APPENDIX J 

DRAFT AQUATIC RESOURCE MITIGATION PLAN 
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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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