

62.70 66.27 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

E-5 Appendix I 
TABLE E-1 Pipeline Construction Method by Milepost 

Milepost 

Begin End 

Primary Construction Method 

Description Figure Number

66.27 66.95 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

66.95 67.37 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

65.37 72.91 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

72.91 73.85 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

73.85 76.20 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

76.20 76.98 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

76.98 77.65 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

77.65 78.40 Typical HDD Waterbody Crossing 2.3.1.3-1 

78.40 88.61 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

88.61 89.08 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

89.08 89.20 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

89.20 89.40 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

89.40 89.58 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

89.58 99.02 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

E-6 Appendix I 
TABLE E-1 Pipeline Construction Method by Milepost 

Milepost 

Begin End 

Primary Construction Method 

Description Figure Number

99.02 99.76 Typical HDD Waterbody Crossing 2.3.1.3-1 

99.76 101.52 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

101.52 105.73 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

105.73 106.97 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

106.97 109.14 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

109.14 109.36 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

109.36 101.14 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

101.14 112.01 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

112.01 112.42 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

112.42 118.30 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

118.30 118.68 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

118.68 118.86 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

118.86 121.95 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

121.95 122.06 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

E-7 Appendix I 
TABLE E-1 Pipeline Construction Method by Milepost 

Milepost 

Begin End 

Primary Construction Method 

Description Figure Number

122.06 129.57 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

129.57 129.69 42” Typical Cross Section without Topsoil 

Segregation 2.3.1.1-2 

129.69 129.80 Typical Inland Open Water ≥8’ Depth 2.3.1.3-5

129.80 132.16 

Typical Cross Section with 42” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-3 

0.00 0.92 42” & 36” Typical Cross Section without 

Topsoil Segregation (LNG Terminal) 2.3.1.1-6 

0.92 1.22 36” Typical Cross Section without Topsoil 

Segregation (LNG Terminal) 2.3.1.1-7

0.00 0.77 

Typical Cross Section with 24” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-8

0.77 1.57 Unsaturated Wetland Crossing with Topsoil 

Segregation 

2.3.1.2-1 and 

2.3.1.2-2 

1.57 2.30 

Typical Cross Section with 24” Pipe 

Adjacent to Foreign Pipeline without Topsoil 

Segregation 

2.3.1.1-8

E-8 Appendix I 
APPENDIX F 

ROUTE VARIATION MAPS
[This page intentionally left blank] 
 F-1 

Non-Internet Public 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

KINDER MORGAN LOUISIANA PIPELINE PROJECT 

Docket No. CP06-449-000 

Pages F-1 to F-13 

Maps 

Public access for this Non-Internet Public information is available only thro

Reference Room, or by e-mail at public.referenceroom@ferc.go
[This page intentionally left blank.] 
APPENDIX G 

WATERBODY CROSSINGS 
[This page intentionally left blank] 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

LEG 1 AND LEG 2 Canal 0.08 I 12.3 n No impairment reported None Waterbody 0.24 I 30.1 n No impairment reported None Canal 1.73 P 24.6 n No impairment reported None Canal 3.47 P 36.6 n No impairment reported None Big Forge Bayou 3.99 P 77.9 n No impairment reported None Sabine Lakee 11.07 P 71205.2 ABCE No impairment reported Commercial and recSabine Rivere 18.55 P 1074.2 ABC No impairment reported Recreational fishery Sabine Rivere 19.54 P 3651.6 ABC No impairment reported Recreational fishery Sabine Rivere 21.92 P 3165.1 ABC No impairment reported Recreational fishery Sabine Rivere 22.49 P 333.4 ABC No impairment reported Recreational fishery Canal 22.60 P 59.6 n No impairment reported None Burton Shell Slip 23.83 P 99.7 ABC No impairment reported Recreational fishery Canal 30.39 P 37.2 n No impairment reported None Black Bay Cutoffe 30.61 P 167.2 ABC No impairment reported Recreational fishery Intracoastal Waterwaye 30.69 P 1729.4 ABC No impairment reported Recreational and coIntracoastal Waterway 31.05 P 94.4 ABC No impairment reported Recreational and coVinton Drainage Canale 32.21 P 242.1 ABC Turbidity (5) Recreational fishery Waterbody 35.14 P 46.2 n No impairment reported None Waterbody 35.70 P 24.4 n No impairment reported None Waterbody 36.21 P 42.8 n No impairment reported None 

G-1 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Canal 37.88 P 57.7 n No impairment reported None Waterbodyf 37.96 I 48.5 n No impairment reported None Waterbodyf 38.93 I 28.8 n No impairment reported None Waterbodyf 39.07 I 16.8 n No impairment reported None Canalf 39.09 I 25.7 n No impairment reported None Canal 40.17 P 37.9 n No impairment reported None Canal 40.24 P 35.9 n No impairment reported None Canal 41.46 P 33.2 n No impairment reported None Canal 42.77 P 35.9 n No impairment reported None Canal 43.21 P 42.2 n No impairment reported None Bayou Choupiquee 44.32 P 154.3 ABC Dissolved Oxygen (4a) Recreational fishery

Fish and Wildlife Prodesignation 

Waterbody 45.55 P 20.9 n No impairment reported None Waterbody 45.86 P 30.9 n No impairment reported None Waterbody 46.68 P 29.9 n No impairment reported None Waterbody 47.01 P 43.5 n No impairment reported None Drain 47.36 I 22.9 n No impairment reported None Waterbodyf 47.75 I 19.1 n No impairment reported None Waterbodyf 47.76 I 16.7 n No impairment reported None Canalf 48.11 I 19.0 n No impairment reported None Waterbodyf 48.26 I 17.4 n No impairment reported None Waterbodyf 48.32 I 10.5 n No impairment reported None 

G-2 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Waterbodyf 48.33 I 7.0 n No impairment reported None Calcasieu Rivere 49.63 P 1099.8 ABCE No impairment reported (USEPA 

[2004] listed the Calcasieu River as an area of probable concern regarding sediment contamination in 1997, but not in 2004 -- see Section 2.2.1.) 

Recreational and cofisheries. Not suppoWildlife Propagation 

Pond 49.89 P 92.4 n No impairment reported None Canal 50.72 P 59.1 n No impairment reported None Calcasieu Tributarye 50.84 P 1326.9 n No impairment reported None Calcasieu Tributary (swamp)e

52.57 I 230.9 n No impairment reported None 

Waterbody 53.02 P 17.6 n No impairment reported None Waterbody 53.34 P 22.4 n No impairment reported None Waterbodyf 53.52 I 10.0 n No impairment reported None Waterbody 53.60 P 25.4 n No impairment reported None Waterbody 53.72 I 24.2 n No impairment reported None Waterbody 54.02 P 47.1 n No impairment reported None Waterbodyf 54.53 I 11.2 n No impairment reported None Waterbodyf 54.54 I 12.3 n No impairment reported None Coulee Hippolyte Trib. 54.94 P 37.7 n No impairment reported None Waterbodyf 55.54 I 11.2 n No impairment reported None Waterbodyf 55.54 I 16.5 n No impairment reported None Coulee Hippolyte Trib. 55.77 P 29.0 n No impairment reported None Coulee Hippolyte 56.26 P 84.0 n No impairment reported None 

G-3 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Waterbodyf 56.65 I 14.7 n No impairment reported None Waterbodyf 56.66 I 17.6 n No impairment reported None Canalf 56.91 P 23.7 n No impairment reported None Waterbodyf 57.63 I 19.5 n No impairment reported None Waterbodyf 57.64 I 22.1 n No impairment reported None Waterbodyf 57.93 I 18.4 n No impairment reported None Waterbodyf 59.06 I 11.3 n No impairment reported None Waterbodyf 59.07 I 11.3 n No impairment reported None Waterbody 59.56 P 21.9 n No impairment reported None Black Bayou 60.03 P 49.9 n No impairment reported None Waterbodyf 60.05 I 22.4 n No impairment reported None Waterbodyf 60.22 I 9.6 n No impairment reported None Waterbodyf 60.22 I 10.9 n No impairment reported None Waterbody 60.40 P 54.8 n No impairment reported None Canalf 60.95 I 29.6 n No impairment reported None Waterbodyf 60.96 I 10.4 n No impairment reported None Waterbodyf 60.97 I 12.9 n No impairment reported None Waterbodyf 61.27 I 9.4 n No impairment reported None Waterbodyf 61.50 I 9.3 n No impairment reported None Waterbodyf 61.51 I 6.5 n No impairment reported None Waterbody 61.96 P 54.2 n No impairment reported None Waterbody 62.64 P 16.5 n No impairment reported None Waterbody 63.02 P 36.3 n No impairment reported None 

G-4 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Waterbody 63.24 P 44.1 n No impairment reported None Waterbody 63.48 P 33.4 n No impairment reported None Waterbodyf 63.49 I 8.5 n No impairment reported None Canal 64.26 P 98.7 n No impairment reported None Waterbody 64.69 I 25.0 n No impairment reported None Waterbody 64.71 P 12.6 n No impairment reported None Waterbody 65.35 P 39.2 n No impairment reported None Waterbodyf 65.97 I 26.9 n No impairment reported None Waterbodyf 65.98 I 29.7 n No impairment reported None Canal 66.00 P 34.1 n No impairment reported None Waterbodyf 66.31 I 20.9 n No impairment reported None Waterbodyf 66.93 I 6.5 n No impairment reported None Waterbodyf 66.95 I 11.1 n No impairment reported None Waterbodyf 67.64 I 33.7 n No impairment reported None Waterbodyf 67.66 I 25.8 n No impairment reported None Waterbody 68.08 P 27.4 n No impairment reported None Waterbodyf 68.35 I 14.5 n No impairment reported None Waterbodyf 68.35 I 11.2 n No impairment reported None Waterbodyf 68.62 I 31.7 n No impairment reported None Waterbodyf 68.64 I 46.1 n No impairment reported None Waterbodyf 68.70 I 21.6 n No impairment reported None Waterbodyf 68.71 I 24.5 n No impairment reported None Waterbodyf 69.07 I 14.5 n No impairment reported None 

G-5 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Waterbodyf 69.08 I 47.5 n No impairment reported None Waterbody 69.41 P 11.6 n No impairment reported None Waterbody 69.41 P 14.0 n No impairment reported None Waterbody 69.43 P 36.2 n No impairment reported None West Fork English Bayou 70.30 P 40.3 n No impairment reported None Waterbody 70.68 P 47.1 n No impairment reported None Waterbodyf 71.04 I 9.7 n No impairment reported None Waterbodyf 71.05 I 8.7 n No impairment reported None Waterbody 71.60 P 24.2 n No impairment reported None Waterbody 71.68 P 56.6 n No impairment reported None East Fork English Bayou 71.80 P 61.0 n No impairment reported None Waterbody 72.71 P 12.9 n No impairment reported None Waterbody 72.72 P 17.9 n No impairment reported None Waterbody 72.88 P 83.2 n No impairment reported None Waterbody 72.92 P 28.0 n No impairment reported None Waterbody 73.02 P 31.2 n No impairment reported None Waterbody 73.27 P 9.6 n No impairment reported None Waterbodyf 73.79 I 9.9 n No impairment reported None Waterbodyf 73.80 I 5.7 n No impairment reported None Waterbodyf 75.29 I 43.6 n No impairment reported None Waterbodyf 75.31 I 21.5 n No impairment reported None Canal 75.99 P 10.0 n No impairment reported None Louisiana Irrigation Canal 76.00 P 77.2 n No impairment reported None 

G-6 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Canal 76.05 P 25.9 n No impairment reported None Waterbody 77.26 P 33.5 n No impairment reported None Waterbodyf 78.06 I 39.5 n No impairment reported None Waterbodyf 78.09 I 66.4 n No impairment reported None Waterbodyf 78.12 I 126.3 n No impairment reported None Waterbodyf 78.16 I 118.1 n No impairment reported None Waterbodyf 78.20 I 44.8 n No impairment reported None Waterbodyf 78.36 I 6.1 n No impairment reported None Waterbodyf 78.37 I 5.6 n No impairment reported None Waterbody 78.72 P 19.8 n No impairment reported None Waterbody 78.99 P 11.2 n No impairment reported None Waterbody 80.38 P 36.1 n No impairment reported None Waterbody 80.73 P 29.8 n No impairment reported None Waterbodyf 80.91 I 19.0 n No impairment reported None Waterbody 80.92 P 44.2 n No impairment reported None Waterbodyf 81.80 I 6.6 n No impairment reported None Canal 81.83 P 40.6 n No impairment reported None Waterbodyf 82.32 I 13.1 n No impairment reported None Waterbodyf 82.33 I 29.2 n No impairment reported None Waterbodyf 82.98 I 5.0 n No impairment reported None Waterbodyf 82.99 I 11.5 n No impairment reported None Waterbodyf 84.22 I 15.6 n No impairment reported None Waterbody 84.23 P 12.2 n No impairment reported None 

G-7 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Canal 84.33 P 43.7 n No impairment reported None Waterbodyf 84.43 I 15.6 n No impairment reported None Waterbodyf 84.45 I 21.0 n No impairment reported None Canal 84.69 P 23.1 n No impairment reported None East Bayou Lacassine 84.94 P 7.5 ABCF Dissolved oxygen (4a) Recreational fishery Waterbodyf 86.54 I 38.4 n No impairment reported None Waterbodyf 86.55 I 13.8 n No impairment reported None Waterbodyf 86.57 I 26.5 n No impairment reported None Waterbodyf 86.58 I 36.5 n No impairment reported None Waterbodyf 87.69 I 7.8 n No impairment reported None Waterbodyf 87.70 I 6.9 n No impairment reported None East Bayou Lacassine 88.49 P 31.6 ABCF Dissolved oxygen (4a) Recreational fishery Waterbodyf 88.79 I 5.9 n No impairment reported None Waterbodyf 88.80 I 9.6 n No impairment reported None Waterbodyf 88.88 I 5.8 n No impairment reported None Waterbodyf 88.89 I 5.8 n No impairment reported None Gum Gully 89.19 P 25.6 AB No impairment reported None Canal 89.60 P 25.3 n No impairment reported None Waterbodyf 89.97 I 8.5 n No impairment reported None Waterbodyf 89.98 I 7.9 n No impairment reported None Canal 90.56 P 31.6 n No impairment reported None Waterbodyf 91.01 I 6.9 n No impairment reported None Waterbodyf 91.01 I 8.2 n No impairment reported None 

G-8 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Canal 91.39 P 13.0 n No impairment reported None Canal 91.64 P 20.6 n No impairment reported None Waterbodyf 92.03 I 22.1 n No impairment reported None Waterbodyf 92.04 I 13.8 n No impairment reported None Canal 92.18 P 30.8 n No impairment reported None Canal 92.64 P 12.5 n No impairment reported None Waterbodyf 93.08 I 8.7 n No impairment reported None Waterbodyf 93.08 I 5.0 n No impairment reported None Canal 93.63 P 13.2 n No impairment reported None Canal 94.09 P 26.8 n No impairment reported None Waterbodyf 94.18 I 13.1 n No impairment reported None West Bayou Grand Marais 94.68 P 51.0 n No impairment reported None Waterbodyf 94.97 I 15.5 n No impairment reported None West Bayou Grand Marais Trib. 95.12 P 27.9 n No impairment reported None Waterbodyf 95.24 I 10.0 n No impairment reported None Canal 96.37 P 25.6 n No impairment reported None Waterbodyf 97.36 I 18.2 n No impairment reported None Waterbodyf 97.37 I 13.3 n No impairment reported None Bayou Nezpique Tributary 97.45 P 15.7 n No impairment reported None Bayou Nezpiquee 99.38 P 146.0 ABCF nitrate/nitrite, dissolved oxygen, 

sedimentation/ siltation, total fecal coliform, total phosphorus, TSS, turbidity (all 4a) 

Recreational fisheryFish and Wildlife Prodesignation 

Waterbodyf 100.05 I 23.0 n No impairment reported None 

G-9 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Waterbodyf 100.40 I 9.3 n No impairment reported None Waterbody 100.43 P 6.4 n No impairment reported None Waterbodyf 100.74 I 19.9 n No impairment reported None Bayou Nezpique Trib. 101.19 P 17.1 n No impairment reported None Waterbodyf 101.49 I 27.4 n No impairment reported None Waterbodyf 101.50 I 20.7 n No impairment reported None Waterbodyf 102.08 I 13.5 n No impairment reported None Waterbodyf 102.35 I 4.4 n No impairment reported None Waterbodyf 102.36 I 26.1 n No impairment reported None Canalf 102.66 I 17.4 n No impairment reported None Canal 102.80 P 23.6 n No impairment reported None Canal 103.03 P 12.6 n No impairment reported None Canalf 103.43 I 17.7 n No impairment reported None Waterbodyf 103.66 I 26.8 n No impairment reported None Canal 103.97 P 14.9 n No impairment reported None Canalf 104.16 I 25.9 n No impairment reported None Waterbodyf 104.18 I 26.5 n No impairment reported None Bayou Des Cannes Trib. 104.30 P 31.6 n No impairment reported None Bayou Des Cannes Trib. 104.73 P 27.9 n No impairment reported None Canalf 104.92 I 20.7 n No impairment reported None Bayou Des Cannes Trib. 105.08 P 36.8 n No impairment reported None Bayou Des Cannes Trib. 105.21 P 27.5 n No impairment reported None Waterbodyf 105.59 I 15.8 n No impairment reported None 

G-10 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Waterbodyf 105.60 I 7.1 n No impairment reported None Waterbody 105.89 P 38.0 n No impairment reported None Waterbodyf 106.20 I 8.5 n No impairment reported None Waterbodyf 106.21 I 10.8 n No impairment reported None Waterbody 106.65 P 18.1 n No impairment reported None Waterbodyf 106.67 I 11.5 n No impairment reported None Waterbodyf 106.82 I 14.7 n No impairment reported None Waterbody 106.83 P 14.0 n No impairment reported None Waterbody 107.37 I 20.1 n No impairment reported None Bayou Des Cannes Trib. 107.55 P 15.7 n No impairment reported None Bayou Des Cannes Trib.f 107.56 P 55.2 n No impairment reported None Bayou Des Cannes Trib. 107.92 P 18.4 n No impairment reported None Bayou Des Cannes Trib. 108.07 P 18.9 n No impairment reported None Bayou Barwick Trib. 108.68 I 27.5 n No impairment reported None Bayou Barwick 109.22 P 30.1 n No impairment reported None Bayou Barwickf 109.25 P 51.8 n No impairment reported None Canalf 110.17 I 71.5 n No impairment reported None Canalf 110.94 I 20.0 n No impairment reported None Waterbodyf 111.23 P 12.6 n No impairment reported None Waterbodyf 111.24 P 16.1 n No impairment reported None Canalf 111.52 I 11.1 n No impairment reported None Tiger Point Gulley Trib. 112.15 P 13.1 n No impairment reported None Tiger Point Gulley 113.27 P 177.7 n No impairment reported None 

G-11 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Waterbodyf 113.62 I 31.2 n No impairment reported None Waterbodyf 114.23 I 94.9 n No impairment reported None Waterbodyf 114.29 I 59.0 n No impairment reported None Canalf 114.55 I 37.0 n No impairment reported None Waterbodyf 114.86 I 8.6 n No impairment reported None Waterbodyf 114.87 I 10.2 n No impairment reported None Waterbodyf 114.88 I 6.5 n No impairment reported None Waterbodyf 114.89 I 5.7 n No impairment reported None Waterbodyf 115.70 I 18.8 n No impairment reported None Waterbodyf 115.71 I 16.1 n No impairment reported None Waterbodyf 116.38 I 15.9 n No impairment reported None Waterbodyf 116.39 I 19.0 n No impairment reported None Waterbodyf 116.55 I 19.6 n No impairment reported None Waterbodyf 116.56 I 16.9 n No impairment reported None Waterbodyf 116.75 I 16.8 n No impairment reported None Waterbodyf 116.76 I 15.5 n No impairment reported None Waterbodyf 117.27 I 10.6 n No impairment reported None Waterbodyf 117.28 I 7.3 n No impairment reported None Waterbodyf 118.06 I 11.3 n No impairment reported None Bayou Des Cannes Trib. 119.28 I 23.8 n No impairment reported None Waterbodyf 119.75 I 9.1 n No impairment reported None Waterbodyf 119.76 I 12.4 n No impairment reported None Bayou Duralde Trib. 120.19 I 24.4 n No impairment reported None 

G-12 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Waterbodyf 120.43 I 28.9 n No impairment reported None Waterbodyf 120.75 I 22.9 n No impairment reported None Waterbodyf 120.76 I 23.3 n No impairment reported None Bayou Des Cannes Trib. 121.47 I 44.6 n No impairment reported None Bayou Des Cannes Trib. 121.86 I 22.1 n No impairment reported None Waterbodyf 122.09 I 11.4 n No impairment reported None Waterbodyf 122.10 I 3.6 n No impairment reported None Canalf 122.36 I 22.4 n No impairment reported None Waterbodyf 123.13 I 9.1 n No impairment reported None Waterbodyf 123.13 I 7.5 n No impairment reported None Waterbodyf 123.69 I 6.3 n No impairment reported None Waterbodyf 123.70 I 6.5 n No impairment reported None Canalf 124.07 I 33.9 n No impairment reported None Bayou Des Cannes Trib. 124.16 I 14.5 n No impairment reported None Bayou Des Cannes Trib. 124.16 I 8.3 n No impairment reported None Bayou Des Cannes Trib. 124.18 I 12.9 n No impairment reported None Bayou Des Cannes 124.71 P 56.2 ABCF Carbofuran, Fipronil, mercury, 

nitrate/nitrite, dissolved oxygen, sedimentation/siltation, total fecal coliform, total phosphorus, TSS, turbidity (all 4a) 

Recreational fisheryFish and Wildlife Prodesignation 

Waterbodyf 126.30 I 30.1 n No impairment reported None Waterbodyf 126.31 I 33.8 n No impairment reported None Waterbodyf 126.38 I 12.9 n No impairment reported None 

G-13 
TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Waterbodyf 126.38 I 16.8 n No impairment reported None Waterbodyf 127.35 I 12.6 n No impairment reported None Waterbodyf 127.72 I 15.7 n No impairment reported None Waterbodyf 127.72 I 11.2 n No impairment reported None Waterbodyf 128.09 I 9.1 n No impairment reported None Waterbodyf 128.10 I 16.1 n No impairment reported None Waterbodyf 128.50 I 21.3 n No impairment reported None Waterbodyf 128.51 I 26.8 n No impairment reported None Bayou Des Cannes Trib. 129.19 I 25.9 n No impairment reported None Canalf 129.31 I 26.3 n No impairment reported None Waterbodyf 129.42 I 9.3 n No impairment reported None Waterbodyf 129.60 I 12.9 n No impairment reported None Bayou Marron Trib. 130.10 P 15.1 n No impairment reported None Waterbodyf 130.60 I 21.9 n No impairment reported None Waterbodyf 130.61 I 24.5 n No impairment reported None Bayou Marron Trib. 130.80 P 18.9 n No impairment reported None Waterbodyf 131.70 I 16.7 n No impairment reported None Waterbodyf 131.71 I 18.2 n No impairment reported None FGT LATERAL Canal 0.13 P 19.2 n No impairment reported None Waterbodyf 0.50 I 8.6 n No impairment reported None Waterbodyf 0.51 I 5.9 n No impairment reported None Waterbodyf 1.38 I 63.6 n No impairment reported None 

G-14 
G-15 

TABLE G-1 

Surface Waterbodies Crossed by the Kinder Morgan Louisiana Pipeline Project 

Waterbody (WB) 

Approx. 

MP 

Waterbody

Typea

Crossing

Distance

(Feet) 

Water 

Quality/

Useb Suspected Existing Impairmentc

Significa

Fisheries/

Water So

Bayou Des Cannes 1.57 P 60.5 ABCF Carbofuran, Fipronil, mercury, 

nitrate/nitrite, dissolved oxygen, sedimentation/siltation, total fecal coliform, total phosphorus, TSS, turbidity (all 4a) 

Recreational fisheryFish and Wildlife Prodesignation 

Bayou Des Cannes Trib. 1.95 I 8.7 n No impairment reported None ACCESS ROADSdBayou Des Cannes Trib FGT-2 I 8.5 n No impairment reported None _______________ a Designated use codes for Waterbody Types: I – Intermittent; P - Perennial b Designated use codes for waterbodies: A – Primary Contact Recreation; B - Secondary Contact Recreation; C – Fish and Wildlife Propagation; L – Limited Aquat

Water Supply; E – Oyster Propagation; F – Agriculture; G – Outstanding Natural Resource Waters; n – No Quality/Use. Source: Louisiana Administrative Code, 

2005. 

c Number in parentheses () indicates Louisiana 2004 303(d) list IR category. Source: Louisiana Department of Environmental Quality (LDEQ), Water Quality Integ

(d) Reports), 2004. 

d All fisheries resources are warmwater fisheries. None of the surface waterbodies listed are utilized as a potable water source. e Waterbody greater than 100 feet in width. 

f Indicates bar ditches and functionally equivalent water features that were not included in the milepost band at the top of the preliminary alignment sheets for clari
[This page intentionally left blank] 
APPENDIX H 

AFFECTED WETLANDS 
[This page intentionally left blank] 
H-1 Appendix H

Table H-1 provides a description of the codes used in the Cowardin Classification System. Wetlands 

crossed by the Project are identified in table H-2 by Cowardin wetland codes and unique wetland ID. 

Table H-2 includes extra workspaces in the areas crossed by the pipelines. Wetlands affected by pipe 

storage yards, access roads, and aboveground facilities are listed at the end of the table. 

TABLE H-1 

Cowardin Classification System 

SYSTEM SUBSYSTEM CLASS SUBCLASS 

1=Bedrock 

RB=Rock Bottom 

2=Rubble 

1=Cobble-Gravel 

2=Sand 

UB=Unconsolidated Bottom 3=Mud 

4=Organic 

1=Algal 

3=Rooted Vascular 

4=Floating Vascular 

5=Unknown Submergent 

AB=Aquatic Bed 

6=Unknown Surface 

2=Mollusc 

RF=Reef 

3=Worm 

1=SUBTIDAL 

OW=Open Water/Unknown Bottom (used on older maps) 

1=Algal 

3=Rooted Vascular 

4=Floating Vascular 

5=Unknown Submergent 

AB=Aquatic Bed 

6=Unknown Surface 

RF=Reef 2=Mollusc 

3=Cobble-Gravel 

4=Sand 

5=Mud 

SB=Streambed 

6=Organic 

1=Bedrock 

RS=Rocky Shore 2=Rubble 

1=Cobble-Gravel 

2=Sand 

3=Mud 

E=ESTUARINE 

2=INTERTIDAL 

US=Unconsolidated Shore 

4=Organic 
H-2 Appendix H

TABLE H-1 

Cowardin Classification System 

SYSTEM SUBSYSTEM CLASS SUBCLASS 

1=Persistent 

EM=Emergent 2=Nonpersistent 

1=Broad-Leaved Deciduous 

2=Needle-Leaved Deciduous 

3=Broad-Leaved Evergreen 

4=Needle-Leaved Evergreen 

5=Dead 

6=Indeterminate Deciduous 

SS=Scrub-Shrub 

7=Indeterminate Evergreen 

1=Broad-Leaved Deciduous 

2=Needle-Leaved Deciduous 

3=Broad-Leaved Evergreen 

4=Needle-Leaved Evergreen 

5=Dead 

6=Indeterminate Deciduous 

FO=Forested 

7=Indeterminate Evergreen 

1=Bedrock 

RB=Rock Bottom 

2=Rubble 

1=Cobble-Gravel 

2=Sand 

3=Mud 

UB=Unconsolidated Bottom 

4=Organic 

1=Algal 

2=Aquatic Moss 

3=Rooted Vascular 

4=Floating Vascular 

5=Unknown Submergent 

AB=Aquatic Bed 

6=Unknown Surface 

1=Cobble-Gravel 

2=Sand 

3=Mud 

4=Organic 

US=Unconsolidated Shore 

5=Vegetated 

1=Moss 

ML=Moss-Lichen 

2=Lichen 

1=Persistent 

P=PALUSTRINE 

EM=Emergent 2=Nonpersistent 
H-3 Appendix H

TABLE H-1 

Cowardin Classification System 

SYSTEM SUBSYSTEM CLASS SUBCLASS 

1=Broad-Leaved Deciduous 

2=Needle-Leaved Deciduous 

3=Broad-Leaved Evergreen 

4=Needle-Leaved Evergreen 

5=Dead 

6=Indeterminate Deciduous 

SS=Scrub-Shrub 

7=Indeterminate Evergreen 

1=Broad-Leaved Deciduous 

2=Needle-Leaved Deciduous 

3=Broad-Leaved Evergreen 

4=Needle-Leaved Evergreen 

5=Dead 

6=Indeterminate Deciduous 

FO=Forested 

7=Indeterminate Evergreen 

OW=Open Water/Unknown Bottom (used on older maps) 

MODIFIERS 

A=Temporarily Flooded 

B=Saturated 

C=Seasonally Flooded 

D=Seasonally Flooded/Well Drained 

E=Seasonally Flooded/Saturated 

F=Semipermanently Flooded 

G=Intermittently Exposed 

H=Permanently Flooded 

J=Intermittently Flooded 

K=Artificially Flooded 

W=Intermittently Flooded/Temporary (used on older maps) 

Y=Saturated/Semipermanent/Seasonal (used on older maps) 

Z=Intermittently Exposed/Permanent (used on older maps) 

Non-Tidal 

U=Unknown 

K=Artificially Flooded 

L=Subtidal 

M=Irregularly Exposed 

WATER REGIME 

Tidal 

N=Regularly Flooded 
H-4 Appendix H

TABLE H-1 

Cowardin Classification System 

SYSTEM SUBSYSTEM CLASS SUBCLASS 

P=Irregularly Flooded 

*S=Temporary-Tidal 

*R=Seasonal-Tidal 

*T=Semipermanent-Tidal 

*V=Permanent-Tidal 

U=Unknown 

*These water regimes are only used in tidally influenced, freshwater 

systems. 

1=Hyperhaline 

2=Euhaline 

3=Mixohaline (Brackish) 

4-Polyhaline 

5=Mesohaline 

6=Oligohaline 

Coastal Halinity 

0=Fresh 

7=Hypersaline 

8=Eusaline 

9=Mixosaline 

WATER 

CHEMISTRY 

Inland Salinity 

0=Fresh 
H-5 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

Leg 1 and Leg 2 and Associated Extra Workspaces 

Cameron Parish 

0.00 0.08 7016 PEM1A No No 1.5 0.8 

0.08 0.18 7001 PEM1A No No 2.1 1.1 

0.17 0.22 7000 PFO1/4 No No 0.7 0.4 

0.24 0.39 7002 PFO1/4 No No 1.9 1.3 

0.30 0.56 7003 PEM1A No No 4.4 2.5 

0.54 1.07 7004 PEM1A No No 9.6 5.3 

1.03 1.13 7005 PEM1A No No 1.1 0.3 

1.12 1.16 7007 PEM1A No No 0.5 0.2 

1.15 1.19 7006 PEM1A No No 0.5 0.2 

1.16 1.26 7007 PEM1A No No 0.5 - 

1.23 1.30 7006 PEM1A No No 0.9 - 

1.34 1.42 7008 PEM1A No No 1.7 0

1.44 1.51 7010 PEM1A No No 0.6 0

1.46 1.50 7009 PEM1A No No 0.3 0

1.51 1.73 7011 PEM1A No No 2.6 1

1.73 2.03 7012 PEM1A No No 3.4 1

2.01 3.47 3032 E2EM1P5 No No 17.7 8

3.48 3.94 3032 E2EM1P5 No No 6.1 3

3.94 4.00 3032 E2EM1P5 No No 0.9 - 

3.99 4.49 3032 E2EM1P5 No No 8.5 2

4.52 4.55 3032 E2EM1P5 No No 0.2 0
H-6 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

18.05 18.53 3034 E2EM1P5 No No 8.4 2

18.56 18.57 3034 E2EM1P5 No No 0.0 - 

18.68 18.77 3034 E2EM1P5 No No 0.4 0

18.76 19.04 1101,1101A E2EM1P5 No No 4.5 1

19.07 19.07 1101B E2EM1P5 No No 0.0 - 

19.67 19.73 1102A E2EM1P5 No No 0.2 0

19.73 19.80 1102 E2EM1P5 No No 1.1 0

19.85 19.89 1103 PSS1C No No 0.4 0

20.14 20.15 1104 PSS1C No No 0.0 - 

20.21 20.24 1105 PSS1C No No 0.3 0

20.29 20.31 2089 PSS1C No No 0.1 0

20.38 20.39 2090 PSS1C No No 0.1 0

20.57 20.65 2093 PSS1C No No 1.1 0

20.65 20.66 2093A PSS1C No No 0.1 0

20.66 20.87 2093A PSS1C No No 1.7 0

20.91 20.97 2093B PSS1C No No 0.9 0

20.94 21.05 2093B PSS1C No No 1.3 0
H-7 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

21.06 21.10 2095 PSS1C No No 0.3 0

21.11 21.16 2095 PSS1C No No 0.9 0

21.17 21.18 2095A E2SS1P5 No No 0.2 - 

21.18 21.52 2095A E2SS1P5 No No 3.9 1

21.18 21.18 2095A E2SS1P5 No No 0.0 - 

21.98 22.08 2096 E2SS1P5 No No 0.8 0

22.08 22.25 2096 E2SS1P5 No No 1.7 0

22.00 22.07 2096A E2EM1P5 No No 0.4 0

22.08 22.14 2096B PFO1As No No 0.2 - 

22.08 22.12 2096A E2EM1P5 No No 0.3 0

22.11 22.12 2096D E2EM1P5 No No 0.3 

22.12 22.23 2096D E2EM1P5 No No 0.6 

0

22.16 22.21 2096B PFO1As No No 0.1 - 

22.24 22.27 2097 PSS1C No No 0.4 0

22.26 22.32 2096 E2SS1P5 No No 0.6 0

22.30 22.30 2096D E2EM1P5 No No 0.0 - 

22.35 22.43 2096 E2SS1P5 No No 0.7 0

22.37 22.39 2096D E2EM1P5 No No 0.1 - 

22.42 22.45 2100 PEM1C No No 0.2 0
H-8 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

22.44 22.47 2096 E2SS1P5 No No 0.3 0

22.47 22.50 2101 PEM1C No No 0.3 0

22.50 22.51 2096 E2SS1P5 No No 0.0 - 

22.56 22.57 2102A E2EM1P5 No No 0.0 - 

22.58 22.61 2102A E2EM1P5 No No 0.1 0

22.61 22.65 4024/3036 E2EM1P5 No No 0.5 0

22.64 22.68 4024a/3038 PSS1A No No 0.6 0

22.67 22.69 4024/3036 E2EM1P5 No No 0.2 0

22.69 22.74 4024/3036 E2EM1P5 No No 0.6 - 

22.69 22.75 4044/3039 PSS1A No No 1.1 0

22.74 22.79 4024/3036 E2EM1P5 No No 0.6 0

22.76 22.83 4024c PSS1A No No 0.5 0

22.78 22.79 3035 PSS1C No No 0.0 - 

22.94 22.97 4025/3033A E2EM1P5 No No 0.3 0

22.95 23.00 4025 PSS1A No No 0.5 0

22.97 23.41 4025/3033A E2EM1P5 No No 6.2 2

23.03 23.04 4025 PSS1A No No 0.1 - 

23.11 23.11 4025 PSS1A No No 0.0 - 

23.27 23.39 4025 PSS1A No No 1.5 0.6 

23.40 23.42 4025 PSS1A No No 0.2 0.1 
H-9 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

23.57 23.83 3033 E2EM1P5 No No 1.7 0.5 

23.86 23.92 2103 E2EM1P5 No No 0.8 0.3 

23.92 24.02 2103 E2EM1P5 No No 1.1 0.3 

24.05 24.11 2103 E2EM1P5 No No 0.5 0.1 

24.13 24.56 2103 E2EM1P5 No No 6.4 2.4 

24.56 24.64 2103B E2SS1P5 No No 0.3 0.0 

24.56 24.62 2103A E2EM1P6 No No 0.2 - 

24.63 24.72 2103A E2EM1P6 No No 0.2 - 

25.24 25.24 2103A E2EM1P6 No No 0.0 - 

Total 122.8 48.7 

Calcasieu Parish 

24.62 24.64 2103B E2SS1P5 No No 0.1 0.1 

24.64 25.26 2103A E2EM1P6 No No 8.9 3.4 

25.23 25.36 2104A E2SS1P5 No No 0.5 0.1 

25.26 25.27 4027/2104/2106 E2EM1P6 No No 0.1 - 

25.27 25.34 4027/2104/2106 E2EM1P6 No No 0.2 - 

25.37 25.40 2104A E2SS1P5 No No 0.1 - 

25.41 25.41 2104A E2SS1P5 No No 0.0 - 

25.46 25.54 2104A E2SS1P5 No No 0.2 - 

25.48 25.53 2105 E2EM1P6 No No 0.3 0.2 

25.55 25.57 2104A E2SS1P5 No No 0.0 - 

25.57 25.98 4027/2104/2106 E2EM1P6 No No 5.4 1.7 

26.34 26.41 2109 PSS1C No No 0.3 0.1 

26.42 26.45 2108 PSS1C No No 0.1 - 

26.51 26.58 4027/2104/2106 E2EM1P6 No No 0.1 - 

26.57 26.61 4028 PSS1A No No 0.2 0.0 

26.70 26.77 4028 PSS1A No No 0.7 0.3 

26.72 26.75 4029 PEM1A No No 0.1 - 

27.03 27.43 2110 E2SS1P6 No No 5.0 2.1 

27.03 27.19 2111A PEM1As No No 0.2 0.0 

27.32 27.34 2111 PEM1C No No 0.1 0.0 

27.44 27.52 2112 PSS1/3R No No 0.7 0.1 

27.54 27.83 2112 PSS1/3R No No 3.7 1.4 

27.56 27.63 2113B PEM1C No No 0.1 0.1 

27.63 27.65 2113B PEM1C No No 0.0 - 

27.70 27.78 2113A PEM1C No No 0.1 0.1 

27.80 27.82 2113 PEM1C No No 0.1 0.0 
H-10 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

27.84 27.85 2114 PSS1C No No 0.2 0.1 

27.86 27.89 2115 PEM1C No No 0.1 - 

27.88 28.24 2114 PSS1C No No 4.6 1.9 

28.14 28.32 2116 PEM1C No No 0.8 0.5 

28.27 28.32 2117 PEM1C No No 0.6 0.1 

28.32 28.40 2118 E2SS1P6 No No 1.1 0.4 

28.39 28.47 2120 E2EM1P6 No No 0.1 0.1 

28.39 28.65 2119 E2EM1P6 No No 3.3 1.5 

28.48 30.05 2120 E2EM1P6 No No 16.4 6.0 

29.04 29.06 2124 E2SS1P6 No No 0.1 0.0 

29.14 29.42 2125 E2SS1P6 No No 1.4 0.2 

29.18 29.48 2126 PFO1As No No 2.4 1.6 

29.34 29.39 2120 E2EM1P6 No No 0.1 - 

29.44 29.51 2125 E2SS1P6 No No 0.5 0.2 

29.46 29.53 6040 E2EM1P6 No No 0.4 - 

29.81 29.86 2127 PFO1/4 No No 0.4 0.2 

29.86 29.90 2128 PSS1C No No 0.3 0.2 

30.04 30.05 2129 E2SS1P6 No No 0.1 0.0 

30.07 30.11 2129 E2SS1P6 No No 0.2 0.1 

30.08 30.38 2120 E2EM1P6 No No 5.4 1.7 

30.38 30.40 2120 E2EM1P6 No No 0.3 - 

30.12 30.15 2120 E2EM1P6 No No 0.1 - 

30.39 30.60 2120C E2EM1P6 No No 3.5 1.2 

30.65 30.72 2121 E2EM1P6 No No 0.4 0.1 

30.66 30.70 2122 E2SS1P6 No No 0.1 0.1 

30.72 30.74 2122A PSS1C No No 0.1 0.0 

31.19 32.21 4030/2087/2087A PEM1A No No 18.2 5.9 

31.19 31.26 2088 E2SS3P6 No No 0.2 0.1 

32.27 32.41 4031/2085 PEM1C No No 2.4 5.1 

32.41 33.14 4031/2085 PEM1C No No 9.4 - 

33.13 34.80 2084 PEM1C No No 19.2 9.7 

33.13 33.22 2083 PFO1A No No 0.7 0.3 

33.24 33.28 2083 PFO1A No No 0.4 0.2 

34.80 34.87 1100 PSS1Cs No No 0.7 0.4 

34.85 34.92 1099 PFO1C No No 0.7 0.3 

34.86 35.07 1097B PEM1C No No 0.2 0.0 

34.92 34.99 1099 PEM1C No No 0.9 0.5 
H-11 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

34.99 35.15 1098 PFO1C No No 1.7 0.9 

35.12 35.15 1097B PEM1C No No 0.0 - 

35.15 35.64 1097 PEM1Cs No No 5.1 2.2 

35.35 35.43 1096 PFO1A No No 0.9 0.3 

35.42 35.65 1095 PFO1A No No 1.6 0.4 

35.72 35.74 1094 PEM1C No No 0.1 0.1 

35.73 35.75 1093 PFO1C No No 0.0 - 

35.87 35.90 1092B PEM1A No No 0.2 0.1 

35.91 35.92 1092A PEM1A No No 0.1 0.1 

35.93 36.03 1092 PEM1A No No 1.1 0.3 

36.17 36.20 1091 PEM1A No No 0.1 0.1 

36.53 36.54 1090 PEM1A No No 0.1 0.0 

36.54 36.56 1088 PEM1A No No 0.2 0.1 

36.54 36.55 1089 PEM1A No No 0.0 0.0 

36.57 36.59 1087 PEM1A No No 0.1 0.1 

36.70 36.71 1086I PEM1A No No 0.1 0.0 

36.73 36.74 1086H PEM1A No No 0.1 0.1 

36.84 36.85 1086F PEM1A No No 0.1 0.0 

36.86 36.96 1086E PEM1A No No 0.9 0.3 

37.00 37.03 1086D PEM1A No No 0.2 - 

37.07 37.09 1086C PEM1A No No 0.1 0.1 

37.08 37.11 1086B PEM1A No No 0.1 0.0 

37.12 37.18 1086 PEM1A No No 0.8 0.3 

37.23 37.24 1081 PEM1A No No 0.1 0.1 

37.28 37.33 1080 PEM1A No No 0.3 0.2 

37.32 37.34 1079 PEM1A No No 0.1 0.0 

37.36 37.38 2075 PEM1A No No 0.2 0.1 

37.39 37.40 2076 PEM1A No No 0.0 - 

37.40 37.72 2077 PSS1A No No 3.1 0.7 

37.43 37.44 2077A PEM1A No No 0.0 0.0 

37.49 37.50 2077B PEM1A No No 0.1 0.1 

37.51 37.56 2077C PEM1A No No 0.2 0.2 

37.57 37.58 2077D PEM1A No No 0.0 0.0 

37.61 37.63 2077E PEM1A No No 0.1 0.1 

37.63 37.71 2077F PEM1A No No 0.3 0.3 

37.71 37.88 2078 PEM1A No No 2.5 1.0 

37.88 37.96 2078A PEM1Ah No No 1.4 0.4 
H-12 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

37.93 37.98 2078B PSS1A No No 0.8 0.1 

37.97 38.24 2079 PEM1A No No 4.9 1.6 

38.31 38.35 2080 PEM1A No No 0.2 0.2 

38.32 38.34 2080A PFO1A No No 0.1 0.0 

38.34 38.34 2081 PEM1A No No 0.0 - 

38.34 38.34 2081 PSS1A No No 0.0 - 

38.35 38.39 2081A PSS1A No No 0.1 0.1 

38.40 38.52 2082 PEM1A No No 1.4 0.6 

38.54 38.62 2082A PEM1A No No 0.7 0.4 

38.65 38.92 4005 PEM1A No No 3.4 1.3 

38.92 38.95 6001 PSS1A No No 0.1 0.0 

38.94 39.08 4001 PEM1A No No 2.0 0.7 

39.08 39.11 4017 PEM1A No No 0.1 0.1 

39.10 39.20 4018 PEM1A No No 1.0 0.5 

39.44 39.46 4019 PEM1A No No 0.1 0.0 

39.45 39.47 4020 PEM1A No No 0.1 0.1 

39.64 39.68 4021 PEM1A No No 0.3 0.1 

39.66 39.81 4022 PEM1A No No 1.8 0.8 

39.92 39.94 4023 PEM1C No No 0.1 0.0 

40.12 40.18 5029 PEM1A No No 0.9 0.3 

40.19 40.24 5030 PEM1A No No 0.6 0.3 

40.19 40.20 5030 PSS1A No No 0.1 0.1 

40.24 40.25 5030a PSS1A No No 0.1 0.1 

40.25 40.26 5033 PEM1A No No 0.1 0.1 

40.26 40.27 5032 PEM1A No No 0.1 0.1 

40.27 40.29 5031 PSS1A No No 0.3 0.1 

42.71 42.76 5007 PEM1A No No 0.7 0.1 

42.79 43.10 5005 PEM1A No No 0.8 0.8 

43.42 43.43 5003 PEM1A No No 0.1 0.0 

43.79 44.32 5002 PEM1A No No 9.1 3.1 

44.34 44.39 5002 PEM1A No No 0.8 0.3 

44.56 44.77 5001 PEM1A No No 3.0 1.2 

44.75 44.76 5001 PSS1A No No 0.0 - 

44.76 44.96 5001 PSS1A No No 2.8 1.2 

45.36 45.54 2027 PEM1C Yes Yes 2.8 1.1 

45.53 45.55 2026 PFO1R No No 0.2 0.1 

45.55 45.60 2027A PEM1C No No 0.8 0.3 
H-13 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

45.59 45.78 2059 PSS1C No No 2.7 1.0 

45.76 45.87 2027B E2EM1P6 No No 2.1 0.6 

45.76 45.80 7017 PSS1C No No 0.4 - 

45.86 45.89 2027B E2EM1P6 No No 0.3 0.1 

45.99 46.00 2030 E2EM1P6 No No 0.1 0.0 

46.05 46.23 2030 E2EM1P6 No No 2.7 1.0 

46.23 46.49 2031 E2EM1P6 Yes Yes 3.9 1.5 

46.49 46.69 2031A E2EM1P6 Yes Yes 3.0 1.1 

46.68 46.70 2032 PSS1C Yes Yes 0.1 0.1 

46.69 46.98 2031B PEM1C No No 5.1 1.6 

46.69 46.69 2032 PSS1C Yes Yes 0.0 - 

46.97 47.02 2031C PEM1C No No 0.9 0.2 

47.02 47.35 2033 PEM1R Yes Yes 5.1 2.0 

47.34 47.36 2034 PSS1S No No 0.2 0.1 

47.36 47.38 2033A PEM1C Yes Yes 0.1 0.1 

47.36 47.37 2034A PSS1S No No 0.1 0.1 

47.48 47.51 2035 PEM1C Yes Yes 0.4 0.2 

47.54 47.75 2036 PEM1C Yes Yes 3.5 1.3 

47.76 47.84 2037A PEM1C No No 1.7 0.5 

47.84 48.05 2037B PEM1C No No 3.2 1.2 

48.04 48.10 4003a PEM1A No No 0.2 0.1 

48.10 48.11 4003a PEM1A No No 0.0 - 

48.13 48.19 4003b PEM1A Yes Yes 0.7 0.3 

48.19 48.25 4003c PEM1A Yes Yes 0.6 0.2 

48.35 48.46 4004 PFO1A No No 0.8 0.6 

48.57 48.58 4005a PEM1A No No 0.1 0.1 

48.62 48.68 4008 PEM1A No No 0.4 0.0 

48.63 48.66 4006 PEM1A No No 0.1 0.1 

48.63 48.67 4007 PFO1A No No 0.1 0.1 

48.70 48.71 4009 PFO1A No No 0.1 0.0 

48.71 48.91 4010 PFO1A No No 1.9 1.0 

49.12 49.14 4011 PSS1A No No 0.1 0.1 

49.32 49.34 4013 PSS1A No No 0.1 0.1 

49.39 49.43 4015 PSS1A No No 0.3 0.2 

49.69 49.81 6045 PSS1As No No 0.7 - 

49.78 50.32 6044 PEM1Chs No No 3.4 - 

49.84 49.91 6003 PEM1A No No 1.0 0.3 
H-14 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

49.92 50.34 5015 PEM1A No No 7.5 2.5 

50.34 50.42 5016 PEM1A No No 1.4 2.2 

50.42 50.70 5016 PEM1A No No 5.8 - 

50.70 50.73 6035 PSS1A No No 0.4 0.1 

52.09 52.11 5017 PSS1A No No 0.0 - 

52.12 52.18 5018 PEM1A No No 0.2 0.0 

52.18 52.31 5018 PEM1A No No 0.2 0.1 

52.38 52.38 5021 PFO1A No No 0.0 - 

52.39 52.41 5022 PFO1A No No 0.1 - 

52.51 52.52 5023 PFO1A No No 0.1 0.0 

52.61 52.63 5026 PEM1A No No 0.1 0.1 

52.77 52.78 5027 PFO1A No No 0.1 0.0 

53.02 53.03 6024 PFO1A No No 0.2 0.1 

53.53 53.60 6021 PFO1A No No 1.3 0.4 

53.89 54.03 6036 PSS1A No No 1.8 0.6 

54.90 54.94 6025\5104 PEM1T No No 0.4 0.2 

54.94 54.97 6026 PEM1T No No 0.3 0.1 

54.96 55.04 6050 PSS1A No No 1.1 0.4 

55.14 55.18 6051 PSS1A No No 0.4 0.2 

55.78 55.80 1049 PFO1A No No 0.1 0.1 

55.91 55.96 1050 PEM1C No No 0.2 0.0 

56.10 56.13 1051 PFO1A No No 0.2 0.0 

56.14 56.17 1051 PFO1A No No 0.1 0.0 

56.27 56.29 1052 PFO1A No No 0.1 - 

56.51 56.51 1054 PEM1C No No 0.0 - 

56.53 56.58 1054 PEM1C No No 0.4 0.1 

56.67 56.67 1056 PEM1C No No 0.0 - 

57.13 57.24 5034/1057 PEM1C Yes Yes 1.2 0.5 

57.25 57.26 1058 PEM1C Yes Yes 0.1 0.0 

57.59 57.63 1059 PEM1C No No 0.1 0.0 

57.69 57.70 1043 PFO1A No No 0.0 - 

57.70 57.91 1043 PFO1A No No 1.8 0.1 

57.73 57.92 1043 PEM1C No No 1.2 1.0 

58.56 58.59 5010 PSS1A No No 0.2 0.1 

59.64 60.05 1046 PEM1C Yes Yes 7.5 2.2 

60.05 60.21 1047 PEM1C Yes Yes 3.4 0.9 

60.97 60.98 1048A PEM1C No No 0.3 - 
H-15 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

60.98 61.26 1048B PEM1C Yes Yes 4.4 1.7 

62.65 63.02 1024A PEM1C Yes Yes 5.8 2.3 

63.04 63.23 1024B PEM1C Yes Yes 3.1 1.2 

66.32 66.69 2060 PEM1C Yes Yes 6.1 2.2 

66.68 66.70 2059 PFO1/4 No No 0.1 0.1 

66.69 66.91 2058 PSS1C Yes Yes 3.8 1.3 

66.70 66.70 2059 PFO1/4 No No 0.0 - 

66.95 67.15 2056 PSS1C No No 3.1 1.1 

67.13 67.17 2055 PFO1A No No 0.5 0.2 

67.16 67.28 2053 PSS1C No No 1.9 0.6 

67.16 67.17 2054 PFO1A No No 0.1 0.1 

67.28 67.36 5019 PEM1A No No 1.6 0.5 

67.37 67.38 5020 PEM1A No No 0.1 0.1 

67.38 67.62 1028 PEM1C Yes Yes 4.1 1.4 

67.65 67.82 1064 PEM1C No No 0.8 0.3 

67.68 67.81 1064 PSS1C No No 1.4 0.4 

67.81 67.82 1064 PEM1C No No 0.0 0.0 

67.81 67.82 1064 PSS1C No No 0.1 0.1 

68.33 68.34 1074 PFO1A No No 0.1 0.1 

68.91 68.99 1033/2061 PEM1C No No 0.8 0.4 

69.02 69.07 1033/2061 PEM1C No No 0.2 0.1 

69.91 69.94 2063A PEM1C No No 0.3 0.1 

69.92 69.92 2063B PEM1C No No 0.0 0.0 

69.93 69.95 2063C PSS1C Yes Yes 0.1 0.0 

70.69 70.85 2066\1032 PEM1C Yes Yes 2.5 1.0 

71.06 71.10 2069 PEM1C Yes Yes 0.1 0.0 

71.60 71.68 1035/2068 PEM1C Yes Yes 0.6 0.4 

71.82 72.17 1037 PSS1C Yes Yes 6.2 2.1 

72.18 72.72 1038 PEM1C Yes Yes 8.7 3.1 

72.73 72.87 1039 PEM1C Yes Yes 2.2 0.8 

72.87 73.03 2070 PEM1C No No 2.2 0.6 

73.02 73.26 1040/2071 PEM1C No No 3.1 1.2 

73.28 73.29 2072 PEM1C No No 0.0 0.0 

73.29 73.79 1041 PEM1C No No 7.6 3.0 

73.80 73.83 1042 PEM1A No No 0.3 0.2 

73.83 73.88 1042 PEM1A No No 0.1 0.0 

73.83 73.84 2074 PEM1C No No 0.1 0.1 
H-16 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

Total 342.6 127.7 

Jefferson Davis Parish

74.87 74.91 2073 PEM1C No No 0.1 0.0 

74.88 75.02 1078B PEM1C Yes Yes 1.6 0.6 

74.97 75.08 1078A PEM1C No No 0.2 0.1 

74.98 75.29 1078 PEM1C Yes Yes 4.0 1.4 

75.99 76.00 1077 PSS1C No No 0.0 0.0 

76.02 76.02 1076 PFO1A No No 0.1 0.0 

76.03 76.04 1076 PFO1A No No 0.1 0.0 

76.82 76.83 3014 PSS1C No No 0.1 0.1 

76.84 76.85 5013 PEM1A No No 0.1 0.0 

76.99 77.26 3015/1075 PEM1C Yes Yes 4.2 1.6 

78.32 78.33 3019 PEM1C Yes Yes 0.1 - 

78.93 78.99 6038 PSS1C Yes Yes 0.9 0.3 

79.95 79.99 3020 PEM1C Yes Yes 0.1 0.1 

80.39 80.41 1020 PEM1C Yes Yes 0.0 0.0 

81.82 81.82 1060 PEM1C Yes Yes 0.0 - 

82.31 82.42 1061 PEM1C Yes Yes 1.5 0.4 

82.41 82.99 2018 PEM1C Yes Yes 9.2 3.5 

83.35 84.24 2019 PEM1C Yes Yes 13.1 5.1 

84.24 84.33 2020A PEM1C Yes Yes 1.5 0.5 

84.32 84.45 2020B PEM1C Yes Yes 1.6 0.6 

87.40 87.70 3052 PEM1C Yes Yes 4.2 1.7 

89.20 89.41 2013 PSS1C No No 3.1 1.2 

92.20 92.26 1019 PEM1C Yes Yes 1.1 0.3 

94.61 94.68 2014 PFO1A No No 0.1 0.1 

98.42 98.56 4016 PEM1A No No 1.9 0.8 

99.04 99.09 1082 PFO1A No No 0.3 0.1 

99.07 99.10 1082 PFO1A No No 0.1 - 

99.12 99.12 1083 PFO1A No No 0.0 0.0 

99.13 99.17 1084 PFO1A No No 0.3 0.2 
H-17 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

99.29 99.37 1085 PFO1/2C No No 1.0 0.3 

99.38 99.38 1085 PFO1/2C No No 0.0 - 

Total 50.6 19.0 

Acadia Parish

99.39 99.67 1059 PFO1/2C No No 4.8 1.6 

99.67 99.69 1059 PFO1/2C No No 0.1 0.1 

100.42 100.42 1012 PEM1C No No 0.1 - 

103.15 103.16 1006 PEM1C No No 0.1 0.1 

103.43 103.52 1005 PFO1A No No 0.9 0.5 

105.90 105.94 3006 PFO1A No No 0.1 0.1 

107.26 107.31 3007 PSS1C No No 0.1 0.1 

107.90 107.91 3009 PEM1C No No 0.0 0.0 

107.91 107.95 3010 PFO1A No No 0.3 0.1 

108.06 108.08 3010B PFO1A No No 0.1 0.0 

108.07 108.10 3010B PFO1A No No 0.1 - 

108.71 108.72 3011 PEM1C No No 0.0 0.0 

109.13 109.22 3012 PFO1A No No 0.9 0.4 

109.22 109.36 2005 PFO1A No No 1.4 0.6 

109.24 109.27 3012 PFO1A No No 0.1 - 

109.25 109.30 2006 PEM1C No No 0.1 0.0 

110.64 110.68 3021 PEM1C Yes Yes 0.2 0.2 

112.06 112.07 1061 PFO1A Yes Yes 0.0 0.0 

Total 9.4 3.8 

Evangeline Parish

112.63 112.68 1016 PEM1C Yes Yes 0.1 0.1 

112.70 112.89 1016 PSS1C Yes Yes 0.1 - 

113.28 113.30 1017 PFO1A No No 0.0 0.0 

113.52 113.54 1018 PEM1C No No 0.1 0.1 

113.58 113.62 3013 PSS1C No No 0.1 0.1 

114.90 114.92 2012 PEM1C Yes Yes 0.5 0.1 

115.02 115.04 2012 PEM1C Yes Yes 0.1 0.0 

115.06 115.22 2011 PEM1C Yes Yes 2.5 1.0 

115.43 115.43 2010 PEM1C Yes Yes 0.1 0.0 

117.84 117.86 2003 PFO1A No No 0.1 0.0 

117.90 117.93 2003 PFO1A No No 0.1 

117.91 117.94 2003 PFO1A No No 0.1 

117.92 117.95 2003 PFO1A No No 0.2 

0.1 
H-18 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

117.97 118.00 2004 PFO1A No No 0.2 0.1 

118.17 118.21 2002 PFO1A No No 0.2 0.1 

118.18 118.20 2002A PFO1A No No 0.1 0.0 

118.68 118.84 1007 PSS1C No No 2.3 0.9 

118.84 118.86 1008 PFO1A No No 0.1 0.1 

118.90 118.92 1009 PSS1C No No 0.1 - 

118.97 119.02 1010 PFO1A No No 0.3 0.1 

119.04 119.07 1011 PEM1C No No 0.1 0.1 

120.43 120.44 3004 PEM1C Yes Yes 0.0 - 

120.44 120.46 3004 PEM1C Yes Yes 0.1 0.0 

123.40 123.41 1004 PEM1C Yes Yes 0.0 0.0 

124.56 124.60 1001 PFO1A No No 0.5 0.2 

124.66 124.67 1000 PFO1A No No 0.0 0.0 

129.11 129.14 2001 PEM1C No No 0.3 0.1 

Total 8.4 3.2 

Total Leg 1 and 2 533.8 202.4 

FGT Lateral and Associated Extra Workspaces

Acadia Parish

0.76 0.79 3022A/5012 PEM1A No No 0.0 - 

0.76 0.81 3023A/5011 PFO1A No No 0.3 0.2 

1.25 1.37 3024 PSS1A No No 1.5 0.7 

1.25 1.38 3022 PEM1A No No 0.0 - 

1.36 1.37 3025 PFO1A No No 0.1 0.1 

1.37 1.40 3027B PFO1A No No 0.2 0.1 

1.38 1.58 3022B PEM1A No No 0.0 - 

1.38 1.58 3025 PFO1A No No 2.1 1.1 

1.59 1.60 1066 PEM1A No No 0.0 0.0 

1.81 1.85 1067 PEM1A No No 0.1 0.1 

1.84 1.85 1067 PSS1A No No 0.1 0.1 

1.94 1.95 1068 PEM1A No No 0.0 0.0 

2.03 2.03 1069 PEM1A No No 0.0 - 

2.06 2.06 1070 PEM1A No No 0.0 0.0 

2.10 2.11 1071 PEM1A No No 0.0 0.0 

2.10 2.12 1073 PSS1A No No 0.1 0.0 

2.11 2.12 1072 PEM1A No No 0.0 - 

2.12 2.13 1072 PEM1A No No 0.0 - 

Total 4.5 2.4 
H-19 Appendix H

TABLE H-2 

Wetlands That Would Be Affected By The Project 

Milepost 

Begin End 

Wetland 

ID 

Cowardin 

Class 

EFH 

Wetland? 

Prior 

Converted? 

Acres 

Affected 

During 

Construction 

(Temporary) 

Acres 

Affected 

During 

Operations

(Permanent)

Access Roads

1 3032 E2EM1P5 No No 8.3 - 

2 4030/2087/2087A PEM1A No No 0.4 - 

3 4031/2085 PEM1C No No 0.2 - 

3 7015 PEM1A No No 0.2 - 

6 4017 PEM1A No No 0.0 - 

7 5030 PSS1A No No 0.0 - 

16 6021 PFO1A No No 0.1 - 

4-1 1079 PEM1A No No 0.0 - 

4-5 1097 PEM1Cs No No 0.0 - 

4-5 4032 PEM1A No No 0.1 - 

10-1 2031 E2EM1P6 Yes Yes 0.0 - 

13-1 3049 PEM1C No No 0.0 - 

Total 9.3 - 

Pipe Yards

1 6042 PSS1C No No 19.8 - 

1 6043 PEM1A No No 19.0 - 

2 4033 PEM1A No No 19.9 - 

4 5032a PEM1A No No 4.0 - 

Total 62.7 - 

Aboveground Facilities 

Southwest Loop 2115 PEM1C No No 0.3 0.3 

Delivery Point 2114 PSS1C No No 0.6 0.6 

TGTPL 

Interconnect Site 3052 PEM1C Yes Yes 1.0 1.0 

NGPL 

Interconnect 7006 E2EM1P5 0.8 0.8 

Total 2.7 2.7 
[This page intentionally left blank] 
APPENDIX I 

DRAFT HORIZONTAL DIRECTIONAL DRILLING CONTINGENCY PLAN 
[This page intentionally left blank] 
TABLE OF CONTENTS 

1. Introduction .............................................................................................................. 1

2. HDD Technique........................................................................................................ 4

2.1. Pilot Hole Installation Process........................................................................... 4

2.2. Reaming and Swabbing Processes .................................................................. 5

2.3. Pullback Process .............................................................................................. 5

3. Potential Modes of HDD Failure............................................................................... 6

3.1. Failure Modes during Pilot Hole Installation Process ........................................ 6

3.2. Failure Modes during Reaming and Swabbing Processes................................ 6

3.3. Failure Modes during Pullback Process............................................................ 7

4. HDD Failure Mitigation ............................................................................................. 7

4.1. Mitigation during Pilot Hole Installation Process ............................................... 7

4.2. Mitigation during Reaming and Swabbing Processes ....................................... 8

4.3. Mitigation during Pullback Process ................................................................... 8

5. Frac-Out Failure and Mitigation................................................................................ 9

5.1. Frac-out Definition............................................................................................. 9

5.2. Drilling Fluid Characteristics.............................................................................. 9

5.3. Potential Environmental Impacts from Frac-outs ............................................ 11

5.3.1. Frac-outs to Water................................................................................... 11

5.3.2. Frac-outs to Marsh................................................................................... 11

5.3.3. Frac-outs to Uplands ............................................................................... 12

5.4. Frac-out Prevention ........................................................................................ 12

5.4.1. Design...................................................................................................... 12

5.4.2. Construction............................................................................................. 13

5.5. Monitoring for Frac-outs.................................................................................. 13

5.5.1. Pump Pressure ........................................................................................ 14

5.5.2. Circulation Rate ....................................................................................... 14

5.5.3. Ground Surface Inspection ...................................................................... 14

I-i Appendix I 
5.5.4. Surface Water Inspection......................................................................... 15

5.5.5. Special Safety Considerations ................................................................. 15

5.5.6. Notifications ............................................................................................. 15

5.6. Initial Response to a Frac-out ......................................................................... 15

5.7. Containment and Removal.............................................................................. 18

5.7.1. To Surface Waters................................................................................... 18

5.7.2. In Marsh................................................................................................... 19

5.7.3. On Uplands.............................................................................................. 22

5.8. Impacts Assessment....................................................................................... 23

6. Definition of HDD Failure and Abandonment Criteria............................................. 23

6.1. Criteria for Pilot Hole Failure........................................................................... 23

6.2. Criteria for Reaming and Swabbing Failure .................................................... 24

6.3. Criteria for Pullback Failure............................................................................. 25

7. KMLP/Agency Communication .............................................................................. 26

I-ii Appendix I 
1. Introduction 

The scope of the proposed Kinder Morgan (KM) Louisiana Pipeline project includes the 

installation of 132.2 miles of 42-inch diameter pipeline referred to as Leg 1, 1.2 miles of 

36-inch diameter pipeline referred to as Leg 2, and 2.3 miles of 24-inch referred to as 

the FGT Lateral. Evaluation of the proposed pipeline right-of-way (ROW) has identified 

potential impacts to several features that could be mitigated by crossing using horizontal 

directional drilling (HDD) instead of conventional pipe installation methods, such as the 

open cut method. These features include wetlands, water bodies, canals, and some 

roads. HDD crossings have been identified only in Leg 1 of the Project. As described 

in Resource Report 1, HDD method provides minimal planned disturbance of the 

surface between the entry and exit points of the HDD. Within Resource Reports 1 and 

2, Tables 1-10, 1-12 and 2-2 identify proposed HDD crossings by milepost. Some of 

these milepost sections contain multiple consecutive (i.e., back-to-back) HDD crossings. 

Table 1 presented in this contingency plan summarizes the HDD crossings for the KM 

Louisiana Pipeline project. 

Table 1 Summary of HDD Crossings by Milepost 

Milepost 

Begin End 

Alternative HDD 

Location Relative 

to Original 

Borehole 

Alternative Construction Method(s) 

(In Order of Attempted Application) 

3.93 4.83 50-foot offset 1. Conventional (open cut) water/land lay 

1. Reroute to shorten and re-drill 

17.96 18.62 50-foot offset 2. Conventional (open cut) water lay around 

Shell Island 

18.62 19.41 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional water lay to next HDD 

1. Relocate entry hole to shorten and re-drill, 

conventional water lay from previous HDD 19.41 20.01 50-foot offset 

2. Open cut 

21.17 22.11 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional water/land lay to next HDD 

I-1 Appendix I 
Table 1 Summary of HDD Crossings by Milepost 

Milepost 

Begin End 

Alternative HDD 

Location Relative 

to Original 

Borehole 

Alternative Construction Method(s) 

(In Order of Attempted Application) 

1. Relocate exit hole to shorten and re-drill, 

conventional land lay to previous HDD 22.11 22.71 50-foot offset 

2. Conventional (open cut) water/land lay 

22.71 23.45 50-foot offset 1. Relocate exit hole to shorten and re-drill, 

conventional land lay to next HDD 

23.45 23.95 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional land lay to previous HDD 

25.26 26.03 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional land lay to next HDD 

26.03 26.80 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional land lay to previous HDD 

30.36 31.46 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

marsh-buggy construction to next HDD 

1. Relocate entry hole to shorten and re-drill, 

marsh-buggy construction to previous HDD 

31.46 32.42 50-foot offset 

2. Marsh-buggy construction and conventional 

open cut (wet) waterbody crossing 

43.69 44.48 50-foot offset 1. Conventional land lay and open cut (wet) 

waterbody crossing 

49.57 50.45 50-foot offset 1. Relocate entry hole to shorten and re-drill, 

conventional land lay to next HDD 

50.45 51.30 50-foot offset 1. Relocate exit hole to shorten and re-drill, 

conventional land lay to previous HDD 

51.78 52.37 50-foot offset 1. Conventional (open cut) land lay 

I-2 Appendix I 
Table 1 Summary of HDD Crossings by Milepost 

Milepost 

Begin End 

Alternative HDD 

Location Relative 

to Original 

Borehole 

Alternative Construction Method(s) 

(In Order of Attempted Application) 

1. Relocate exit hole to shorten and re-drill, 

conventional land lay and horizontal bore 

road remainder 52.37 53.05 50-foot offset 

2. Conventional land lay and open cut (wet) 

waterbody crossing 

1. Relocate exit hole to shorten and re-drill, 

conventional upland construction remainder 

77.65 78.40 50-foot offset 

2. Horizontal bore highway, conventional 

upland construction remainder 

99.02 99.76 50-foot offset 

1. Relocate entry or exit hole to shorten and redrill, conventional upland construction 

remainder 

HDD has been used to successfully install pipelines in soils similar to those underlying 

the KM Louisiana Pipeline ROW and in similar conditions. Pipelines up to 42 inches in 

diameter are commonly installed by HDD today. Experienced HDD contractors will be 

utilized for the installation of the HDDs on the KM Louisiana Pipeline Project. The 

combination of experience and historical HDD success in the southern Louisiana area 

strongly suggests that the HDD method will be successful for this Project. In addition, 

HDD feasibility will be further evaluated using geotechnical data collected from soil 

borings to be collected at the individual crossings. This soils data will also be used to 

design the HDD parameters (e.g., entry and exit angles, depth of drill, depth of cover, 

mud mixture specifications, pullback load requirements) specific for each crossing. 

Although not anticipated for this Project, there is always a potential for failure of any 

HDD pipeline crossing. This contingency plan identifies typical modes of failure 

associated with HDD installations, including frac-out or loss of drilling fluid (Section 5). 

Mitigation and/or remedial procedures are identified for these typical issues. 

In the event that the mitigation and/or remedial procedures do not result in a successful 

HDD crossing, this contingency plan presents a decision process to evaluate the 

I-3 Appendix I 
continuation of the HDD method or the adoption of alternative pipeline design or 

installation methods. Generally, if the HDD fails at the original HDD location, KMLP will 

attempt to move to a second, immediately adjacent (50-foot offset), HDD location. 

However, the KM Louisiana Pipeline project ROW is, at some locations, narrowly 

situated between subsurface obstructions, such as other pipelines, or surface 

obstructions, such as rivers and canals. Consequently, a second HDD location may not 

always be available. The anticipated presence or absence of a second HDD location 

offset by 50 feet is identified in Table 1. In the event that HDD method fails at the first 

and, if available, the second HDD location, an alternative design and/or construction 

method is suggested in Table 1. A typical alternative design for a long HDD would be to 

shorten the HDD length, reducing the stress on the equipment and borehole, and 

completing the distance with a more conventional construction method. When 

identifying the alternative method, KMLP considered engineering restrictions, ROW 

restrictions, and potential environmental impacts. 

Pre-construction approval of these procedures should expedite the response time for 

alternative decisions, ensure that appropriate actions are taken that have been preapproved by the agencies, and minimize adverse environmental impacts that may arise 

as a result of frac-outs. HDD installations are typically a 24-hour per day, 7 days per 

week operation, and the objective is to complete each drill in a timely manner with the 

least adverse impacts to the environment. 

2. HDD Technique 

There are three major processes associated with the HDD installation of a pipeline 

crossing: installation of a pilot hole; incremental reaming of the pilot hole followed by 

swabbing the borehole; and pipe pullback. This section discusses each of these steps. 

2.1. Pilot Hole Installation Process 

The pilot hole is drilled along a predetermined alignment in which the entry and exit 

points are located using traditional survey methods. The drill path is monitored by an 

electronics package housed in the non-rotating pilot drill string near the cutting head. 

Where possible, a TruTracker® survey system is used to survey the location of the drill 

path. A wire coil on the surface creates a magnetic field that is detected by the 

electronic housing. Data from the electronic housing is evaluated by the HDD Operator 

and adjustments are made to the drill pathway. 

Initially, the pilot hole, generally a 9-7/8-inch diameter bore, is installed beneath the 

proposed crossing using a jetting assembly in non-consolidated sediments, such as 

I-4 Appendix I 
those anticipated along the proposed KM Louisiana Pipeline ROW, or a downhole 

displacement mud motor connected to a tri-cone rotary bit in consolidated sediments. 

Drilling fluid, pumped through the annulus of the drill stem, performs multiple functions. 

It aids the mud motor or jetting assembly in cutting the soil, lubricates the drill stem, 

suspends and carries the drilled cuttings to the surface and forms a wall cake on the 

interior of the borehole to maintain the integrity of the borehole. 

Installation of the pilot hole is closely monitored to provide data necessary to complete 

the crossing. These data, including the expected penetration rate and geotechnical 

strata confirmation, are used by the HDD Operator to plan the reaming process 

2.2. Reaming and Swabbing Processes 

Beginning at the exit point of the crossing, a reamer is attached to the drill stem and 

passed through the pilot hole to the entry point. For each section of drill stem removed 

from the entry point of the crossing, a section of drill stem is attached to the reamer and 

successive sections of drill stem at the exit point. This newly attached drill stem is used 

to guide the equipment during the return pass of the reamer from the entry side back to 

the exit side of the crossing. Several passes of a 24-inch reamer are used to initially 

enlarge the pilot hole from 9-7/8 inches to 24 inches. Once completed, incrementally 

larger reamers are passed through the borehole until the pilot hole has been enlarged to 

the final diameter appropriate for insertion of the pipe. 

The HDD borehole is then swabbed to clean out remaining soil cuttings and prepare the 

borehole for the pipe. A swab is constructed by welding caps onto a section of pipe the 

same diameter as that to be installed in the borehole. The swab is connected to the drill 

stem and the drilling rig pulls the swab through the borehole. Again, for each section of 

drill stem removed at the entry side of the crossing, a section of drill stem is attached to 

the swab and successive sections of drill stem at the exit side. Depending on the 

borehole, more than one swab may be required to clean the borehole. At completion, 

the swab will be removed from the exit side of the crossing so that the drill stem can be 

attached to the prefabricated 42-inch pipe laid out at the exit side of the borehole. 

2.3. Pullback Process 

After the reaming and swabbing processes have enlarged the borehole to a diameter 

sufficiently large enough to allow the insertion of the prefabricated pipe, a reinforced 

pullhead is attached to the leading end of the pre-fabricated pipe segment in 

preparation for the pullback process. The pullhead is connected by way of a swivel 

head to the drill stem at the exit side of the crossing. Using the drilling rig, the pipe is 

I-5 Appendix I 
pulled through the borehole to the entry side of the crossing. Since the air-filled pipe will 

float in the drilling fluids, a calculated volume of water is added to the pipe sufficient to 

maintain a neutral buoyancy while pulling the pipe. 

3. Potential Modes of HDD Failure 

The potential for failure exists during each process described in Section 2. These 

modes of failure are detailed in the following discussions. In addition, loss of drilling 

fluids or frac-out can occur, typically during the pilot hole installation process. Failure 

due to frac-outs and procedures to handle frac-outs are described in Section 5. 

3.1. Failure Modes during Pilot Hole Installation Process 

The equipment associated with the pilot hole installation process is subject to a large 

amount of stress. If the equipment has not been maintained appropriately, the 

equipment could break. While HDD surface equipment is easily accessed for repair, the 

equipment is very specialized. Equipment that fails down hole must be retrieved in 

order to be repaired or to continue installation of the pilot hole. 

During the pilot hole installation, the borehole can collapse on the drill stem pipe if 

sufficient bentonite cake is not maintained on the walls of the hole, or if stratum 

containing highly fractured rock, glacial till, noncohesive material, or cobbles is 

encountered. If the pilot hole collapses, the torque required to rotate or advance the 

drill pipe increases due to additional friction from the collapsed material. This increased 

friction can freeze the drill pipe in the borehole. Usage of additional torque and tension 

in an attempt to free the equipment can shear or twist the drill pipe into pieces. Multiple 

changes in strata or excessively long drill lengths contribute to the probability of this 

type of failure. 

During pilot hole installation, the horizontal position of the hole is located using 

TruTracker®. When the HDD is below a water body or wetland area that does not allow 

positioning of the surface cable necessary to operate the TruTracker® system, the pilot 

hole may deviate from the designed path. The potential for this failure mode increases 

during long drill lengths. In addition, metal objects located near the pilot hole pathway 

can interfere with the magnetic field generated by the surface cables resulting in 

inaccurate TruTracker® locations. 

3.2. Failure Modes during Reaming and Swabbing Processes 

Caving of the borehole can be a result of insufficient bentonite cake on the walls. This 

failure type is exacerbated during the reaming process. During each pass, a large 

I-6 Appendix I 
volume of drilling fluid is jetted through the reamer. In nonconsolidated soils, the jetting 

energy can carve out caverns causing the hole to become unstable and cave. The 

caved material may prevent recirculation of the drilling fluids causing a build up of 

cuttings in the base of the hole. 

In addition to the problem of the caved material obstructing the borehole, both soil 

collapsed from the borehole and cuttings built up due to poor recirculation of drilling 

fluids increase the friction on the drill pipe. The increased friction could increase the 

potential for pipe failure by shearing or twisting into pieces and consequently for the 

equipment to become lost in the hole. 

3.3. Failure Modes during Pullback Process 

Failure during the pullback process is identified by pipe refusal in either direction. This 

may be due to an insufficiently reamed or swabbed borehole, caving due to lack of good 

bentonite cake on the walls, increased friction on the pipe wall due to positive or 

negative buoyancy, increased friction on the wall of the pipe due to an excessively long 

run, or deterioration of the borehole due to a time lag while the pipe lays idle. 

4. HDD Failure Mitigation 

Generally, the modes of failure identified in Section 3 can be avoided or mitigated prior 

to complete failure of the HDD technique. 

4.1. Mitigation during Pilot Hole Installation Process 

KMLP will implement procedures to avoid failure well before commencement of 

construction. Soil samples collected from borings located near the crossings will be 

evaluated to verify the subsurface geology and to identify a soil layer depth and type 

that will minimize the potential for caving during pilot hole installation. A drilling 

contractor will be identified with experience in HDD installations in similar geology and 

of similar design to the Project. Proper selection of equipment and well maintained 

equipment will minimize the potential for equipment failure during the drilling process. 

The drilling fluid characteristics will be monitored to minimize the potential for caving 

due to insufficient mud cake on the borehole wall. Cuttings will be monitored to ensure 

that circulation has not failed. If the HDD Operator identifies increased stress on the 

drilling equipment due to poor cuttings return or partial collapse of the pilot hole, he can 

adjust the drilling fluid consistency or decrease the drilling rate to allow the drilling fluid 

more time to penetrate the borehole wall and to transport the cuttings from the annulus 

to the surface. In the event that a decrease in drilling fluid or cutting return is noted, the 

I-7 Appendix I 
HDD Operator can also partially pull out of the boring to ream out the pilot hole and 

flush the collected cuttings before they completely plug the borehole. These preventive 

methods minimize stress on the drilling equipment and decrease the potential for 

equipment failure. 

If the pilot hole deviates from the designed pathway, the HDD Operator can correct the 

pilot hole prior to returning to the surface or if the deviation is significant, he can pull 

back, grouting the abandoned section of the pilot hole with bentonite, correct the 

pathway and re-drill that section of the pilot hole so that the pilot hole exits at the correct 

location. 

4.2. Mitigation during Reaming and Swabbing Processes 

During the pilot hole installation, the HDD Operator will monitor soil cuttings, rate of 

advancement, and torque on the drill bit to help identify the characteristics of the 

underlying strata. Referring to this information, he can adjust pump pressure as he 

reams the pilot hole to minimize the potential for caving due to high jetting pressure 

while also adjusting the rate of advancement to maximize the opportunity for the 

cuttings to exit the borehole. However, if caving does occur, the HDD Operator will 

remove the reamer and re-attach the drill bit to re-drill the pilot hole. The reaming 

process can be re-started adjusting for the location of the cave-in as needed. 

4.3. Mitigation during Pullback Process 

Equipment selection is again very important in the pullback process. The drilling rig 

must have sufficient power to not only pull the weight of the longest section of pipeline 

through the borehole but to overcome potential resistance associated with minor caveins during the pullback process. KMLP will ensure that the pipe is prefabricated, tested, 

and ready to be pulled at the completion of the swabbing process. This will decrease 

the potential for lag time and decrease the likelihood of caving associated with extended 

lag time. 

Knowing the density of the drilling fluids and the weight of the pipe, the volume of water 

needed to maintain neutral buoyancy will be calculated and gradually added to the pipe 

as it enters the borehole. The HDD Operator will monitor the drilling equipment for an 

increase in tension that signifies increased friction on the pipe and possible imminent 

refusal. At that time, pulling is halted and the buoyancy is adjusted or, if necessary, the 

pipeline can be removed and the borehole reamed and swabbed. 

If the pipeline does become stuck during the pullback process, the HDD Operator can 

attach an air hammer to the end of the pipeline segment and either hammer the pipeline 

I-8 Appendix I 
I-9 Appendix I 

past the obstruction and through the borehole or hammer the pipeline back towards the 

exit side, freeing the pipe from the obstruction allowing the drilling rig to again move the 

pipeline. 

5. Frac-Out Failure and Mitigation 

This section establishes the procedures for preventing, monitoring, and responding to 

frac-outs of drilling fluids that may occur during the HDDs. The intent of this section is 

to set forth a plan of the actions to be taken, under various conditions and for various 

sizes of frac-outs, should frac-outs occur. There are duplications between the mitigation 

methods described in Section 4 and in this section; however, since frac-out occurrences 

are relatively common during HDD, the duplications were permitted in order to make 

this section as complete as possible. 

5.1. Frac-out Definition 

For the purposes of this procedure, a “frac-out” shall be defined as the unintentional or 

inadvertent loss of drilling fluids from the HDD borehole to the ground surface, other 

than at the borehole entry or exit points. Loss of drilling fluids to the subsurface 

geological formation may result in an apparent reduction in the return of fluids and 

cuttings, but will not be considered a frac-out under this plan unless drilling fluids are 

observed in surface waters or at the ground surface. 

5.2. Drilling Fluid Characteristics 

“Drilling fluids” (often referred to as “drilling mud”) to be used on this Project will be a 

mixture of liquids (mostly fresh water) and solids used in a circulating system in the 

drilling process for the removal of soil cuttings from the borehole, while filling the void 

left by the cuttings, lubricating and cooling the drill string, and sealing the borehole wall 

to eliminate fluid loss and maintain borehole stability. 

Relatively small proportions of approved “additives,” identified in Table 2, may be mixed 

with the drilling fluids. These additives will modify the physical and chemical properties 

of the drilling fluids in order to improve drilling performance or in response to a frac-out. 

The additives will be used when deemed necessary and appropriate by the On-Site 

Mud Engineer, approved by the HDD Superintendent, and in the concentrations 

recommended by the manufacturers and the On-Site Mud Engineer. Other additives 

may be added to the list by the Mud Engineer, if approved by KMLP. 
I-10 

Table 2 Approved Drilling Fluid Additives 

Additive Manufacturer Description Purpose or Use 

Pargel 220® Parchem Mining & 

Waterwell, a division of Smith/Schlumberger Company 

A naturally occurring Wyoming bentonite clay with low sand content 

Lubrication, stabilization of the borehole walls, and the suspension and removal of soil cuttings from the borehole 

Polypac R® A business unit of M-I 

L.L.C. 

100 percent carboxymethylcellulose sodium salt, a polyanionic cellulose polymer 

To control fluid loss and increase the viscosity of the drilling fluid 

Soda Ash A business unit of M-I 

L.L.C. 

100 percent sodium carbonate To increase the pH of the 

drilling fluids to precipitate calcium 

Ringfree® A business unit of M-I 

L.L.C. 

60 to 100 percent acrylic polymer To eliminate or cut mud 

bridging and free up borehole circulation; helps free stuck pipbecause it dissolves sticky clays. 

FSF Polyswell® 

A business unit of M-I L.L.C. 

100 percent acrylamide polymer or copolymer 

Primarily as a lost circulation material. 

My-Lo-Jel® A business unit of M-I 

L.L.C. 

100 percent pre-gelantized starch Fluid loss agent and viscosifier
Refer to the Material Safety Data Sheets (MSDS) in Appendix A for more details on the 

physical, chemical, and environmental characteristics of these non-toxic additives. 

KMLP must approve the use of any additional additives that the HDD Contractor may 

deem necessary to resolve specific drilling difficulties, prior to their use. 

5.3. Potential Environmental Impacts from Frac-outs 

5.3.1. Frac-outs to Water 

Drilling fluids released from an HDD frac-out directly into a surface water body at the 

mud line will be dissipated by the natural currents or blended with the existing solids, 

primarily clay, suspended in the water column. The solids in the drilling fluids are also 

primarily clay, but at low concentrations (no more than 5 percent by volume). 

Inadvertent discharges of the nontoxic drilling fluids may result in a very localized and 

transient increase in suspended solids concentrations, but these increases pose no 

significant threat to public health and safety or to aquatic resources. If an underwater 

frac-out is located in the existing turbid conditions, containment and recovery of the 

drilling fluids would be impractical due to mixing with the surface water. Frac-outs under 

water are a greater impediment to the successful completion of an HDD, due to lost 

circulation, than they are a significant impact on the environment. In the event of a fracout, the HDD Contractor will employ measures described herein to regain proper 

circulation in order to complete the borehole, which in turn should reduce or eliminate 

the frac-out to surface water. As directed by KMLP in consultation with the regulatory 

agency representative, containment may be attempted if sensitive resources, such as 

oyster beds or marsh, are threatened and conditions permit. 

5.3.2. Frac-outs to Marsh 

Several of the HDDs will cross under salt and brackish marsh; in fact, many of the 

HDDs are being performed in order to eliminate direct impacts to marsh from 

conventional pipe installation by trenching. Because of the low concentration (less than 

5 percent) of solids in the drilling fluids, and the natural tendency of the fluid to seek a 

uniform elevation equal to the water level in the marsh, a measurable or permanent 

increase in any ground surface elevation is not likely. If the drilling fluid has a 

particularly high viscosity and the tide is low, a temporary rise might be visible, but this 

will quickly dissipate. On the other hand, the settlement of fines, if of sufficient volume, 

in the marsh may suffocate existing vegetation or affect surface hydrology. Efforts by 

the HDD Contractor to contain and recover frac-out fluids in marsh will also cause 

disturbance of the marsh surface and vegetation by equipment and personnel, and 

I-11 Appendix I 
depending upon its location, such disturbance could offset the benefit gained in 

removing the released fluids. Because it is difficult to predict the net effect of a frac-out 

and attempts to recover the fluids, any frac-outs to the marsh must be evaluated on a 

case-by-case basis and an appropriate level of response mounted as described herein. 

5.3.3. Frac-outs to Uplands 

Uplands crossed by HDD on this project are limited to some road and railroad crossings 

including the I-10 HDD crossing. Environmental impacts will be limited to possible 

surface runoff of fines into adjacent surface waters. Typically the upland crossings are 

readily accessible by conventional construction equipment, so the HDD Contractor will 

perform containment and recovery of drilling fluids utilizing Containment and Recovery 

Equipment listed in Appendix B. 

5.4. Frac-out Prevention 

The first and most effective step in limiting the potential environmental impacts of HDD 

frac-outs is to prevent frac-outs from occurring in the first place. This can be 

accomplished in the conservative design of the HDD profile, as well as by observing 

preventative procedures during the actual HDD crossing. 

5.4.1. Design 

Precautionary measures incorporated into the design of the proposed HDDs to minimize 

the possibility of frac-outs, include: 

a) Geotechnical Investigations 

The soils strata targeted for the majority of the length of each borehole will be selected 

based on physical properties most conducive to producing a successful boring. These 

strata and their properties will be identified in pre-construction geotechnical 

investigations conducted along the length of each proposed HDD installation. 

b) Depth of Cover 

The proposed depth of cover will be maintained at a minimum of 20 feet (and in most 

cases, significantly more) below waterbodies and marsh, except in the initial and final 

100 feet (+/-) where the borings enter and exit the ground. Since the possibility of a 

frac-out may increase as depth of cover decreases, the initial and terminal 100-foot 

sections of each HDD will be located in either upland areas or in open water, and have 

been purposely kept out of marsh areas, where possible. 

I-12 Appendix I 
5.4.2. Construction 

The HDD Contractor will employ reasonable measures during drilling activities to 

prevent or minimize the occurrence of frac-outs, including as a minimum: 

a) On-site Mud Engineer 

A full-time, qualified, mud engineer will be on site. The On-site Mud Engineer will 

continuously monitor the drilling fluid circulation and returns, and ensure that the fluids 

handling equipment is operating within expected and optimum parameters (i.e. 

pressures, flow rates, etc.) for the soils conditions observed. 

The On-site Mud Engineer will continuously monitor returned cuttings for soils type, and 

will modify the drilling fluid properties (i.e. viscosity, density, etc.) with the appropriate 

additives, as he deems necessary to account for changes in soil conditions. 

b) Controlled Drill Head Advance 

Where possible at the beginning of a drill, the drill head will be initially advanced with 

minimum drilling fluid pressure to minimize frac-outs in the relatively shallow depths. 

The HDD Operator will advance the drill head at a pace that permits soils cuttings 

sufficient time to be flushed from the borehole by the drilling fluids. This prevents 

plugging and thereby maintains down-hole pressures at an acceptable level. The 

maximum rate of advance will be set, and periodically adjusted, by the HDD Operator, 

based on consultation with the On-site Mud Engineer, and as subsurface conditions 

change. If plugging occurs (i.e. return flow is diminished relative to fluid pumping rate), 

the rate of advance will be reduced, stopped, or reversed, as appropriate, until the plug 

has been cleared. 

c) Minimum Pump Pressure 

Drilling fluid pump pressure will be maintained at no more than the minimum necessary 

to maintain good circulation and to keep the borehole clear of cuttings. In the event a 

reduction in circulation is observed, at the discretion of the On-site Mud Engineer, 

adjustments to drilling fluid properties (i.e., density, viscosity, etc.), rate of drill head 

advance, and reaming diameter will be considered before pump pressure is increased. 

5.5. Monitoring for Frac-outs 

The HDD Operator will ensure that HDD operations are monitored for the occurrence of 

frac-outs using each of the following methods, where appropriate: 

I-13 Appendix I 
5.5.1. Pump Pressure 

The drilling fluid pump discharge pressure shall be continuously monitored by the Onsite Mud Engineer and recorded on a field data log prior to each joint connection. 

Significant changes or fluctuations in pressure may indicate the possibility of a frac-out, 

requiring immediate response. 

5.5.2. Circulation Rate 

The On-site Mud Engineer shall continuously monitor the flow rate of drilling fluid 

circulation and the volume of returns and record the data prior to each joint connection 

or following a change in return rate. Differences between the pumping rate and the rate 

of returns may indicate a frac-out. 

5.5.3. Ground Surface Inspection 

The HDD Operator shall assign one person to visually inspect the ground surface in 

uplands and marsh along the progress of the HDD for indications of escaping drilling 

fluids. Where possible, without trespassing outside the approved workspace or entering 

marsh (i.e., from a boat adjacent to the marsh), the inspection will cover a corridor 

approximately 500 feet wide, centered on the drill. Inspections shall be made relative to 

the rate of advance of the drill head, but an inspection pass shall be made at least once 

every hour while pumping drilling fluids. Any indications of a frac-out shall be reported 

immediately to the HDD Operator. If operating parameters (i.e., fluctuations in fluid 

pressure or returns) indicate the possibility of a frac-out, the surface inspection shall 

become continuous (daylight only) until the location of the suspected frac-out is found, 

the drill is completed, or measures to remedy the frac-out using additives or other 

operational adjustments have been successful. Daylight continuous monitoring will 

supplement the monitoring of operating parameters. Reasonable efforts will be made to 

locate the point of frac-out, if possible, in order to assess environmental damage, if any. 

Inspections on uplands may be made on foot or from an appropriate vehicle. 

Inspections in marsh may be made on foot or from a boat in adjacent waters, depending 

on the potential for negative impacts to marsh by the inspection activities. Site-specific 

marsh inspection methods shall be reviewed and approved by the On-site KMLP 

Environmental Monitor, following consultation with the regulatory agency representative, 

if present. 

I-14 Appendix I 
5.5.4. Surface Water Inspection 

The HDD Operator shall assign an individual to visually inspect the waterbodies under 

which the HDD is crossing for turbidity plumes that might indicate a frac-out is occurring. 

Inspection passes shall be made at least once every hour while pumping. Any 

indication of a frac-out shall be reported immediately to the HDD Operator. If operating 

parameters indicate the possibility of a frac-out under water, the water inspection shall 

become continuous (daylight only) until the location of the suspected frac-out is found, 

the drill is completed, or measures to remedy the frac-out using additives or other 

operations adjustments have been successful. Inspections shall be made by boat, or 

from an elevated position on land with an unobstructed line-of-sight to the water body 

(binoculars are recommended). Inspection boats shall be positioned and operated so 

as not to interfere with the ability to observe a plume or create a prop-induced plume 

(i.e. down-current from the drill centerline). 

5.5.5. Special Safety Considerations 

Monitoring in water or marsh at night or in fog will require special safety precautions and 

equipment considerations, including Coast Guard-approved navigation lights on all 

vessels, two men in each boat, continuous communication with the onshore crew or the 

drill barge, and portable lights of sufficient power to effectively monitor the area. No 

continuous nighttime monitoring will be allowed. Monitoring in water or marsh will be 

discontinued whenever conditions render the activity unsafe. At such time, the HDD 

Operator will determine, subject to KMLP approval, if drilling can safely continue while 

monitoring for frac-outs based solely on pump pressure and drilling fluids returns. 

5.5.6. Notifications 

Upon first indication of a frac-out, the HDD Operator shall notify the On-site KMLP 

Environmental Monitor. Upon confirmation of a frac-out, the On-site KMLP 

Environmental Monitor will notify the appropriate regulatory agencies, and the HDD 

Operator shall notify the affected landowner(s). 

5.6. Initial Response to a Frac-out 

The HDD Contractor’s initial response to a potential frac-out shall be in accordance with 

the flow diagram provided in Figure 1, and as described in further detail below. 

• Upon first indication of a potential frac-out, the HDD Operator shall reduce 

drilling fluid circulating pressure, continue rotation of the drill string, and 

I-15 Appendix I 
continue to advance the drill head in an attempt to stop or substantially 

reduce the frac-out rate. 

• If the frac-out is initially or subsequently confirmed by an observed release of 

fluids to the surface or an observed turbidity plume in water, the HDD 

Operator will attempt to advance the drill head past the known point of the 

frac-out. 

• Concurrently, the On-site Mud Engineer may inject pre-approved additives, in 

concentrations recommended by the manufacturer and as calculated by the 

On-site Mud Engineer, into the drilling fluid mixture in an additional attempt to 

control the release. 

• If the release of drilling fluids continues unabated at a rate that threatens to 

expand to more than 0.1 acres of marsh habitat, or at a rate otherwise 

deemed excessive by the On-site KMLP Environmental Monitor (in 

consultation with the regulatory agency representative, if present), or 

completion of the drill is in jeopardy due to failure to remove cuttings from the 

borehole, advancement of the drill will be temporarily suspended. 

• The Drill Operator may continue to rotate the drill string in the borehole and 

circulate fluids at a pressure that does not result in continued fluid release at 

the frac-out point, in order to keep the borehole open. 

• If the frac-out is to marsh, the HDD Operator shall request that the On-site 

KMLP Environmental Monitor proceed to the analysis for containment and 

recovery described in Section 5.7.2 below, before continuing with the drill. 

• If the frac-out is to uplands, the HDD Operator may continue advancing the 

drill, provided the released fluids are contained and removed (as described in 

Section 5.7.3 below), and after confirmation that cuttings are being returned 

at a sufficient rate to ensure successful completion of the borehole. The Onsite Mud Engineer shall make adjustments to the drilling fluid properties to 

plug the frac-out or reduce the volume of fluids being released. 

I-16 Appendix I 
Proceed with 

pullback

Figure 1. HDD Frac-out Flow Chart

Reduce circulating pressure (5.6.1)

Advance drill past frac-out (5.6.2)

Mix additives (5.6.3)

Start HDD

Monitor drilling 

fluids circulation

 and ROW (5.5)

Frac-out 

indicators 

observed?

Frac-out indicators:

- pressure changes (5.5.1)

- reduced returns (5.5.2)

- mud discharge to surface (5.5.3)

- turbidity plume (5.5.4)

Drilling 

complete

?

Frac-out 

location?

Upland

Marsh

Open 

water

Yes

No

Yes

No

Obtain landowner 

access 

permission

Contain, remove, 

and dispose mud

(5.7.1, 5.7.3)

Obstructs 

channel, impacts

oysters, 

excessive 

turbidity?

No

Yes

Adjust drilling fluids 

properties to reduce 

volume released 

Sufficient 

returns to 

complete 

hole?

Continue 

 advancing the 

drill (5.6.7, 5.6.8)

Yes

Measure 

impacted area 

(5.7.2)

Estimate additional impact if

drilling continued without 

containment (5.7.2)

Containment 

indicated? 

(Form 1)

Yes

No

No

Stop advancing drill.

Reduce circulating 

pressure.

Continue rotation.

Options 

exhausted

?

No

Abandon hole?

Yes

Characterize 

impacted area 

(5.7.2)

Note: See Frac-Out Procedures 

text for detailed descriptions and 

assigned responsibilities for

each activity. Procedure section 

numbers shown in parentheses.

Compare net impacts 

(5.7.2)

Continue 

drilling

Cease 

operations and 

consult with KM

Excessive 

release? 

(5.6.4)

Stop advancing drill (5.6.4)

Circulate at pressure that results in 

no discharge (5.6.5)

No

Yes

Notify landowner 

and regulatory 

agencies (5.5.6)

Temporarily 

suspend drilling

(5.6.8)

Estimate impacts from

containment activities (5.7.2)

Estimate reduction in impacts if

fluids are contained and removed 

(5.7.2)

Proceed with drill, 

continue to monitor 

(5.7.2)

Drill 

complete

?

No

Proceed with 

pullback

Yes

Frac-out 

stopped?

Continue 

drilling

Yes

No

Frac-out 

stopped, 

reduced, or 

contained?

Yes

No

I-17 Appendix I 
• The HDD Operator may also continue to advance the drill if the release is to 

open water, the release does not obstruct a navigation channel, directly 

impact oyster resources, or accumulate in marsh and the cuttings are being 

returned at a sufficient rate to ensure successful completion of the borehole. 

The On-site Mud Engineer shall make adjustments to the drilling fluid 

properties to plug the frac-out or reduce the volume of fluids being released. 

If, however, the On-site KMLP Environmental Monitor (in consultation with the 

regulatory agency representative, if present) deems the resulting turbidity 

plume to be excessive, the HDD Operator shall temporarily suspend drilling 

until necessary corrective measures are successfully implemented. 

• The On-site Mud Engineer shall record all parameters being tracked at the 

time of frac-out, including fluid circulating pressure, fluid mixture composition, 

fluid viscosity, location and depth of the drill head, location of the frac-out, rate 

of drill advance, and time of day. The HDD Operator shall keep a running log 

of all activities associated with the attempts to control the frac-out. 

5.7. Containment and Removal 

Containment and removal of drilling fluid releases to the surface from a frac-out shall be 

performed where practical and where there will be a net benefit in the reduction of total 

environmental impacts. 

5.7.1. To Surface Waters 

Containment and removal of drilling fluids released to surface waters as a result of a 

frac-out is generally impractical and ineffective because of dilution in the water column, 

and dispersion due to tides and currents. If, however, the On-site KMLP Environmental 

Monitor (in consultation with the regulatory agency representative, if present) considers 

the resulting plume excessive, or the plume may directly and negatively impact oyster 

resources or adjacent marsh, the HDD Operator shall implement the following 

containment measures. 

• Depending upon the depth of water and surface conditions, floating silt 

booms, anchored in place, shall be placed over the location of the frac-out. 

The purpose of the containment is to confine the suspended solids until some 

observable degree of settlement can occur. Removal of the diluted drilling 

fluids is not anticipated, unless dictated by unusual circumstances, and 

subject to KMLP approval. 

I-18 Appendix I 
• The containment shall remain in place until the frac-out stops, and settlement 

renders the turbidity inside the containment similar to the adjacent waters 

based on visual inspection (Secchi disk), or the threat to the sensitive 

resource has passed (e.g. reversal of tidal currents). 

• Any containment structure placed in open water shall be clearly marked as an 

obstruction in accordance with Coast Guard regulations, with special 

consideration given to the type of marine traffic observed in the area. 

5.7.2. In Marsh 

Containment and removal of released drilling fluids from a frac-out to marsh shall be 

performed when there is a net benefit in the reduction of impacts, as determined by the 

following actions. 

• Upon confirmation of a frac-out in marsh, the HDD Operator shall assist the 

On-site KMLP Environmental Monitor in measuring the area directly affected 

by the released drilling fluids. The area affected may be estimated from a 

distance, if access to the affected area for measurement would result in 

additional unacceptable negative impacts. 

• The On-site KMLP Environmental Monitor (a qualified wetlands biologist) will 

characterize the type of impact (e.g., temporary, permanent, vegetation only, 

change in surface hydrology) caused by the released fluids. The On-site 

KMLP Environmental Monitor will seek concurrence from the regulatory 

agency representative, if present. 

• The HDD Operator and the On-site KMLP Environmental Monitor shall jointly 

estimate the additional area, if any, likely to be affected if the drilling were to 

proceed and the drilling fluids were not contained and removed. 

• In consultation with the HDD Operator, the On-site KMLP Environmental 

Monitor will estimate and characterize the additional impacts to marsh likely to 

occur as a result of accessing the affected area for containment and removal 

of the drilling fluids. 

• The On-site KMLP Environmental Monitor will estimate any reduction in 

impacts that might be achieved if the released fluids were removed. 

I-19 Appendix I 
I-20 Appendix I 

• The total actual impacts, plus the estimated impacts from continuation of an 

uncontained release, shall be compared to the total actual impacts, plus the 

estimated impacts from accessing the area for containment and removal, less 

the estimated reduction in impacts as a result of recovery of the fluids. (Use 

Form 1 for guidance.) When making this comparison, some consideration 

and judgment should be given to the types of impacts, and value of the 

resources affected, if dissimilar. The action resulting in the least total impacts 

will generally be selected, unless there are mitigating circumstances, or as 

otherwise instructed by the regulatory agency representative, if present. 

• If the decision is to forgo containment and proceed with the drill, the On-site 

KMLP Environmental Monitor will continue to observe the location of the fracout. If the impacts continue to increase, the On-site KMLP Environmental 

Monitor will periodically repeat the comparison described above, until such 

time as containment and removal are justified, or the drill is complete. 

• In the event of excessive and uncontrolled discharges of drilling fluids to 

marsh, KMLP and the HDD Operator shall determine a course of action. The 

frac-out shall be successfully plugged through adjustments in mud mixture or 

drilling techniques, or the released fluids shall be contained and recovered 

from the marsh with minimal and acceptable levels of impact. [NOTE: No 

containment or recovery activities will be allowed in the marsh without agency 

approval.] If this cannot be achieved, the borehole shall be abandoned. 

• Prior to commencement of any HDD, the HDD Operator shall ensure that 

appropriate equipment is available at each HDD location to contain and 

recover drilling fluid flow from frac-outs into marsh. (See checklist in 

Appendix B.) 

• If it is determined (as described above) that the released drilling fluid is to be 

contained and recovered, the HDD Operator shall direct the placement of the 

equipment at the obvious point or points of frac-out and transfer the contained 

fluids to a hopper barge or frac tank for reuse or disposal. 
I-21 

Form 1. Marsh Frac-out Impacts Comparison 

Drilling Fluids Containment vs. No Containment (to be completed by On-site KMLP Environmen

HDD No.: Date: Frac-out Location: X= Y= Distance from Entry Point (ft) = 

Impact Characterization 

Description Area (Acres) Vegetation Surface Hydrology Comm

No Containment or Recovery Option: Actual marsh area impacted by drilling fluids Temp 

 Perm  None 

 Temp  Perm  None 

Plus estimated additional area impacted if drill proceeds (consider all reduction measures, such as drill head advancing past frac-out, frac-out control additives, reduced pump pressure, etc.) 

 Temp  Perm  None 

 Temp  Perm  None 

Subtotal No Containment or Recovery 

Containment and Recovery Option: Actual marsh area impacted by drilling fluids Temp 

 Perm  None 

 Temp  Perm  None 

Plus estimated impacts from accessing area for containment and recovery 

 Temp  Perm  None 

 Temp  Perm  None 

Less estimated reduction in impacts by removing drilling fluids Temp 

 Perm  None 

 Temp  Perm  None 

Subtotal Containment and Recovery 

Option Selected: Least total acreage impacted Other, explain: Construction (To Be Determined ): KMLP: Agency: 
• All access to the marsh shall be done in such a manner as to cause the least 

impacts to the marsh vegetation and surface hydrology, and only with agency 

approval. Because of site-specific variables, such as distance from open 

water, surface hydrologic conditions, and vegetation cover, the selection of 

the most appropriate access method (e.g., using shallow draft boats, airboats, 

or on foot) must be made on a case-by-case basis, subject to approval by the 

On-site KMLP Environmental Monitor. The least number of personnel and 

equipment necessary to accomplish the task safely and in a timely manner 

shall be deployed into the marsh as described above. 

• Following containment and removal, the HDD Operator shall continue to 

monitor this location for additional releases, and the remainder of the drill for 

new frac-outs, as the drill progresses. 

• Whether or not containment and recovery is performed, all impacts to marsh 

from frac-outs will be measured, assessed, and recorded by the On-site 

KMLP Environmental Monitor, with assistance from the HDD Operator, for 

determination of any mitigation or restoration measures that may be 

necessary, as described below. 

• Upon completion of the boring, the HDD Operator shall ensure that all 

containment and recovery equipment, tools, supplies, materials, wastes, and 

debris are removed from the marsh. 

5.7.3. On Uplands 

• The HDD Operator shall utilize as necessary, the appropriate combination of 

sand bags, hay bales, silt fence, pumps, hoses, and frac tanks that will most 

effectively contain and remove drilling fluids from upland areas (see checklist 

in Appendix B). The HDD Superintendent shall make the determination of the 

equipment and materials to be used, with approval of the On-site KMLP 

Environmental Monitor. 

• The HDD Operator shall instruct the recovery crew to pump the contained 

and recovered fluids to frac tanks on site for reuse, if the On-site Mud 

Engineer determines the fluids are reusable. Otherwise, the fluids will be 

transported off site for disposal. (See HDD procedures for instructions on 

proper transportation and disposal of drilling fluids.) 

I-22 Appendix I 
• KMLP will obtain landowner permission prior to accessing any upland sites for 

fluids containment and removal operations, except in an emergency where 

inaction would pose an imminent threat to human health, sensitive 

environment, or property. 

5.8. Impacts Assessment 

Whether or not the drilling fluids have been successfully contained and removed, the 

On-site KMLP Environmental Monitor will fully characterize the environmental impacts 

from any release of drilling fluids following completion of the HDD, including the areal 

extent of the plume, the area affected by any recovery efforts, the type of marsh and 

vegetation impacted, changes to marsh elevation and hydrology, and whether the 

impacts are permanent or temporary. The On-site KMLP Environmental Monitor will 

seek concurrence of his assessment with the regulatory agency representative, if 

present. 

The HDD Operator will provide an assistant and a boat (if necessary) to assist the Onsite KMLP Environmental Monitor in completing this assessment. 

A report of the assessment will be provided to the regulatory agency representative for 

determination of any further action. 

6. Definition of HDD Failure and Abandonment Criteria 

In the event the mitigation methods identified in Sections 4 and 5 are implemented with 

unsatisfactory results, KMLP will employ the following criteria to determine if the HDD 

method has failed and should be abandoned. If it is determined that HDD has failed, 

the alternative crossing method (or methods) identified in Table 1 will be utilized to 

complete the installation of the pipe. 

6.1. Criteria for Pilot Hole Failure 

Generally, breakdown of the HDD equipment is not considered to be acceptable criteria 

for an HDD failure. If surface HDD equipment, such as the HDD rig, breaks, it is the 

responsibility of the HDD Contractor to repair the equipment within 7 days. If the HDD 

Contractor can not repair the equipment within that time period, a second HDD 

Contractor may be identified and the HDD crossing will be re-started. 

If, according to the HDD Operator, subsurface conditions are such that additional 

attempts at completing the HDD crossing would likely result in continued equipment 

failure, and, in the HDD Operator’s option, the HDD method will not be successful, 

KMLP and the agency will discuss the possibility of abandoning the HDD method. 

I-23 Appendix I 
If drilling equipment breaks in the boring and cannot be retrieved, the HDD Operator will 

attempt to drill around the downhole equipment. If the HDD Operator cannot advance 

the pilot hole, the HDD equipment will be moved to the second, immediately adjacent, 

HDD location, if available (see Table 1), and the HDD Operator will attempt to re-drill 

the pilot hole. If a second HDD location is not available, the HDD as designed will have 

failed, and KMLP will advance to the alternative crossing method (see Table 1). 

If, after adjusting the drilling fluids, the initial pilot hole collapses on the downhole 

equipment or there is a frac-out that meets conditions of failure identified in Section 5, 

the HDD Operator and the On-site KMLP Environmental Monitor will determine if the 

pilot hole can be redesigned to utilize a different subsurface strata and attempt a 

second installation of the pilot hole at the original HDD location. 

If the pilot hole can be redesigned but not installed at the original HDD location or if the 

pilot hole can not be redesigned, the HDD equipment will be moved to the second 

adjacent location, if available (see Table 1), and a pilot hole installation attempt will be 

completed at the second, adjacent HDD location. If the attempt fails at the second HDD 

location, KMLP may consider the HDD as designed a failure. If a second adjacent HDD 

location is not available, the HDD as designed may be considered a failure. 

Failure of the pilot hole installation due to deviation from the designed pathway is not 

anticipated. If the pilot hole deviates from the designed pathway, the HDD operator will 

back out of the borehole, grout the incorrect pathway and re-drill the pilot hole, 

correcting for the pathway deviation as needed. 

Once HDD has been determined to have failed, the HDD Contractor will demobilize its 

equipment from the site after approval from KMLP and the crossing will be completed 

using the alternative method. 

6.2. Criteria for Reaming and Swabbing Failure 

If, following the collapse of the opened borehole or due to stresses on the equipment, 

the reamer equipment fails and part or the entire reamer is lost downhole, the HDD 

Contractor will be allowed 7 working days to attempt to retrieve the equipment from the 

hole and then return to the HDD crossing installation. If the HDD Contractor cannot 

retrieve the lost equipment, this is an unsuccessful attempt at opening the completed 

pilot hole due to equipment failure. If possible, a new pilot hole will be redesigned and 

installed at the first HDD location or if available, installed at the second adjacent HDD 

location. If neither of these two options can be implemented, HDD may be considered a 

failure due to equipment failure. 

I-24 Appendix I 
If the borehole collapses during the reaming process and the reaming equipment is 

retrieved, the pilot hole will be re-drilled at the original location and the pilot hole 

opening re-attempted. If, there is a second unsuccessful attempt at opening the pilot 

hole, the HDD Operator and the On-site KMLP Environmental Monitor will determine if 

the pilot hole can be redesigned and installed at the original location. If not, the HDD 

equipment will be moved to the second adjacent HDD location, if available (see Table 

1), and the HDD Operator will attempt pilot hole installation and conditioning. If there 

are two unsuccessful attempts at opening the pilot hole at the second HDD location, 

HDD may be considered a failure. If there is not a second adjacent HDD location, the 

HDD as designed may be considered a failure. 

Once HDD has been determined to have failed, the HDD Contractor will demobilize its 

equipment from the site after approval from KMLP and the crossing will be completed 

using the alternative method. 

6.3. Criteria for Pullback Failure 

If during the pull back process the pipe becomes stuck in the borehole, the HDD 

Operator will attempt to remove the pipe. If the pipe can be removed, the hole will be 

reconditioned and a second attempt to pullback the pipe will be completed. If during the 

second attempt to pullback the pipe, the pipe again becomes stuck, the HDD Operator 

will attempt to remove the pipe. If the pipe can be removed, the HDD Operator and the 

On-site KMLP Environmental Monitor will determine if a third attempt at the original 

location is warranted or if a new pilot hole should be drilled and opened at the second 

adjacent HDD location, if available (see Table 1). If a third attempt to pull the pipe at 

the original location fails, the HDD equipment will be moved to the second adjacent 

HDD location, if available (see Table 1) and a new pilot hole will be installed and 

opened. If a second HDD location is not available, HDD may be considered a failure. 

If the crossing is moved to the second HDD location, three attempts to pullback the 

pipe, in which the pipe becomes stuck but can be retrieved, will be completed before 

HDD may be considered a failure. 

If during the pullback process the pipe becomes stuck and cannot be retrieved from the 

borehole, the pipe will be abandoned in place. If a second HDD location is available, a 

new pilot hole will be installed and conditioned. A maximum of three attempts at the 

second location to pullback the pipe will be completed before HDD may be considered a 

failure. If a second location is not available, then HDD may be considered a failure. 

I-25 Appendix I 
Once HDD has been determined to have failed, the HDD Contractor will demobilize its 

equipment from the site after approval from KMLP and the crossing will be completed 

using the alternative method. 

7. KMLP/Agency Communication 

The On-site KMLP Environmental Monitor will prepare documentation in the form of 

daily progress reports, as-built information, and a description of the events leading up to 

the HDD failure. This documentation will be presented to the appropriate agencies 

notifying them of the HDD failure and KMLP’s schedule for implementing the approved 

alternative crossing method. Pre-approval of the alternative crossing method will allow 

KMLP to proceed in a timely manner to begin implementation of the alternative method 

without additional agency approval or acknowledgement of the receipt of the failure 

documentation. 

I-26 Appendix I 
Appendix A – MSDS Sheets for Drill Additives 

I-27 Appendix I 
I-28 Appendix I 
I-29 Appendix I 
I-30 Appendix I 
I-31 Appendix I 
I-32 Appendix I 
I-33 Appendix I 
I-34 Appendix I 
I-35 Appendix I 
I-36 Appendix I 
Appendix B – Containment and Recovery Equipment 

Checklist 

Silt fence 500 feet 

Hay bales 50 bales 

Small pumps 2 

Flex-line (2”) pump hose 200 feet 

Aluminum boats 2 

Shovels 6 

I-37 Appendix I 
[This page intentionally left blank] 
APPENDIX J 

DRAFT AQUATIC RESOURCE MITIGATION PLAN 
[This page intentionally left blank.] 
NOTE TO REVIEWERS: This is a preliminary draft of the Aquatic Resources Mitigation 

Plan and is incomplete. It is being revised and will be improved in future versions of the 

EIS. 

TABLE OF CONTENTS 

1.0 PROJECT DESCRIPTION ................................................................................... 1

2.0 DESCRIPTION OF AFFECTED AQUATIC RESOURCES................................... 1

2.1 Wetland Types .................................................................................................. 4

3.0 MITIGATION APPROACH.................................................................................. 17

3.1 Mitigation for Temporary Impacts.................................................................... 17

3.2 Mitigation for Permanent Impacts ................................................................... 18

3.3 Goals and Objectives...................................................................................... 18

4.0 WETLAND ACREAGE REQUIRING MITIGATION ............................................ 19

5.0 MITIGATION OPTIONS ..................................................................................... 19

5.1 Wetland Creation and Restoration .................................................................. 19

5.2 Mitigation Banking........................................................................................... 20

5.3 Wetland Preservation...................................................................................... 20

5.4 In-lieu-fee Mitigation........................................................................................ 21

5.5 Location(s) for Mitigation Efforts ..................................................................... 22

5.6 Mitigation Acreage Considerations ................................................................. 22

6.0 PIPELINE MONITORING PLAN......................................................................... 22

6.1 Temporary Impacts ......................................................................................... 22

6.2 Additional Monitoring Plans............................................................................. 22

7.0 MAINTENANCE AND CONTINGENCY PLAN ................................................... 24

7.1 Maintenance ................................................................................................... 24

7.2 Contingency Plan............................................................................................ 24

7.3 Invasive Species Control Plan ........................................................................ 24

7.3.1 Introduction.............................................................................................. 24

7.3.2 Logistics................................................................................................... 25

7.3.3 Chinese Tallow Control............................................................................ 25

8.0 LITERATURE CITED ......................................................................................... 27

 J-i Appendix J 
LIST OF TABLES 

Table 1 – Summary of Wetland Acreage Impacted by the Project 1................................ 3

Table 2 – Habitat Description. ......................................................................................... 6

Table 3 – Representative Plant Species by Wetland Type.............................................. 9

 J-ii Appendix J 
LIST OF ACRONYMS 

Banking Guidance Federal Guidance on the Establishment, Use and Operation of 

Mitigation Banks 

CGT Columbia Gulf Transmission 

CUP Coastal Use Permit 

CWA Clean Water Act 

Dth decatherms 

FAC Facultative (wetland indicator status) 

FACU Facultative Upland (wetland indicator status) 

FACW Facultative Wetland (wetland indicator status) 

FEMA Federal Emergency Management Agency 

FERC Federal Energy Regulatory Commission 

FGDC Federal Geographic Data Committee 

FGT Florida Gas Transmission 

GIS Geographic Information System 

GPS Global Positioning System 

KM Kinder Morgan 

KMLP Kinder Morgan Louisiana Pipeline, LLC 

LDEQ Louisiana Department of Environmental Quality 

LDNR Louisiana Deportment of Natural Resources 

LDWF Louisiana Department of Wildlife and Fisheries 

LNG Liquefied Natural Gas 

MBRT Mitigation Banking Review Team 

MP Milepost 

NGPL Natural Gas Pipeline Company of America 

NI No Indicator (wetland indicator status) 

 J-iii Appendix J 
LIST OF ACRONYMS (CONTINUED) 

NL not-listed (regarding wetland indicator status) 

NMFS National Marine Fisheries Service 

OBL Obligate Wetland (wetland indicator status) 

Plan FERC’s Upland Erosion Control, Revegetation and Maintenance 

Plan (FERC 2003b) 

Procedures FERC’s Wetland and Waterbody Construction and Mitigation 

Procedures (FERC 2003a) 

Psig pounds per square inch gauge 

SE-EPPC Southeast Exotic Pest Plant Council 

UPL Obligate Upland (wetland indicator status) 

USACE U.S. Army Corps of Engineers 

USEPA U.S. Environmental Protection Agency 

USDA U.S. Department of Agriculture 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geological Survey 

 J-iv Appendix J 
1.0 PROJECT DESCRIPTION 

The Kinder Morgan (KM) Louisiana Pipeline will consist of three pipelines and 

associated pipeline support facilities, including pig launchers and receivers, and 

metering equipment. The three pipelines are described as follows: 

• Leg 1 will consist of approximately 132 miles of 42-inch diameter pipeline 

commencing at a receipt point within the proposed Sabine Pass LNG Terminal 

and continuing to a point of interconnection with an existing Columbia Gulf 

Transmission (CGT) interstate pipeline in Evangeline Parish, Louisiana. The 

proposed route of Leg 1 is in Cameron, Calcasieu, Jefferson Davis, Acadia, and 

Evangeline Parishes, Louisiana. 

• Leg 2 will consist of approximately 1.2 miles of 36-inch diameter pipeline, 

commencing at a receipt point within the Sabine Pass LNG Terminal and 

continuing to a point of interconnection with the existing Natural Gas Pipeline 

Company of America (NGPL) pipeline just south of Highway 82. The proposed 

route of Leg 2 is entirely in Cameron Parish, Louisiana. 

• The Florida Gas Transmission (FGT) Lateral will consist of approximately 

2.3 miles of 24-inch diameter lateral pipeline, extending eastward from Leg 1 at 

approximately Milepost (MP) 110.60, to the existing FGT Compressor Station 7. 

The proposed route of the FGT Lateral is entirely in Acadia Parish, Louisiana. 

More details concerning the proposed routes can be found in Resource Report 1 – 

General Project Description. 

2.0 DESCRIPTION OF AFFECTED AQUATIC RESOURCES 

An aquatic resource determination was conducted on approximately 3,031 acres along 

the proposed KM Louisiana Pipeline and construction footprint. The proposed 

construction footprint includes work areas, permanent and temporary access roads, 

pipe yards, and interconnects. Emergent wetlands, scrub/shrub wetlands, and forested 

wetlands were identified during this determination. Wetland acreages have not been 

verified by the U.S. Army Corps of Engineers (USACE) and will likely change. The 

proposed project will affect approximately 4 miles of linear waterbodies, including 

bayous, rivers, canals, tributaries, and roadside drainages and an approximately 13.5-

mile section of open water in Sabine Lake. 

 J-1 Appendix J 
The underwater aquatic resource surveys did not identify any submerged aquatic 

vegetation or live oysters along the approximately 13.5-mile section of the route that 

crosses Sabine Lake. The bottom substrates found during sampling of a 3,000-foot 

wide corridor included soft mud with buried shell (4,552.2 acres, 87.9%), firm mud 

(187.6 acres, 3.6%), soft mud with exposed scattered shell (172.1 acres, 3.3%), 

moderately firm mud (151.8 acres, 2.9%), soft mud (105.5 acres, 2.0%), reef (5.9 acres, 

1%), and exposed shell (5.4 acres, 1%). Within this 3,000 foot corridor, over 99% of the 

water bottom contained no evidence of live and/or recently dead oysters. The greatest 

density of live oysters in the study area was located within the substrates defined as 

exposed shell and reef. However, the pipeline route crosses mostly soft mud and firm 

mud; it does not cross the exposed shell and reef substrate types (see the Sabine Lake 

Engineering, Shallow Hazard, and Oyster Survey Reports in Appendix 2-A of Resource 

Report 2 – Water Use and Quality). 

This document addresses the wetlands and waterbodies potentially impacted by the 

project. KMLP has taken measures to reduce the potential effects to wetlands by: 

• Optimizing the construction ROW design to avoid and minimize filling of 

wetlands; 

• Routing of the KM Louisiana Pipeline to avoid wetlands; and 

• Selecting construction techniques that minimize wetland impacts. 

The acreage of jurisdictional wetlands affected by the proposed pipeline project has not 

been determined by the USACE. However, once the wetland delineation report has 

been finalized it will be submitted to the USACE, New Orleans District for a jurisdictional 

determination. Table 1 shows the acreage by Cowardin Classification and wetland 

category (habitat description) as determined during field studies conducted during 

January - July 2006. 

 J-2 Appendix J 
Table 1 – Summary of Wetland Acreage Impacted by the Project 1

Area Within ROW 

Cowardin 

Classification 

Habitat 

Description 

Construction 

Workspace 

(acres) 

Operations 

ROW 

(acres) 

Acreage 

Mitigated 

by HDD 

Permanent 

Impacts 

(acres)2

Leg 1 and Leg 2 

E2EM Herbaceous 

Wetland 119.6 43.6 46.5 0.0 

PEM Herbaceous 

Wetland 183.7 72.9 41.3 0.0 

E2SS Scrub Shrub 

Wetland 18.0 6.5 7.0 0.0 

PSS Scrub Shrub 

Wetland 52.0 18.0 6.0 0.0 

PFO Forested Wetland 32.3 13.4 7.0 25.3 

FGT Lateral 

PEM Herbaceous 

Wetland 0.2 0.1 0.0 0.0 

PSS Scrub Shrub 

Wetland 1.6 0.8 0.0 0.0 

PFO Forested Wetland 2.8 1.4 0.0 2.8 

Access Roads 

E2EM Herbaceous 

Wetland 8.4 0.0 0.0 0.0 

PEM Herbaceous 

Wetland 0.9 0.0 0.0 0.0 

PSS Scrub Shrub 

Wetland 0.0 0.0 0.0 0.0 

PFO Forested Wetland 0.1 0.0 0.0 0.1 

Pipe Yards 

PEM Herbaceous 42.8 0.0 0.0 0.0 

 J-3 Appendix J 
Table 1 – Summary of Wetland Acreage Impacted by the Project 1

Area Within ROW 

Cowardin 

Classification 

Habitat 

Description 

Construction 

Workspace 

(acres) 

Operations 

ROW 

(acres) 

Acreage 

Mitigated 

by HDD 

Permanent 

Impacts 

(acres)2

Wetland 

PSS Scrub Shrub 

Wetland 19.8 0.0 0.0 0.0 

Aboveground Facilities 

PEM Herbaceous 

Wetland 1.3 1.3 0.0 1.3 

PSS Scrub Shrub 

Wetland 0.6 0.6 0.0 0.6 

E2EM Herbaceous 

Wetland 0.8 0.8 0.0 0.8 

1 Wetland acreages have not been verified by the USACE.

2.1 Wetland Types 

Existing Conditions 

Wetlands are defined as “those areas inundated or saturated with ground or surface 

water at a frequency and duration sufficient to support, and that under normal 

circumstances support, a prevalence of vegetation typically adapted to life in saturated 

soil conditions” (33 CFR Part 328). Wetlands are protected from alteration or 

destruction by Federal and State regulations. At the Federal level, wetlands are 

protected under Section 404 of the Clean Water Act. Under Section 404, the USACE 

has the authority to regulate the discharge of dredged or fill materials into waters and 

adjacent wetlands of the United States. The State of Louisiana administers a regulatory 

program within the jurisdiction of their Coastal Zone. Any activity affecting the Coastal 

Zone must obtain a Coastal Use Permit (CUP) to ensure that the activity is consistent 

with the Louisiana Coastal Resources Program. The KM Louisiana Pipeline falls within 

the coastal zone boundary for Louisiana within the parishes of Calcasieu and Cameron. 

KMLP will utilize the joint permit application that has been developed between the 

Louisiana Department of Natural Resources (LDNR) and the USACE to obtain both the 

CUP and USACE Section 404 permit. The Louisiana Department of Environmental 

 J-4 Appendix J 
Quality (LDEQ), Office of Environmental Services exerts the authority to protect aquatic 

resources under Section 401 of the Clean Water Act, which requires that the LDEQ 

conduct a Section 401 certification review of USACE Section 404 permit applications to 

determine if a proposed discharge would comply with State water quality standards. 

This Aquatic Resource Mitigation Plan was developed in accordance with the USACE 

Regulatory Guidance Letter No. 02-2 dated December 24, 2002. 

The KM Louisiana Pipeline lies within the Western Gulf Coastal Plain Level III 

ecoregion. The principal distinguishing characteristics of the Western Gulf Coastal 

Plain are its relatively flat topography and mainly grassland potential natural vegetation. 

Inland from this region, the plains are older, more irregular, and have mostly forest 

vegetation in the Louisiana portion or savanna-type vegetation potentials to the west in 

Texas. Largely because of its flat topography and fertile soils, a higher percentage of 

the land is in cropland than in bordering ecological regions. Rice and soybeans are the 

principal crops. Urban and industrial land uses have expanded greatly in recent 

decades in some parts of the region, and oil and gas production is common (Daigle et 

al. 2006). 

Wetland delineation was conducted in areas with landowner/manager permission in 

accordance with methods defined in the USACE Wetlands Delineation Manual (USACE, 

1987). Table 1 lists the delineated wetland types impacted by the KMLP Pipeline. The 

data reflected in Table 1 were generated from field surveys and for areas where land 

access was denied or the route was adjusted, aerial photography interpretation 

delineated wetland areas. Wetlands are defined by the presence of three parameters: 

hydrophytic vegetation, hydric soils, and wetland hydrology. Topography and soil 

characteristics along the pipeline corridor dictate the presence of those parameters, and 

therefore dictate the presence, type, and extent of wetlands along the construction 

ROW. 

The Cowardin system further classifies these wetland types according to their flooding 

regime, which ranges from temporarily or irregularly flooded to seasonally flooded or 

permanently flooded (see Resource Report 2 – Water Use and Quality). The Cowardin 

system of wetland classification (Cowardin, et al., 1979) was used to classify the 

wetlands into several wetland types which are described in Table 2. 

 J-5 Appendix J 
Table 2 – Habitat Description. 

Vegetation 

Type 

Cowardin 

Classification Wetland Type Habitat Description 

Estruarine Interdial 

Emergent (E2EM) 

Coastal Emergent 

Marsh 

Consists of brackish, intermediate, and fresh 

marshes. Includes smooth cordgrass, black 

rush, salt meadow cordgrass, cattail, and 

bulrush. 

Typical Palustrine 

Emergent Wetland 

Includes natural palustrine wetlands and 

man-made wetlands in existing ROWs and 

other disturbed sites. Includes a wide 

variety of emergent species, such as cattail, 

rushes, bulrush, arrowhead, etc. 

Herbaceous 

Wetland 

Palustrine 

Emergent Wetland 

(PEM) 

Herbaceous 

Agriculture Wetland 

Herbaceous wetlands that have developed 

on agricultural lands. Typically found in 

fallow rice fields or wet cattle pastures. 

Estruarine Interdial 

Scrub-Shrub 

(E2SS) 

Coastal ScrubShrub Wetlands 

Consists within brackish, intermediate, and 

fresh marshes. Includes wax-myrtle, Iva 

fructescens, Sesbania, smooth cordgrass, 

black rush, salt meadow cordgrass, cattail, 

and bulrush. 

Typical Palustrine 

Scrub-Shrub 

Wetland 

Generally includes sites in various stages of 

regrowth from timber harvest, fallow 

fields/pasture, or some other disturbance. 

Species include water oak, red maple, 

Chinese tallow, bramble, etc. 

Scrub Shrub 

Wetland 

Palustrine ScrubShrub Wetland 

(PSS) 

Scrub Shrub 

Agriculture Wetland 

Scrub shrub wetlands that have developed 

on agricultural lands. Typically found in 

fallow rice fields or wet cattle pastures. 

Bottomland 

Hardwood Wetland 

Dominated by water oak, willow oak, green 

ash, and other hydrophytic hardwood 

species. Invasive species such as Chinese 

tallow are commonly found as dominants in 

these systems. Forested 

Wetland 

Palustrine Forested 

Wetland (PFO) 

Swamp 

Normally associated with riparian zones and 

dominated by bald cypress, water tupelo, 

and water elm. 

The following sections describe the wetland categories listed above, and Table 3 lists 

representative species for each of the wetland category. 

 J-6 Appendix J 
Coastal Emergent Marsh 

The coastal emergent marsh consists of three primary marsh communities: brackish 

marsh (5-10 parts per thousand salinity), intermediate marsh (0.5-3.5 parts per 

thousand salinity), and coastal fresh marsh (<0.5 parts per thousand salinity; 

Stutzenbaker, 1999). Coastal emergent marsh is restricted primarily to areas along the 

KM Louisiana Pipeline south of the Intracoastal Waterway. 

Brackish marsh communities are tidal brackish marshes typically with smooth cordgrass 

shoreline fringes and saltmeadow cordgrass dominating just inshore. The saltmeadow 

cordgrass marsh often includes some or all of the following species: common reed, hog 

cane, chairmaker’s bulrush, saltmarsh bulrush, cattail, eastern baccharis, marshelder, 

and sea-ox-eye daisy. The intermediate marsh includes the above listed species, with 

increasing dominance by black rush and saltmarsh bulrush in the intertidal zone. Other 

commonly occurring species within the intermediate marsh communities include hog 

cane, chairmaker’s bulrush, California bulrush, and cattail. 

The coastal fresh marsh community occurs in tidal and non-tidal areas on the coastal 

plain with a salinity range of 0-0.5 parts per thousand (Stutzenbaker,1999). This habitat 

intergrades with the intermediate marsh along tidally influenced canals and bayous that 

exchange with more saline water bodies such as the GIWW. A large section of coastal 

fresh marsh, with exception of upland levees and open water areas, occurs north of the 

GIWW. Intermediate marsh species occur more commonly along canals and bayous in 

close proximity to the GIWW. Salt meadow cordgrass is the dominant plant species in 

this community with rice cutgrass, yellow bristle grass, cattail, California bulrush, fall 

panicum, saltmarsh bulrush, Olney bulrush, rattlebox, bigpod sesbania, seedbox, 

swamp smartweed, white waterlily, lotus, pennywort, and watergrass also occurring. Big 

Hill Bayou and most of the canals are bordered by bands of fresh marsh species such 

as common reed, giant cutgrass, cattail, dwarf spikerush, and California bulrush. 

Typical Palustrine Emergent Wetland 

This community classification includes natural, as well as man-made wetlands resulting 

from hydrologic modifications. Herbaceous wetlands occur within existing ROWs and 

cattle grazing pastures which are temporarily to seasonally flooded. These areas are 

common and vary in size from <0.01 acre to >1 acre. Many of the herbaceous species 

listed in the coastal emergent marsh section (above) are represented in this community 

in varying combinations and dominance. Commonly encountered plant species in this 

habitat include Gulf coast spikerush, dwarf spikerush, slender spikerush, soft-stem rush, 

 J-7 Appendix J 
pine barren flatsedge, green flatsedge, rusty flatsedge, bushy bluestem, dallisgrass, 

dotted smartweed, water primrose, swamp smartweed, and maidencane. 

Herbaceous Agricultural Wetlands 

This habitat is typically associated with active rice or crawfish production. These 

communities are similar to other palustrine emergent wetlands. Jungle rice, smart 

weed, and various spike rushes are normally the dominant vegetation. 

Coastal Scrub/Shrub Wetlands 

Coastal scrub/shrub marsh communities, associated with coastal emergent marsh, are 

often dominated by saltmeadow cordgrass and shrubby species including wax-myrtle, 

Iva fructescens, marshelder, sea-ox-eye daisy, Carolina wolf-berry, rattlebox, and 

common reed. 

Typical Palustrine Scrub/Shrub Wetlands 

This classification represents several community variations. The most common 

variation includes many of the plants listed in the emergent wetland section above, but 

also includes shrubby species such as bramble, marshelder, saplings (usually water 

oak, red maple, and sweetgum) and/or Chinese tallow. Other areas with the 

scrub/shrub wetland classification are sites in various states of regrowth in areas of 

disturbance. These areas often contain mixes of scrub/shrub sapling species listed 

above, pine, waxmyrtle, and other plants common to the surrounding area. 

Scrub Shrub Agricultural Wetlands 

This habitat includes wetlands that have developed in fallow rice fields and wet cattle 

pastures. Vegetation types are similar in community structure to other scrub shrub 

wetlands, and are typically dominated by sesbania, Chinese tallow, and black willow. 

Bottomland Hardwood Wetlands 

Bottomland hardwood wetland communities occur along the larger streams and rivers 

and are characterized by overcup oak, laurel oak, willow oak, green ash, sweetgum, 

American hornbeam, deciduous holly, cedar elm, Texas sugarberry, red maple, and 

hawthorn. Shrub species commonly associated with this community include the above 

listed species and indigo bush, swamp cyrilla, poison ivy, Drummond sesbania, 

dogwood, and Sebastian bush. Common woody vines include wooly Dutchman’s pipe, 

American buckwheat vine, common greenbrier, supplejack, cross vine, Virginia creeper, 

sweet grape, and Kentucky wisteria. Some of the local variations in bottomland 

hardwood communities within the project area might include American hornbeam, water 

 J-8 Appendix J 
oak, blackgum, and sweetgum on ridges between sloughs and swamps, with Carolina 

ash, red maple, American snowbell, and laurel oak dominating on flats between ridges. 

Some flats support extensive populations of dwarf palmetto. 

Species dominance in the bottomland hardwood wetland communities is highly varied, 

from highly vegetatively diverse communities to much less complex stands of overstory 

species like red maple or sweetgum. 

Swamp 

Cypress tupelo swamp communities are restricted primarily to wetlands associated with 

the banks and islands of the larger rivers and bayous in the area (e.g., in the Bayou 

Nezpique and the Bayou Des Cannes riparian zones). The most extensive swamp 

communities occur in association with bottomland hardwood wetlands. Cypress tupelo 

swamp communities often include some or all of the following species: bald cypress, 

water tupelo, swamp privet, water elm, Carolina ash, water locust, and common 

buttonbush. Other commonly encountered species include summersweet clethra, water 

willow, scarlet rosemallow, corkwood, sweetbells leucothoe, possumhaw viburnum, 

cupseed, and decumaria vine. Swamp community composition variations include 

wetlands dominated by sweetgum and/or red maple. 

Table 3 – Representative Plant Species by Wetland Type

Wetland Plant Species Stratum Indicator Status1

Agrostis sp. Herbaceous - 

Agrostis stolonifera Herbaceous FACW 

Alternanthera philoxeroides Herbaceous OBL 

Althaea officinalis Herbaceous NI 

Ambrosia altissima Herbaceous FACU 

Ambrosia trifida Herbaceous FAC 

Andropogon glomeratus Herbaceous FACW+ 

Andropogon virginicus Herbaceous FACArundinaria gigantea Herbaceous FACW 

 J-9 Appendix J 
Table 3 – Representative Plant Species by Wetland Type

Wetland Plant Species Stratum Indicator Status1

Aster dumosus Herbaceous FAC 

Aster laevis Herbaceous UPL 

Aster paludosus Herbaceous FACW 

Axonopus affinis Herbaceous FACW+ 

Axonopus fissifolius Herbaceous FACWBacopa monnieri Herbaceous OBL 

Care sp. Herbaceous - 

Centella asiatica Herbaceous FACW 

Centella erecta Herbaceous FACW 

Chasmanthium latifolium Herbaceous FACCircium vulgare Herbaceous FAC 

Cladium mariscus Herbaceous OBL 

Cynodon dactylon Herbaceous FACU 

Cyperus articulatus Herbaceous OBL 

Cyperus sp. Herbaceous - 

Cyperus virens Herbaceous FACW+ 

Dichanthelium acuminatum Herbaceous FAC 

Dichanthelium scoparia Herbaceous FACW 

Digitaria ciliaris Herbaceous NI 

Distichlis spicata Herbaceous FACW+ 

Eleocharis equisetoides Herbaceous FAC 

Eleocharis baldwnii Herbaceous OBL 

Eleocharis ovata Herbaceous OBL 

 J-10 Appendix J 
Table 3 – Representative Plant Species by Wetland Type

Wetland Plant Species Stratum Indicator Status1

Eleocharis palustris Herbaceous OBL 

Eleocharis parvula Herbaceous OBL 

Eleocharis vivipara Herbaceous OBL 

Eupatorium capillifolium Herbaceous FACU 

Eupatorium compositifolium Herbaceous FACFragaria virginiana Herbaceous FACFrimbristylis sp. Herbaceous FAC 

Gallium trifidium Herbaceous NI 

Geranium carolinianum Herbaceous NL 

Gnaphalium chilense Herbaceous FACHibiscus aculeatus Herbaceous FACW 

Hydrocotyle bonariensis Herbaceous FACW 

Hydrocotyle umbellata Herbaceous OBL 

Hygrophila polysperma Herbaceous OBL 

Iris prismatica Herbaceous OBL 

Iris virginica Herbaceous OBL 

Juncus effuses Herbaceous FACW+ 

Juncus interior Herbaceous FACU 

Juncus roemerianus Herbaceous OBL 

Ludwigia repens Herbaceous OBL 

Lygodium japonica Herbaceous FAC 

Nothoscordum bivalve Herbaceous FAC 

Osmunda regalis Herbaceous OBL 

 J-11 Appendix J 
Table 3 – Representative Plant Species by Wetland Type

Wetland Plant Species Stratum Indicator Status1

Panicum repens Herbaceous FACWPaspalum setaceum Herbaceous FAC 

Paspalum sp. Herbaceous - 

Paspalum urvillei Herbaceous FAC 

Phalaris angusta Herbaceous FACW+ 

Phragmities australis Herbaceous FACW 

Phyla notiflora Herbaceous FACW 

Plantago cordata Herbaceous OBL 

Plantago major Herbaceous FAC+ 

Poa annua Herbaceous FAC 

Polygonum amphibium Herbaceous OBL 

Polygonum hydropiperodies Herbaceous OBL 

Polygonum pensylvaniaicum Herbaceous FACW 

Polygonum punctatum Herbaceous FACW+ 

Polypogon monspeliensis Herbaceous FACW 

Pontederia cordata Herbaceous OBL 

Potomogeten sp. Herbaceous OBL 

Ptilimnium capillaceum Herbaceous FAC 

Ptilimnium sp. Herbaceous - 

Ranunculus acris Herbaceous FAC 

Ranunculus alterniflora Herbaceous OBL 

Ranunculus marginata Herbaceous FAC 

Ranunculus muricatus Herbaceous FACW 

 J-12 Appendix J 
Table 3 – Representative Plant Species by Wetland Type

Wetland Plant Species Stratum Indicator Status1

Ranunculus parviflorus Herbaceous FAC 

Rhynchospora sp. Herbaceous - 

Rumex crispus Herbaceous FAC 

Sabal minor Herbaceous FACW 

Saccharum alopecuroides Herbaceous FAC 

Saccharum giganteum Herbaceous FACW 

Sagitaria latifoila Herbaceous OBL 

Sagittaria graminea Herbaceous OBL 

Sagittaria latifolia Herbaceous FAC-OBL 

Sanguinaria canadensis Herbaceous NI 

Schoenoplectus californicus Herbaceous OBL 

Schoenoplectus pungens Herbaceous OBL 

Scirpus pungens Herbaceous OBL 

Scirpus tabernaemontani Herbaceous OBL 

Senecio glabellus Herbaceous FACW+ 

Senecio vulgaris Herbaceous FACU 

Setaria glauca Herbaceous FAC 

Solidago canadensis Herbaceous FACU 

Solidago sp. Herbaceous - 

Sorghum halepense Herbaceous OBL 

Spartina cynosuroidies Herbaceous OBL 

Spartina patens Herbaceous FAC 

Sporobolus indicus Herbaceous FACU+ 

 J-13 Appendix J 
Table 3 – Representative Plant Species by Wetland Type

Wetland Plant Species Stratum Indicator Status1

Trasescantia hirsutiflora Herbaceous NL 

Trifolium repens Herbaceous FACU 

Typha latifolia Herbaceous OBL 

Typha sp. Herbaceous OBL 

Verbena brasilinsis Herbaceous FACVerbena hastata Herbaceous FAC 

Vicia ludovicidana Herbaceous FACU 

Vicia sativa Herbaceous FACU 

Viola peditifida Herbaceous FACU 

Zizanium aquatica Herbaceous OBL 

Acer rubrum Sapling FAC 

Celtis laevigata Sapling FACW 

Fraxinus pennsylvanica Sapling FACW 

Ligustrum sinense Sapling FAC 

Liquidambar styracifola Sapling FAC+ 

Pinus taeda Sapling FAC 

Quercus nigra Sapling FAC 

Quercus phellos Sapling FACWSalix nigra Sapling OBL 

Sambucus canadensis Sapling FACWSapium sebiferum Sapling FAC 

Ulmus americana Sapling FACW 

Baccharis angustifolia Shrub FACW+ 

 J-14 Appendix J 
Table 3 – Representative Plant Species by Wetland Type

Wetland Plant Species Stratum Indicator Status1

Baccharis halimifolia Shrub FAC 

Cephalanthus occidentalis Shrub OBL 

Halesia diptera Shrub FAC 

Ilex vomitoria Shrub FAC 

Iva frutescens Shrub FACW 

Ligustrum sinense Shrub FAC 

Ligustrum vulgare Shrub UPL 

Myrica cerifera Shrub FAC+ 

Rosa laevaigata Shrub NL 

Rubus strigosis Shrub FAC 

Rubus trivialis Shrub FAC 

Sabal minor Shrub FACW 

Sambucus canadensis Shrub FACWSasbania drummondii Shrub FACW 

Viburnum dentatum Shrub FAC 

Acer rubrum Tree FAC 

Carpinus caroliniana Tree FAC 

Celtis laevigata Tree FACW 

Crataegus mollis Tree FAC 

Crataegus viridis Tree FACW 

Fraxinus pennsylvanica Tree FACW 

Gleditsia triacanthus Tree FACIlex decidua Tree FACW- 

 J-15 Appendix J 
Table 3 – Representative Plant Species by Wetland Type

Wetland Plant Species Stratum Indicator Status1

Liquidambar styraciflua Tree FAC+ 

Nyssa sylvatica Tree FACW 

Pinus taeda Tree FAC 

Planaera aquatica Tree OBL 

Quercus lyrata Tree OBL 

Quercus nigra Tree FAC 

Quercus phellos Tree FACWQuercus virginiana Tree FACU+ 

Salix nigra Tree FAC 

Sapium sebiferum Tree FAC 

Taxicodium disticium Tree OBL 

Ulmus Americana Tree FACW 

Vitis rotundifolia Vine FAC 

Aeschynomene indica Vine FACW 

Ampelopsis arborea Vine FAC 

Berchemia scandens Vine FACW 

Lonicera japonica Vine FAC 

Mikania scandens Vine FACW+ 

Smilax rotundafolia Vine FAC 

Smilax sp. Vine - 

Toxicodendron radicans Vine FAC 

1 Indicator Statuses (Resource Management Group, Inc. 1994): FAC = Facultative (equally likely to occur in 

wetlands and non-wetlands, 34%-66% probability); FACU = Facultative Upland (67% - 99% probability to 

occur in non-wetlands, 1%-33% probability in wetlands); FACW = Facultative Wetland (estimated 67% - 

99% probability to occur in wetlands); NI = No Indicator (insufficient information available to determine an 

indicator status); NL = not-listed (may be because, OBL = Obligate Wetland (occurs with an estimated 99% 

 J-16 Appendix J 
probability in wetlands); and UPL = Obligate Upland (>99% probability of occurring in nonwetlands in this 

region; may occur in wetlands in other regions). If a species doesn't occur in wetlands in any region, it is not 

included in Resource Management Group, Inc. (1994). 

3.0 MITIGATION APPROACH 

Table 1 outlines the approximate delineated acreage of each wetland community 

expected to be: · 

• Temporarily affected during construction and restored which would not result in a 

permanent loss of habitat; and 

• Permanently (i.e., for at least the life of the project) affected by construction and 

operation of the pipeline. 

Temporary impacts include pipeline construction through waterbodies, coastal emergent 

marsh, herbaceous wetland (palustrine emergent), and scrub/shrub wetlands and 

temporarily disturbed construction areas (e.g., laydown areas, staging areas). These 

areas will be graded and restored to pre-construction conditions, as applicable. 

Wetlands in temporarily affected sites will be allowed to revegetate, restoring wetland 

function. Permanent impacts include pipeline interconnect sites, permanent access 

roads, and the removal of forested wetlands. Where possible, construction techniques 

like horizontal directional drilling (HDD) will be implemented to avoid and/or minimize 

impacts. In addition, extensive use of HDD technology to avoid impacts to 

watercourses or sensitive areas and alternative pipeline routes involving additional 

mileage (discussed in Resource Report 10) were evaluated to minimize impacts. 

3.1 Mitigation for Temporary Impacts 

KMLP proposes to mitigate areas of temporary impact through restoration of the 

affected areas at a 1:1 ratio according to the FERC (2003a) Wetland and Waterbody 

Construction and Mitigation Procedures (Procedures). These procedures, and the 

proposed mitigation implementation plans, include: 

• Trench breakers will be installed to prevent the pipeline from draining wetlands; 

• A permanent slope breaker will be installed at the base of slopes for gradients 

steeper than five percent; 

• No fertilizer, lime, or mulch will be applied to wetlands, unless instructed in 

writing by the appropriate state agency; 

 J-17 Appendix J 
• KMLP will consult with the appropriate state agency to develop a project specific 

wetland restoration plan; 

• Until a project-specific management plan is implemented, KMLP will revegetate 

construction ROW utilizing seed mixes, application rates, and planting dates 

obtained from the local soil conservation authority [in upland areas]; 

• KMLP will ensure that disturbed wetland areas are successfully revegetate with 

wetland herbaceous or woody species; and 

• KMLP will remove temporary sediment barriers between wetlands and uplands 

once uplands have been stabilized. 

In addition, although the proposed KM Louisiana Pipeline does not expect to impact any 

oyster habitat, KMLP will compensate the state of Louisiana according to the Louisiana 

Department of Wildlife and Fisheries (LDWF) established compensation rates for 

impacts to water bottoms on public oyster seed grounds, public oyster seed 

reservations, and public oyster tonging areas (LDWF 2003). 

3.2 Mitigation for Permanent Impacts 

Construction of the KM Louisiana Pipeline will permanently affect approximately 30.9 

acres of wetlands based on environmental surveys (Table 1). However, this acreage 

estimate is not based on USACE jurisdictional determinations and is not considered 

final. Once the survey information is verified by the USACE, KMLP will implement a 

mitigation plan that outlines mitigation components in detail. Mitigation options being 

considered include wetland creation and restoration projects, wetland preservation, inlieu-fee mitigation, and mitigation banking. KMLP does not expect to permanently 

impact any oyster habitat. 

3.3 Goals and Objectives 

The goal of wetland mitigation is to ensure no net loss of wetland functional value for 

the wetlands affected by the proposed Project. For the proposed project, this goal will 

be accomplished through: 

• Wetland creation and restoration project(s); 

• Wetland preservation; 

• Mitigation banking; 

 J-18 Appendix J 
• In-lieu-fee mitigation; or 

• A combination of some or all of these options. 

4.0 WETLAND ACREAGE REQUIRING MITIGATION 

Table 1 provides an approximation of acreage requiring mitigation. USACE 

jurisdictional determination for the pipeline and terminal has not been completed, and 

the values listed in Table 1 do not necessarily reflect the actual jurisdictional wetlands, 

as verified by the USACE, that will require mitigation. 

5.0 MITIGATION OPTIONS 

The KMLP Draft Aquatic Resource Mitigation Plan explores four mitigation options to 

mitigate for permanent wetland impacts: 

• Wetland restoration; 

• Wetland preservation; 

• Mitigation banking; and 

• In-lieu-fee mitigation. 

KMLP is currently exploring these options and will not finalize the mitigation 

components until the wetland types and acreages identified during the wetland 

delineation have been verified and approved by the USACE. 

5.1 Wetland Creation and Restoration 

KMLP is currently exploring several possibilities for wetland creation and restoration. A 

representative of the U.S. Fish and Wildlife Service (USFWS), Sabine National Wildlife 

Refuge has been contacted to determine whether there are potential wetland creation or 

restoration sites within or near the refuge (Voros 2006). The Sabine National Wildlife 

Refuge is directly adjacent to Leg 1 of the KM Louisiana Pipeline and would be an ideal 

location for mitigating wetland impacts associated with this project. In addition to the 

USFWS, private lands along the route are currently being identified that may serve as 

potential wetland creation or restoration sites. It is the goal of KMLP to identify wetland 

creation and restoration sites that are in-kind and as close as possible to the actual 

wetlands being mitigated. 

Several Coastal Wetlands Planning, Protection, and Restoration Act (CWPPRA) 

projects were identified in the vicinity of the proposed project (see Resource Report 8 – 

 J-19 Appendix J 
Land Use, Recreation, and Aesthetics). KMLP investigated whether it could work with 

any of these projects to achieve its mitigation goals. It was discovered that the 

organization of these projects precludes the use of additional funds once the projects 

have been initiated (Clark 2006). 

5.2 Mitigation Banking 

In 1995, the Federal Guidance on the Establishment, Use and Operation of Mitigation 

Banks (Banking Guidance) was issued. Consistent with that guidance, KMLP may 

purchase mitigation credits from an approved bank. Mitigation banking instruments are 

reviewed and approved by an interagency Mitigation Banking Review Team (MBRT). 

The MBRT ensures that the banking instrument appropriately addresses the physical 

and legal characteristics of the bank and how the bank will be established and operated 

(e.g., classes of wetlands and/or other aquatic resources proposed for inclusion in the 

bank, geographic service area where credits may be sold, wetland classes or other 

aquatic resource impacts suitable for compensation, methods for determining credits 

and debits). The bank sponsor is responsible for the operation and maintenance of the 

bank during its operational life, as well as the long-term management and ecological 

success of the wetlands and/or other aquatic resources, and must provide financial 

assurances (USEPA 2000). 

KMLP has initiated contact with the USACE, New Orleans District to determine if any of 

the mitigation banks listed on their website would be in the vicinity of the project and 

have available mitigation credits (Barlow 2006; Breaux 2006). KMLP also has 

contacted USFWS in Lafayette, Louisiana to investigate mitigation banking 

opportunities (Holland 2006). 

5.3 Wetland Preservation 

The USACE and U.S. Environmental Protection Agency (USEPA) agree that if on-site 

compensatory mitigation is not practicable, off-site compensatory mitigation should be 

undertaken in the same geographic area if practicable (i.e., in close proximity and, to 

the extent possible, the same watershed). They have also agreed that generally, inkind compensatory mitigation is preferable to out-of-kind and that mitigation banking 

may be an acceptable form of compensatory mitigation. The agencies recognize the 

general preference for restoration over other forms of mitigation, given the increased 

chance for ecological success (USEPA 2000). However, if wetland creation, 

 J-20 Appendix J 
restoration, or mitigation banking options are not available within an acceptable distance 

from the project, wetland preservation may be a desirable alternative. In many areas, 

certain wetland types are becoming fragmented to the point that they eventually cannot 

perform as functional wetlands or serve as a viable habitat for wetland species. In 

these cases, where the destruction of a particular wetland type is imminent based on 

current trends, preservation may be as ecologically beneficial as the other 

compensatory mitigation options discussed. 

KMLP has discussed wetland preservation opportunities with LDWF (Myers 2006) and 

is in the process of exploring possibilities with conservation organizations including The 

Nature Conservancy and Sierra Club. KMLP also has discussed the role that The Trust 

for Public Land may play in facilitating this process (Schmidt 2006). The Trust for Public 

Land is a non-profit organization that acts as an intermediary between willing sellers 

and typically a public entity to purchase land for public use. 

5.4 In-lieu-fee Mitigation 

In-lieu-fee, fee mitigation, or other similar arrangements, wherein funds are paid to a 

natural resource management entity for implementation of either specific or general 

wetland or other aquatic resource development project, are not considered to meet the 

definition of mitigation banking because they do not typically provide compensatory 

mitigation in advance of project impacts. Moreover, such arrangements do not typically 

provide a clear timetable for the initiation of mitigation efforts. The USACE, in 

consultation with the other agencies, may find circumstances where such arrangements 

are appropriate so long as they meet the requirements that would otherwise apply to an 

offsite, prospective mitigation effort and provide adequate assurances of success and 

timely implementation. In such cases, a formal agreement between the sponsor and 

the agencies, similar to a mitigation bank, is necessary to define the conditions under 

which its use is considered appropriate. In-lieu-fee agreements may be used to 

compensate for impacts authorized by a USACE individual permit if the in-lieu-fee 

arrangement is developed, reviewed, and approved using the process established for 

mitigation banks in the Banking Guidance. MBRTs should review applications from 

such in-lieu-fee sponsors to ensure that such agreements are consistent with the 

Banking Guidance (USEPA 2000). 

KMLP will only consider in-lieu-fee mitigation if compensatory mitigation, mitigation 

banking, or wetland preservation are not practicable for mitigating wetland impacts 

associated with this project. 

 J-21 Appendix J 
5.5 Location(s) for Mitigation Efforts 

Mitigation options selected will be located in the Sabine Lake, Lower Sabine, Lower 

Calcasieu, Upper Calcasieu, Mermentau, and Mermentau Headwaters watersheds. 

This rationale complements the goal of Section 404(b)(1) guidelines of no net loss of 

function and value. 

5.6 Mitigation Acreage Considerations 

Wetland acreages requiring mitigation will be quantified and presented by habitat type 

following USACE determination of the wetland locations identified during the field 

studies. 

6.0 PIPELINE MONITORING PLAN 

6.1 Temporary Impacts 

Monitoring the success of the wetland restoration for temporarily affected wetlands will 

be conducted for three years or until the revegetation is considered to be successful as 

described in FERC’s Procedures (FERC 2003a). Revegetation shall be considered 

successful if the herbaceous and/or woody species is at least 80 percent areal coverage 

of native wetland vegetation. KMLP, and/or its agents, will conduct monitoring in these 

areas. 

6.2 Additional Monitoring Plans 

Areas within the pipeline construction corridor and associated work areas will be 

restored to pre-project contours. Pre- and post-construction elevation surveys will be 

conducted. Elevation survey results will be submitted to the USACE within 90 days 

after completion of pipeline installation. Additional soil from off site may be brought into 

areas containing highly organic soils susceptible to high erosion rates. 

Aerial photography with Geographic Information System (GIS) analysis will be used to 

monitor the entire pipeline construction corridor and an additional 200- meter buffer 

zone (100 meters paralleling each side of the construction corridor). The following 

GIS/Remote Sensing method and standard will be used: The pipeline corridor will be 

monitored by pre- and post-construction aerial photography (taken 12 months after 

construction completion to allow for vegetative regrowth) at a scale of 1:4800 or 1 inch 

to 400 feet. GIS and Remote Sensing techniques will be used to conduct an analysis of 

 J-22 Appendix J 
change to determine the amount of vegetated marsh impacted by pipeline construction 

activities. 

Monitoring reports will be submitted that include at a minimum: (1) a pre-project GIS 

analysis assessing the existing emergent marsh to open water ratio, in acres, within the 

permitted corridor (which includes the construction corridor and the 200 meter buffer 

zone); (2) a post-project GIS analysis assessing the emergent marsh to open water 

ratio, in acres, within the permitted corridor (which includes the construction corridor and 

the 200-meter buffer zone); (3) Ortho corrected imagery covering the construction 

corridor and buffer zone, maximum of 6-inch pixel size and Color Infra-red imagery, 

about 2 meter spatial accuracy; and (4) all vector deliverables to be in Arcview 

Shapefile format with Federal Geographic Data Committee (FGDC) compliant metadata 

and all raster imagery in GeoTIFF format with FGDC compliant metadata. A binary 

classification system will be used consisting of open water and vegetated areas. The 

classified data will meet or exceed 90 percent attribute accuracy as determined by 

industry standard and verified by statistically valid ground truth sampling techniques; 

this may include Global Positioning System based ground surveys. Monitoring reports 

will be submitted to the USACE, detailing the results from the pre- and post-GIS 

analysis and the above referenced data sets, within 90 days after completion of the 12-

month interval between the pre- and post-construction analysis. 

In addition, pursuant to NMFS (2006) recommendations, monitoring of wetlands 

considered to be Essential Fish Habitat (EFH) will document project impacts as follows: 

• The monitoring primarily would be photographic in nature, with photos being 

taken from on the ground at work sites; 

• It would occur pre-construction, immediately post-construction, and one growing 

season post-construction with photos of all work sites; and 

• Photos would be taken every 500 feet (pictures taken in both directions) with the 

location recorded on GPS to allow a return to the exact site, and the exact 

location and direction of the photo being recorded in a tabular form and 

referenced to an aerial photo documenting photo numbers. 

Wetlands considered EFH are listed in Table 3-1 in Resource Report 3 - Fish, Wildlife 

and Vegetation. 

 J-23 Appendix J 
7.0 MAINTENANCE AND CONTINGENCY PLAN 

7.1 Maintenance 

Maintenance to address temporary impacts as well as long-term vegetation 

management of the pipeline ROW will be conducted by KMLP according to the FERC 

regulations summarized below. 

• Vegetative maintenance will not be conducted over the entire width of the ROW 

in wetlands. Rather a corridor centered on the pipeline and up to 10 feet wide 

will be maintained in an herbaceous state. Trees within 15 feet of the pipeline 

greater than 15 feet in height may be cut and removed from the permanent ROW 

in accordance with the FERC guidelines in order to protect the integrity of the 

pipeline operations over time (FERC 2003a). 

• Herbicides will not be used within 100 feet of a wetland unless directed to do so 

by the appropriate state agency (FERC 2003a). 

Variances from FERC’s Upland Erosion Control, Revegetation and Maintenance Plan 

(Plan) (FERC 2003b) and Procedures (FERC 2003a) that KMLP has requested be 

considered are described in Resource Report 2 – Water Use and Quality. 

7.2 Contingency Plan 

If revegetation success is not achieved after three years, the area along the pipeline 

ROW that has not revegetated will have the topography checked by a land survey to 

determine if long-term surface grading impacts remain from construction. Proper grade 

will be restored if necessary, and the area will be revegetated and monitored for another 

year, as before. If revegetation is not successful after an additional year of monitoring, 

a supplemental planting will be conducted. 

7.3 Invasive Species Control Plan 

7.3.1 Introduction 

Chinese Tallow, a noxious invasive species of tree commonly found throughout the 

Project area (USGS 2000; USDA 2006), is likely to become established in the disturbed 

area of the ROW following restoration, if not controlled. As part of its Implementation 

Plan, KMLP will prepare a plan for the control of Chinese Tallow and other invasive 

species, if identified. Control of invasive species would allow native species to become 

 J-24 Appendix J 
re-established. The plan would be initiated after right-of-way restoration and in 

consultation with landowners. Key elements of the plan would include: 

• Training field personnel in the identification and control of the Chinese Tallow 

Tree; 

• Providing field personnel with the applicable registration for the purchase of 

regulated herbicides and training in their proper handling and application; 

• Controlling the spread of older Chinese Tallow Trees by mechanical cutting and 

chemical treatment; 

• Removing young Chinese Tallow Tree saplings by hand or machine; and 

• Documenting and reporting control activities and the volumes of herbicide used. 

7.3.2 Logistics 

Field personnel qualifications 

Invasive plant control field personnel will be trained to identify Chinese tallow and other 

invasive species, and perform the prescribed mechanical and chemical treatment 

procedures. Additionally, these individuals will have the applicable training and 

registration to purchase, handle, and apply regulated herbicides used for control. An 

accompanying safety and health plan will be developed and implemented in conjunction 

with this control plan. 

Site access 

After initial restoration is completed along the pipeline ROW, pipe yards and extra 

workspaces, KMLP will contact the affected landowners and/or managers to gain 

permission to initiate the Chinese tallow and other invasive species control on their 

property. 

7.3.3 Chinese Tallow Control 

The Chinese tallow control plan requires mechanical (cutting and hand pulling) and 

potentially chemical treatment to effectively manage while providing the opportunity for 

native and other preferred species to establish after pipeline construction is completed. 

Chinese tallow mechanical cutting 

Field personnel will cut any remaining Chinese tallow trees found within the former 

construction areas at ground level with power equipment or manual saws (SE-EPPC 

2005). Debris will be gathered and transported to an approved offsite disposal facility. 

 J-25 Appendix J 
Chinese tallow chemical treatment 

As cutting older trees leads to stump and root suckering, cutting will not provide 

satisfactory control unless stumps are treated with chemicals (LSU 2005). It is common 

practice to use diesel or another oil as an application medium for several herbicides; 

however, KMLP will not use diesel or another oil since the pipeline route has a 

significant acreage of wetlands and open-water habitats. For cut stumps, one of the 

following chemical applications will be used: 

• Glyphosate (common trade names include Ranger,® Rodeo,® and Roundup 

Ultra,®): Horizontally cut stems at or near ground level. Immediately apply a 50 

percent solution of glyphosate and water to the cut stump, covering the outer 20 

percent of the stump (SE-EPPC 2005). Since glyphosate is nonselective, it is 

very important to protect the surrounding desirable plants. Thus, a sponge or 

similar discrete application method will be used to apply the glyphosate solution. 

Also, the water mixed with glyphosate must be free of dirt as this herbicide binds 

tightly to soil clay and organic matter; otherwise the effectiveness of the 

application is reduced. 

• Triclopyr (common trade names include Remedy® and Grandstand®): 

Horizontally cut stems at or near ground level. Immediately apply a 50 percent 

solution of triclopyr and water to the cut stump, covering the outer 20 percent of 

the stump (SE-EPPC 2005). In areas where desirable grasses are growing 

under and around Chinese tallow, SE-EPPC (2005) reports that triclopyr can be 

used without non-target damage. 

Chinese tallow sapling control 

Chinese tallow is effectively controlled by removal of young seedlings; hand or machine 

pulling of seedlings and saplings provides excellent control (LSU 2005). Plants should 

be pulled as soon as they are large enough to grasp, but before they produce seeds. 

Seedlings are best pulled after a rain when the soil is loose. The entire root must be 

removed since broken fragments may resprout (SE-EPPC 2005). 

Chinese tallow control frequency 

As Chinese tallow is a successful invasive species, there is always a potential for the 

plant to establish. However, the goal of this control program is to allow native and other 

desirable plants sufficient opportunity to establish along the construction ROW and 

other extra workspaces. Therefore, KMLP will control Chinese tallow growth in areas of 

 J-26 Appendix J 
the construction ROW for 3 years after completion of the pipeline system. The following 

describes the control procedures to be used for a given year. 

Year 0 (during construction demobilization): Cutting including off-site debris disposal 

followed with chemical treatment as described above will be conducted during 

construction demobilization. KMLP will record the herbicide(s) volume used during this 

effort. 

Year 1 (late-summer): Reports indicate that spring herbicide application may not be 

successful, and that to translocate (i.e., transporting the herbicide into the root system 

by natural circulation within the plant) the herbicide into the plant most effectively, late 

summer to early fall applications should be employed (TNC 2005). KMLP will apply 

chemical (herbicide) treatment to stumps and roots exhibiting sprouts. Also, saplings 

will be removed by pulling as described above. KMLP will record the herbicide(s) 

volume used during this effort. 

Year 2 (late-summer): KMLP will apply chemical (herbicide) treatment to stumps and 

roots exhibiting sprouts. Also, saplings will be removed by pulling as described above. 

KMLP will record the herbicide(s) volume used during this effort. 

Year 3 (late-summer): KMLP will apply chemical (herbicide) treatment to stumps and 

roots exhibiting sprouts. Also, saplings will be removed by pulling as described above. 

KMLP will record the herbicide(s) volume used during this effort. KMLP will present a 

report to the USACE and FERC documenting the control activities conducted since 

construction demobilization, including the volume by year of herbicide(s) used. 

8.0 LITERATURE CITED 

Barlow, J. 2006. Personal communication. Telephone conversation record between 

James Barlow (USACE, New Orleans District, 504-862-2250) and Matt Comeaux 

(AMEC Paragon), August 24, 2006. 

Breaux, B. 2006. Personal communication. Telephone conversation record between 

Brian Breux (USACE, New Orleans District, 504-862-1938) and Matt Comeaux 

(AMEC Paragon), August 24, 2006. 

Clark, D. 2006. Personal communication. Telephone conversation record between 

Darryl Clark (USFWS, Lafayette, 337-291-3111) and Matt Comeaux (AMEC 

Paragon), August 24, 2006. 

 J-27 Appendix J 
Daigle, J.J., G.E. Griffith, G.E., J.M. Omernik, J.M., P. Faulkner, P., R.P. McCulloh, 

R.P., L.R. Handley, L.R., L.M. Smith, L.M., and S.S. Chapman, S.S. 2006. 

Ecoregions of Louisiana (color poster with map, descriptive text, summary tables, 

and photographs): Reston, Virginia, U.S. Geological Survey (map scale 

1:1,000,000). (Pre-publication review copy provided by LDWF May 17, 2006). 

FERC. 2003a. Wetland and Waterbody Construction and Mitigation Procedures. 

http://www.ferc.gov/industries/gas/enviro/wetland.pdf. Accessed 8/25/2006. 

FERC. 2003b. Upland Erosion Control, Revegetation and Maintenance Plan. 

http://www.ferc.gov/industries/gas/enviro/uplndctl.pdf. Accessed 8/25/2006. 

Holland, P. 2006. Phone conversations between Patty Holland, USFWS, Lafayette, 

Louisiana and Helen Shumway (AMEC Paragon). August 24 and 25, 2006. 

Louisiana Department of Wildlife and Fisheries 2003. LDWF Compensation Rates For 

Impacts to Water Bottoms on Public Oyster Seed Grounds, Public Oyster Seed 

Reservations, and Public Oyster Tonging Areas. 

http://dnr.louisiana.gov/crm/coastmgt/permitsmitigation/oyster/rate-schedule.pdf. 

Accessed 8/25/2006. 

Louisiana State University Agriculture Center Research and Extension (LSU). 2005. 

Louisiana invasive plants, species: Tridica sebifera (L.) Small. 

http://www.lsuagcenter.com/invasive/chinesetallow.asp. Accessed 3/08/2005. 

Myers, R. 2006. Phone conversation between Randy Myers, The Trust for Public 

Land, and Helen Shumway (AMEC Paragon). August 24, 2006. 

NMFS. 2006. Email from Rick Hartman, NMFS, Baton Rouge, Louisiana, to AMEC 

Paragon. August 14, 2006. 

Resource Management Group, Inc. 1994. National List of Plant Species That Occur in 

Wetlands, Region 6 - South Plains, Oklahoma, Texas, Region 7 - Southwest, 

Arizona, New Mexico. Resource Management Group, Inc., Grand Haven, 

Michigan. 

Schmidt, L. 2006. Phone conversation between Larry Schmidt, LDWF and Helen 

Shumway (AMEC Paragon). August 28, 2006. 

Southeast Exotic Pest Plant Council (SE-EPPC) 2005. Chinese Tallowtree - Southeast 

Exotic Pest Plant Council Invasive Plant Manual. 

http://www.invasive.org/eastern/eppc/SASE.html. Accessed 3/08/2005. 

 J-28 Appendix J 
Stutzenbaker, Charles D. 1999. Aquatic and Wetland Plants of the Western Gulf 

Coast. Texas Parks and Wildlife Press. ISBN 1-885696-31-0. 

The Nature Conservancy (TNC) 2005. Element Stewardship Abstract for Sapium 

sebiferum Chinese tallow-tree, Florida aspen, popcorn tree. 

http://tncweeds.ucdavis.edu/esadocs/documnts/sapiseb.pdf. Accessed 

3/08/2005. 

USEPA (U.S. Environmental Protection Agency). 2000. Federal Guidance on the Use 

of In-Lieu-Fee Arrangements for Compensatory Mitigation under Section 404 of 

the Clean Water Act and Section 10 of the Rivers and Harbors Act. 

http://www.epa.gov/owow/wetlands/pdf/inlieufee.pdf. Accessed 8/26/2006. 

USACE. 1987. Wetlands Delineation Manual. Technical Report Y-87-1, Environmental 

Laboratory, U.S. Army Waterways Experiment Station, Vicksburg, MS. 

USDA (U.S. Department of Agriculture). 2006. Species Profiles -- Chinese Tallow. 

National Agricultural Library, National Invasive Species Information Center. 

http://www.invasivespeciesinfo.gov/plants/chintallow.shtml. Accessed May 2006. 

USGS (U.S. Geological Survey). 2000. Chinese Tallow: Invading the Southeastern 

Coastal Plain. National Wetlands Research Center, Lafayette, LA. 

http://www.nwrc.usgs.gov/factshts/154-00.pdf. Accessed May 2006. 

Voros, D. 2006. Personal communication. Telephone conversation record between 

Don Voros (USFWS, Sabine National Wildlife Refuge, 337-598-2216) and Matt 

Comeaux (AMEC Paragon), August 24, 2006. 

 J-29 Appendix J 
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APPENDIX K 

SEATURTLE CONSTRUCTION GUIDELINES 
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K-1 Appendix K
K-2 Appendix K
K-3 Appendix K
K-4 Appendix K
K-5 Appendix K
K-6 Appendix K
K-7 Appendix K
K-8 Appendix K
K-9 Appendix K
K-10 Appendix K
K-11 Appendix K
K-12 Appendix K
K-13 Appendix K
K-14 Appendix K
K-15 Appendix K
K-16 Appendix K
K-17 Appendix K
K-18 Appendix K
K-19 Appendix K
K-20 Appendix K
APPENDIX L 

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Pipeline Projects. http://www.ferc.gov/industries/gas/ enviro/culresor.pdf. 

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and Lehning, D.W. 1995. WATERSHEDSS: Water, Soil and Hydro-Environmental Decision 

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Perez-Farfante, I. 1969. Western Atlantic shrimps of the genus Penaeus. Fish Bull. 67: 461-591. 

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 Accident and Incident Data. http://ops.dot.gov/stats/IA98.htm 

Renken, R. A. 1998. Ground Water Atlas of the United States, Arkansas, Louisiana, Mississippi, 

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Website. Served by the USGS Patuxent Wildlife Research Center, Laurel, Maryland. 

www.partnersinflight.org. Accessed 2006. 

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 Research Center, Laurel, Maryland. www.partnersinflight.org. Accessed 2006. 

Teal, J.M, and M. Teal. 1969. Life and death of the salt marsh. Little Brown and Company, Boston. 

278 pp. 

Texas Department of Environmental Quality . 2006. An Introduction to the Texas Surface Water Quality 

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WQ_standards_intro.html

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United States Army Corps of Engineers. 2006. Phone conversation between James Little (COE) and 

Jennifer Ward (Entrix) regarding regulatory function of drainage ditches. December 20, 2006. 

United States Army Corps of Engineers. 1987. Wetlands Delineation Manual, Technical Report Y-87-1, 

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MS. 

U.S. Census Bureau. 2005. State and County Quick Facts. http://quickfacts.census.gov/qfd/

U.S. Census Bureau. 2004. 2000 Tiger/Line Data. http://www.census.gov/geo/www/tiger/tiger2k/

tgr2000.html 

U.S. Department of Agriculture (USDA), Farms Services Agency. 2007. Cumulative CPR Enrollment by 

County, FY 2004. http://www.fsa.usda.gov/FSA/webapp?area=home&subject=copr&topic=crpst. Accessed January 2007. 

U.S. Department of Agriculture (USDA). 2006. Personal Communication. Evangeline County FSA 

Office. 

U.S. Department of Agriculture, Soil Survey Division Staff. 1993. Soil Survey Manual. USDA 

Agricultural Handbook 18. U. S. Government Printing Office,Washington, DC. 

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118th Edition. 

U.S. Department of Energy. 2006. Annual Energy Outlook 2006 with Projections to 2030. 

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U.S. Environmental Protection Agency. 2006a. National Priorities List Sites in Louisiana. 

http://www.epa.gov/superfund/sites/npl/la.htm. 

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Ward (ENTRIX) regarding FWS easement lands. January 8, 2007. 

 L-6 Appendix L 
U.S. Fish and Wildlife Service. 2006a. Letter from James Boggs (FWS) Lafayette, Louisiana, to Bob 

Honig, regarding T&E species. May 10, 2006. 

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northlouisiana/. 

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U.S. Fish and Wildlife Service. 2002a. Leatherback Sea Turtle (Dermochelys coriacea) Fact Sheet. 

http://northflorida.fws.gov/SeaTurtles/ Turtle%20FactSheets/leatherback-sea-turtle.htm. 

Accessed April 2003. 

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Accessed April 2003. 

U.S. Fish and Wildlife Service. 2002c. Green Sea Turtle (Chelonia mydas) Fact Sheet. Available online: 

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April 2003. 

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verobeach/Programs/Recovery /vbms4.html. Accessed November 2005. 

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Accessed September 2006. 

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endangered/i/b/sab4a.html. Accessed September 2006. 

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http://www.fws.gov/swlarefugecomplex/sabine/. Accessed September 2006. 

U.S. Fish and Wildlife Service. No date(b). Lacassine National Wildlife Refuge. 

http://www.fws.gov/swlarefugecomplex/lacassine/. Accessed September 2006. 

U.S. Fish and Wildlife Service. No date(c). Bald Eagle. 

http://www.fws.gov/endangered/i/b/msab0h.html. Accessed October, 2006. 

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products/landcover/lulc.html

U.S. Geological Survey. 2006b. 1988 National Wetlands Inventory Data. National Wetlands Research 

Center. http://www.nwrc.usgs.gov/data.htm

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States, Revised April 2003, U.S. Geological Survey website, http://earthquake.usgs.gov/ 

research/hazmaps/products_data/2002/ 2002April03/US/USpga500v4.pdf. Accessed April 2006. 

 L-7 Appendix L 
 

U.S. Geological Survey. 2003. Map: 100+ Years of Land Change for Coastal Louisiana. Map ID 

USGS-NWRC 2003-03-085. USGS National Wetlands Research Center, Lafayette, Louisiana.

U.S. Geological Survey. 1998. Groundwater Atlas of the United States. Arkansas, Louisiana, 

Mississippi. HA 730-F. http://capp.water.usgs.gov/ gwa/ch_f/F-text1.html 

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NCEER and 1998 NCEER/NSF workshop on evaluation of liquefaction resistance of soils. 

Journal of Geotechnical and Geoenvironmental Engineering. 127(4):297-313. 

 L-8 Appendix L 
APPENDIX M 

LIST OF PREPARERS 
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Federal Energy Regulatory Commission

Kochhar, Medha – Project Manager; Alternatives, Geologic Resources, Soils, Water Resources, 

Wetlands, Vegetation, Wildlife and Aquatic Resources, Threatened and Endangered 

Species, Land Use, Recreation, and Visual Resources

 Ph.D., Plant Ecology, 1974, North Carolina State University 

 M.S., Botany, 1968, B.I.T.S., Pilani, India 

 B.S., Biology and Chemistry, 1966, University of Delhi 

Button, Van, T. – Cultural Resources, Socioeconomics 

M.A., Anthropology, 1976, University of Arizona 

 B.A., Anthropology, 1973, Reed College 

Manco, Magdalene – Air Quality and Noise, Reliability and Safety 

 B.S., Environmental Systems Engineering, 2004, Pennsylvania State University 

 

Peconom, John – Water Resources, Wetlands, Vegetation, Wildlife and Aquatic Resources, and 

Threatened and Endangered Species

 B.S., Environmental Biology & Management, 2000, University of California at Davis 

Wisniewski, John – Alternatives 

 B.S. Mineral Economics, 1975, Pennsylvania State University 

ICF International

Barkley, Matt – Cumulative Impacts 

M.A., Organizational Management, 2006, University of Phoenix 

 Certificate of Environmental Management, 2002, Duquesne University 

 B.S., Environmental Resource Management, 1997, Pennsylvania State University 

Crook, Leonard – Alternatives 

M.A., History, 1972, University of Memphis 

 B.A., History and Economics, 1970, University of Memphis 

Fadely, Karen – Geologic Resources, Soils 

 Master of Environmental Management, 2005, Duke University 

 B.S., Biology, 1999, Bucknell University 

Gardiner, James – Proposed Action, Alternatives, Reliability and Safety 

M.S., Chemical Engineering, 1998, University of Bradford, Great Britain 

 B.S., Chemistry, Management and Industry, 1996, University of York, Great Britain 

Messenger, Wendy – Cultural Resources 

 Master of Urban Planning and Policy, 2006, University of Illinois-Chicago 

 B.S., Environmental Design, 2001, Auburn University 

Quick, Polly McWhoter – Cultural Resources 

Ph.D., Anthropology, 1976, Harvard University 

 M.A., Anthropology, 1970, Harvard University 

 B.A., Anthropology, 1968, Radcliffe College 

January 17, 2007 Draft M-1 Appendix M 
Stanwood, Mike – Purpose and Need, Land Use, Socioeconomics 

M.S., Mineral Economics, 1979, Colorado School of Mines 

 B.A., Psychology, 1975, University of Colorado 

Woods, Hova – Public Involvement 

M.P.A., Environmental Policy and Management, 2001, Indiana University 

 B.S., Finance (Science and Technology concentration), 1999, Indiana University 

Wyngarden, Steve – Project Manager 

Master of Environmental Management, 1982, Duke University 

 B.S., Applied Biology, 1980, Georgia Institute of Technology 

Zhang, Lianyang – Geologic Resources, Soils 

Ph.D., Geotechnical Engineering, 1999, Massachusetts Institute of Technology 

 M.S., Civil and Environmental Engineering, 1997, Massachusetts Institute of Technology 

 M.S., Geotechnical Engineering, 1988, Tongji University, China 

 B.S., Naval Architecture and Ocean Engineering, 1985, Shanghai JiaoTong University, China 

ENTRIX Environmental Consultants

De Caro, David – Project Manager 

B.S., Natural Resources Management, 1991, Cook College, Rutgers University 

Jackson, David - Land Use, Recreation, and Visual Resources

 B.S. Environmental Science, Messiah College, 1999

Kirkner, Stephanie - Land Use, Recreation, Visual Resources, Wetlands and Water Resources 

 B.S. Biological Sciences: Marine Biology, University of Maryland, 1998 

Loveday, Trevor – Water Resources

M.S., Biology, 1995, Stephen F. Austin State University 

 B.B.A., Finance, 1990, Baylor University 

Slate, Jennifer – Wetlands, Vegetation, Wildlife and Aquatic Resources, and Threatened and 

Endangered Species

B.S., Marine Biology, Texas A&M University 

 

Wakefield, Jeffrey – Socioeconomics 

Ph.D., Economics, 2001, University of Delaware 

 M.A., Environmental Economics, 1998, University of Delaware 

 M.S., Marine Biology and Biochemistry, 1996, University of Delaware 

 B.S., Biology, 1994, Rochester Institute of Technology 

Ward, Jennifer – Land Use, Recreation, and Visual Resources

 M.S., Resource Economics and Policy, 2006, University of Maine 

 B.A., Mathematics, 2001, University of North Carolina – Asheville 

Willoughby, Craig – Air Quality and Noise 

B.S., Mining Engineering, 1980, University of Missouri – Rolla 

January 17, 2007 Draft M-2 Appendix M 
APPENDIX N 

SUBJECT INDEX 
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abandoned wells, 4-5 

aboveground facility, 1-1, 1-3, 2-5, 2-7, 2-8, 2-9, 

2-10, 2-12, 2-45, 2-46, 3-11, 4-19, 4-29, 4-31, 

4-34, 4-35, 4-43, 4-49, 4-74, 4-75, 4-77, 4-78, 

4-84, 4-94, 4-95, 4-106, 4-114, 4-116, 4-117, 

5-3, 5-4, 5-7, 5-9 

Acadia (Parish, River, Lake), 1-1, 1-2, 2-1, 2-3, 

2-4, 2-6, 2-7, 3-10, 3-12, 4-1, 4-3, 4-4, 4-10, 

4-16, 4-18, 4-38, 4-50, 4-86, 4-87, 4-88, 4-89, 

4-93, 4-114, 4-115, 4-118 

access road, 1-1, 2-1, 2-5, 2-6, 2-7, 2-8, 2-10, 2-

12, 2-46, 2-48, 3-6, 3-11, 4-1, 4-23, 4-29, 4-

31, 4-33, 4-34, 4-35, 4-41, 4-43, 4-49, 4-74, 4-

75, 4-77, 4-90, 4-94, 4-95, 4-107, 4-112, 4-

113, 5-3, 5-7, 5-9, 5-11, 5-15 

accidents, 4-90, 4-116, 4-117, 4-119, 4-123 

Advisory Council on Historic Preservation 

(ACHP), 1-4, 4-93, 5-9 

agriculture, 1-5, 2-13, 2-15, 2-24, 2-44, 2-47, 3-

10, 3-11, 3-12, 3-13, 3-17, 3-18, 3-19, 3-20, 3-

21, 3-22, 3-23, 4-9, 4-10, 4-11, 4-12, 4-13, 4-

14, 4-15, 4-16, 4-20, 4-22, 4-25, 4-34, 4-35, 4-

38, 4-42, 4-43, 4-44, 4-45, 4-46, 4-47, 4-50, 4-

52, 4-71, 4-74, 4-75, 4-77, 4-78, 4-84, 4-86, 4-

87, 4-88, 4-99, 4-100, 4-102, 4-108, 5-7 

air pollutants, 4-10, 4-108, 4-109, 4-110, 4-111, 

4-112, 4-113 

air quality, 1-3, 4-97, 4-102, 4-107, 4-108, 4-109, 

4-111, 4-112, 4-113, 5-9 

alternatives, 1-3, 1-6, 1-7, 2-10, 2-12, 2-13, 2-

15, 2-16, 2-24, 2-25, 3-1, 3-2, 3-3, 3-4, 3-5, 3-

6, 3-7, 3-8, 3-10, 3-11, 3-12, 3-13, 3-14, 3-15, 

3-16, 3-17, 3-18, 3-19, 3-20, 3-21, 3-22, 3-23, 

4-8, 4-27, 4-33, 4-34, 4-35, 4-36, 4-38, 4-39, 

4-41, 4-49, 4-50, 4-62, 4-64, 4-69, 4-113, 5-1, 

5-3, 5-4, 5-5, 5-9, 5-10, 5-14, 5-15 

American Petroleum Institute (API), 2-3, 2-16, 2-

37 

American Society of Mechanical Engineers 

(ASME), 2-16, 2-37 

Ancillary Areas, 2-6, 2-7, 2-10 

ANR Pipeline Company (ANR), 1-5, 2-6, 4-76, 4-

77, 4-87 

Aquatic Resources Mitigation Plan, 4-13, 4-41, 

4-45, 4-50, 4-63, 4-64, 5-3, 5-6, 5-15 

aquifer, 4-16, 4-17 

area of potential effects (APE), 4-93, 4-94, 5-8 

area of probable concern (APC), 4-28 

Bayou Choupique, 2-3, 3-14, 3-17, 4-20, 4-21, 

4-22, 4-25, 4-26, 4-52 

Bayou des Cannes, 2-3, 4-20, 4-21, 4-22, 4-23, 

4-25, 4-26, 4-32, 4-40, 4-50, 4-52, 4-53, 5-2, 

5-14, 5-15 

Bayou Lacassine, 4-20, 4-21, 4-25, 4-52, 4-53 

Bayou Nezpique, 2-3, 3-13, 3-14, 3-20, 3-21, 4-

20, 4-21, 4-22, 4-25, 4-26, 4-32, 4-39, 4-40, 4-

50, 4-52, 4-55 

Bayou Vista, 4-69 

best available control technology (BACT), 4-111 

Best Management Practices (BMPs), 4-27, 4-41, 

4-54, 4-63, 4-71, 5-3, 5-6 

Biochemical oxygen demand (BOD), 4-53 

Biological Assessment (BA), 4-10 

Black Bayou, 1-7, 4-26, 4-35, 4-36, 4-37, 4-52, 

4-81, 4-83, 4-100, 5-7, 5-15 

boring method, 2-34, 2-36, 2-42, 3-14, 3-19, 4-

21, 4-52, 4-53, 4-82, 4-84, 4-91, 4-107, 5-8 

Bridgeline Holdings, L.P., 1-8, 1-9, 2-5, 2-6, 4-

77, 4-87, 4-113 

Calcasieu (Parish, River, Lake), 1-1, 1-2, 1-7, 2-

1, 2-3, 2-4, 2-6, 2-7, 2-42, 2-45, 3-6, 3-10, 3-

12, 3-14, 3-18, 4-1, 4-2, 4-3, 4-4, 4-7, 4-16, 4-

17, 4-18, 4-20, 4-21, 4-22, 4-26, 4-28, 4-32, 4-

36, 4-51, 4-52, 4-54, 4-55, 4-59, 4-62, 4-63, 4-

66, 4-68, 4-69, 4-79, 4-81, 4-82, 4-86, 4-87, 4-

88, 4-89, 4-90, 4-91, 4-100, 4-101, 4-105, 4-

107, 4-114, 4-115, 4-118, 5-3, 5-4, 5-5, 5-15 

Cameron (Parish, River, Lake, Pipeline), 1-1, 1-

2, 2-1, 2-3, 2-4, 2-6, 2-7, 3-4, 3-8, 3-10, 4-1, 

4-4, 4-7, 4-18, 4-36, 4-66, 4-82, 4-86, 4-87, 4-

88, 4-89, 4-100, 4-101, 4-102, 4-104, 4-109, 

4-114, 4-118 

cathodic protection, 2-46, 2-48, 4-121, 4-122 

Certificate of Public Convenience and Necessity 

(Certificate), 1-1, 1-5, 1-8, 3-1, 3-2, 4-1, 4-70, 

4-80, 4-117, 5-10, 5-12, 5-13 

Cheniere Sabine Pass Pipeline (SPP), 3-2, 3-3, 

3-4, 3-6 

Chevron, 1-2, 3-1, 3-2, 3-7 

Chicot Aquifer, 4-16, 4-17, 5-2 

Chief Inspector, 2-47 

Clean Air Act (CAA), 4-109, 4-110 

Clean Water Act (CWA), 1-4, 1-5 

Coastal Lowlands Aquifer System, 4-16 

Coastal Management Division, 1-5, 1-8, 4-85, 5-

8 

Coastal marsh, 1-9, 3-10, 3-12, 4-1, 4-36, 4-37, 

4-46, 4-48, 4-103, 4-106, 4-108 

Coastal prairie, 4-44, 4-71, 4-72, 5-4 

Coastal Use Permit (CUP), 1-5, 1-8, 4-56, 5-8 

Coastal Wetland Planning, Protection and 

Restoration Act, 4-36, 4-48, 5-3 

coastal zone management, 1-3, 1-4, 1-5, 4-74, 

4-85, 5-8 

Coastal Zone Management Act (CZMA), 1-3, 1-

4, 4-85 

Coastal Zone Management Program (CZMP), 1-

4, 5-8 

N-1 Appendix N 
Code of Federal Regulations (CFR), 1-2, 1-4, 1-

6, 2-10, 2-46, 2-48, 4-25, 4-58, 4-93, 4-97, 4-

109, 4-110, 4-111, 4-117, 4-120 

Columbia Gulf Transmission (CGT), 1-1, 2-3, 2-

6, 4-77, 4-87 

compensatory mitigation, 4-50, 4-58, 4-63, 4-78, 

4-79, 4-80, 5-5 

compressor station, 1-1, 1-3, 2-3, 2-48, 3-2, 3-6, 

3-7, 3-8, 4-114 

Conservation Reserve Program (CRP), 1-5, 4-

38, 4-81, 4-83, 5-7, 5-15 

contamination, 4-13, 4-14, 4-16, 4-17, 4-19, 4-

24, 4-27, 4-28, 4-54, 4-57, 4-83, 5-1, 5-2, 5-5 

Council on Environmental Quality (CEQ), 1-2, 1-

8, 4-97, 4-99 

Craft Inspectors, 2-47 

crawfish ponds, 1-7, 2-13, 2-24, 2-44, 4-46, 4-

52, 5-1 

Creole Trail Pipeline (CTP), 3-4, 3-6, 3-7 

cultural resources, 1-3, 1-8, 2-36, 3-6, 3-8, 3-11, 

3-13, 3-15, 4-27, 4-93, 4-94, 4-95, 4-96, 5-8, 

5-11, 5-16 

cumulative impacts, 1-3, 3-10, 4-1, 4-97, 4-98, 

4-99, 4-100, 4-101, 4-103, 4-104, 4-105, 4-

106, 4-107, 4-108, 5-9 

Demand Side Management (DSM), 3-2 

Director of the OEP, 2-42, 4-22, 5-9, 5-14 

earthquake, 4-6, 4-7, 4-123, 5-1 

easement, 4-43, 4-78, 4-79, 4-83, 5-7, 5-16 

emergency response, 2-10, 2-45, 2-47, 2-48, 4-

90, 4-107, 4-116, 4-120, 5-8 

eminent domain, 4-78, 5-11 

emissions, 4-108, 4-111, 4-112, 4-113, 5-9 

employment, 2-24, 2-25, 2-28, 2-45, 2-46, 2-47, 

2-48, 4-14, 4-51, 4-54, 4-71, 4-87, 4-88, 4-90, 

4-92, 4-106, 4-112, 4-122, 4-123, 5-4, 5-8, 5-

9, 5-12 

Endangered Species Act of 1973 (ESA), 1-3, 1-

4, 1-5, 4-58, 4-65 

Energy Information Administration (EIA), 1-2 

environmental impact statement (EIS), 1-1, 1-2, 

1-3, 1-4, 1-6, 1-7, 1-8, 2-5, 2-13, 2-47, 3-1, 3-

4, 3-6, 4-1, 4-6, 4-23, 4-27, 4-32, 4-35, 4-38, 

4-51, 4-52, 4-55, 4-57, 4-64, 4-65, 4-71, 4-80, 

4-83, 4-97, 4-99, 4-108, 5-1, 5-7, 5-9, 5-10, 5-

11, 5-14, 5-15, 5-16 

Environmental Inspector (EI), 2-47, 4-33, 5-11, 

5-13 

erosion, 1-5, 1-9, 2-10, 2-11, 2-12, 2-15, 2-24, 2-

25, 2-42, 2-46, 3-14, 3-16, 4-7, 4-8, 4-9, 4-10, 

4-11, 4-12, 4-15, 4-24, 4-25, 4-27, 4-29, 4-33, 

4-36, 4-37, 4-38, 4-39, 4-41, 4-43, 4-44, 4-53, 

4-54, 4-59, 4-63, 4-69, 4-72, 4-97, 4-107, 4-

116, 5-1, 5-2, 5-5, 5-11 

Erosion and Sediment Control (ES&C), 2-10, 5-

14 

essential fish habitat (EFH), 1-3, 1-4, 1-5, 1-7, 3-

12, 4-21, 4-27, 4-32, 4-40, 4-41, 4-55, 4-58, 4-

59, 4-60, 4-61, 4-62, 4-63, 4-64, 5-2, 5-3, 5-5, 

5-6 

estuarine emergent (E2EM), 4-29, 4-31, 4-39, 4-

62 

estuarine scrub-shrub (E2SS), 4-29, 4-31, 4-39 

Eunice, LA, 3-4, 3-10, 3-12, 3-13 

Evangeline (Parish, River, Lake, Aquifer), 1-1, 1-

2, 2-1, 2-3, 2-4, 2-6, 2-7, 3-10, 3-12, 3-13, 4-

1, 4-3, 4-16, 4-17, 4-18, 4-38, 4-50, 4-66, 4-

81, 4-86, 4-87, 4-88, 4-89, 4-109, 4-118 

extra workspaces, 2-6, 2-8, 2-12, 2-24, 2-44, 4-

27, 4-29, 4-31, 4-34, 4-35, 4-43, 4-49, 4-57, 4-

62, 4-74, 4-77, 4-80, 4-94, 4-97, 5-3, 5-7 

farmlands, 1-5, 4-9, 4-10, 4-11, 4-14, 4-15, 5-1 

Federal Emergency Management Agency 

(FEMA), 4-7 

Federal Energy Regulatory Commission (FERC 

or Commission), 1-1, 1-2, 1-3, 1-4, 1-5, 1-6, 1-

8, 1-9, 2-5, 2-10, 2-12, 2-24, 2-34, 2-45, 2-46, 

2-47, 2-48, 2-49, 3-1, 3-2, 3-6, 3-14, 4-1, 4-6, 

4-45, 4-59, 4-65, 4-70, 4-71, 4-73, 4-80, 4-86, 

4-90, 4-93, 4-95, 4-96, 4-101, 4-105, 4-117, 5-

1, 5-9, 5-10, 5-12, 5-13, 5-16 

FERC’s Office of Energy Projects (OEP), 1-2, 2-

9, 2-10, 2-47, 4-8, 4-14, 4-23, 4-28, 4-35, 4-

38, 4-73, 4-83, 4-84, 4-96, 4-115, 5-7, 5-10, 5-

11, 5-12, 5-13, 5-14, 5-15, 5-16, 5-17 

FGT Lateral, 2-1, 2-3, 2-4, 2-6, 2-8, 2-9, 2-15, 3-

1, 3-8, 4-18, 4-21, 4-22, 4-23, 4-26, 4-32, 4-

34, 4-40, 4-44, 4-50, 4-53, 4-75, 4-76, 4-77, 4-

87, 4-94, 4-95, 4-118, 4-119, 5-2, 5-4, 5-13, 5-

14, 5-15 

fish entrainment or impingement, 4-25, 4-54, 5-5 

fisheries, 1-3, 1-4, 1-7, 2-33, 4-19, 4-21, 4-25, 4-

27, 4-28, 4-37, 4-51, 4-52, 4-53, 4-54, 4-55, 4-

56, 4-57, 4-58, 4-59, 4-62, 4-65, 4-67, 5-4, 5-

5, 5-6, 5-7 

Fishery Management Plan (FMP), 4-59 

floodplains, 1-5, 4-2, 4-3, 4-7 

Florida Gas Transmission (FGT), 1-1, 2-1, 2-3, 

2-4, 2-6, 2-8, 2-9, 2-15, 3-1, 3-4, 3-8, 4-18, 4-

21, 4-22, 4-23, 4-26, 4-32, 4-34, 4-40, 4-44, 4-

50, 4-53, 4-75, 4-76, 4-77, 4-87, 4-94, 4-95, 4-

118, 4-119, 5-2, 5-3, 5-4, 5-13, 5-14, 5-15 

geology, 1-3, 1-5, 1-7, 2-8, 2-9, 2-12, 2-15, 2-16, 

2-24, 2-25, 2-28, 2-32, 2-34, 2-37, 2-42, 2-44, 

2-45, 2-46, 2-48, 3-12, 4-2, 4-3, 4-5, 4-7, 4-9, 

4-10, 4-11, 4-12, 4-13, 4-14, 4-15, 4-19, 4-20, 

4-23, 4-24, 4-27, 4-29, 4-32, 4-33, 4-34, 4-38, 

4-39, 4-44, 4-45, 4-46, 4-53, 4-54, 4-58, 4-63, 

4-72, 4-83, 4-116, 4-118, 4-121, 5-1, 5-2, 5-3, 

5-4, 5-7, 5-14 

global positioning system (GPS), 2-36, 4-63 

Golden Pass Pipeline (GPP), 3-3 

N-2 Appendix N 
gravel pit, 4-3, 4-6, 4-74, 4-75, 5-1, 5-7, 5-14 

groundwater, 4-14, 4-16, 4-17, 4-18, 4-19, 4-29, 

4-44, 4-54, 4-83, 4-99, 4-108, 5-1, 5-2, 5-7, 5-

14 

Gulf Coast, 1-2, 4-3, 4-6, 4-9, 4-59, 4-68, 4-71, 

4-97, 4-103 

Gulf Intracoastal Waterway (GIWW), 2-3, 2-12, 

3-12, 3-16, 4-20, 4-22, 4-26, 4-32, 4-34, 4-35, 

4-36, 4-37, 4-40, 4-52, 4-62, 4-100, 4-107, 5-

4, 5-5 

Gulf of Mexico Fishery Management Council 

(GMFMC), 4-59, 4-60, 4-61, 4-62, 4-63 

hazardous waste site, 4-81, 4-83, 5-7 

high consequence areas (HCAs), 4-119 

horizontal directional drill (HDD), 2-12, 2-13, 2-

24, 2-25, 2-32, 2-33, 2-36, 2-42, 2-44, 2-45, 3-

10, 3-12, 3-14, 3-18, 3-19, 4-5, 4-6, 4-7, 4-12, 

4-21, 4-22, 4-24, 4-25, 4-26, 4-27, 4-28, 4-31, 

4-32, 4-34, 4-35, 4-37, 4-39, 4-40, 4-41, 4-44, 

4-50, 4-52, 4-53, 4-54, 4-57, 4-58, 4-62, 4-63, 

4-79, 4-80, 4-82, 4-84, 4-91, 4-94, 4-95, 4-

107, 4-108, 4-114, 4-115, 4-116, 4-118, 5-1, 

5-2, 5-3, 5-5, 5-8, 5-9, 5-14, 5-15, 5-17 

Houston, Texas, 2-5 

human disturbance, 4-69 

hurricanes, 3-12, 4-7, 4-52, 4-100, 4-106, 4-109, 

4-116 

hydric soils, 1-5, 4-9, 4-10, 4-11, 4-13 

hydrostatic test, 1-5, 2-16, 2-24, 2-48, 4-25, 4-

26, 4-39, 4-53, 4-57, 4-63, 4-118, 5-5 

Integrated Resource Planning, 3-2 

Integrity Management Plan, 2-48 

interconnecting pipelines (interconnects), 1-1, 1-

2, 1-3, 1-8, 1-9, 2-1, 2-3, 2-5, 2-6, 2-10, 2-12, 

2-45, 2-48, 3-1, 3-2, 3-3, 3-4, 3-6, 3-7, 3-8, 4-

1, 4-9, 4-12, 4-13, 4-15, 4-31, 4-34, 4-35, 4-

40, 4-43, 4-77, 4-84, 4-87, 4-94, 4-95, 4-101, 

4-112, 4-113, 5-3, 5-8, 5-9, 5-10, 5-16 

invasive species, 4-33, 4-40, 4-44, 4-45, 4-103, 

4-108 

invertebrates, 4-32, 4-40, 4-58, 4-59, 4-60, 4-61, 

5-5 

Jefferson Davis (Parish, River, Lake), 1-1, 1-2, 

2-1, 2-4, 2-6, 2-7, 3-10, 3-12, 4-1, 4-3, 4-4, 4-

16, 4-17, 4-18, 4-38, 4-39, 4-50, 4-81, 4-86, 4-

87, 4-88, 4-89, 4-118, 5-7, 5-15 

Johnsons Bayou, 1-8, 1-9, 2-3, 2-6, 3-8, 3-10, 3-

12, 4-4, 4-77, 4-87, 4-100 

Lacassine National Wildlife Refuge (LNWR), 4-

48, 4-82 

Lake Charles, 1-7, 2-3, 3-3, 3-4, 3-10, 3-12, 3-

13, 4-4, 4-90, 4-100 

land use, 1-3, 1-7, 2-7, 2-46, 3-6, 3-11, 3-15, 3-

17, 3-18, 3-19, 3-20, 3-21, 3-22, 3-23, 4-52, 4-

74, 4-75, 4-77, 4-78, 4-80, 4-91, 4-97, 4-102, 

4-106, 4-108, 5-2, 5-7, 5-9, 5-11 

landslide, 5-1 

Liberty Pipeline, 3-3, 3-8, 4-104 

liquefied natural gas, 1-1, 1-2, 1-9, 2-3, 2-13, 3-

1, 3-2, 3-3, 3-4, 3-6, 4-26, 4-79, 4-97, 4-98, 4-

100, 4-101, 4-102, 4-103, 4-104, 4-105, 4-

108, 5-9, 5-10 

Louisiana Department of Environmental Quality 

(LDEQ), 1-5, 4-14, 4-19, 4-83, 4-112 

Louisiana Department of Natural Resources 

(LDNR), 1-4, 1-5, 1-8, 4-36, 4-37, 4-41, 4-50, 

4-56, 4-85, 5-7, 5-8, 5-15, 5-16 

Louisiana Department of Transportation (LDOT), 

1-5, 3-12, 4-17 

Louisiana Department of Wildlife and Fisheries 

(LDWF), 1-3, 1-5, 1-6, 1-7, 2-25, 3-8, 3-12, 4-

22, 4-32, 4-41, 4-43, 4-49, 4-50, 4-51, 4-52, 4-

55, 4-56, 4-57, 4-58, 4-63, 4-65, 4-67, 4-71, 4-

72, 4-79, 4-83, 5-2, 5-3, 5-4, 5-5, 5-6, 5-14, 5-

15, 5-16 

Louisiana Irrigation Canal, 4-26 

Louisiana Natural and Scenic Rivers, 3-6, 3-7, 3-

11, 3-12, 4-83 

Louisiana Oil Spill Coordinators Office (LOSCO), 

4-3 

Magnuson-Stevens Fishery Conservation and 

Management Act (MSA), 1-3, 1-4, 1-5, 4-58 

mainline block valve (MLV), 1-1, 1-3, 2-1, 2-4, 2-

5, 2-45, 2-46, 2-48, 4-77, 4-108, 4-113, 4-118 

Major Land Resource Areas (MLRAs), 4-9 

maximum allowable operating pressure (MAOP), 

4-118, 4-119 

Memorandum of Understanding on Natural Gas 

Transportation Facilities (Memorandum), 4-

117 

milepost (MP), 1-1, 2-1, 2-3, 2-4, 2-6, 2-11, 2-12, 

2-28, 2-32, 2-36, 2-42, 2-44, 3-4, 3-8, 3-12, 3-

13, 3-14, 3-16, 3-17, 3-18, 3-19, 3-20, 3-21, 3-

22, 3-23, 4-3, 4-4, 4-6, 4-8, 4-17, 4-18, 4-21, 

4-22, 4-23, 4-25, 4-26, 4-27, 4-28, 4-32, 4-34, 

4-35, 4-36, 4-37, 4-44, 4-50, 4-53, 4-57, 4-58, 

4-62, 4-71, 4-76, 4-77, 4-79, 4-80, 4-81, 4-82, 

4-84, 4-85, 4-86, 4-91, 4-94, 4-113, 4-114, 4-

115, 4-118, 5-2, 5-3, 5-5, 5-8, 5-9, 5-14, 5-15, 

5-16, 5-17 

National Ambient Air Quality Standards 

(NAAQS), 4-109, 4-110, 4-111 

National Environmental Policy Act of 1969 

(NEPA), 1-2, 1-3, 1-4, 1-8, 3-1, 4-58, 4-59, 4-

99 

National Historic Preservation Act (NHPA), 1-3, 

1-4, 1-5, 4-93, 4-95 

National Oceanic and Atmospheric 

Administration (NOAA), 1-3, 1-4, 1-5, 1-6, 1-7, 

2-25, 3-8, 4-13, 4-32, 4-36, 4-37, 4-41, 4-58, 

4-59, 4-60, 4-61, 4-62, 4-63, 4-65, 4-67, 4-68, 

4-72, 4-73, 5-3, 5-5, 5-6, 5-7, 5-15, 5-16 

N-3 Appendix N 
National Pollutant Discharge Elimination System 

(NPDES), 2-24, 4-25 

National Register of Historic Places (NRHP), 1-

4, 3-6, 3-11, 4-93, 4-94, 4-95, 5-8 

National Wetland Inventory (NWI), 3-6, 3-8, 3-

16, 3-17, 3-18, 3-19, 3-20, 3-21, 3-22, 3-23, 4-

29 

National Wildlife Refuge (NWR), 3-10, 3-11, 4-

48, 4-81, 4-82, 4-111 

Native Americans, 4-93 

Natural Gas Act (NGA), 1-1, 1-5, 1-8, 3-1, 4-78, 

5-11 

Natural Gas Pipeline Company of America 

(NGPL), 1-1, 1-9, 2-3, 2-6, 3-3, 3-10, 4-35, 4-

40, 4-76, 4-77, 4-87, 5-10 

Natural Gas Pipeline Safety Act (NGPSA), 4-117 

Natural Heritage Program (NHP), 4-49, 4-50, 4-

51, 4-65, 4-71, 4-72, 5-4, 5-6, 5-16 

Natural Resources Conservation Service 

(NRCS), 1-5, 4-9, 4-11, 4-36, 4-37, 4-38, 5-7, 

5-15 

navigation, 1-4, 2-28, 2-36, 2-37, 4-8, 4-20, 4-

79, 4-81, 4-91, 4-118 

New Source Performance Standards (NSPS), 4-

109, 4-111 

NOAA’s National Marine Fisheries Service 

(NOAA Fisheries Service), 1-3, 1-4, 1-5, 1-6, 

1-7, 2-25, 3-8, 4-13, 4-32, 4-36, 4-37, 4-41, 4-

58, 4-59, 4-63, 4-65, 4-68, 4-72, 4-73, 5-3, 5-

5, 5-6, 5-7, 5-15, 5-16 

noise, 1-3, 2-4, 4-49, 4-51, 4-68, 4-80, 4-82, 4-

97, 4-102, 4-107, 4-108, 4-113, 4-114, 4-115, 

5-6, 5-9, 5-17 

noise-sensitive area (NSA), 4-114, 4-115 

Nonattainment New Source Review (NNSR), 4-

110 

Notice of Intent, 1-6 

Notice to Mariners, 2-37, 4-91 

Office of Pipeline Safety (OPS), 4-116, 4-119 

Orange County, 2-7, 4-86 

oysters, 1-5, 1-7, 3-12, 3-14, 3-15, 4-20, 4-27, 4-

28, 4-52, 4-56, 4-57, 4-58, 4-59, 4-61, 4-63, 4-

79, 5-2, 5-5, 5-6, 5-7 

palustrine emergent (PEM), 4-29, 4-31, 4-39, 4-

40 

palustrine forested (PFO), 4-29, 4-31, 4-40, 4-41 

palustrine scrub-shrub (PSS), 4-29, 4-31, 4-39, 

4-40 

peak ground acceleration (PGA), 4-6, 4-7 

Perry Ridge, 1-7, 4-36, 4-37, 4-38, 4-81, 4-83, 4-

100, 5-7, 5-15 

Pig Launchers/Receivers, 1-1, 1-3, 2-1, 2-4, 2-

45, 2-46, 2-48 

pipe storage and contractor yards, 2-1, 2-6, 2-7, 

2-10, 2-46, 4-1, 4-29, 4-31, 4-43, 4-49, 4-74, 

4-78, 4-94, 4-95, 5-3, 5-7, 5-11 

Pipeline and Hazardous Materials Safety 

Administration (PHMSA), 4-116 

pipeline right-of-way, 1-1, 1-7, 2-1, 2-5, 2-6, 2-7, 

2-8, 2-9, 2-11, 2-12, 2-13, 2-15, 2-16, 2-24, 2-

25, 2-28, 2-32, 2-34, 2-36, 2-37, 2-42, 2-44, 2-

45, 2-46, 3-6, 3-7, 3-8, 3-10, 3-11, 3-12, 3-13, 

3-14, 3-16, 3-19, 3-20, 4-1, 4-3, 4-5, 4-6, 4-7, 

4-12, 4-13, 4-14, 4-17, 4-19, 4-27, 4-29, 4-31, 

4-32, 4-33, 4-34, 4-35, 4-37, 4-39, 4-40, 4-41, 

4-42, 4-43, 4-44, 4-45, 4-49, 4-50, 4-54, 4-57, 

4-58, 4-63, 4-70, 4-71, 4-72, 4-74, 4-75, 4-76, 

4-77, 4-78, 4-79, 4-80, 4-81, 4-83, 4-84, 4-91, 

4-94, 4-97, 4-103, 4-105, 4-106, 4-116, 4-118, 

5-2, 5-3, 5-4, 5-5, 5-6, 5-7, 5-8, 5-11, 5-12, 5-

13 

FERC’s Upland Erosion Control, Revegetation 

and Maintenance Plan (our Plan), 1-5, 2-10, 

2-12, 2-24, 2-44, 2-46, 2-47, 4-8, 4-12, 4-13, 

4-14, 4-24, 4-41, 4-44, 4-45, 4-49, 4-50, 4-53, 

4-54, 4-71, 4-72, 4-78, 4-79, 4-80, 4-82, 4-83, 

4-96, 4-99, 4-100, 4-101, 4-102, 4-120, 5-1, 5-

2, 5-3, 5-4, 5-5, 5-6, 5-7, 5-11, 5-12, 5-14 

Port Arthur Pipeline (PAP), 3-3 

Pre-Filing Process, 1-6, 3-8, 3-16, 3-17, 3-18, 3-

19, 3-20, 4-80, 4-83 

Prevention of Significant Deterioration (PSD), 4-

109, 4-110, 4-111 

FERC’s Wetland and Waterbody Construction 

and Mitigation Procedures (our Procedures), 

2-9, 2-10, 2-12, 2-24, 2-25, 2-28, 2-34, 2-44, 

2-46, 2-47, 2-48, 4-13, 4-14, 4-18, 4-19, 4-23, 

4-25, 4-26, 4-32, 4-33, 4-34, 4-35, 4-39, 4-40, 

4-41, 4-44, 4-45, 4-49, 4-50, 4-53, 4-54, 4-63, 

4-64, 4-71, 4-72, 4-80, 5-2, 5-3, 5-4, 5-5, 5-6 

push/pull method, 2-9, 2-25, 2-28, 4-32, 4-34, 4-

35, 4-39 

recreational activities, 1-3, 1-5, 2-37, 3-6, 3-11, 

3-13, 4-20, 4-21, 4-27, 4-28, 4-29, 4-48, 4-52, 

4-53, 4-55, 4-56, 4-57, 4-65, 4-68, 4-71, 4-74, 

4-81, 4-82, 4-83, 4-87, 4-88, 4-89, 4-91, 4-

100, 4-102, 4-106, 4-107, 4-115, 4-123, 5-7 

red-cockaded woodpecker (RCW), 4-70, 4-72, 

5-6, 5-16 

Rivers and Harbors Act, 1-4, 1-5 

route variation, 3-1, 3-7, 3-8, 3-9, 3-10, 3-11, 3-

12, 3-13, 3-14, 3-15, 3-16, 3-17, 3-18, 3-19, 3-

20, 3-21, 3-22, 3-23, 4-27, 4-83, 5-10 

runoff, 1-9, 4-8, 4-12, 4-24, 4-29, 4-39, 4-44, 4-

53, 4-61, 4-99, 5-3 

Sabine Lake, 1-5, 1-7, 2-3, 2-9, 2-12, 2-13, 2-28, 

2-32, 2-36, 3-10, 3-12, 3-13, 3-14, 3-15, 3-16, 

4-3, 4-19, 4-20, 4-21, 4-26, 4-27, 4-32, 4-34, 

4-36, 4-39, 4-41, 4-55, 4-56, 4-57, 4-58, 4-59, 

4-62, 4-63, 4-67, 4-68, 4-69, 4-74, 4-79, 4-81, 

4-82, 4-91, 4-94, 4-99, 4-100, 4-105, 4-106, 4-

107, 4-116, 5-2, 5-4, 5-5, 5-7, 5-8 

N-4 Appendix N 
Sabine National Wildlife Refuge (SNWR), 3-10, 

4-36, 4-48, 4-82, 4-103 

Sabine Pass LNG Terminal, 1-1, 1-2, 1-8, 2-1, 2-

3, 2-5, 2-6, 2-12, 2-21, 2-22, 3-1, 3-2, 3-3, 3-

4, 3-6, 3-8, 3-10, 3-12, 3-15, 4-34, 4-35, 4-75, 

4-88, 4-100, 4-102, 4-104, 4-116, 5-10 

Sabine Pipeline, LLC, 2-6, 3-2, 3-4 

Sabine River, 2-3, 2-12, 2-36, 3-3, 4-2, 4-20, 4-

21, 4-22, 4-26, 4-27, 4-32, 4-34, 4-40, 4-57, 4-

59, 4-62, 4-63, 4-100, 4-106, 4-107, 5-5 

safety, 1-3, 1-7, 2-4, 2-10, 2-15, 2-25, 2-37, 2-

45, 2-46, 3-16, 4-1, 4-5, 4-25, 4-33, 4-68, 4-

80, 4-91, 4-107, 4-114, 4-116, 4-117, 4-119, 

4-122, 4-123, 5-9 

Scenic Byways, 4-82 

scoping, 1-6, 1-7, 4-97 

Sea Turtle and Smalltooth Sawfish Construction 

Conditions (Construction Conditions), 4-68, 4-

72, 5-6 

sea turtles, 4-65, 4-67, 4-68, 5-6 

Secretary of the Commission (Secretary), 2-9, 2-

10, 2-42, 2-47, 4-6, 4-8, 4-14, 4-19, 4-22, 4-

23, 4-28, 4-35, 4-38, 4-41, 4-58, 4-70, 4-72, 4-

80, 4-83, 4-84, 4-85, 4-96, 4-115, 5-1, 5-3, 5-

7, 5-10, 5-11, 5-12, 5-13, 5-14, 5-15, 5-16, 5-

17 

Shell Island, 2-3, 3-12, 4-32, 4-62, 5-5 

socioeconomics, 1-3, 1-7, 4-56, 4-86, 4-97, 4-

102, 4-106, 5-8 

soil compaction, 1-7, 4-9, 4-12, 4-13, 4-14, 4-39, 

5-1 

soil contamination, 4-14, 4-15, 4-19 

Spill Prevention and Response Plan (SPRP), 2-

10, 4-14, 4-15, 4-24, 4-25, 4-54, 5-2, 5-5, 5-14 

spills, 2-10, 4-14, 4-19, 4-24, 4-27, 4-33, 4-39, 4-

54, 5-2, 5-3, 5-5 

Starks, Louisiana, 3-12, 4-101, 4-102, 4-105 

State Historic Preservation Office (SHPO), 4-93, 

4-94, 4-95, 4-96, 5-8, 5-9, 5-16 

stormwater, 1-5, 2-10, 2-16, 4-12, 4-19, 4-39 

Stormwater Pollution Prevention Plan (SWPPP), 

2-10, 4-14, 4-15, 4-24, 4-27, 4-54, 4-63, 5-2, 

5-3, 5-5, 5-14 

submerged aquatic vegetation (SAV), 4-59, 4-

61, 4-62, 4-66, 4-67 

Supervisory Control and Data Acquisition 

(SCADA), 2-5, 2-48 

surface water, 2-24, 2-32, 4-24, 4-25, 4-26, 4-

29, 4-99, 4-100, 4-108, 5-5 

Temporary Threshold Shift (TTS), 4-68 

Temporary workspaces, 2-6, 2-12, 2-13, 2-36, 2-

44, 2-46, 3-6, 3-11, 3-14, 3-18, 4-3, 4-5, 4-17, 

4-34, 4-43, 4-70, 4-74, 4-81, 4-86, 4-114, 5-3, 

5-11 

Tennessee Gas Pipeline Company, 2-6 

Texas Eastern Transmission, LLC, 2-6, 3-3, 3-4 

Texas Gas Transmission, 2-6 

threatened and endangered species, 1-3, 1-5, 1-

7, 1-8, 3-6, 3-11, 3-12, 3-13, 4-20, 4-46, 4-48, 

4-52, 4-59, 4-65, 4-67, 4-68, 4-69, 4-70, 4-72, 

4-82, 5-6, 5-9, 5-11, 5-16 

topsoil, 2-7, 2-9, 2-13, 2-15, 2-16, 2-17, 2-18, 2-

19, 2-20, 2-21, 2-22, 2-23, 2-24, 2-25, 2-26, 2-

27, 2-28, 2-29, 2-30, 2-44, 4-9, 4-12, 4-14, 4-

33, 4-39, 4-78, 5-1, 5-4 

Total LNG USA, 1-2, 3-1, 3-2, 3-7 

Transco pipeline, 3-3, 3-12, 4-76, 5-10 

Transcontinental Gas Pipeline Corporation 

(Transco), 2-6, 3-3, 3-4, 3-12, 4-76, 4-77, 4-

84, 4-87, 5-8, 5-10, 5-16 

transportation, 1-8, 2-3, 2-10, 3-2, 4-12, 4-44, 4-

75, 4-79, 4-90, 4-91, 4-99, 4-100, 4-102, 4-

116, 4-117, 4-123, 5-9, 5-11 

Trunkline Gas Company, LLC, 2-6, 4-77 

Trunkline LNG Terminal, 2-42, 4-28, 4-102, 4-

105 

Trunkline Pipeline Lateral, 3-3 

U.S. Army Corps of Engineers (COE), 1-2, 1-4, 

1-5, 1-7, 1-8, 1-9, 2-25, 2-37, 2-42, 3-8, 3-14, 

3-18, 4-13, 4-22, 4-23, 4-28, 4-29, 4-32, 4-36, 

4-38, 4-41, 4-45, 4-50, 4-85, 4-103, 5-2, 5-3, 

5-8, 5-14, 5-15 

U.S. Coast Guard (USCG), 2-37, 4-79, 4-91, 5-7 

U.S. Department of Agriculture (USDA), 1-5, 4-

14, 4-38 

U.S. Department of Commerce, 1-3, 1-5, 4-123 

U.S. Department of Energy (DOE), 1-2 

U.S. Department of Transportation (DOT), 2-4, 

2-10, 2-16, 2-24, 2-47, 2-48, 4-25, 4-34, 4-35, 

4-116, 4-117, 4-118, 4-119, 4-120, 4-123, 5-9 

U.S. Environmental Protection Agency (EPA), 1-

4, 1-7, 4-14, 4-16, 4-17, 4-29, 4-54, 4-83, 4-

112, 4-114 

U.S. Fish and Wildlife Service (FWS), 1-2, 1-3, 

1-5, 1-6, 1-7, 2-25, 2-44, 3-8, 4-13, 4-22, 4-

29, 4-32, 4-36, 4-37, 4-41, 4-48, 4-50, 4-51, 4-

65, 4-67, 4-68, 4-69, 4-70, 4-71, 4-73, 4-81, 4-

82, 4-83, 4-103, 5-2, 5-3, 5-4, 5-6, 5-7, 5-14, 

5-15, 5-16 

U.S. Geological Survey (USGS), 3-8, 3-15, 3-16, 

3-17, 3-18, 3-19, 3-20, 3-21, 3-22, 3-23, 4-1, 

4-3, 4-6, 4-16, 4-107 

Unanticipated Discovery Plan, 4-96 

United States Code (USC), 1-3, 4-109, 4-116, 4-

119 

vegetation, 1-3, 1-7, 2-12, 2-13, 2-15, 2-24, 2-

25, 2-28, 2-44, 2-46, 4-9, 4-23, 4-24, 4-25, 4-

27, 4-28, 4-29, 4-32, 4-36, 4-38, 4-39, 4-42, 4-

43, 4-44, 4-45, 4-46, 4-47, 4-48, 4-49, 4-53, 4-

54, 4-67, 4-71, 4-84, 4-102, 4-103, 4-106, 5-3, 

5-4, 5-5, 5-9, 5-15 

N-5 Appendix N 
Vinton Drainage Canal, 3-14, 3-16, 3-17, 4-20, 

4-21, 4-22, 4-25, 4-52 

Vinton, Louisiana, 3-12 

visual resources, 1-3, 4-74, 4-82, 4-84, 4-106, 5-

8 

water resources, 1-3, 1-7, 3-10, 4-13, 4-24, 4-

41, 4-45, 4-46, 4-50, 4-51, 4-54, 4-57, 4-58, 4-

63, 4-64, 4-97, 4-99, 4-102, 4-108, 5-2, 5-3, 5-

4, 5-5, 5-6, 5-15 

Wellhead Protection Areas, 4-16, 4-17 

Wetland Reserve Program (WRP), 4-81, 4-83 

wetlands, 1-3, 1-4, 1-7, 1-8, 1-9, 2-6, 2-8, 2-9, 2-

10, 2-12, 2-13, 2-25, 2-26, 2-27, 2-28, 2-29, 2-

30, 2-32, 2-34, 2-42, 2-44, 2-46, 3-1, 3-6, 3-7, 

3-8, 3-10, 3-11, 3-12, 3-13, 3-14, 3-15, 3-16, 

3-17, 3-18, 4-13, 4-21, 4-22, 4-23, 4-25, 4-27, 

4-29, 4-30, 4-31, 4-32, 4-33, 4-34, 4-35, 4-36, 

4-38, 4-39, 4-40, 4-41, 4-42, 4-43, 4-45, 4-46, 

4-47, 4-48, 4-49, 4-50, 4-59, 4-60, 4-61, 4-62, 

4-63, 4-72, 4-74, 4-75, 4-79, 4-81, 4-83, 4-97, 

4-99, 4-100, 4-102, 4-103, 4-104, 4-105, 4-

108, 5-2, 5-3, 5-4, 5-5, 5-6, 5-7, 5-8, 5-9, 5-

11, 5-14, 5-15 

wildlife, 1-3, 1-4, 1-7, 3-12, 4-3, 4-9, 4-19, 4-20, 

4-27, 4-28, 4-29, 4-38, 4-43, 4-44, 4-46, 4-47, 

4-48, 4-49, 4-50, 4-52, 4-55, 4-82, 4-83, 4-

102, 4-103, 4-108, 5-4, 5-9 

N-6 Appendix N