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)
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