4-1 Environmental Analysis

4.0 ENVIRONMENTAL ANALYSIS 

The environmental consequences of constructing and operating the Project would vary in duration 

and significance. Four levels of impact duration were considered: temporary, short-term, long-term, and 

permanent. Temporary impacts generally occur during construction with the resource returning to 

preconstruction conditions almost immediately afterward. Short-term impacts would continue for 

approximately three years following construction. Impacts were considered long-term if resources would 

require more than three years to recover. Permanent impacts would occur as a result of activities that 

modify resources to the extent that they would not return to preconstruction conditions during the life of 

the Project, such as with construction of an interconnect. We considered an impact to be significant if it 

would result in a substantial adverse change in the physical environment. 

In this section, we discuss the affected environment, general construction and operational 

impacts, and proposed mitigation for each resource. KMLP, as part of its proposal, agreed to implement 

certain measures to reduce impacts, and we evaluated the proposed mitigation measures to determine 

whether or not additional measures would be necessary to further reduce impacts. These additional 

mitigation measures that we have identified appear as bulleted, boldface paragraphs in the text. We are 

recommending that these measures be included as specific conditions to the Certificate that the FERC 

may issue to KMLP for the Project. 

Conclusions in this draft EIS are based on our analysis of the environmental impact and the 

following assumptions: 

• KMLP would comply with all applicable laws and regulations; 

• The facilities would be constructed as described in section 2.0 of this draft EIS; and 

• KMLP would implement the mitigation measures identified in its application and 

supplemental filings to the FERC. 

This section of the draft EIS is organized by environmental resource. For most resources, the 

scope of our analysis includes the construction and operation of the facilities, which are limited to the 

pipelines, their support facilities, workspaces extra to the pipelines’ rights-of-way, interconnect sites, 

access roads, and yards for pipe storage and contractor use during the construction phase. The draft EIS 

also includes detailed discussion of natural gas pipeline reliability and safety (see section 4.13) and the 

cumulative impacts of the Project and other projects in the area (see section 4.11). 

4.1 GEOLOGIC RESOURCES 

4.1.1 Affected Environment 

Geologic Setting 

The entire state of Louisiana is within the physiographic section referred to as the Coastal Plain 

Province by the USGS. The surface of this region is underlain by geologically young sediments 

deposited in or adjacent to rivers and deltas in a coastal plain setting. Below the surface sediments are 

Tertiary rocks at a depth of thousands of feet. The KMLP Project begins in the Holocene coastal marshes 

of Cameron Parish and extends across the Pleistocene terraces of Calcasieu, Jefferson Davis, Acadia, and 

Evangeline Parishes (table 4.1.1-1). The Holocene coastal marshes are alluvium deposits associated with 

major rivers and tributaries along with coastal deposits of marine sediments, and account for 

approximately 55 percent of the surface in Louisiana. The Pleistocene terraces consist of sand, gravel, 
 4-2 

TABLE 4.1.1-1 

Geology Along the Proposed KMLP Project 

Map Unit 

Epoch Symbol Name Description 

Holocene HsM Small river meanderbelt deposits Point-bar and associated overbank deposits underlying meander belts of the Sabine R

surface of the meander-belt is characterized by ridge and swale topography. These d

typically consist of gray to reddish brown sand, silt, silty clay, and sandy clay. 

Holocene Hm Mermentau 

Alloformation 

Complex interfingering and interbedded, dark-colored marine muds, sandy and shelly deposits, organic marsh clays, and lacustrine and bay muds. These deposits bury the 

of the Prairie and Deweyville Allogroups. The Louisiana chenier plain forms the surfaMermentau Alloformation. The unit extends westward along the coast into Texas as fGalveston Bay. Eastward, it extends almost to the west shore of Vermilion Bay, wher

interfingers with deltaic sediments of the Teche delta lobe. Seaward of the shoreline, 

Mermentau Alloformation grades laterally into unnamed marine sediments. 

Holocene Hs Small river deposits, 

undifferentiated 

Undifferentiated alluvium of small coastal rivers, consisting of recognizable but unmapchannel and overbank deposits within the Calcasieu River Valley. 

Holocene Hua Undifferentiated 

alluvium of small upland streams 

Alluvial deposits of minor streams and creeks filling valleys cut into older deposits. Thfloodplain within these valleys constitutes the surface of the deposits. The lithology of alluvial deposits reflects the reworked lithology of their adjacent source. 

Pleistocene Ppbe Beaumont 

Alloformation 

Coastal plain deposits of late-to-middle-Pleistocene streams: the oldest and topographighest surface of the Prairie Allogroup units of southwestern Louisiana. It exhibits thchannels of the Red and Calcasieu rivers, and includes deposits of the Ingleside barri

the southwest of the Ville Platte quadrangle. 

Pleistocene Pper Relict Pleistocene 

coastal ridges 

Low-lying ridges delineated on the surface of the Beaumont Alloformation. Some of thare coast-parallel and others trend obliquely to the coast and radiate from the end of tmeander-belts. Limited drilling indicates that these ridges are either meander-belt ridgdeltaic distributaries of differing ages. The origins of other coastal ridges developed oBeaumont surface to the west of the Crowley quadrangle remain undetermined. 
 4-3 Environmental Analysis

and mud deposits and were formed as remnants of pre-existing floodplains tilted in response to the downwrapping of the crustal floor of the Gulf of Mexico. The Pleistocene terraces account for approximately 

25 percent of the surface in Louisiana (Louisiana Geological Survey 2006). 

Permeable Quarternary sedimentary deposits overlie sedimentary rock formations at depths of at 

least 5,000 feet along the northernmost reaches of the Project, and increase to over 10,000 feet near the 

coastline (Renken 1998). There is no bedrock exposure within 50 miles of the pipeline. 

The topography throughout the Project area is characterized by low elevation and relief. Slopes 

are generally flat to gentle except for river/stream banks, man-made levees, roadways, and areas of fill. 

The beginning of the Project in the vicinity of Sabine Lake has an elevation at sea level. Elevation rises 

to 65 feet above sea level at the end of the Project in Acadia Parish. 

Cheniers can be found along the Gulf Coast and within the vicinity of the Project. Cheniers are 

geomorphological formations consisting of ridges and low-lying marshes formed by alternating high and 

low sediment supply periods. The ridges are typically 1 to 3 feet above adjacent areas and provide 

elevated land for commercial and residential development. They support maritime forests typically of 

live oak, which provide important habitat for birds and mammals amongst the marshes of coastal 

Louisiana. The State of Louisiana provides special protection to chenier formations, requiring that 

“surface alterations which have high adverse impacts on natural functions shall not occur, to the 

maximum extent practicable, on barrier islands and beaches, isolated cheniers, isolated natural ridges or 

levees, or in wildlife and aquatic species breeding or spawning areas, or in important migratory routes” 

(Louisiana Administrative Code Title 43, Part I, Subchapter B, Coastal Use Guidelines, Section 711 (I)). 

Mineral Resources 

Mineral resources currently exploited or potentially exploitable in the region where the KMLP 

Project would be located include oil, gas, coal, salt, sand and gravel, gypsum, lime, and stone. 

Southern Louisiana is an active area for oil and gas production. Oil and gas wells in the vicinity 

of the KMLP Project were identified using maps and ownership databases obtained from the Louisiana 

Oil Spill Coordinators Office (LAOSCO). According to these data, there are 218 oil and gas wells within 

1⁄4 mile of the pipeline. Of those 218 wells, 21 are within 150 feet of the pipeline and 9 wells are within 

the construction work area. The approximate locations and status of these 21 wells are listed in table 

4.1.1-2. 

The closest major salt mine, Texas Brine Corp. in northern Jefferson County, Texas, is about 

25 miles west of the pipeline. No brine wells or other salt recovery operations have been found within the 

construction workspace of the KMLP Project. 

Sand and gravel operations are present in Calcasieu, Jefferson Davis, and Evangeline Parishes. 

The closest major sand and gravel operations are located in northwest Jefferson Davis Parish, about 

10 miles north of the Project (National Atlas 2006). Two borrow pits are located in the vicinity of the 

pipeline. One is located completely across the construction right-of-way at approximately MP 52.7. The 

other is located about 200 feet away from the pipeline with its entrance road at approximately MP 66.0. 
 4-4 

TABLE 4.1.1-2 

Oil and Gas Wells Within 150 feet of the KMLP Project 

MP Parish Owner/Operator Oil and Gas Field 

Distance from

Proposed 

Pipeline 

(feet) 

Within 

Constructio

Right-ofWay? 

1.2 Cameron Sabine Pass Terminal SWD Johnsons Bayou, West 52.2 Yes 

40.5 Calcasieu MGGT-GL Wildcat – So. LA Lafayette Dist. 122.5 No 48.4 Calcasieu Grady Mayeaux Wildcat – So. LA Lk. Charles Dist. 41.3 No 49.5 Calcasieu M CAM RE SUA; SL 11524 Moss Lake, East 4.5 Yes 49.5 Calcasieu William T. Burton IND Inc. Wildcat – So. LA Lafayette Dist. 5.8 Yes 57.5 Calcasieu Walker Unit A Lake Charles, South 135.8 No 67.9 Calcasieu Humoris Spears Manchester 28.7 Yes 69.3 Calcasieu Farmers Land and Canal Company Manchester 0.6 Yes 84.0 Jefferson Davis William E. Trimble Welsh, North 120.1 No 

104.9 Acadia Phillip Klumpp Wildcat – So. LA Lafayette Dist. 35.3 No 106.9 Acadia T. Ortego A SU; BNKHD Fruge Tepetate 94.2 No 107.0 Acadia Theogene Ortego Tepetate 134.3 No 107.4 Acadia T. Ortego A SU; L L Welch A Tepetate 63.3 No 107.5 Acadia L. L. Welch A Tepetate 42.5 Yes 108.3 Acadia J. R. Jones Tepetate 115.5 No 109.5 Acadia M. L. Vincent Jr. Tepetate, North 30.5 Yes 109.8 Acadia M. L. Vincent Tepetate, North 104.4 No 109.8 Acadia HMSKR B SUF; M L Vincent Jr. Tepetate, North 104.4 No 109.8 Acadia M. L. Vincent Jr. Tepetate, North 104.4 No 112.2 Acadia M. R. Jenkins Estate Wildcat – So. LA Lafayette Dist. 44.9 Yes 112.2 Acadia Mark Jenkins Estate Basile 44.9 Yes 
 4-5 Environmental Analysis

4.1.2 Impacts and Mitigation 

The primary effect of pipeline construction on geology would be disturbances to the existing 

topography along the construction right-of-way. As described in section 2.3, all areas disturbed during 

pipeline construction would be graded and restored as closely as possible to preconstruction contours 

during cleanup and restoration. Additionally, blasting is not anticipated because the Project would be 

unlikely to encounter bedrock exposures. For these reasons, we believe that construction, maintenance, 

and operation of the Project would be unlikely to result in significant alterations of the topography or 

geological resources of the Project area. 

The Project would cross the western-most portion of a chenier known as Garrison Ridge. This 

crossing would be done by HDD to avoid impacts to this chenier. Maintenance and operation of the 

pipeline would not disturb the chenier. There are two other cheniers, Saunders Ridge and Blue Buck 

Ridge, in the vicinity, but they would not be crossed by the Project. 

Mineral Resources 

As noted above, 9 oil and gas wells are reported to be within the construction right-of-way. 

However, no wells within the construction right-of-way were actually observed in locations where survey 

permission had been granted. Some wells may have been plugged and abandoned and surface features 

may no longer remain. The centerline has not been adjusted to miss these recorded well locations. The 

reported location of the well may be incorrect and moving the line could move it to the actual location of 

the well, or with the high level of oil and gas production in the area, could interfere with another well. To 

confirm the existence of active or plugged/abandoned wells within the pipeline construction right-of-way, 

and minimize impacts on those wells that could be affected, KMLP would: 

• Conduct a pre-construction physical survey using a magnetometer (or equivalent 

instrumentation) to identify non-reported or abandoned oil or gas wells, and to confirm the 

location of reported wells, in those areas along the right-of-way where wells are reported to 

be within 1⁄4 mile of the pipeline; 

• In the event a well is found, determine a safe buffer zone around the well for each 

construction procedure based on the size and current condition of the well, in consultation 

with the owner of the well; 

• Adjust the pipeline centerline, if necessary, to ensure that the pipe trench excavation would 

not interfere with the integrity of the well (generally, a minimum separation distance of 50 

feet would be maintained between the pipeline and the well); 

• Reduce the construction workspace, as necessary, to keep stockpiled spoil and associated 

equipment a safe distance from the well; 

• Flag wells within the construction right-of-way and place barricades at the edge of the buffer 

zone to exclude construction equipment and personnel; 

• Document the condition of each well before construction and repair any damage caused by 

pipeline construction activities to surface facilities or the well casing, as appropriate; and 

• Follow the safety precautions similar to those maintained while crossing foreign pipelines 

(e.g., no mechanized equipment within a prescribed distance, no open flames or smoking, and 
 4-6 Environmental Analysis

monitoring for detection of 25 percent of the lower explosive limit of natural gas in the air) in 

the vicinity of oil and gas wells, as appropriate. 

Minor route changes to reduce impacts on existing mineral resources, such as oil and gas 

production wells, may result in impacts to additional landowners or may affect other resources. If this 

occurs, KMLP would contact the FERC for any route realignments. Construction, operation, and 

maintenance of the Project would not affect future recovery of oil and gas, and nearby oil and gas wells 

would not affect the Project. The Project is limited to near-surface disturbance over a relatively small 

area that would not restrict access to oil and gas resources that are typically located at depths of more than 

1,000 feet. 

There are no salt or brine operations identified near the Project area. The nearest salt mine is 

about 25 miles west of the Project. No major sand and gravel mining operations are located near the 

project area. The nearest one is located at about 10 miles away. However, two borrow pits are located 

along Leg 1 near MP 52.7 and MP 66.0. The borrow pit near MP 52.7 would be crossed by Leg 1 and 

KMLP plans to cross this pit using HDD. KMLP has indicated the landowner/owner of the pit may 

receive inert highway demolition material for disposal to fill the pit in the future. KMLP has not provided 

any documentation of consultation with the owner of the pit. KMLP believes that since the pipeline 

would be installed by HDD and be separated from the bottom of the pit by a distance determined to be 

safe by KMLP engineering analysis, no impact to the integrity of the pipeline is anticipated nor would it 

cause any disruption to the disposal operations. However, in order to minimize impact to the borrow pit 

at MP 52.7, we recommend that:

• Prior to the closing of the draft EIS comment period, KMLP file with the Secretary a 

letter from the borrow pit owner addressing the existing and future use of this resource.

Upon completion of pipeline construction, no excavations would be allowed within the operating 

pipeline right-of-way to recover sand or gravel. These resources are relatively abundant throughout the 

area so the Project would have no adverse effect on the future commercial use of sand and gravel if 

limited areas are excluded from mining. 

Based on this analysis, we believe the Project would have an inconsequential effect on mineral 

resources in the area. 

Seismicity and Faulting 

Hazards associated with seismicity and faulting include ground shaking, surface rupture of faults, 

and offset along normal, reverse, or strike-slip faults. These are especially hazardous to linear, rigid 

structures, such as pipelines, in which the ground is not moving the same distance or in the same 

direction. According to seismic hazard maps of the United States and Louisiana, the Project would be 

located in a region of low seismic risk (USGS 2006c). The Gulf Coast, including the Project area, is 

within Seismic Zone 0, the lowest seismic hazard category, according to the Uniform Building Code’s 

Seismic Risk Map (International Conference of Building Officials 1997). The peak ground acceleration 

(PGA) with 10 percent probability of exceedance over 50 years (i.e., annual frequency of exceedance of 

0.002) in the vicinity of the Project is estimated to be extremely low at between 1 and 2 percent of the 

gravity acceleration. An earthquake with PGA between 1 and 2 percent of the gravity acceleration would 

not result in damage to the pipeline. 

There are numerous growth faults located throughout the Gulf Coast Region, but they present 

little risk of earthquakes since no earthquakes have been definitely attributed to any of the specific 

mapped fault systems (McCulloh 2001). The pipeline likely crosses several growth faults. However, 
 4-7 Environmental Analysis

movement along these growth faults, if active, would be a slow creep, measured in a few millimeters or 

fractions of millimeters per year. The minimum wall thickness proposed for the KMLP Project would be 

sufficient to withstand any expected ground movement associated with these growth faults. 

Based on the low historic seismicity and the slow creep of the faults in the area, we believe 

seismicity and faulting would not present a significant risk to the Project. Further, construction and 

operation of the Project would not change the local seismic and faulting conditions. 

Soil Liquefaction 

Soil liquefaction is a condition that occurs when loosely packed deposits change from a solid to a 

liquid state because of increased pressure and reduced stress resulted from seismic shaking or other 

events. The horizontal PGA required to induce soil liquefaction is typically more than 10 percent of the 

gravity acceleration (Youd and Idriss 2001). Since the PGA in the vicinity of the Project is only 1 to 2 

percent of the gravity acceleration, the potential for soil liquefaction would be very low. 

Subsidence 

Subsidence is lowering of the land surface from changes that take place underground such as 

dissolution of limestone in karst terrain areas, mining or extraction of underground resources, and 

consolidation of sedimentary deposits. There is no karst terrain or underground mines in the Project area. 

Extraction of oil and gas and the consolidation of sedimentary deposits are known to cause ground 

subsidence in southern Louisiana. However, since this type of subsidence is a gradual movement of the 

land surface over generally large areas, with little or no localized differential settlement, the potential for 

subsidence to occur and affect the KMLP facilities is low. At the same time, the construction and 

operation of the KMLP facilities would not increase subsidence in the area. 

Flooding from Hurricanes and Other Major Storms 

Coastal areas of Louisiana are subject to flooding and shoreline erosion from storm surge and 

heavy precipitation associated with hurricanes, tropical storms, and other major storms. Most of the 

Project in Cameron and Calcasieu Parishes would be located in the 100-year floodplain as defined by the 

Federal Emergency Management Agency (FEMA). The northeast sections are primarily out of the 

floodplain except where it crosses lowlands associated with bayous and other waterbodies. In total, 55 

miles of the 132 miles (about 42 percent) of Leg 1 of the Project would be within the 100-year floodplain. 

After construction, the original grade would be restored. Construction, operation, and 

maintenance would not significantly alter the floodplain. Flooding could increase the buoyancy of the 

pipelines, causing them to rise to the surface and become exposed. In areas that are saturated or could 

become saturated with water, KMLP proposes to use concrete weight-coated pipe to counteract buoyancy. 

Major waterbodies would be crossed by HDD, which would place the pipe at least 20 feet below the 

waterbody and minimize the chance that the pipeline would be exposed due to scour by fast moving water 

and debris. Regular maintenance activities along the right-of-way would identify areas of soil erosion, 

exposed pipe, or other flood-related damage. KMLP would use terrace repair or backfill replacement in 

areas of concern. 

Based on these precautions, the potential for the project to increase the frequency or magnitude of 

flooding is very low. 
 4-8 Environmental Analysis

Slope Stability 

Impacts to slope stability include landslides, debris flows, and rock falls, which are generally 

associated with steep slopes and can be instigated by cutting slopes, the use of heavy equipment, and/or 

unusually heavy precipitation. Topography along the Project is characterized as flat to gently sloping 

where slope failure would not be expected. Steeper slopes are present at some navigation and stream 

channel banks, flood control levees, and construction excavation and fill areas such as where Leg 1 

crosses Bayou Cannes near MP 124.7. These areas are relatively short in length and therefore any sliding 

would not result in any damage to the pipe integrity. Pipeline construction would be accomplished in 

accordance with our Plan, which includes measures to control runoff and erosion and to minimize the 

potential for slope failures. With these measures, construction, operation, and maintenance of the Project 

would not affect slope stability. 

KMLP proposed an alternative measure to item V.A.5 of our Plan, which requires land surfaces 

to be restored to pre-construction contours, unless such contours threaten the integrity of the pipeline. 

While we agree with this concept, KMLP did not provide sufficient justification for the alternative 

measure either for the Project as a whole or for any particular sites. Therefore, we recommend that:

• KMLP comply with the requirements of item V.A.5 of our Plan. If KMLP identifies a 

location(s) where it can not implement item V.A.5, KMLP should file with the Secretary 

for review and written approval by the Director of OEP, any alternative measures that 

it would use to ensure pre-construction contours are restored without compromising 

pipeline integrity. 
 4-9 Environmental Analysis

4.2 SOILS 

4.2.1 Affected Environment 

The Project would cross three Major Land Resource Areas (MLRAs), as designated by NRCS 

(2006a). The Project would originate in the Gulf Coast Marsh MLRA, which is generally dominated by 

Saprist and Aquent soils. These are hydric soils susceptible to frequent flooding because the water table 

is at or above the surface most of the time. This area supports marsh vegetation and is primarily used for 

wildlife habitat. The Project would cross the Gulf Coast Prairies MLRA where Aqualfs are the dominant 

soils. The area naturally drains poorly and in the past it supported forest vegetation. At present this area 

is primarily artificially drained and farmed for hay, soybeans, grain, cotton, corn, and rice. The Project 

would terminate in the Western Gulf Coast Flatwoods MLRA in which Aqualfs, Udalfs, and Udults are 

the dominant soils. These soils range from poorly drained to moderately well drained. About 72 percent 

of the Western Gulf Coast Flatwoods MRLA is managed for harvest of pine and hardwoods. 

Table 4.2.1-1 presents basic characteristics of the soil series along the Project that could affect 

pipeline construction or maintenance, including the soil series or complex name (and corresponding soil 

map unit), soil texture, presence of hydric soils, drainage class, flooding frequency and duration, presence 

of prime farmland, erosion factor, and compaction potential. All of the soils present at the interconnect 

sites are crossed by the pipeline with the addition of one map unit, Aquents (AN), and one soil complex, 

Hackberry-Mermentau (Hm). These characteristics were identified using data from NRCS’s online Soil 

Survey Geographic Database (NRCS 2006b and 2006c). 

Soil characteristics determine its susceptibility to erosion, flooding, and compaction, or make it 

suitable for agricultural uses. The erosion factor of a soil represents the likelihood of the soil to erode as 

determined by soil detachment and water infiltration properties. In general, the soils that would be 

crossed by the Project are low to moderately susceptible to erosion with erosion factors ranging from 0.24 

to 0.49. The majority of soils that would be crossed by the Project drain somewhat poorly to very poorly. 

The majority of soils also experience frequent and long duration flooding events and are characterized as 

hydric soils. Drainage properties, frequency and duration of flooding events, or the classification as 

hydric soils are all indicators of the relative wetness of the soil under natural conditions. Soil compaction 

can modify the structure and natural properties of the soil and affect hydrology, erodibility, and 

revegetation. Approximately 50 miles of the Project would cross soils with a severe compaction 

potential. None of the soils crossed have shallow bedrock and no blasting would be required during 

pipeline construction. All of the soils have a good revegetation potential after construction disturbance. 

Approximately two-thirds of the Project would cross through soils designated as prime farmland by 

NRCS. Soils designated as prime farmland provide the highest crop yield per unit energy expended due 

to the favorable conditions of the soils for agricultural production. 

4.2.2 Impacts and Mitigation 

4.2.2.1 Construction Impacts 

Construction activities associated with the Project, such as clearing, grading, trenching, and 

backfilling, have the potential to affect soil resources through multiple mechanisms. The most significant 

effects include the potential increases in soil erosion and compaction, the loss of soil productivity and 

fertility by mixing of topsoil and subsoil horizons, and changing drainage patterns. Removal of 

vegetative cover increases the possibility of erosion by wind and water. Mixing of topsoil with subsoil 

and compaction caused by passage of heavy construction equipment can adversely affect revegetation 
4-10 

TABLE 4.2.1-1 

Soils Crossed by the Proposed KMLP Pipeline 

Cumulative 

Length 

Crossed 

(miles) Map Unit 

Soil Series 

or 

Complex Namea Soil Texture 

Hydric

Soil? 

Drainage 

Class 

Flooding 

Frequency 

and 

Duration 

Prim

Farmla

1.3 AcB Acadia Silt loam No Somewhat Poorly N/A Yes 1.5 AdB Acadiana Silt loam No Moderately Well None Yes 1.2 AN Aquents Silty clay loam/silty 

clay/clay 

n/a Very Poorly Frequent No 

0.9 BA Bancker Muck Yes Very Poorly Frequent, Very 

Long 

No 

0.8 BSA Basile and Brule Silt loam/silty clay 

loam 

Yes Poorly (Basile), Moderately 

Well (Brule) 

Frequent, Long No 

0.1 BEA Basile and 

Cascilla 

Silt loam Yes Poorly Frequent, Very 

Long 

No 

0.7 Bw BasilenWrightsville Silt loam Yes Poorly Frequent, Long No 1.8 CO Clovelly Muck Yes Very Poorly Frequent, Very 

Long 

No 

1.2 CR Creole Mucky clay Yes Very Poorly Frequent, Very 

Long 

No 

6.5 Cr, CrA, 

CrB, 

Crowley Silt loam No Somewhat Poorly None Yes 

30.7 Cv Crowley-Vidrine Silt loam No Poorly, Somewhat Poorly N/A Yes 

0.1 FrA Frost Silt loam Yes Poorly Occasional, Brief Yes 1.1 GB Ged Clay Yes Very Poorly Frequent, Long No 3.1 GC Gentilly Muck Yes Very Poorly Frequent, Very 

Long 

No 

0.1 IoD Iota Silt loam No Well N/A No 0.9 Je Jeanerette Silt loam No Poorly N/A Yes 
4-11 

TABLE 4.2.1-1 (continued) 

Soils Crossed by the Proposed KMLP Pipeline 

Cumulative 

Length 

Crossed 

(miles) Map Unit 

Soil Series 

or 

Complex Namea Soil Texture 

Hydric

Soil? 

Drainage 

Class 

Flooding 

Frequency 

and 

Duration 

Prim

Farmla

1.7 Ju Judice Silty clay loam Yes Poorly Rare, Brief Yes 4.2 KpA, KpB Kaplan Silt loam No Somewhat Poorly N/A Yes 4.3 KvA Kinder-Vidrine Silt loam Yes Poorly N/A Yes 4.9 Lt, LeA Leton Silt loam Yes Poorly Rare, Brief Yes 0.4 MaB Mamou Silt loam No Somewhat Poorly N/A Yes 0.1 ME Mermentau Clay Yes Poorly Frequent, Brief No 0.7 Mn, MdA Midland Silty clay loam/silt 

loam 

Yes Poorly Rare, Brief Yes 

11.9 Mr Morey Loam No Poorly Rare, Brief Yes 

5.0 Mt, MtA Mowata Silt loam Yes Poorly N/A Yes 

14.7 Mt, MwA Mowata-Vidrine Silt loam Yes Poorly N/A Yes 

0.6 Pc PatoutvilleCrowelly Silt loam No Somewhat Poorly N/A Yes 1.9 SC Scatlake Mucky clay Yes Very Poorly Frequent, Very 

Long 

No 

12.6 UA, UD Udifluvents, 

varies 

Varies No N/A None No 

0.1 Up Urban Land N/A No N/A None No 

16.7 W Water, Large N/A n/a N/A None N/A 

5.5 Wv WrightsvilleVidrine Silt loam Yes Poorly and Somewhat Poorly N/A Yes 

_______________ a Soil series descriptions are from the Official Soil Series Descriptions (OSD) maintained by NRCS 
 4-12 Environmental Analysis

potential and agricultural productivity. Alteration of the surface topography can affect hydrology, 

influencing stormwater runoff and soil drainage patterns. 

In general, the above impacts would be avoided or minimized through implementation of our 

Plan. The Plan is intended to identify baseline mitigation measures for minimizing erosion and enhancing 

revegetation. These measures include erosion controls, reducing soil disturbance, and reestablishing 

preconstruction contours and vegetative cover as soon as practicable. Some of the relevant aspects of our 

Plan include: 

• segregate a maximum of 12 inches of topsoil in all actively cultivated or rotated croplands, 

pastures, residential areas, hayfields, and at other areas at the request of the landowner or land 

management agency; 

• provide temporary erosion and sediment control measures such as silt fences, straw bales, 

slope breakers, seeding, mulch, and erosion control fabric to minimize any impacts related to 

soil erosion and sedimentation that may result from precipitation runoff; 

• mitigate soil compaction following construction and right-of-way restoration activities, as 

described below; 

• ensure revegetation of all areas disturbed by project-related activities; disturbed upland areas 

would be seeded in accordance with written recommendations from local conservation 

authorities or as requested by the landowner; 

• provide post-construction monitoring of mitigation practices to ensure their success; and 

• utilize EIs to ensure implementation of the practices outlined above.

Erosion

The soils affected by the Project have a low to moderate susceptibility to erosion, and 

construction activities would remove vegetative cover and expose soils to erosive forces. Without 

mitigative measures, soil erosion can degrade soil quality, adversely affect nearby waterbodies, and 

impair revegetation efforts. KMLP would implement erosion control practices during construction and 

operation of the Project. Temporary control measures would be installed immediately after initial soil 

disturbance. Disturbed areas would be restored to their original contours and revegetation efforts would 

begin within six days of final grading, weather and soil conditions permitting. With the implementation 

of the above measures, we believe impacts associated with soil erosion would be minimized. 

Soil Compaction

Soil compaction during construction is caused by heavy construction equipment or other 

unauthorized vehicles. Soil compaction damages the structure of the soil and reduces transport of air and 

water to plant roots. Compacted soils may have lower productivity, slower plant growth, increased 

erosion, and change natural drainage of water. Approximately 50 miles of the Project and 11 of the 

interconnect sites would affect soils with a high soil compaction potential. In these areas, use of heavy 

equipment would result in compaction. Some of these impacts would be avoided by the use of HDD 

especially under waterbodies. In other areas, board roads or low-ground pressure equipment would be 

used to prevent severe compaction. The heavy equipment that would be used to construct the Project are 
 4-13 Environmental Analysis

tracked vehicles, with a ground pressure (i.e., pounds per square foot) similar to or less than the large 

four-wheel-drive tractors commonly used for rice farming in the region. 

In areas with compaction potential, KMLP would implement the measures specified in our Plan, 

as appropriate for the site-specific conditions, such as the use of a para-plow or other deep tillage 

equipment. Alternatively, KMLP may plant and plow under a green manure crop (a growing crop that is 

plowed under) to decrease soil density, with landowner approval. 

In rice fields and crawfish ponds, KMLP would attempt to schedule construction when fields are 

not normally flooded or negotiate with landowners to defer flooding so that construction would occur 

when the soils are dry. Drier soil conditions would allow KMLP to ensure that a reasonable degree of 

compaction at near-optimum moisture content can be achieved when backfilling the pipe trench. KMLP 

would ensure that the low permeability layer underlying the field is re-installed to near pre-construction 

conditions in order to contain water during subsequent flooding for crop production. With these 

measures, we believe impacts associated with soil compaction would be minor and temporary. 

Hydric Soils

Hydric soils are formed under conditions of saturation, flooding, or ponding long enough to cause 

anaerobic conditions. Hydric soils are poorly drained soils, and may still be considered hydric if 

artificially drained or protected from flooding. The status of hydric soils is part of the definition used by 

the COE to determine wetland status. The majority of soils that would be affected by the Project are 

hydric soils. Construction activities can cause compaction and rutting of hydric soils. Due to the unique 

condition of these wetland soils, special construction techniques would be used for construction in 

wetland areas, as described in section 2.3.1.2, to minimize impacts. Following construction, KMLP 

would restore these areas to their pre-construction conditions including restoring drainage systems and 

original contours. With these measures, we believe KMLP would minimize impacts to hydric soils. 

Revegetation

All of the soils that would be affected by the Project have a moderate to good revegetation 

potential. KMLP would restore affected areas to preconstruction conditions as practicable in accordance 

with our Plan and Procedures. For example, in upland areas, an herbaceaous layer would be reestablished by seeding. The type of seed would be selected to match adjacent cover or as requested by the 

landowner, management agency, or county extension agent. In agricultural areas, revegetation would be 

considered successful if crop yields are similar to adjacent undisturbed portions of the same field. In 

wetlands, revegetation would occur by the transplantation of similar mature specimens from adjacent 

areas or temporary nurseries. Revegetation efforts in wetlands would be monitored by KMLP until a 

cover similar to 80 percent of adjacent areas is achieved. If revegetation efforts in wetlands are not 

successful at the end of 3 years, KMLP would develop and implement a remedial revegetation plan to 

actively revegetate the wetland. Revegetation in wetlands would also be controlled according to a 

project-specific Aquatic Resources Mitigation Plan that KMLP would finalize in consultation with COE, 

FWS, and NOAA Fisheries Service (see section 4.4.2). Forested areas would also be recovered in a 

similar manner, except for in the permanent right-of-way where shrubs and small trees are not allowed. 

The areas inside interconnections would be permanently converted to an industrial use and covered with 

crushed rock around piping and equipment or reseeded with an easily maintained grass. 

Soil Contamination 

A potential impact during construction would include the accidental release of petroleum 

hydrocarbons or other hazardous materials, as well as the discovery of contaminated soils during trench 
 4-14 Environmental Analysis

excavation and grading activities. As discussed in section 2.3, KMLP would develop and implement a 

project-specific SWPPP and SPRP that provide a description of the containment and cleanup procedures 

that would be employed in the event of a spill or a leak of hazardous materials. In section 2.3 we are 

recommending these project-specific plans be filed with the Secretary for review and approval prior to 

construction. 

There are no known contaminated soils in the Project area. KMLP searched the National 

Priorities List (EPA 2006a), Leaking Underground Storage Tanks database (LDEQ 2006a), and Louisiana 

Department of Environmental Quality (LDEQ) Voluntary Remediation Program (LDEQ 2006b) and 

found no known contaminated sites within 0.25 miles of the Project. Further, no contaminated soils were 

identified during field studies. Although the potential to encounter contaminated soils during pipeline 

construction is relatively low, KMLP’s application proposed several steps that would be followed in the 

event contaminated soils are encountered, including immediately stopping working in the vicinity, 

restricting access to the suspected area, engaging qualified contractors to determine the nature and extent 

of contamination, notifying applicable environmental authorities, and devising site-specific plans for 

cleanup, risk minimization, and continued construction. To ensure that such steps are actually developed 

and implemented, and that they also address contaminated groundwater that may be associated with the 

soils, we recommend that: 

• Prior to construction, KMLP file with the Secretary for review and written approval by the 

Director of OEP, a Plan for the Discovery and Management of Contaminated Soils and 

Groundwater. 

With the use of KMLP’s proposed measures and our recommendation, we believe the risks 

associated with soil contamination would be minimized. 

Prime Farmland

The USDA defines prime farmland as “land that is best suited to food, feed, fiber, and oilseed 

crops” (USDA 1993). This designation includes cultivated land, pasture, woodland, or other lands that are 

either used for food or fiber crops or are available for these uses. Urbanized land and open water are 

excluded from prime farmland. Prime farmland typically contains few or no rocks, is permeable to water 

and air, is not excessively erodible or saturated with water for long periods, and is not subject to frequent, 

prolonged flooding during the growing season. Soils that do not meet the above criteria may be 

considered prime farmland if the limiting factor is mitigated (e.g., artificial drainage). 

Approximately 79 percent (1,437 acres) of the soils that would be affected during construction by 

the KMLP project are considered prime farmland. Impacts on prime farmland from construction of the 

proposed pipelines could include interference with agricultural drainage (if present), mixing of topsoil and 

subsoil, and compacting and rutting. These impacts would result primarily from trench excavating and 

backfilling, and vehicular traffic along the construction right-of-way. 

KMLP would minimize impacts on prime farmland by constructing the pipelines in accordance 

with our Plan and Procedures. Mitigation measures employed to minimize impacts on prime farmland 

would include topsoil segregation, compaction relief, removal of excess rock, and restoration of 

agricultural drainage systems. Any drain tiles, culverts, or other items damaged during construction would 

be repaired or replaced to preconstruction conditions. Adherence to these measures would minimize 

impacts on prime farmland and other agricultural land and would promote the long-term productivity of 

the soil. In addition, impacts caused by the pipeline faculties would be temporary and would not result in 

permanent conversion of prime farmland to non-agricultural uses. 
 4-15 Environmental Analysis

However, at the nine interconnect sites with soils designated as prime farmland, the operation of 

these sites would result in the permanent conversion of approximately 7.7 acres of prime farmland to 

industrial land. 

4.2.2.2 Operation Impacts 

Operation activities are not expected to result in further impacts to soil resources. The SWPPP 

and SPRP would remain effective during operation of the pipeline to minimize and mitigate impacts of 

soil contamination. Monitoring activities would include surveys for soil erosion or other conditions that 

may expose or harm the pipeline, or indicate a leak in the pipeline. 
 4-16 Environmental Analysis

4.3 WATER RESOURCES 

4.3.1 Groundwater 

Although the depth to groundwater is variable along the proposed pipeline route, it is often found 

at or near the ground surface. In all five parishes crossed by the KMLP Project, groundwater is the 

primary or only source of public water supply (LDOTD 2002). Four of the parishes crossed by the 

proposed pipeline utilize groundwater for the majority of their total water usage. In these parishes, 

groundwater is primarily used in the irrigation of rice fields (Jefferson Davis, Acadia, and Evangeline 

Parishes), for industrial purposes (Calcasieu Parish), and as a public water supply. Information regarding 

the groundwater resources located along the proposed pipeline route, including aquifers, Sole Source and 

primary source aquifers, wellhead protection areas, wells and springs, and contaminated groundwater, is 

presented below. 

4.3.1.1 Affected Environment 

According to the USGS, the Project is underlain by the Coastal Lowlands Aquifer System (USGS 

1998) which extends from coastal counties in Texas eastward into the Coastal Plain of Louisiana, 

Mississippi, and to a smaller extent southern Alabama and the western part of the Florida panhandle. 

Groundwater derived from the Coastal Lowlands Aquifer System is used for agricultural, public supply, 

commercial, and industrial purposes. This system is divided into five permeable zones (A–E) consisting 

of discontinuous beds of sand, silt, and clay. Permeable Zone A has also been referred to as the top layer 

of the Chicot Aquifer. The Chicot Aquifer underlies about 9,900 square miles of Louisiana, extending 

west from the Atchafalaya River into southern Texas and south to the Gulf of Mexico. The landward 

boundary of the aquifer consists of outcrop areas where the aquifer system feathers out at a point of 

contact with the underlying Vicksburg-Jackson confining unit (Lovelace et al. 2004). The Gulf-ward 

boundary is near the coastline where the water becomes increasingly saline and the upper boundary is the 

land surface (Ryder 1996). The Chicot Aquifer is the most heavily pumped aquifer system in 

southwestern Louisiana and provides approximately 800 million gallons of water per day for a variety of 

uses. The primary use is for agriculture (68 percent), in particular, rice irrigation. Other uses include 

public water supply (11 percent), industrial (9 percent), aquaculture (8 percent), power generation (2 

percent), and other (2 percent) (LSU AgCenter 2001). The Chicot Aquifer ranges from 50 to 1,050 feet in 

thickness and is composed of Pleistocene interbedded sands, silt, gravel, and clay deposited in fluvial, 

deltaic, and near-shore marine environments. 

Sole Source and Primary Source Aquifers 

In southwestern Louisiana, the Chicot Aquifer is designated as an EPA Sole Source Aquifer 

(USEPA 2006b). A Sole Source or primary source aquifer is defined by the EPA as an aquifer that 

supplies a minimum of 50 percent of the drinking water used in the area overlying the aquifer. The areas 

served by these aquifers may not have readily available alternate water sources. In southwestern 

Louisiana, the Chicot Aquifer is designated as an EPA Sole Source Aquifer (USEPA 2006b). All five 

parishes crossed by the KMLP Project utilize the Chicot Aquifer. 

Wellhead Protection Areas 

Wellhead protection areas are designated to protect drinking water supplies obtained from 

municipal or community wells. KMLP identified 10 wellhead protection areas that would be crossed by 

the Project. The locations of these wellhead protection areas are listed in table 4.3.1.1-1. 
 4-17 Environmental Analysis

TABLE 4.3.1.1-1 

Drinking Water Wellhead Protection Areas That Would be Crossed by the KMLP Project 

Aquifer Parish Begin MP End MP 

Chicot Aquifer Calcasieu Parish 50.8 52.4 

Chicot Aquifer Calcasieu Parish 51.0 52.8 

Chicot Aquifer Calcasieu Parish 53.5 54.3 

Chicot Aquifer Calcasieu Parish 56.2 57.2 

Chicot Aquifer Calcasieu Parish 58.0 59.1 

Chicot Aquifer Calcasieu Parish 59.8 61.3 

Chicot Aquifer Calcasieu Parish 73.8 74.7 

Chicot Aquifer Jefferson Davis Parish 75.6 77.8 

Chicot Aquifer Jefferson Davis Parish 95.7 96.9 

Evangeline Aquifer Evangeline Parish 119.6 121.7 

Wells and Springs 

Based on information provided by the Louisiana Department of Transportation and Development, 

28 wells would be located within 150 feet of the construction right-of-way, including eight domestic 

supply wells (two of which are either abandoned or plugged), two industrial wells, nine irrigation wells, 

four monitoring wells (all four are plugged), and five rig supply wells (three of which are plugged). 

These wells and their locations relative to the Project are listed in table 4.3.1.1-2. Because the locations 

of these wells are not precise, KMLP would confirm actual well locations in the field prior to construction 

and provide us with that information. In addition to the wells identified within 150 feet of the 

construction right-of-way listed in table 4.3.1.1-2, there are three wells located within 400 feet of 

proposed construction work areas. These include two domestic supply wells located approximately 194 

feet from the construction workspace near MP 104.2. There is also one rural public supply well located 

approximately 314 feet from the construction workspace near MP 120.7. 

No springs have been identified within the vicinity of the Project and therefore, construction and 

operation of the proposed project would not affect springs. 

Contaminated Groundwater 

No instances of contaminated groundwater have been identified within the vicinity of the Project. 

4.3.1.2 Impacts and Mitigation 

Construction of the proposed pipeline would result in several effects to groundwater resources 

including the Chicot Aquifer, which has been designated by the EPA as a Sole Source aquifer and 

wellhead protection area. Effects resulting from construction include temporary and permanent changes 

to infiltration/recharge rates, groundwater flow, and groundwater quality. Specifically, construction 

activities such as clearing and grading would alter local infiltration/recharge rates, which would affect the 

quality and quantity of groundwater resources within the immediate vicinity of the Project. Additionally, 

trenching, trench dewatering, and backfilling would alter infiltration/recharge rates and groundwater flow, 
 4-18 Environmental Analysis

TABLE 4.3.1.1-2 

Wells Located Within 150 Feet of the KMLP Projecta

Well Type Parish 

Approximate 

MPb

Approximate 

Well Depth 

(feet) 

Approximate 

Distance from 

Centerline 

(feet) 

Approximate 

Distance from 

Construction 

Workspace 

(feet) 

Rig Supply Calcasieu 31.1 606 88.0 13.0 

Industrial Calcasieu 34.3 603 155.0 120.0 

Industrial Calcasieu 34.3 780 82.2 47.2 

Monitoring Calcasieu 44.8 16 8.6 0.0 

Monitoring Calcasieu 44.8 77 8.6 0.0 

Monitoring Calcasieu 44.9 38 80.8 0.0 

Monitoring Calcasieu 44.9 38 80.8 0.0 

Rig Supply Calcasieu 48.4 242 29.9 0.0 

Rig Supply Calcasieu 49.6 265 14.7 0.0 

Domestic Calcasieu 54.1 245 102.0 67.0 

Domestic Calcasieu 55.5 249 36.6 0.0 

Irrigation Calcasieu 61.6 0 214.8 124.8 

Domestic Calcasieu 62.6 205 8.3 0.0 

Irrigation Calcasieu 65.1 30 148.3 113.3 

Rig Supply Calcasieu 69.3 240 154.2 64.2 

Domestic Calcasieu 71.0 215 234.9 144.9 

Domestic Jefferson Davis 87.8 145 96.0 0.0 

Domestic Jefferson Davis 87.8 145 96.0 0.0 

Irrigation Jefferson Davis 90.0 296 188.8 128.8 

Irrigation Jefferson Davis 91.4 0 139.3 95.6 

Irrigation Jefferson Davis 91.4 311 10.4 0.0 

Rig Supply Jefferson Davis 91.4 251 10.4 0.0 

Irrigation Jefferson Davis 94.3 260 53.1 18.1 

Domestic Acadia 106.8 168 32.0 0.0 

Irrigation Evangeline 121.6 275 68.4 0.0 

Domestic Evangeline 124.9 0 48.6 13.6 

Irrigation Evangeline 127.1 235 39.3 4.3 

Irrigation Cameron 0.6 255 200.3 114.2 

_______________ 

a Actual well locations may vary by as much as 100 feet due to the level of accuracy associated with well coordinate data. 

KMLP would confirm the actual location of the wells prior to construction. b All MPs are on Leg 1 except for the last row (MP 0.6), which is on the FGT Lateral. 

which would also result in changes to the quality and quantity of groundwater resources within the 

immediate vicinity of the Project. The disturbance of unknown contaminants and/or an inadvertent 

release of fuel and/or equipment-related fluids during construction could also affect groundwater quality. 

In order to minimize effects to groundwater resources resulting from construction of the Project, 

KMLP would implement groundwater-related measures described in our Procedures, including 
 4-19 Environmental Analysis

stormwater management measures, spill prevention and response procedures, and minimization measures 

related to the discharge of trench water and trench breakers. We are recommending that KMLP develop a 

plan for the Discovery and Management of Contaminated Soil and Groundwater to address encounters 

with unanticipated groundwater and soil contamination during construction (see section 4.2.2.1). 

Implementation of this plan would ensure that any previously existing groundwater contamination that 

may be encountered during construction would be managed in accordance with applicable regulatory 

requirements. Following construction, KMLP would also restore contours and manage the revegetation 

of affected lands, both of which would minimize effects to groundwater resources resulting from 

construction of the Project. 

Additionally, in order to minimize potential adverse effects to wells resulting from construction 

of the Project, KMLP would notify landowners in the general vicinity of the proposed construction rightof-way of their ability to request well testing and monitoring prior to and after construction. This 

monitoring would include water quality and well yield. KMLP has not stated the steps it would take if 

impaired water quality or well yield were observed; therefore, we recommend that: 

• Prior to construction, KMLP file with the Secretary a statement that if water quality or 

yield were found to be impaired due to the Project, KMLP would provide a temporary 

water supply and re-test the well within 30 days. In addition, KMLP should replace any 

potable water supply system that it damages during construction and cannot repair to 

its former capacity and quality. KMLP should identify in its report to the Secretary all 

potable water supply systems damaged by construction and how they were repaired. 

In general, operation of the Project would not significantly affect groundwater resources; 

however, the development of impervious surfaces and structures in association with the proposed 

aboveground facilities would result in minor effects to groundwater resources due to the alteration of 

infiltration/recharge rates. 

Based on the characteristics of the identified groundwater resources, KMLP’s proposed 

construction methods and operations procedures, and its implementation of groundwater-related measures 

described in our Procedures, as well as the acceptance of our recommendations, we believe that impacts 

to groundwater resources resulting from construction and operation of the Project would be temporary 

and localized, and would not significantly affect overall groundwater quantity and quality. 

4.3.2 Surface Water 

This section identifies the waterbodies that would be affected by the Project, and describes them 

and the impacts to them resulting from construction and operation of the Project. All affected 

waterbodies, with the exception of Sabine Lake and the Calcaseiu River which are addressed individually 

in section 4.3.2.3, are addressed in the following sections. 

4.3.2.1 Affected Environment 

Construction of the proposed pipeline would require 310 waterbody crossings. Appendix G 

identifies each of these crossings, their location, the proposed crossing method, the width of crossing, the 

waterbody type, and the impairment status and significance to fisheries/potable water sources, if 

applicable. 

In Louisiana, waterbodies have been designated by LDEQ which has developed a series of 

standards to maintain water quality, consistent with the associated goals of protecting public health, 

conserving fish and wildlife, and enhancing economic development, in accordance with a use(s) that 
 4-20 Environmental Analysis

characterizes the best intended use(s) of that waterbody. These designated uses include primary contact 

recreation; secondary contact recreation; fish and wildlife propagation; limited aquatic life and wildlife 

use; drinking water supply; oyster propagation; agriculture; outstanding natural resource waters; and no 

quality/use. With the exception of 12 waterbodies which account for 18 waterbody crossings, all of the 

identified waterbodies crossed by the proposed pipeline have been designated “no water quality/use.” 

The designated uses of the 12 waterbodies with uses other than “no water quality/use” are provided in 

table 4.3.2.1-1. 

TABLE 4.3.2.1-1 

Water Quality/Use Designations Other Than No Quality/Use 

Waterbody Name Designated Usea Number of Crossings 

Sabine Lake ABCE 1 

Sabine River ABC 4 

Burton Shell Slip ABC 1 

Black Bay Cutoff ABC 1 

GIWW ABC 2 

Vinton Drainage Canal ABC 1 

Bayou Choupique ABC 1 

Calcasieu River ABCE 1 

East Bayou Lacassine ABCF 2 

Gum Gully AB 1 

Bayou Nezpique ABCF 1 

Bayou des Cannes ABCF 2 

_______________ 

a Designated use codes for affected waterbodies: A - Primary Contact Recreation; B - Secondary Contact Recreation; C - Fish and 

Wildlife Propagation; E - Oyster Propagation; F – Agriculture.

The proposed pipeline would also cross 13 major waterbodies (16 waterbody crossings): Sabine 

Lake, Sabine River, Black Bay Cutoff, GIWW, Vinton Drainage Canal, Bayou Choupique, Calcasieu 

River, Calcasieu Tributary, Calcasieu Tributary (swamp), two unnamed waterbodies, Bayou Nezpique, 

and Tiger Point Gulley. Major waterbodies are those that are larger than 100 feet in width at the point of 

crossing. There is no official list of navigable waters in Louisiana, but numerous waterbodies that would 

be affected by the Project have been characterized as navigable, including Sabine Lake, Sabine River, 

Black Bay Cutoff, GIWW, and Calcasieu River. 

Sensitive Waterbodies 

Sensitive waterbodies generally include waterbodies that do not meet designated water quality 

standards; have been designated for intensified water quality management and improvement; contain 

threatened and endangered species or critical habitat; would be crossed less than three miles upstream of 

potable water intake structures; are classified as outstanding or exceptional quality waterbodies; are 

waters of particular ecological and recreational importance; are located in sensitive and protected 

watershed areas; have steep banks, potentially unstable soils, high-volume flows, and actively eroding 

banks; have associated important riparian areas; and are on or designated to be added to the Nationwide 

Rivers Inventory or a state river inventory. 
 4-21 Environmental Analysis

Sensitive waterbodies that have identified water quality impairments are identified in 

table 4.3.2.1-2. Sensitive waterbodies containing EFH and commercial and/or recreational fisheries are 

addressed in section 4.6. All other sensitive waterbodies are addressed as appropriate in sections 4.5 – 

4.8. As mentioned previously, Sabine Lake and the Calcasieu River are addressed in section 4.3.2.3. 

TABLE 4.3.2.1-2 

Sensitive Waterbodies Affected by the Proposed Project 

Waterbody Name MP of Crossing Impairment 

Vinton Drainage Canal 32.2 (Leg 1) Turbidity 

Bayou Choupique 44.3 (Leg 1) Dissolved oxygen 

East Bayou Lacassine 84.9 and 88.5 (Leg 1) Dissolved oxygen 

Bayou Nezpique 99.4 (Leg 1) Nitrate/nitrite, dissolved oxygen, sedimentation/siltation, total 

fecal coliform, total phosphorus, total suspended solids (TSS), 

and turbidity 

Bayou des Cannes 124.7 (Leg 1) and 1.57

(FGT Lateral) 

Carbofuran, fipronil, mercury, nitrate/nitrite, dissolved oxygen, 

sedimentation/siltation, total fecal coliform, total phosphorus, 

TSS, and turbidity 

Waterbody Crossing Methods

As described in section 2.3.1.3 and listed in appendix G, waterbody crossings would be 

conducted using conventional open-cut construction methods, flumes, boring techniques, and HDDs. Of 

the 310 waterbody crossings that would be required for construction of the proposed pipeline, 133 would 

be completed using open-cut methods, three would be completed using flumes, 147 would be completed 

using boring techniques, 24 would be completed using HDDs, and 3 would be completed using a 

combination of open-cut methods and HHDs. 

Waterbody crossings that would be completed using HDDs are listed in table 4.3.2.1-3. 

TABLE 4.3.2.1-3a

Features Crossed Using HDD Along the Kinder Morgan Louisiana Pipeline 

Directional 

Drill Number 

Approximate 

Entry MP 

Approximate 

Exit MP 

Length of Drill 

(feet) Features Crossed 

1 3.9 4.8 4,752 Big Forge Bayou; Wetlands; 

Southern Bank of Sabine Lakeb

2 18.0 18.6 3,485 Northern Bank of Sabine Lake; 

Wetlands; Mouth of Sabine Riverb,c

3 18.6 19.4 4,171 Sabine River;b,c Wetlands 

4 19.4 20.0 3,168 Sabine River;b,c Wetlands 

5 21.2 22.1 4,963 Sabine River;b,c Wetlands 

6 22.1 22.7 3,168 Sabine River;b,c Pipelines; Wetlands; 

Canal 

7 23.4 24.0 2,640 Burton Shell Slip; Pipelines; 

Wetlands 

8 25.3 26.0 4,066 Pipelines; Wetlands 

9 26.0 26.8 4,066 Pipelines; Wetlands 
 4-22 Environmental Analysis

TABLE 4.3.2.1-3a (cont’d) 

Features Crossed Using HDD Along the Kinder Morgan Louisiana Pipeline

Directional 

Drill Number 

Approximate 

Entry MP 

Approximate 

Exit MP 

Length of Drill 

(feet) Features Crossed 

10 30.4 31.5 5,808 Canal; Black Bay Cutoff;b

 GIWW;b

Pipelines 

11 31.5 32.4 5,069 Vinton Drainage Canal;b

 Wetlands; 

Pipelines 

12 43.7 44.5 4,171 Bayou Choupique;b Wetlands 

13 49.6 50.5 4,646 Calcasieu River;b

 Pond; Dredge Spoil 

Area 

14 50.5 51.3 4,488 Canal; Calcasieu Tributary;b Marina 

15 51.8 52.4 3,115 Industrial Area; Road 

16 52.4 53.1 3,590 Calcasieu Tributary (swamp);b

Forest; Unnamed Waterbody; Borrow 

Pit 

17 77.7 78.4 3,960 Agricultural Waterbodies;b,d

Interstate-10 

18 99.0 99.8 3,907 Bayou Nezpique;b Wetlands 

_______________ 

a Table includes three HDDs (Numbers 8, 9, and 15) not associated with a waterbody crossing. b Waterbodies greater than 100-feet wide at the proposed crossing. c

 Temporary construction areas limited to barges and flotation areas for HDD strings would extend into the Sabine River. d

 HDD 14 crosses 7 different agricultural waterbodies, 2 of which are greater than 100-feet wide.

KMLP has proposed to file with the Secretary prior to construction site-specific construction 

plans for all areas disturbed by construction at each major waterbody crossing; however, the site-specific 

construction plans for the major waterbody crossings filed by KMLP in its application are incomplete; 

therefore, to fully assess the potential impacts associated with these crossings, we recommend that:

• KMLP file with the Secretary a site-specific construction plan for the crossing of each 

waterbody proposed as a HDD crossing. These site-specific plans should include scaled 

drawings identifying all areas that would be disturbed by construction. KMLP should 

file these plans for review and written approval by the Director of the OEP along with 

the COE permit prior to construction across those waterbodies.

With one exception, all major waterbodies would be crossed using HDDs. Tiger Point Gulley is 

the only major waterbody that KMLP has not proposed to cross using a HDD. However, the FWS, COE, 

and the LDWF have recommended that Tiger Point Gulley along with Bayou Barwick and Bayou des 

Cannes be crossed using HDDs to avoid and minimize impacts to these waterbodies and adjacent 

resources; therefore we recommend that: 

• KMLP evaluate the feasibility of using the HDD method to cross Tiger Point Gulley at 

MP 113.3 and Bayou Barwick at MP 109.2 along Leg 1 and Bayou des Cannes along the 

FGT Lateral at MP 1.57, and develop a site-specific construction plan for each of these 

crossings in coordination with FWS and LDWF that clearly identifies all construction 

work areas including the laydown area for the pipe string if the HDD method is 

determined to be feasible. KMLP should file the results of its evaluation, the site-
 4-23 Environmental Analysis

specific construction plans, and any agreed-upon mitigation measures to minimize 

impacts on riparian areas and the associated forested wetlands. KMLP should file the 

above information with the Secretary for review and written approval by the Director 

of OEP prior to the close of the comment period on this draft EIS. 

Additionally, the use of three new access roads would require the crossing of three waterbodies. 

Two of the new access roads, Access Roads 15 and 19 at MPs 52.3 and 61.4 of Leg 1, respectively, would 

cross roadside drainage ditches, and the third access road would cross a minor tributary of Bayou des 

Cannes (Access Road FGT-2 at MP 2.3 of the FGT Lateral). KMLP has stated that access road 

improvements would include grading, placement of gravel for stability, replacing or installing culverts, 

and clearing of overhead vegetation; however, it does not specify how these waterbodies would be 

crossed and the COE has indicated that drainage ditches in this region function as flowing waters (COE, 

2006) and must be protected as waterbodies; therefore, we recommend that: 

• Prior to construction of Access Roads 15, 19, and FGT-2, KMLP reroute these access 

roads to avoid crossing drainage ditches at MPs 52.3 and 61.4 of Leg 1, and avoid 

crossing Bayou des Cannes Tributary at MP 2.3 of the FGT Lateral. KMLP should file 

with the Secretary the reroutes for these access roads, copies of the revised alignment 

sheets, and necessary environmental information for review and written approval by 

the Director of OEP. 

If any of these access roads can not be rerouted, KMLP should provide: 

a. justification why rerouting is infeasible; 

b. documentation of consultation with COE, including proposed mitigation measures; 

c. construction plans for these access roads; 

d. copies of necessary permits/approvals; and 

e. landowner concurrences. 

KMLP should not use these access roads until the Director or OEP notifies KMLP in 

writing that it may proceed. 

Minimization Measures 

In order to minimize potential impacts to waterbodies resulting from the construction of the 

proposed pipeline, KMLP would implement the measures described in our Procedures, which include: 

• a requirement to obtain all necessary permits from the COE and state agencies prior to 

construction and notify applicable state agencies at least 48 hours before commencing with 

instream trenching; 

• use of EIs during construction; 

• routing the proposed pipeline as close to perpendicular to the axis of the waterbody as 

practicable and minimize the number of individual crossings where waterbodies meander or 

have multiple channels; 

• limiting the use of equipment within the waterbody to that necessary to construct the 

crossing, and utilize equipment bridges for passage of other construction equipment; 

• placing spoil at least 10 feet away from the water’s edge with installation of sediment barriers 

to prevent the flow of spoil or silt-laden water into the waterbody; 
 4-24 Environmental Analysis

• completing all instream construction activity, including stabilization and re-contouring of 

banks, within 24 hours for minor waterbody crossings and 48 hours for intermediate 

waterbody crossings; 

• using temporary erosion and sediment control measures such as sediment barriers and trench 

plugs; and 

• restoration activities including restoration of preconstruction bank contours, installation of 

slope breakers, and revegetation of disturbed riparian areas. 

The use of an HDD could result in an inadvertent release of drilling mud that could return to the 

surface or enter a waterbody. This inadvertent release is commonly referred to as a “frac-out.” To 

minimize the effects of potential frac-outs occurring during HDD operations, KMLP would conduct 

geotechnical evaluations prior to construction to determine the potential for a frac-out to occur at a 

proposed HDD crossing and adjust its crossing plan accordingly. Should a frac-out occur during HDD 

operations, KMLP would implement measures outlined in its HDD Contingency Plan which describes 

how inadvertent releases of drilling fluids would be prevented or mitigated if a release of drilling fluids 

were to occur. A draft of KMLP’s HDD Contingency Plan is provided in appendix I. 

In addition to implementing these and other measures, KMLP would consult with state and 

federal resource agencies to finalize construction methods. As discussed in the beginning of section 2.3, 

KMLP would also develop and implement a SWPPP and SPRP to prevent and contain, if necessary, 

accidental equipment-related spills. 

4.3.2.2 Impacts and Mitigation 

Construction of the proposed pipeline through waterbodies using open-cut construction methods 

would result in several impacts to these waterbodies including changes to water quality and in-stream 

habitat. Construction activities including the clearing and grading of stream banks, in-stream trenching, 

trench dewatering, and backfilling of the in-stream trench would result in increased turbidity and 

sedimentation, decreased dissolved oxygen (DO) levels, modifications to aquatic habitat, and increased 

stream water temperatures. The removal of riparian vegetation associated with open-cut construction 

methods would also result in increased surface runoff, an increased erosion potential, and elevated water 

temperatures. In addition, the disturbance of unidentified contaminated soils and/or sediments could 

result in adverse impacts to water quality and aquatic resources. Operation of heavy equipment or other 

vehicles in and near surface waterbodies could also introduce chemical contaminants, such as fuels and 

lubricants, into surface waters or result in accidental spills during construction that would result in 

decreased water quality. The use of flumes during construction would result in impacts similar to those 

resulting from the use of open-cut construction methods; however, the use of flumes would significantly 

minimize these impacts especially the increases in turbidity and sedimentation commonly associated 

within pipeline crossings. 

Construction of the proposed pipeline through waterbodies using bores and HDDs would also 

significantly reduce impacts to crossed waterbodies. However, the use of an HDD could result in drilling 

mud entering a waterbody due to a frac-out. A frac-out would result in increased turbidity and 

sedimentation, which would decrease water quality and in-stream habitat integrity. Because drilling mud 

is primarily composed of freshwater, a small release would likely dissipate and would not be expected to 

adversely affect water quality beyond a temporary increase in turbidity. In larger quantities, the release of 
 4-25 Environmental Analysis

drilling fluid could negatively affect fisheries and/or vegetation, although impacts would generally be less 

than those associated with an open-cut crossing. 

Operation of the Project would not affect surface water resources. 

Sensitive Waterbodies 

Impacts to the Vinton Drainage Canal, Bayou Choupique, and Bayou Nezpique would be 

minimized by crossing these waterbodies using HDDs. As described above, the use of HDDs to cross 

these waterbodies would significantly reduce impacts to them. Impacts to Bayou des Cannes would be 

minimized by using a flume. Impacts to East Bayou Lacassine resulting from the two crossings of the 

waterbody would be minimized by using a flume at the crossing at MP 84.9. East Bayou Lacassine at MP 

88.5 would be crossed by open-cut, but we do not believe impacts resulting from this crossing would 

significantly contribute to the water’s DO impairment that has been created by adjacent agricultural 

operations. 

Hydrostatic Testing 

KMLP would hydrostatically test the pipeline after installation to ensure structural integrity in 

compliance with the DOT pipeline safety regulations identified in 49 CFR Part 192. The proposed 

hydrostatic test water sources, withdrawal locations, and estimated volumes of water required are 

identified in table 4.3.2.2-1. 

KMLP has indicated that all hydrostatic test waters would be discharged overland at the original 

source, discharged directly to the original source, or managed in compliance with applicable NPDES 

permit conditions. As described in section 2.3.1.1, KMLP would use energy dissipation devices at all 

discharge points to reduce discharge velocities and thereby prevent or minimize associated erosion and 

sedimentation. Additionally, no chemical additives would be used in hydrostatic test water. 

KMLP would minimize potential effects to waterbodies resulting from hydrostatic testing by 

implementing our Procedures, which include, but are not limited to the following measures: 

• obtain and comply with all applicable water withdrawal permits and special-status stream 

permits; 

• address the operation and fueling of any pumps located within 100 feet of waterbodies or 

wetlands in the Project-specific SPRP; 

• maintain adequate flow rates in all source waterbodies to protect aquatic life and to provide 

for all downstream uses; 

• screen all hydrostatic test water withdrawal intakes to prevent entrainment of fish and aquatic 

organisms; and 

• regulate the discharge of hydrostatic test waters using energy dissipation devices to prevent 

erosion, scour, turbidity, or excessive streamflow. 

With the implementation of our Procedures and the above measures, we believe that the surface 

water impacts associated with hydrostatic testing of the pipeline would be temporary. 
 4-26 Environmental Analysis

TABLE 4.3.2.2-1 

Hydrostatic Test Water Source and Discharge Locations 

Pipeline Withdrawal Source/Discharge 

Approximate 

Withdrawal 

Location (MP) 

Approximate Volume 

(gallons)a

Leg 1 Calcasieu River 49.6 18,837,000 

Leg 1 Calcasieu River 49.6 31,384,000 

Leg 1 Sabine Lake 4.8 684,000 

Leg 1 Sabine Lake 18.0 502,000 

Leg 1 Sabine River/GIWW 18.6 600,000 

Leg 1 Sabine River/GIWW 20.0 456,000 

Leg 1 Sabine River/GIWW 21.2 714,000 

Leg 1 Sabine River/GIWW 22.1 456,000 

Leg 1 Sabine River/GIWW 23.5 562,000 

Leg 1 Sabine River/GIWW 23.9 365,000 

Leg 1 Sabine River/GIWW 25.3 585,000 

Leg 1 Sabine River/GIWW 26.8 585,000 

Leg 1 Black Bayou Cutoff 30.6 836,000 

Leg 1 GIWW 32.4 730,000 

Leg 1 Bayou Choupique 43.4 600,000 

Leg 1 Calcasieu River 49.6 707,000 

Leg 1 LNG Terminal Channel 51.1 646,000 

Leg 1 LNG Terminal Channel 51.1 448,000 

Leg 1 LNG Terminal Channel 51.1 517,000 

Leg 1 Louisiana Irrigation Canal 76.0 570,000 

Leg 1 Bayou Nezpique 99.4 562,000 

Leg 2 Sabine Pass 0.0 339,000 

FGT Lateral Bayou des Cannes 2.3 285,000 

_______________ 

a

 HDD segments, which include all but the first two rows listed above for Leg 1, would be tested three times: (1) before 

installation; (2) after installation; and (3) with the entire pipeline system. 

Based on the characteristics of the identified waterbodies, KMLP’s proposed construction 

methods and operations procedures, its implementation of waterbody-related measures described in our 

Procedures, and our recommended measures, we believe that effects to surface waters resulting from 

construction and operation of the proposed project would be temporary and localized. 

4.3.2.3 The Sabine Lake and Calcasieu River Crossings 

Sabine Lake 

Sabine Lake is an estuarine waterbody located on the Texas/Louisiana border and connected to 

the Gulf of Mexico via the Sabine Pass. The lake has an average depth of 2.0 feet and covers a surface 

area of approximately 94 square miles. The land surrounding Sabine Lake is covered, in large part, by 
 4-27 Environmental Analysis

sensitive wetland areas that include EFH and provide habitat for a diversity of wildlife. The lake itself 

has been designated as supporting primary and secondary contact recreation, fish and wildlife 

propagation, and oyster propagation. Additionally, Sabine Lake supports both commercial and 

recreational fisheries and is a public harvesting area for oysters. No water quality impairments or 

contaminated sediments are reported for Sabine Lake. 

KMLP proposes to cross Sabine Lake via the HDD method at the lake’s southern and northern 

shorelines and via the open-cut construction method requiring the use of spud barges across the lake’s 

open water. Impacts to the southern bank of Sabine Lake, including riparian vegetation and nearshore 

oyster resources, would be avoided by using an HDD that would enter on land and exit within Sabine 

Lake at MP 4.8. From MP 4.8 to MP 17.9 of Leg 1, the open-cut construction method would be used. 

The crossing would be accomplished using a shallow draft spud barge with pipe supply barges connected 

in a line to form the lay barge spread. To accommodate vessel drafts, excavation of a floatation channel 

would be required in water depths of less than 8 feet. Where the floatation channel is needed, a 300-footwide construction right-of-way would also be required to accommodate the floatation channel, pipeline 

trench, and spoil pile. In water depths greater than 8 feet, the floatation channel would not be necessary 

and the construction right-of-way would be reduced to a width of 200 feet. The use of HDD would 

resume at MP 17.9 within Sabine Lake, exiting on land at MP 18.6, avoiding sensitive wetland habitats on 

the northern bank. A detailed description of the crossing methods through Sabine Lake is provided in 

section 2.3.1.3. 

KMLP conducted a shallow hazards survey over a 3,000-foot corridor centered on the proposed 

pipeline route through Sabine Lake to identify the locations of foreign pipelines and obstructions that 

could affect construction, as well as the locations of any submerged cultural resources. At locations 

where potential obstructions or significant cultural resources were found, KMLP adjusted the centerline 

route for avoidance. Where adjustments of the pipeline were deemed infeasible, locations of potential 

obstructions or cultural resources would be further investigated and regulatory agencies consulted as 

discussed in section 4.10 of this draft EIS. 

Major route alternatives and route variations were also considered. Three major route alternatives 

involved construction through Sabine Lake while two major route alternatives took a southern route, 

avoiding the lake altogether. As discussed in section 3.3, we did not consider the two southern routes to 

be environmentally preferable. Within Sabine Lake, the Blue Buck Point route variation was considered 

to potentially avoid marsh areas south of the lake. It was determined that although this route variation 

would cause fewer impacts to the marsh, it would cause greater impacts to oysters. Therefore, this route 

variation was not adopted (see section 3.4.1). 

The use of the HDD crossing method at the northern and southern banks of Sabine Lake would 

avoid impacts to sensitive vegetation, EFH, and other wildlife habitat, while also avoiding shoreline 

erosion. Open-cut construction would adversely affect water quality during construction, causing 

sediment resuspension and related impacts in the water column as discussed in section 4.3.2.2. Impacts 

to oyster resources and fishes within Sabine Lake are discussed in section 4.6.3 and impacts to vessel 

traffic through spoil pile placement are discussed in section 4.8.3.2. 

KMLP has proposed to allow refueling activities within Sabine Lake and the Sabine River. As 

discussed in section 4.4.1, we believe that this measure as well as an additional measure to allow certain 

extra workspaces within 50 feet of waterbodies is acceptable and would result in minimal effects to the 

environment. To minimize impacts to Sabine Lake during construction, KMLP would utilize BMPs 

developed with the construction contractor as part of the SWPPP prior to construction to address 

hazardous materials handling and storage, as well as spill prevention and response. 
 4-28 Environmental Analysis

Calcasieu River 

Calcasieu River is a freshwater river that drains a rural forest and bayou complex that connects to 

the estuarine Calcasieu Lake. The river has been designated as supporting primary and secondary contact 

recreation, fish and wildlife propagation, and oyster propagation. Additionally, the lake supports both 

commercial and recreational fisheries (see section 4.6.2.1). As described in section 4.6.2.2, the lower 

Calcasieu watershed contained areas of probable concern (APCs) in 1997; however, later surveys 

indicated that those APCs are no longer present, although some areas still contained contaminated 

sediments. 

KMLP would install the pipeline across Calcasieu River between MP 49.6 and MP 51.1 of Leg 1. 

Back-to-back HDDs are proposed for the crossing of the main shipping channel of Calcasieu River and 

the major tributary that serves as a ship channel to the Trunkline LNG Terminal. The proposed route 

would cross under a marina on the east bank of the river and a COE dredge spoil area, and one of the 

HDD pull strings would lie across this dredge spoil area. KMLP is currently consulting with the COE 

regarding potential effects to the disposal area. Since these consultations are still ongoing, we 

recommend that: 

• Prior to construction, KMLP file the following environmental information with the 

Secretary for review and written approval by the Director of OEP: 

a. site-specific construction plan for the HDD crossing of the Calcasieu River and 

marina between MP 49.6 and MP 51.1 along Leg 1; and 

b. documentation of consultation with COE for the HDD crossing of the Calcasieu 

River and use of the COE dredge spoil area located at MP 50.0. 

Crossing the Calcasieu River by the HDD method would eliminate impacts from the resuspension 

of potentially contaminated sediments and the removal of riparian vegetation. 
 4-29 Environmental Analysis

4.4 WETLANDS 

4.4.1 Affected Environment 

Wetlands are defined by the COE and the EPA as areas that are inundated or saturated by surface 

water or groundwater at a frequency and duration sufficient to support, and that under normal 

circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. 

Wetlands generally include swamps, marshes, bogs, and similar areas. Wetlands provide a number of 

valuable functions including flood flow attenuation, sediment retention, nutrient retention, wildlife 

habitat, groundwater recharge and discharge, recreation, and erosion control. 

KMLP conducted wetland delineations within the proposed pipeline construction right-of-way, as 

well as within the proposed locations for the pipe storage/contractor yards, access roads, aboveground 

facilities, and extra workspaces in accordance with the COE Wetland Delineation Manual (USACE 

1987). In areas where land access has not yet been granted (approximately 8.3 miles along the proposed 

route), NWI maps and aerial photographs were used to determine the presence of wetlands. 

A total of 352 wetlands, covering approximately 504.2 acres, would be affected by construction 

of the Project. The COE has yet to validate KMLP’s wetland delineations; therefore, the acreage of 

wetlands affected by the Project may change. The location, wetland classification, and affected acreage 

for each wetland that would be affected by construction and operation of the Project are listed in appendix 

H, table H-2. Wetland vegetative species found along the pipeline route are listed in table 4.4.1-1 

according to the wetland type. The FWS wetland Cowardin classification system (described in appendix 

H, table H-1) was used to classify the wetlands that would be affected by the Project (Cowardin et al. 

1979). According to the Cowardin classification, the wetlands crossed by the Project are classified as: 

• estuarine emergent (E2EM); 

• estuarine scrub-shrub (E2SS); 

• palustrine emergent (PEM); 

• palustrine scrub-shrub (PSS); and 

• palustrine forested (PFO). 

Estuarine wetlands are tidal habitats and adjacent tidal wetlands that are usually semi-enclosed by 

land but have open, partly obstructed, or sporadic access to the ocean, with ocean-derived water at least 

occasionally diluted by freshwater runoff from the land. The upstream and landward limit is where oceanderived salts measure less than 0.5 parts per thousand (ppt) during the period of average annual low flow. 

Palustrine wetlands are nontidal wetlands dominated by trees, shrubs, persistent emergents, 

emergent mosses, or lichens with salinities less than 5 ppt. A palustrine system can exist directly adjacent 

to or within an estuarine system. (Osmond et al. 1995) 
 4-30 Environmental Analysis

TABLE 4.4.1-1 

Common Wetland Species Identified Within the KMLP Project Area 

Common Name Scientific Name Common Name Scientific Name 

Estuarine Emergent Wetlands 

marsh elder Iva fructescens Cattail Typha latifolia

black rush Juncus roemerianus Bulrush Scirpus litoralis

salt meadow cordgrass Spartina patens 

Estuarine Scrub-Shrub Wetlands 

wax-myrtle Myrica cerifera Cattail Typha latifolia

marsh elder Iva fructescens Bulrush Scirpus litoralis

riverhemp Sesbania sp. black rush Juncus roemerianus

Chinese tallow Triadica sebifera salt meadow cordgrass Spartina patens

Palustrine Emergent Wetlands 

alligatorweed Alternanthera 

philoxeroides

Sedges Carex spp. and Cyperus 

spp.

bushy bluestem Andropogon glomeratus Bermudagrass Cynodon sp.

broomsedge bluestem Andropogon virginicus Spikesedges Eleocharis spp.

spadeleaf Centella asiatica carolina geranium Geranium carolinianum

pennyworts Hydrocotyle spp. soft rush Juncus effusus

smartweeds Polygonum spp. Cattail Typha latifolia

Palustrine Scrub-Shrub Wetlands 

sweetgum Liquidambar styraciflua saltwater false willow Baccharis angustifolia

elderberry Sambucus sp. eastern baccharis Baccharis halimifolia

Chinese tallow Triadica sebifera Buttonbush Cephalanthus 

occidentalis

giant cane Arundinaria gigantea marsh elder Iva fructescens

southern dewberry Rubus trivialis wax myrtle Myrica cerifera

dwarf palmetto Sabal minor Cherokee rose Rosa laevigata

Palustrine Forested Wetlands 

sweetgum Liquidambar styraciflua Chinese tallow Triadica sebifera

water oak Quercus nigra poison ivy Toxicodendron radicans

American elm Ulmus Americana Greenbriers Smilax spp.

winged elm Ulmus alata Raspberries Rubus spp.

hackberry Celtis sp. Violets Violaceae

Chinese privet Ligustrum sinense bald cypress Taxodium distichum

tupelo gum Nyssa aquatica swamp blackgum N. sylvatica var. biflora

swamp red maple Acer rubrum var. 

drummondii

black willow Salix nigra

pumpkin ash Fraxinus profunda green ash Fraxinus pennsylvanica

water elm Planera aquatica water locust Gleditsia aquatica

Virginia willow Itea virginica Buttonbush Cephalanthus 

occidentalis
 4-31 Environmental Analysis

Table 4.4.1-2 summarizes impacts to wetlands from construction and operation of the Project, 

including impacts from access roads, rights-of-way, pipe storage/contractor yards, extra workspaces, and 

aboveground facilities. 

TABLE 4.4.1-2 

Summary of Wetlands Affected by the KMLP Project 

Wetland Type 

Number of 

Wetlands 

Crossed 

Estimated 

Crossing 

Length 

(miles)a

Construction 

Impacts 

(acres)a,b

Operation 

Impacts 

(acres)a,c

E2EM 27 6.5 89.3 47.1 

E2SS 11 1.3 11.1 6.5 

PEM 197 20.7 296.2 114.2 

PSS 62 5.0 79.3 23.1 

Subtotal of Non-Forested 297 33.5 475.9 190.9 

PFO 55 3.4 28.3 14.9 

Total Wetlands 352 36.9 504.2 205.8 

_______________ 

E2EM = estuarine emergent 

E2SS = estuarine scrub-shrub 

PEM = palustrine emergent 

PSS = palustrine scrub-shrub 

PFO = palustrine forested 

a Acreages shown do not account for the wetlands that would be crossed by the HDD construction method and would not be 

affected by construction or operation of the Project. b Wetland impact calculations are based on a 125-foot-wide construction right-of-way in areas where the crossing distance is 

greater than 100 feet, and a 100-foot-wide construction right-of-way where the width of crossing is less than 100 feet. c Operation impacts for the pipeline facilities are based on a 50-foot-wide, permanent right-of-way. 

Temporary impacts to wetlands resulting from installation of all of the facilities including extra 

workspaces associated with the Project would include approximately 28.3 acres of forested wetlands and 

475.9 acres of non-forested wetlands. The pipeline facilities would result in the conversion of 14.9 acres 

of forested wetlands within the operational right-of-way to emergent or scrub-shrub wetlands and 

permanent impact to 0.8 acres of E2EM, 1.3 acres of PEM, and 0.6 acres of PSS wetlands resulting from 

the installation and operation of aboveground facilities. 

Prior-converted wetlands are wetlands that have been altered so that they no longer have potential 

to provide valuable wetland functions. Of the 504.2 acres of wetlands that would be impacted by 

construction of the Project, 182.8 acres have been classified as prior-converted. 

KMLP has identified several locations where proposed extra workspaces are located entirely or 

partially within wetlands. The use of these extra workspaces would temporarily affect 50.2 acres of nonforested wetlands and 1.1 acres of forested wetlands during construction. Three of the 14 interconnect 

sites would be located in wetlands and impact 2.7 acres of non-forested wetlands. In addition, three of the 

12 proposed pipe storage and contractor yards would be located in wetlands and impact 62.6 acres of nonforested wetlands. The Project would also require the construction of three new roads (Access Roads 2, 

3, and 4-5) and improvement of seven existing access roads in wetlands (Access Roads 1, 4-1, 6, 7, 10-1, 
 4-32 Environmental Analysis

13-1, and 16) for access to rights-of-way and workspaces that would impact 9.3 acres of non-forested 

wetlands and 0.1 acres of forested wetlands. 

NOAA Fisheries Service (2006a) has indicated that aquatic and tidally influenced wetland 

habitats in the Project area have been designated as EFH for various species of fish and invertebrates. 

Construction through the first 50 miles of the pipeline route would impact approximately 99.5 acres of 

EFH wetlands along the northern and southern banks of Sabine Lake, Shell Island, the Sabine and 

Calcasieu Rivers, and the GIWW. KMLP has routed the pipeline through Sabine Lake to avoid/minimize 

impacts to EFH wetlands and it would install the pipeline using HDD at the north and south shores of 

Sabine Lake. KMLP would also minimize impacts to EFH wetlands by using a combination of HDD and 

open-cut methods along the Sabine River/GIWW, and by using low-ground-pressure equipment, board 

roads, and marsh buggies during construction activities in saturated estuarine areas. Additional 

discussion of EFH wetlands is provided in section 4.6.3. 

Significant forested wetlands crossed by the Project include forested wetlands from MP 99.0 to 

99.7, in the vicinity of Bayou Nezpique, and a forested wetland from MP 1.3 to 1.6 along the FGT Lateral 

in the vicinity of Bayou des Cannes. Bayou Nezpique would be crossed by HDD, avoiding impacts to 

approximately 1.6 acres of forested wetlands. The FGT Lateral would be collocated with an existing 

right-of-way through a large forested area. Although collocation is generally acceptable as a way to 

minimize impacts to an area, this particular area is a quality forested wetland that would be disrupted by 

the clearing of the right-of-way and by widening the right-of-way through the area. FWS, COE, and 

LDWF have requested HDD through this area to minimize impact to forested wetland. Therefore, in 

section 4.3.2.1, we are recommending that the FGT Lateral cross Bayou des Cannes and associated 

wetlands by HDD. 

Wetland Construction Procedures 

KMLP would use wetland construction methods described in section 2.3 of this draft EIS, and 

applicable permit conditions to avoid or minimize impacts to wetlands. 

KMLP would cross numerous wetlands along the pipeline rights-of-way using the HDD method 

to avoid the need to clear or otherwise disturb about 7.0 acres of forested wetlands and 100.8 acres of 

non-forested wetlands. Use of HDD would minimize disturbance of the surface between the entry and 

exit points of the HDD. The disturbance would be limited to the deployment of telemetry cable. 

However, KMLP has not explained how it would clear the vegetation to facilitate deployment of 

telemetry cable. The COE has expressed concern that the mechanized clearing could result in greater 

impacts to wetland vegetation and prefers the use of hand clearing. Therefore, we recommend that: 

• KMLP use hand clearing methods for clearing vegetation in the path of HDDs in 

wetland areas.

KMLP would also use the push-pull method and marsh buggies for construction through coastal 

estuarine herbaceous marsh that is tidally influenced and mostly submerged. This construction method, 

as described in section 2.3, is generally used in large wetland areas with suitable hydrology and 

topography (i.e., flooded or saturated soils and minimal local relief). Push-pull construction generally 

requires a narrower right-of-way and minimizes the operation of construction equipment within wetlands. 

This method offers environmental advantages over conventional wetland construction approaches. 

Because of the potential environmental advantages of the push-pull construction method, Item VI.B.2.c in 

our Procedures requires that this method be used where sufficient water is present in the trench and other 

site conditions allow. KMLP proposes to cross approximately 63.7 acres of wetland using the push-pull 
 4-33 Environmental Analysis

method. Locations where the push-pull (typical submerged marsh) construction method would be used 

are listed in appendix E. 

In order to minimize construction-related impacts to wetlands, KMLP would implement measures 

outlined in our Procedures that include, but are not limited to, the following requirements: 

• Construction equipment operating within the right-of-way would be limited to that equipment 

necessary for clearing, excavation, pipe installation, backfilling, and restoration activities. 

All nonessential equipment would use upland access roads to the maximum extent 

practicable. 

• Equipment operating within saturated wetlands would be low-ground-weight equipment or 

would operate from timber or board mats. 

• Temporary erosion and sedimentation control measures would be installed immediately after 

the initial disturbance of wetland soils and would be inspected and maintained regularly until 

final stabilization. 

• Sedimentation controls would be installed across the construction right-of-way, as needed, 

within wetlands to contain trench spoil. 

• Grading and pulling of tree stumps would be limited to the area directly over the trenchline 

unless additional grading or stump removal is required for worker safety. 

• In unsaturated wetlands, the uppermost 12 inches of topsoil along the pipeline trench would 

be segregated from the underlying subsoil. 

• Project-specific restoration plans would be developed based on consultations with appropriate 

land management or state agencies. The wetland restoration plan should include measures 

for re-establishing herbaceous and/or woody species, controlling the invasion and spread of 

undesirable exotic species, and measures for monitoring the success of the revegetation and 

weed control efforts. 

• Monitoring of wetlands would be conducted for a minimum of three years post-construction 

to ensure the success of wetland revegetation. If revegetation is not successful after three 

years, a remedial revegetation plan would be developed and implemented. 

Requested Alternative Measures to Our Procedures 

KMLP has requested alternative measures to certain items in our Procedures. Items pertaining to 

wetlands and waterbodies are discussed below and summarized in table 4.4.1-3. 

Item IV.A.1.d of our Procedures requires that all equipment be parked overnight and/or fueled at 

least 100 feet from a waterbody or in an upland area at least 100 feet from a wetland boundary unless the 

EI finds, in advance, no reasonable alternative, and appropriate steps are taken to prevent and provide for 

prompt cleanup of spills. Item IV.A.1.e requires that hazardous materials (e.g., chemicals, fuels, 

lubricants) not be stored within 100 feet of a wetland or waterbody unless the location is designated for 

such use by a government authority. KMLP has requested alternative measures to these requirements 

based on site-specific circumstances and proposed construction methods. We have reviewed the Project 
 4-34 Environmental Analysis

TABLE 4.4.1-3 

Acceptance or Denial of Requested Alternative Measures from our Procedures 

MP 

Applicable 

Item in our 

Proceduresa Reason for Request 

Accepted/ 

Denied Basis for Acceptance/Denial 

Various IV.A.1.d & e Refueling activities in 

waterbodies 

Accepted This alternative measure is accepted for 

use only in Sabine Lake and the Sabine 

River as in-lake construction provides 

no practicable alternative to refueling 

from barges within the lake 

Various VI.A.3 A typical temporary construction 

right-of-way width of 125 feet in 

wetlands where the crossing 

length exceeds 100 feet and a 

right-of-way width of 100 feet in 

wetlands where the crossing 

length is less than 100 feet (see 

specific MP locations in 

appendix D) 

Accepted only 

along Leg 1 

This alternative measure is accepted 

because larger equipment and soil 

limitations require a larger right-of-way 

to assure a safe work site and space for 

spoil storage 

28.24 of 

Leg 1 and 

1.23 of the 

FGT 

Lateral 

VI.A.6 Two aboveground facilities 

located within jurisdictional 

wetlands (see specific MP 

locations in appendix D) 

Accepted Locations of interconnects dictated by 

intersection of the proposed pipeline 

and existing pipelines and by the 

location of the Sabine Pass LNG 

Terminal 

Various VI.B.1.e A portion of Access Roads 2 and 

3 constructed in wetlands 

Accepted Access is required from the GIWW to 

reach the HDD workspace needed to 

minimize impacts to wetlands 

Various VI.B.1.a Some extra workspaces located 

within 50 feet of wetland 

boundaries (see specific MP 

locations in appendix D) 

Accepted Accepted only for specific sites listed in 

appendix D based on lack of practicable 

locations with 50-foot setbacks; also 

some sites are to facilitate HDD or 

other methods designed to reduce 

impacts (see appendix D) 

Various V.B.2.a Some extra workspaces located 

within 50 feet of water's edge 

(see specific MP locations in 

appendix D) 

Accepted Accepted only for specific sites listed in 

appendix D, Table D-3 based on lack of 

practicable locations with 50-foot 

setbacks; also some sites are to 

facilitate HDD or other methods 

designed to reduce impacts (see 

appendix D) _______________ 

a Requirements specified in the referenced Procedure items are summarized below: 

 IV.A.1.d and e: Requires a 100-foot minimum setback from a waterbody or wetland for equipment parking, fueling, and hazardous 

materials storage; 

VI.A.3: Limits construction right-of-way width in wetlands to 75 feet; 

VI.A.6: Prohibits the location of aboveground facilities in wetlands except when in compliance with DOT; 

VI.B.1.a: Requires a 50-foot setback from water’s edge for all extra work areas (except where adjacent land is actively cultivated or rotated 

cropland or other disturbed land); and 

VI.B.1.e: Prohibits the use of access roads in wetlands without Director approval unless those access roads are existing and require no 

modification or impact to wetlands. 

and have determined that the alternative measures are justified within Sabine Lake and the Sabine River 

due to the use of spud barges during construction and a lack of practicable refueling options. 

Item VI.A.3 of our Procedures requires that the construction right-of-way width in wetlands be 

limited to 75 feet. KMLP proposes to use a 125-foot construction right-of-way within wetlands where the 
 4-35 Environmental Analysis

crossing length would exceed 100 feet. KMLP states that the 125-foot right-of-way is necessary to 

accommodate installation of the 42-inch-diameter pipeline, due to the unstable and saturated soil 

conditions, larger pipe-installation equipment, wider ditches, and non-cohesive spoil piles during 

construction. KMLP also stresses the need for safe construction practices that meet OSHA requirements 

and minimize the environmental impact. Milepost locations where a 125-foot construction right-of-way 

is requested for wetland crossings are given in appendix D. We believe that the justification KMLP has 

provided is adequate and reasonable for areas where the push-pull method is not viable; therefore, we 

accept the request for a construction right-of-way of 125 feet at the specific milepost locations listed in 

appendix D. 

Item VI.A.6 of our Procedures prohibits the location of aboveground facilities in any wetland, 

except where the location of such facilities outside of wetlands would prohibit compliance with DOT 

regulations. KMLP proposes to construct three aboveground facilities in wetlands: 

• The NGPL Interconnect Site (MP 1.2) is an industrial wetland area within the Sabine Pass 

LNG Terminal where no available upland areas were identified in the vicinity. 

• The Southwest Loop Delivery Point is proposed at MP 28.2, within the Black Bayou 

Hydrologic Restoration Project boundaries. KMLP states that the nearest upland area in this 

vicinity is located approximately 800 feet north of the proposed site, along the banks of the 

GIWW, and would require installation of the connecting pipeline under a major pipeline 

corridor. 

• KMLP has stated that the TGTPL interconnect site (MP 87.5) is within a rice field. 

We have reviewed the proposed locations for these interconnect sites and have determined that 

there are no practicable alternatives to locate these aboveground facilities outside of wetland areas. 

Therefore, we concur with KMLP.

Item VI.B.1.e of our Procedures states that the only access roads, other than the construction 

right-of-way, which can be used in wetlands without Director approval are those existing roads that can 

be used with no modification and no impact on the wetlands. Portions of Access Roads 2 and 3 would 

cross wetlands in order to provide access from the GIWW to the HDD workspaces for HDD equipment 

and construction access. The construction of these two access roads would temporarily impact 

approximately 0.9 acres of non-forested wetland, and the use of HDD at these two access points would 

avoid approximately 25.3 acres of wetlands as well as riparian areas and waterbodies. We believe that 

use of HDD would minimize impacts to wetlands; therefore, we accept the use of KMLP’s alternative 

measure to construct portions of Access Roads 2 and 3 within wetlands. KMLP also proposes to 

construct a portion of Access Road 4-5 within wetlands, but has not provided any justification for such 

construction in wetlands. Therefore, we recommend that: 

• KMLP evaluate alternative routes for Access Road 4-5 or provide justification for the 

wetland impacts associated with its construction in wetlands. Any revision to the route 

of Access Road 4-5 should be shown on revised alignment sheets. KMLP should file 

with the Secretary results of its evaluation and copies of the revised alignment sheets for 

review and written approval by the Director of OEP prior to the close of the comment 

period on the draft EIS. 

Items VI.B.1.a and V.B.2 of our Procedures require that all extra workspaces such as staging 

areas and additional spoil storage areas be located at least 50 feet from water’s edge or wetland 
 4-36 Environmental Analysis

boundaries, respectively, except where the adjacent upland consists of cropland or other disturbed land. 

KMLP proposes to locate 164 extra work areas within 50 feet of water’s edge or wetland boundaries. A 

list of the proposed extra workspaces requiring alternative measures is in appendix D along with the 

milepost location and justification for each. The justifications provided by KMLP for these alternative 

measures are adequate; therefore, we accept the use of each of the extra workspaces listed in appendix D. 

Wetland Restoration Projects 

There are seven Coastal Wetland Planning, Protection, and Restoration Act (CWPPRA) projects 

in the Project vicinity; each of these projects is described in table 4.4.1-4. Only two of the seven 

CWPPRA projects would be crossed by the Project. 

TABLE 4.4.1-4 

The Coastal Wetlands Planning, Protection, and Restoration Act Projects 

in the Vicinity of the KMLP Project 

Project Name Location Sponsor(s) Purpose 

Relationship to 

Project 

 Impact 

(acres) 

Black Bayou 

Hydrologic 

Restoration Project 

(CS-27) 

MP 22.3 -

30.7 

NOAA 

Fisheries and 

LDNR 

Restore coastal marsh habitat 

and slow the conversion of 

wetlands to shallow, open 

water 

7.6-mile crossing 153.5 

Perry Ridge Shore 

Protection Project 

(CS-24) 

MP 30.8- 

32.2 

NRCS and 

LDNR 

Reduce erosion at the GIWW 

shoreline and at the spoil 

banks protecting nearby 

marshes 

1.4-mile crossing 25.9 

East Sabine Lake 

Hydrologic 

Restoration 

(CS-32) 

MP 15 FWS, NRCS, 

and LDNR 

Restore the hydrologic regime 

within the Sabine NWR 

2.6 miles east of MP 

15 

No impact 

Plowed Terraces 

Demonstration 

(CS-25) 

MP 33 NRCS and 

LDNR 

Construct earthen terraces in 

shallow open water to allow 

the establishment of emergent 

vegetation 

1,000 feet south of 

MP 33 

No impact 

Perry Ridge West 

Bank Stabilization 

(CS-30) 

MP 27 NRCS and 

LDNR 

Construct riprap terraces along 

the GIWW to reduce wave 

fetch and allow the recovery 

of marshes 

1,000 feet north of 

MP 27 

No impact 

Clear Marais Bank 

Protection 

(CS-22) 

MP 40 COE and 

LDNR 

Prevent further erosion to a 

levee preventing 

encroachment of the GIWW 

into marshes 

1,000 feet north of 

MP 40 

No impact 

Black Bayou 

Culverts 

Hydrologic 

Restoration 

(CS-29) 

MP 55 NRCS and 

LDNR 

Prevent saltwater intrusion, 

excessive water levels, and 

erosion in areas near Calcasieu 

Lake 

500 feet north of MP 

55 

No impact 

_______________ 

Source: LaCoast 2006a,b. 
 4-37 Environmental Analysis

Black Bayou Hydrologic Restoration Project 

The Black Bayou Hydrologic Restoration Project, sponsored by NOAA Fisheries Service and 

LDNR, is a 25,529-acre wetland located in Cameron and Calcasieu Parishes, Louisiana. Bordered by the 

GIWW, Sabine Lake, Black Bayou, and Gum Cove Ridge, the restoration area consists of tidally 

influenced intermediate and brackish marshes. The goal of the Black Bayou Hydrologic Restoration 

Project is to restore coastal marsh habitat and to slow the conversion of wetlands to shallow, open water. 

The restoration projects are designed to limit the amount of saltwater intrusion into the surrounding 

marshes and reduce erosion caused by wave action from nearby boats and tides (LaCoast 2006a). The 

KMLP Project would traverse this restoration project area between MP 22.3 and MP 30.7. The Project 

would affect approximately 153.5 acres of the Black Bayou Hydrologic Restoration Project, much of 

which would be crossed by the HDD method. Of these 153.5 acres, 60.0 acres are comprised of 

nonforested wetlands and 2.8 acres of forested wetlands would be crossed by open-cut construction. 

During operations, 35.6 acres of non-forested and 1.8 acres of forested wetlands within the permanent 

right-of-way would be maintained in an herbaceous state. Because the objective of this project is to 

restore coastal marsh habitat and slow the conversion of wetlands to shallow open waters, impacts from 

the KMLP Project could temporarily delay any progress made in this restoration area. 

NOAA Fisheries Service expressed concern that the pipeline construction in the Black Bayou 

Hydrologic Restoration Project would interfere with future construction and maintenance activities for 

rock structures at various locations (e.g., MPs 23.9 and 30.7) and near Burton Shell Slip at MP 23.8. 

They also stated that KMLP and NOAA Fisheries Service would need to enter into an agreement that 

would allow KMLP to access and maintain the pipeline in a manner that would not damage any rock 

structures within the Black Bayou Hydrologic Restoration Project. Because several existing pipelines 

stretch through the Black Bayou Hydrologic Restoration Project area, KMLP proposes to install its 

pipeline using two HDDs (MPs 25.3 to 26.8). We believe use of the HDD method of construction would 

minimize disturbance to these rock structures and minimize impact to restoration activities in the Black 

Bayou Hydrologic Restoration Project (see sections 2.3.1.3 and 4.3.2.1 for more discussion). 

Perry Ridge Shore Protection Project 

The crossing of the Perry Ridge Shore Protection Project, sponsored by the NRCS and LDNR, 

would traverse the restoration area between MP 30.8 and 32.2. The construction right-of-way through 

this area would affect approximately 25.9 acres of land, including approximately 18.5 acres of fresh-tointermediate marsh and open water habitats. Operation of the Project would impact approximately 0.06 

acres of similar habitat. 

At the recommendation of various resource agencies, KMLP developed a pipeline route that 

avoids most of the Perry Ridge Shore Protection Project by staying on the southern bank of the GIWW 

until MP 30.7. In addition, most surface disturbance to the Perry Ridge Shore Protection Project would 

be avoided by installing the pipeline by two successive HDDs between MPs 30.4 and 32.4. Where 

conditions allow, approximately 0.2 miles of the pipeline within the Perry Ridge Shore Protection Project 

would be installed using the conventional method. The resulting impact to the Perry Ridge Shore 

Protection Project would be short-term, but would temporarily delay progress made within the protection 

area, in this case, affecting progress on the minimization of erosion along the GIWW and the associated 

impacts of that erosion to adjacent habitats. 

Areas within the permanent right-of-way within the Perry Ridge Shore Protection Project and the 

Black Bayou Hydrologic Restoration Project would be maintained in an herbaceous state for the life of 

the KMLP Project. KMLP has stated that a site-specific construction and restoration plan for the Black 

Bayou Hydrologic Restoration Project and the Perry Ridge Shore Protection Project would be developed 
 4-38 Environmental Analysis

in cooperation with LDNR, NOAA Fisheries Service, and FWS. To ensure that this plan addresses 

agency concerns, we recommend that: 

• KMLP consult with LDNR, NOAA Fisheries Service, and FWS, and develop sitespecific construction and restoration plans for crossing the Black Bayou Hydrologic 

Restoration Project and Perry Ridge Shore Protection Project. KMLP should file with 

the Secretary copies of its consultation, along with construction and restoration plans, 

for review and written approval by the Director of OEP prior to the completion of the 

final EIS. 

Conservation Reserve Program Lands 

The CRP is a voluntary program, administered by the Farm Service Agency (FSA) and planned 

and implemented by the NRCS. The goal of the CRP is to reduce soil erosion, protect the Nation’s ability 

to produce food and fiber, reduce sedimentation in streams and lakes, improve water quality, establish 

wildlife habitat, and enhance forest and wetland resources. It encourages farmers to convert highly 

erodible cropland or other environmentally sensitive areas to vegetative cover, such as native grasses, 

wildlife plantings, trees, or riparian buffers. Farmers receive an annual rental payment for the term of the 

multi-year contract (NRCS 2006b). 

Within the Parishes crossed by the Project, Acadia, Evangeline, and Jefferson Davis are known to 

contain several CRP lands (FSA 2006a), but according to local FSA offices, CRP lands in Acadia and 

Evangeline Parishes are located at least 0.3 miles away from the Project and therefore no impacts are 

expected from construction (Haller 2006, USDA 2006). Consultations are ongoing with regard to CRP 

locations in Jefferson Davis Parish. 

Should any CRP lands be crossed by the Project, the enrolled landowners would no longer be 

eligible to participate in the CRP and would lose the income provided by the NRCS. Additionally, 

KMLP would be required to obtain Compatible-Use Permits from the NRCS authorizing the crossing of 

any lands enrolled in the CRP. Therefore, we recommend that: 

• KMLP continue consultations with the FSA and NRCS to identify the extent and 

location of all CRP lands within Jefferson Davis Parish that would be affected by 

construction and operation of the Project. In addition, KMLP should file with the 

Secretary prior to construction, copies of its consultation and documentation of any 

stipulations or recommendations to avoid and minimize impacts to any CRP lands that 

would be affected. 

4.4.2 Impacts and Mitigation 

The COE requires that all appropriate and practicable actions be taken to avoid or minimize 

wetland impacts, pursuant to its section 404(b)(1) guidelines, which restrict discharges of dredged or fill 

material where a less environmentally damaging and practicable alternative exists. All wetland crossings 

would be subject to review by the COE to ensure that wetland impacts are fully identified and appropriate 

wetland restoration and mitigation measures are implemented. 

Construction Impacts 

Construction activities have the potential to diminish the value of wetlands through clearing, 

trenching, spoil placement, equipment passage, and related construction disturbances. Wetland functions 
 4-39 Environmental Analysis

such as erosion control, buffering and flood flow attenuation, sediment retention, and nutrient retention 

would also be affected by construction. These effects would typically be greatest during and immediately 

following construction, resulting in a temporary impact. Clearing of wetland vegetation would result in 

both short- and long-term loss of wetland wildlife habitat and some wetland functions, with the duration 

of the impact varying by habitat type. Forested wetlands would require as much as 30 years or more to 

recover from clearing and would be subjected to more stages of succession, ensuring the slow, but 

continuous alteration of available habitat until the land has been restored to a pre-construction state. 

Impacts to scrub-shrub wetlands would be mostly short-term, as restoration would likely occur within 

three years. Emergent wetlands, which can restore rapidly, would typically experience only short-term 

impacts, and may re-establish in one or two growing seasons. 

Excavation of the pipeline trench, installation of the pipe, and backfill of the trench would affect 

the rate and direction of water movement within wetlands. In addition, excavation activities may alter 

perched water tables by disturbing impermeable soil layers. This would adversely affect wetland 

hydrology and revegetation by creating soil conditions that might not support wetland communities and 

hydric vegetation at pre-construction levels. Failure to properly segregate soils during construction would 

result in mixed soil layers, which would alter biological components of the wetland and affect the 

reestablishment of native wetland vegetation. Temporary stockpiling of soil and the movement of heavy 

machinery across wetlands would lead to inadvertent compaction and furrowing of soils, which would 

alter natural hydrologic patterns, inhibit seed germination, and increase seedling mortality. Altered 

surface drainage patterns, stormwater runoff, runoff from the trench, accidental spills, and discharge of 

hydrostatic test water would also negatively affect water quality by increasing the potential for siltation 

and turbidity resulting from construction activities. 

KMLP would minimize impacts to wetlands by implementing our Procedures, as modified with 

accepted alternative measures, as discussed above. In accordance with our Procedures, KMLP would 

install sediment barriers across the entire construction right-of-way, as needed, within wetlands as well as 

along the edge of the construction right-of-way, when adjacent to wetlands, in order to prevent sediment 

flow into wetlands. Additionally, energy dissipating devices would be used to discharge hydrostatic test 

water to further minimize sedimentation in wetlands. Section 2.3.1 describes the specialized pipeline 

construction procedures that KMLP would implement to minimize impacts to wetlands, including the use 

of the push-pull method through wetlands where possible. Within the construction right-of-way, KMLP 

would grade tree stumps, but would only remove them within 15 feet of the proposed pipeline, and install 

erosion control devices to minimize sediment flow into the wetland. KMLP would reduce the maintained 

portion of the permanent pipeline right-of-way to 10 feet in wetlands, rather then the 50-foot width 

proposed for uplands. 

KMLP has stated that no shallow bedrock occurs at or near the surface of the pipeline route; 

therefore, no perched water tables are expected to be present. Soil segregation along the Project would 

occur in unsaturated wetlands but would not be practical in saturated and submerged wetlands. In 

unsaturated wetlands where rutting or mixing of the topsoil can occur, KMLP would use low-groundpressure equipment or temporary board roads for passage through the area. If the crossing length of an 

unsaturated wetland would be less than 100 feet, the spoil would be moved to adjacent upland areas 

located within the right-of-way, avoiding soil disturbance in the wetland. Board mats would also be used 

for passage through saturated wetlands. KMLP has stated that it would also disc any over-compacted 

soils found after construction. 

The proposed pipeline route is located adjacent to existing rights-of-way to the extent practical so 

that the construction right-of-way would overlap with existing permanent rights-of-way. The amount of 

overlap would be limited to 15 feet to minimize wetland impacts. 
 4-40 Environmental Analysis

Of the 18 proposed HDDs, 17 would cross waterbodies and/or wetlands (table 4.3.2.1-3). 

Through the use of HDD, KMLP would avoid impacts to approximately 87.8 acres of herbaceous 

wetlands (E2EM and PEM), 13.0 acres of scrub-shrub wetlands (E2SS and PSS), and 7.0 acres of 

forested wetlands. This includes the extensive bottomland forest located in Jefferson Davis Parish near 

Bayou Nezpique. Additionally, KMLP would avoid impacts to wetlands along the shores of Sabine Lake 

by routing the proposed pipeline through the open water as opposed to along the shoreline, where 

sensitive wetlands occur. 

KMLP has stated that all emergent and scrub-shrub wetlands impacted by construction would be 

restored to original contours, revegetated as appropriate, and monitored to ensure a successful recovery. 

Forested wetlands would be allowed to naturally revegetate with the exception of a 10-foot-wide corridor 

over the pipeline that would be maintained in an herbaceous state. Wetland recovery would be 

considered successful when native species cover at least 80 percent of the wetland. 

Sensitive or Unique Wetlands 

KMLP would minimize impacts to EFH wetlands by using a combination of HDD and open-cut 

construction methods along the Sabine River/GIWW, and by using low-ground-pressure equipment, 

board roads, and marsh buggies during construction activities in saturated estuarine areas. Wetlands 

designated as EFH are discussed in section 4.6.4 with regard to their importance as a habitat to federally 

managed fishes and invertebrates. 

Bayou Nezpique would be crossed by HDD, avoiding impacts to approximately 7.0 acres of 

forested wetlands. 

The FGT Lateral would be collocated with an existing right-of-way through a large forested area 

adjacent to Bayou des Cannes. Although collocation is generally acceptable as a way to minimize 

impacts, this particular area is considered a quality forested wetland that would be impacted by the 

widening of the existing right-of-way. Therefore, we are recommending in section 4.3.2.1 that KMLP 

evaluate the feasibility of the FGT Lateral to cross Bayou des Cannes and associated wetlands by HDD. 

Operation Impacts 

Operation of the pipeline would require 190.9 acres of non-forested wetlands to be maintained in 

an herbaceous state. Operation of the Southwest Loop Delivery Point and the NGPL and TGTPL 

interconnect sites would permanently convert 2.7 acres of non-forested wetlands to industrial land. 

Additionally, 14.9 acres of forested wetlands would be converted to herbaceous wetland for the life of the 

Project. 

KMLP would maintain a 10-foot-wide strip centered over the pipeline in a herbaceous state. 

Additionally, trees that are within 15 feet of the pipeline and greater than 15 feet in height would be cut 

and removed. These activities would not affect PEM wetlands. However, mowing, clearing, and tree 

removal would affect PSS and PFO wetlands along the permanent right-of-way, causing constant 

disruption to natural successional growth and increasing the chance of invasion by non-native species. 

Functions associated with these wetland types would be altered because forested or scrub-shrub wetlands 

within the maintained portion of the permanent pipeline right-of-way would be permanently converted to 

an herbaceous state. 

All emergent and scrub-shrub wetlands impacted by construction would be restored to preconstruction contours. KMLP would consult with the appropriate state and federal agencies to develop 

project-specific measures for re-establishing herbaceous and/or woody species. In accordance with our 
 4-41 Environmental Analysis

Procedures, KMLP would monitor the recovery of wetlands for a minimum of three years postconstruction to ensure the success of revegetation. If revegetation is not successful at the end of three 

years, a remedial revegetation plan would be developed and implemented in consultation with a 

professional wetland ecologist. The remedial revegetation plan would serve as a guide to actively 

revegetate the wetland with native wetland herbaceous and woody plant species. Revegetation efforts 

would be continued until revegetation was considered successful. 

Wetland Protection Measures 

We believe the implementation of our Procedures with the accepted alternative measures, along 

with the use of HDDs, existing access roads, mitigation, and avoidance of PFO wetlands to the extent 

practical, KMLP would have adequately avoided, minimized, and mitigated impacts to wetlands. 

Avoidance 

KMLP would avoid impacts to wetlands through the use of HDD crossing methods and the 

routing of the Project through less sensitive areas such as Sabine Lake in order to avoid the shoreline 

where sensitive EFH wetlands occur. Additional areas of avoidance include areas of collocation where 

the width of construction rights-of-way could be reduced by utilizing existing operational and maintained 

areas. 

Minimization 

KMLP would minimize impacts to wetlands through a variety of methods, including the use of: 

• The Aquatic Resources Mitigation Plan (appendix H); 

• BMPs to control erosion and sedimentation; 

• Routing that avoids wetlands to the extent practical; and 

• The push-pull construction method where feasible, which would avoid the need for access 

canal excavation. 

Mitigation 

KMLP would implement its Aquatic Resources Mitigation Plan to ensure that wetlands within the 

construction right-of-way would experience no net loss in functional value. Temporary impacts would be 

mitigated by full restoration, with the exception of forested wetlands within the permanent right-of-way, 

after construction has been completed. KMLP is evaluating wetland mitigation banking options (Dorsey 

2007) and is developing its draft Aquatic Resources Mitigation Plan in consultation with COE, FWS, 

NOAA Fisheries Service, LDNR, and LDWF; therefore, we recommend that: 

• Prior to construction, KMLP file with the Secretary a copy of the finalized Aquatic 

Resources Mitigation Plan developed in consultation with COE, NOAA Fisheries 

Service, FWS, LDNR, and LDWF. 
 4-42 Environmental Analysis

4.5 VEGETATION 

The vegetative communities that would be crossed by the Project can be generally grouped into 

uplands and wetlands. This section identifies and describes the vegetation types composing the two 

general vegetative communities and describes the impacts to these communities resulting from 

construction and operation of the Project. This section also addresses vegetation types of special concern, 

and exotic/invasive plant species. Section 4.4 addresses vegetation in wetlands. 

4.5.1 Affected Environment 

The upland vegetative community consists of several vegetation types: agricultural, upland forest, 

rangeland, and developed. The agricultural vegetation type consists of common crops and pasture 

grasses. The upland forest vegetation type consists of deciduous, evergreen, and mixed forests including 

managed pine forests. The rangeland vegetation type consists of common scrub-brush, herbaceous, and 

mixed vegetative species. The developed vegetative type consists of common grasses and shrubs 

associated with commercial, residential, and industrial lands as well as utility rights-of-way. The upland 

vegetative types crossed by the Project, as well as representative species occurring in each cover type, are 

listed in table 4.5.1-1. 

TABLE 4.5.1-1 

Upland Vegetation Types Crossed by the KMLP Project 

Vegetation 

Cover Type General Description Common Species 

Agricultural Cropland and pasture Rice (Oryza sativa), soybeans (Glycine spp.), corn (Zea spp.), sugar cane 

(Saccharum officinarum), turf grass, and sweet potatoes (Ipomoea 

batatas). 

Upland 

Forest 

Deciduous, evergreen, 

and mixed forests 

Red Maple (Acer rubrum), Ironwood (Carpinus carolinianum), hickories 

(Carya spp.), Hackberry (Celtis occidentalis), Sugarberry (C. laevigata), 

Yaupon Holly (Ilex vomitoria), Chinese Privet (Ligustrum sinense, invasive 

non-native), Sweetgum (Liquidambar styraciflua), Red Mulberry (Morus 

rubra), Loblolly Pine (Pinus taeda), White Oak (Quercus alba), Water oak 

(Q. nigra), Live Oak (Quercus virginiana), Chinese Tallow (Sapium 

sabiferum = Triadica sebifera, invasive non-native), Winged Elm (Ulmus 

alata), American Elm (Ulmus americana), Japanese Honeysuckle 

(Lonicera japonica, invasive non-native), greenbriers (Smilax spp.), Poison 

Ivy (Toxicodendron radicans), sedges (Carex spp.), and Carolina Violet 

(Viola villosa). 

Rangeland Scrub-brush, 

herbaceous, and 

mixed rangelands 

Giant Ragweed (Ambrosia trifida), sedges (Carex spp.), Bermudagrass 

(Cynodon dactylon), grasses in the genus Paspalum, Curly Dock (Rumex 

crispus), Chinese Tallow (invasive, non-native), Eastern Baccharis 

(Baccharis halimifolia), American Holly (Ilex opaca), Yaupon Holly, Marsh 

Elder (Iva frutescens), Chinese Privet (invasive non-native), Japanese 

Honeysuckle (invasive non-native), Osage Orange (Maclura pomifera), 

Virginia creeper (Parthenocissus quinquefolia), Smooth Sumac (Rhus 

glabra), Cherokee Rose (Rosa laevigata), Field Blackberry (Rubus 

arvensis) and other Rubus spp., Elderberry (Sambucus canadensis), 

Rattlebox (Sesbania drummondii), and Poison Ivy. 

Developed Commercial, industrial, 

residential, rights-ofway 

Grasses and small shrubs. 
 4-43 Environmental Analysis

Vegetation Types of Special Concern 

Based on field surveys and consultations with LDWF, no critically imperiled plant species have 

been identified within 0.5 miles of the Project. Additionally, no unique communities or communities of 

special concern are located within 0.5 miles of the Project. 

Several wetland and hydrologic restoration projects that have vegetative components occur in the 

vicinity of the Project and are addressed in sections 4.4 and 4.8. 

4.5.2 Impacts and Mitigation 

4.5.2.1 Primary Impact to Vegetative Cover Types 

Construction of the Project, including the pipeline, aboveground facilities, access roads, pipe 

storage/contractor yards, and extra work spaces would require the clearing of 1,463.4 acres of agricultural 

land, 115.4 acres of upland forest, 134.4 acres of rangeland, and 130.2 acres of developed land. 

Operation of the Project would require approximately 522.8 acres of upland vegetation, including 

43.8 acres of upland forest, to be converted to permanently maintained pipeline right-of-way, 

aboveground facilities, or permanent access roads. Table 4.5.2.1-1 identifies the number of acres of 

vegetation temporarily and permanently impacted by construction and operation of the Project. 

The majority of construction-related clearing would be temporary and cleared vegetation would 

be able to return to natural conditions after construction, with the exception of the permanent pipeline 

right-of-way that would be maintained in an herbaceous state throughout the life of the Project. The loss 

of vegetation along the pipeline route would result in forest fragmentation and the loss or conversion of 

wildlife habitat. Other impacts resulting from the removal of vegetation include increased erosion, 

TABLE 4.5.2.1-1

Upland Vegetation Cover Types Affected by the KMLP Project 

Pipelinea Ancillary Facilitiesb

Vegetation 

Cover Type 

Temporary 

Construction 

Impact 

(acres) 

Permanent 

Operations 

Impact 

(acres) 

Temporary 

Construction 

Impact 

(acres) 

Permanent 

Operations 

Impact 

(acres) 

Agriculturalc 1,178.5 415.8 284.9 7.9 

Upland Forest 114.9 43.8 0.6 0.0 

Rangeland 95.0 28.3 39.3 0.5 

Developed Land 56.4 18.5 73.7 8.1 

Total 1,444.8 506.3 398.5 16.5 

_______________ 

a

 Temporary construction acreages reflect a nominal 125-foot-wide construction right-of-way and temporary extra workspaces. 

The permanent operations acreages reflect a 50-foot-wide permanent easement that would be maintained in upland areas 

following construction. b For the purpose of this table, ancillary facilities include acres affected for interconnect sites, access roads, pipe 

storage/contractor yards.. c The acres of agricultural land reported above differs from acreage reported in section 4.8. This is because section 4.8 includes 

in agricultural land a category of “other” which is land without vegetative cover. Land without vegetative cover is excluded from 

the analysis of vegetation.
 4-44 Environmental Analysis

sediment runoff, altered soil chemistry, modified infiltration and groundwater recharge rates, and an 

increased susceptibility to colonization by invasive and/or exotic plant species. Additionally, the 

removal of trees on the right-of-way could expose formerly interior trees growing adjacent to the newly 

cleared areas to higher levels of wind, which may increase the risk of blow downs. 

The severity of these impacts would depend on the specific vegetation type affected and the time 

that it takes the vegetation type to return to pre-construction conditions. Specifically, most impacts to 

agricultural lands and rangelands would be short term as these vegetation types would return to their 

herbaceous or shrub-covered status within one to three growing seasons after the completion of 

construction activities, cleanup, and restoration. Areas planted with field crops are typically disturbed by 

periodic agricultural practices and would be replanted in the next growing season. The clearing of upland 

forest would result in a long-term impact as upland forests can take up to 30 years or more to return to 

pre-construction conditions. Impacts to upland forested areas constitute the most significant change in 

vegetative strata, appearance, and habitat, as mature trees would be replaced for a period of years by 

herbaceous plants, shrubs, saplings, and other successional species. Impacts to previously developed 

lands such as industrial areas and linear transportation corridors would result in short-term impacts due to 

the existing maintained or disturbed condition. 

In order to minimize impacts to affected vegetation types, KMLP would implement measures 

outlined in our Plan as described below and further discussed in section 2.3. Our Plan includes measures 

for minimizing erosion and enhancing revegetation in upland areas. To further minimize effects on 

vegetation, especially upland forests, KMLP proposed a pipeline route that would be collocated with 

existing rights-of-way to the extent practicable. Approximately 54 percent (73.7 miles) of the combined 

Leg 1, Leg 2, and FGT Lateral rights-of-way would be located adjacent to existing rights-of-way. By 

following existing rights-of-way, KMLP would avoid further segmentation of a relatively unfragmented 

forested area at MP 108.6, limiting the habitat disruption to a widening of the corridor that would need to 

be maintained. KMLP would also avoid impacts to many riparian areas located throughout the Project 

area through the use of HDD. 

Based on the characteristics of the identified vegetation types, the expected impacts to vegetation 

and KMLP’s described construction, restoration, and mitigation measures including the implementation 

of our Plan and Procedures, we believe that construction and operation of the Project would not 

significantly affect vegetation. 

4.5.2.2 Exotic/Invasive Plant Species 

Federal agencies are required to prevent the introduction and spread of invasive species, and to 

minimize the impacts that such species would cause by implementing feasible and prudent measures. 

Invasive species are generally characterized by their hardiness and a relatively increased ability to 

reproduce and spread. Invasive species are also commonly exotic species which are non-native species of 

trees, shrubs, and flowering or non-flowering plants. Within the project area, exotic and invasive plant 

species out-compete native plant species and decrease the amount of available habitat for wildlife that 

depend on native plants for nesting and feeding (GBEP 2006). Exotic and invasive species found in the 

project area include the Chinese tallow tree (Triadica sebifera) and the Chinese privet (Ligustrum sinese). 

The Chinese tallow tree is a small, rapidly growing tree found in every parish in Louisiana. The 

Chinese tallow tree is considered problematic in bottomlands, coastal prairies, and riparian areas. Until 

recently, the Chinese tallow was not considered a threat to upland forests because it grows poorly in the 

shade; however, its appearance in the understory of closed canopy forests and undisturbed sites has raised 
 4-45 Environmental Analysis

concerns about its potential to dominate gaps created by construction activities and operations 

maintenance and to prevent the regeneration of desirable plant species. 

The Chinese privet plant is considered to be one of the worst forest invaders in the Southeast 

because of its ability to dominate the understory, midstory, and edges of forests and to impede 

regeneration of desirable plants, including canopy trees. The Chinese privet grows easily under a variety 

of soil and light conditions, is bothered by relatively few pests, and is difficult to remove once 

established. 

The spread of any invasive species during construction and operation of the Project would 

displace native species and negatively alter the appearance, composition, and habitat value of the affected 

area. 

In order to minimize the spread of exotic and invasive species, KMLP would implement related 

measures in our Plan and Procedures. Specifically, KMLP would monitor the success of revegetation and 

weed control efforts. Additionally, our Plan and Procedures require post-construction monitoring for the 

first and second growing seasons in uplands, and for three years in wetlands, to evaluate the success of 

revegetation. As part of this monitoring program, KMLP would be required to examine the right-of-way 

for the presence of invasive species. In areas not used for agriculture, restoration would be considered 

successful when the density and cover of non-nuisance vegetation is similar to adjacent undisturbed land. 

Similarly, wetland revegetation would be considered successful if the cover and destruction of herbaceous 

and/or woody species is at least 80 percent of the type, density, and distribution of the vegetation in 

adjacent areas that were not disturbed by construction. 

KMLP has also developed an Invasive Species Control Plan as part of their draft Aquatic 

Resources Mitigation Plan (see appendix J) that would help control the spread of the Chinese tallow 

during construction and operation of the Project. In accordance with this plan, field personnel would be 

trained to identify Chinese tallow and would be registered to purchase and use regulated herbicides. 

Additionally, older trees would be controlled by mechanical cutting and chemical treatment while 

saplings would be removed by hand or machine. Each incidence of control activities would be 

documented and reported to the FERC and COE after the completion of the 3-year monitoring period. 

Based on our consultations with federal and state agencies, we believe that the measures outlined 

in KMLP’s Invasive Species Control Plan and those identified in our Plan and Procedures would be 

sufficient to control the spread of invasive species during construction and operation of the Project. 
 4-46 Environmental Analysis

4.6 WILDLIFE AND AQUATIC RESOURCES 

This section describes the existing wildlife, aquatic habitats, and biological communities along 

the Project route with emphasis on wetland habitat, unique or sensitive habitats, and the biological 

communities associated with those habitats. In addition, the discussion includes general and specific 

impacts that would occur during construction and operation, and the measures to avoid and minimize 

those impacts. 

4.6.1 Terrestrial Wildlife Resources 

A variety of habitat types would be crossed by the KMLP Project. These habitat types include 

agricultural lands, forested wetlands, non-forested wetlands, upland forests, rangeland, and developed 

land. Table 4.6.1-1 lists species commonly associated with these habitat types. Descriptions of the 

vegetation found in these habitats are provided in sections 4.4 and 4.5. Federal- and state-listed 

threatened and endangered species are discussed separately in section 4.7. 

4.6.1.1 Affected Environment 

Agricultural lands include actively harvested cropland, idle cropland, and open pasture. Within 

the Project area, the agricultural land is predominantly used for pasture, rice production, and crawfish 

farming (see section 4.8.3.1). Agricultural lands provide cover and foraging opportunities for wildlife 

species within the crops or pastures themselves, or within the small areas of natural vegetation, such as 

vegetation along streams or small forested patches, that sometimes occur within agricultural lands. 

Species found in these areas include those that prefer disturbed habitats and edge habitats between 

forested and open areas. Flooded rice fields and crawfish ponds provide important habitat for shorebirds, 

wading birds, and waterfowl. Wading birds and crustaceans are often found in irrigation ditches, while 

fencerows can serve as breeding areas for some song birds. 

Detailed discussion of wetland habitats potentially impacted by the Project is provided in 

section 4.4. Forested wetlands in the project area include bottomland hardwood forests and cypresstupelo-blackgum swamps which have been generally characterized as highly productive and providing an 

abundance of natural cover for numerous species. Bottomland hardwood forests are found along major 

waterbodies and are dominated by mature trees and shrubs. In general, bottomland forests provide high 

quality habitat, attracting a variety of birds, mammals, reptiles, and amphibians. Throughout their natural 

range, cypress-tupelo-blackgum swamps are forested, alluvial swamps growing on intermittently exposed 

soils. They are found along rivers, streams, and in back swamp depressions and swales. The vegetative 

community has low species diversity, but is generally co-dominated by bald cypress and tupelo gum. The 

undergrowth in these areas is generally sparse due to low light intensity and the long periods of soil 

inundation. 

Non-forested wetlands include estuarine and palustrine wetlands. Estuarine wetlands include salt 

marsh, brackish marsh, intermediate marsh, and freshwater marsh. Changes in salinity can cause the 

wildlife and vegetative species to change as the marsh becomes more saline or fresh. Marshes are 

typically interspersed with small ponds and pools, providing habitats for a diverse assemblage of birds, 

mammals, fishes, and reptiles. These habitats are important breeding and feeding grounds for many 

recreationally and commercially important species such as fish, crustaceans, fur-bearers, and waterfowl. 

The coastal marshes in Louisiana are part of the Mississippi Flyway and provide wintering grounds for 

over 20 species of ducks and geese. 
 4-47 Environmental Analysis

TABLE 4.6.1-1 

Habitats and Typical Non-Fish Wildlife Species Found within the Project Area 

Habitat/Common Name (Scientific Name) Habitat/Common Name (Scientific Name)

Agriculture 

eastern bluebirds (Sialia sialis) 

northern bobwhite (Colinus virginianus) 

rusty blackbird (Euphagus carolinus) 

white-tailed deer (Odocoileus virginianus) 

wood duck (Aix sponsa) 

woodcock (Scolopax minor) 

Forested Wetlands 

black bear (Ursus americanus) 

blue jay (Cyanocitta cristata) 

box turtle (Terrapene sp.) 

Chuck Will’s widow (Caprimulgus carolinensis) 

common raccoon (Procyon spp.) 

coral snake (Micrurus fulvius) 

eastern diamondback (Crotalus adamanteus) 

eastern gray squirrel (Sciurus carolinensis) 

mink (Mustela vison) 

mud turtle (Kinosternon sp.) 

northern cardinal (Cardinalis cardinalis) 

river otter (Lutra canadensis) 

striped skunk (Mephitis mephitis) 

vireos (Vireo spp.) 

western cottonmouth (Agkistrodon piscivorus leucostoma) 

white-tailed deer (Odocoileus virginianus) 

wild turkey (Meleagris gallopavo) 

wood duck (Aix sponsa) 

woodcock (Scolopax minor) 

Non-Forested Wetlands 

alligators (Alligator mississippiensis) 

American bittern (Botaurus lentiginosus) 

American wigeon (Anas Americana) 

beaver (Castor canadensis) 

diamondback water snake (Nerodia rhombifer) 

eastern narrowmoth toad (Gastrophryne carolinensis) 

marsh hawk (Circus cyaneus) 

marsh rice rat (Oryzomys palustris) 

mink (Mustela vison) 

Missouri slider (Pseudemys floridana hoyi) 

muskrat (Ondatra zibethicus) 

nutria (Myocastor coypus) 

red-winged blackbird (Agelaius phoeniceus) 

river otter (Lutra canadensis) 

southeastern myotis (Myotis austroriparius) 

Wilson’s snipe (Gallinago gallinago) 

Woodhouse’s toad (Bufo woodhousii) 

Upland Forests 

bobwhite (Colinus sp.) 

common raccoon (Procyon sp.) 

coyote (Canis latrans) 

flying squirrel (Glaucomys sp.) 

nine-banded armadillo (Dasypus novemcinctus) 

Virginia opossum (Didelphis virginiana) 

white-tailed deer (Odocoileus virginianus) 

wild turkey (Meleagris gallopavo) 

Rangeland 

bobwhite (Colinus sp.) 

common raccoon (Procyon spp.) 

coyote (Canis latrans) 

flying squirrel (Glaucomys sp.) 

nine-banded armadillo (Dasypus novemcinctus) 

Virginia opossum (Didelphis virginiana) 

white-tailed deer (Odocoileus virginianus) 

wild turkey (Meleagris gallopavo) 

Developed Land 

Species that utilize the vegetated areas of developed land 

are likely to include species that inhabit agricultural land, 

rangeland, and forest edge habitat. 

Palustrine wetlands are inland freshwater marshes and swamps. Wildlife generally uses these 

areas for breeding and foraging. These wetlands also serve as habitats for migratory species. Emergent 

wetlands consist primarily of grasses. Scrub-shrub wetlands consist of saplings and low-lying vegetation. 
 4-48 Environmental Analysis

Emergent and scrub-shrub wetlands supply breeding and foraging habitat, along with resting areas for 

migratory species. 

Upland forests consist of deciduous forests, evergreen forests, and forests of mixed evergreen and 

deciduous trees. Upland forests provide both interior and edge habitats that often attract different species 

based on their habitat preferences. Interior forested habitats are secluded, wetter, and more stable 

whereas edge habitats are more volatile, experiencing more dramatic environmental change. They are 

sunnier, drier, and windier, and are more prone to disturbance (LandOwner Resource Center 2005). 

Rangeland ecosystems are dominated by grasses, grass-like plants, forbs, or shrubs and other 

herbaceous species. Rangeland habitats are classified as shrub and brush, herbaceous, or mixed. Shrub 

and brush rangeland are dominated by woody vegetation. Herbaceous rangelands are dominated by 

naturally occurring grasses and or forbs, or are those lands that have been modified to include such 

vegetation as their natural cover. Mixed rangelands are those where more than one-third of the land is a 

mixture of herbaceous and shrub and brush rangeland species (NASA 1996). 

Developed lands are generally a mixture of paved and/or graveled areas, but may contain 

vegetated strata as well. Species utilizing developed land may include species that inhabit other grassy or 

shrub-covered areas although these areas are not expected to be a primary habitat. 

These terrestrial and aquatic habitats support various species of wild game. The American 

alligator, nutria, muskrat, river otter, raccoon, red swamp crawfish, red fox, and gray fox have an 

economic benefit for local trappers. Whitetail deer, fox squirrel, gray squirrel, swamp rabbit, eastern 

cottontail rabbit, waterfowl, northern bobwhite, eastern wild turkey, woodcock, rails, mourning dove, and 

Wilson’s snipe are important recreational species in the area. 

Unique or Sensitive Wildlife Habitats

The SNWR is a 124,511-acre coastal marsh administered by FWS. The primary objective of this 

NWR is to preserve a large area of coastal wetlands for wintering and migratory waterfowl, and it is 

known as an internationally important bird area. The SNWR is also a major nursery area for many 

estuarine-dependant marine species as well as home for alligators and other reptiles, mammals, and 

various species of wading, water, and marsh birds. Recreational activities available within the refuge 

include hunting, fishing, boating, and hiking (FWS no date a). The Project would not cross the SNWR, 

and at the closest point would pass approximately 0.25 miles from it. 

The Lacassine National Wildlife Refuge (LNWR), also administered by the FWS, is nearly 

35,000 acres, most of which is freshwater marsh habitat. The refuge preserves a major wintering site for 

waterfowl and provides habitat for nesting colonies of wading birds, alligators, mink, otter, and raccoon, 

among various other species. Threatened species such as the bald eagle and the Louisiana black bear 

have also been found residing in this refuge. The LNWR supports recreational activities such as hunting, 

fishing, bird-watching, and hiking (FWS no date b). The main unit of the LNWR would be 

approximately 15 miles southeast of the Project. The smaller Vidrine unit is the closest unit and the 

pipeline would be located approximately two miles southwest of this unit. 

The Project would impact two tracts of land included in the CWPPRA program. This program 

was implemented to create, protect, and enhance wetlands in Louisiana. Impacts to these specific tracts 

of land are discussed in section 4.4. 
 4-49 Environmental Analysis

In addition to specific tracts of sensitive land, forests and wetlands in Louisiana provide quality 

habitat for migratory waterfowl and colonial-nesting waterbirds, which are protected by the Migratory 

Bird Act. 

Louisiana, including the Project area, is an important stopover for migratory birds along the 

Mississippi Flyway, which extends from Alaska and central Canada along the Mississippi River drainage 

into central and South America. Forests, including riparian habitat, provide important stopover habitat for 

migratory birds. 

Colonial nesting birds share two general traits; they gather into large assemblages, called 

colonies, during the nesting season, and they obtain all or most of their food from the water. Colonial 

wading birds include the following: herons, egrets, night-herons, ibis, roseate spoonbills, anhingas, and/or 

cormorants. The Natural Heritage Program (NHP) of LDWF database indicates the presence of rookeries 

for the roseate spoonbill, a state-listed species of concern, and other colonial nesters in coastal Louisiana. 

The roseate spoonbill and other federal- and state-listed species are discussed in section 4.7. 

4.6.1.2 Impacts and Mitigation 

Construction Impacts 

Construction of the Project, including the pipeline, aboveground facilities, extra workspaces, 

access roads, and pipe storage and contractor yards would temporarily affect approximately 2,417.9 (total 

construction impacts less the following land types: open water, beaches, and other) acres of upland and 

wetland habitat suitable for wildlife. Of that, 16.5 acres of upland and 2.7 acres of wetland habitats 

within the footprint of aboveground facilities and access roads would be permanently converted to 

industrial areas. Following construction, extra workspaces and non-forested portions of the permanent 

right-of-way would be allowed to revert to pre-construction conditions. Portions of the permanent rightof-way in forested lands would be maintained in an herbaceous state in accordance with our Plan and 

Procedures (and approved alternative measures) to facilitate pipeline maintenance. Approximately 14.9 

acres of forested wetland and 40.6 acres of upland forest located within the permanent right-of-way would 

be converted to an herbaceous state for the life of the Project. 

Impacts to wildlife species and habitats resulting from construction and operation of the Project 

would depend on the vegetation type affected, the mobility and habitat requirements of affected wildlife 

species as well as the amount of adjacent wildlife habitat. Specifically, construction activities including 

increased noise and habitat disruption would impact wildlife by displacing, stressing, injuring or leading 

to the mortality of wildlife. Species typically move away from inhospitable environments, utilizing 

nearby suitable habitats until the disruption has passed. Less mobile species may experience direct 

mortality from habitat clearing and the passing construction spreads if unable to escape the area. 

Disruption of any habitat type could cause alterations in the breeding, feeding, nesting, and rearing 

activities of species that actively use those habitats. Impacts to habitats are often related to the growth 

rates of the vegetation species found there. 

Forested lands would require as much as 30 years or more to recover from clearing and would be 

subjected to more stages of succession, ensuring the slow, but continuous alteration of available habitat 

until the land has been restored to a pre-construction state. Impacts to wildlife from construction and 

operation in large forested tracts would be diverse and long-term or permanent. These impacts would 

include the loss of forest interior habitat, displacement of wildlife, inhibition of the migrations and 

foraging habits of forest interior species, invasion of non-native plant or animal species, and increased 

stress and mortality to local wildlife. 
 4-50 Environmental Analysis

Although the Project would cross through several forested areas, few of these would be 

considered forest interior habitat. The exceptions occur at approximately MP 99.1 and MP 108.6. One 

bottomland forested area located in Jefferson Davis Parish begins at MP 99.1 and ends at MP 99.7. This 

forested habitat includes Bayou Nezpique, and this habitat would be avoided using HDD. Another 

relatively large forested tract begins at approximately MP 108.6 in Acadia Parish, stretching for slightly 

less than a mile. Although this forest is relatively large, the pipeline route follows an existing right-ofway. This limits the habitat disruption to widening of an existing corridor and would not increase 

fragmentation of interior forest habitat. Two additional forested areas of concern are located in 

Evangeline and Acadia Parishes. In Evangeline Parish, the pipeline would enter a large, relatively 

unfragmented forested area, associated with Tiger Point Gulley, crossing for approximately 0.4 miles. 

Although there are nearby rights-of-way transecting this area, the pipeline route would cause further 

fragmentation, decreasing its value as a wildlife habitat. In Acadia Parish, the FGT Lateral would be 

collocated with an existing right-of-way through a large forested area associated with Bayou des Cannes. 

Although collocation is generally acceptable as a way to minimize impacts to an area, this particular area 

provides quality wildlife habitat that would be disrupted by widening the right-of-way through quality 

forest habitat. Therefore, in section 4.3.2.1, we are recommending that KMLP consult with LDWF, FWS, 

and COE regarding the appropriate crossing methods and collocation through the forested areas near MP 

113.1 of Leg 1 and MP 1.4 of the FGT Lateral. 

KMLP has also proposed to use a total of 18 HDDs to cross a variety of habitats consisting 

mainly of waterbodies and wetlands. HDD crossing methods would reduce impacts to these streams as 

well as to the adjacent wetlands, riparian areas, and bottomland hardwood communities. KMLP has 

provided potential opportunities for the mitigation and/or compensation of wetland losses in the draft 

Aquatic Resources Mitigation Plan (appendix J), but is still finalizing the plan in consultation with the 

relevant agencies. Therefore, in section 4.4, we are recommending that prior to construction, KMLP 

develop an Aquatic Resources Mitigation Plan developed in consultation with and approved by the COE, 

NMFS, FWS, LDNR, and LDWF. 

Operation Impacts 

To minimize impacts on wildlife and wildlife habitats, the affected areas would be revegetated 

and maintained according to our Plan and Procedures. Routine maintenance would be periodically 

conducted to maintain the permanent right-of-way in an herbaceous state. Along cropland, pasture, and 

emergent wetlands, no routine maintenance would be necessary. However, in forested areas including 

forested wetlands, routine mowing would be conducted to allow inspection of the pipeline corridor. Our 

Plan does not allow routine vegetative maintenance to occur more frequently than every three years, 

except along a 10-foot-wide corridor centered over the pipeline that can be maintained annually. 

Based on the characteristics of the affected wildlife habitats, the known habitat requirements of 

wildlife identified within proposed project areas, the anticipated impacts to wildlife and their habitats, 

KMLP’s stated construction measures, and its adherence to our Plan and Procedures with modified 

alternative measures; we believe that construction and operation of the project would not significantly 

affect wildlife resources. 

Waterbirds 

The Project route could include suitable habitat for migratory waterfowl and nesting habitat for 

various species of colonial wading birds. Although the closest known wading bird nesting colony is 

approximately 1 mile from the footprint of the Project, the NHP of LDWF cautions that rookeries may 

move from year to year, potentially placing them closer to, or within, the Project right-of-way. 
 4-51 Environmental Analysis

Noise and construction activities occurring in the vicinity of colonial waterbird rookeries have the 

potential to displace birds during active construction. In addition, displacement could result in the birds 

leaving the area. This displacement could disrupt breeding and nesting activities of the waterbirds within 

the Project area. 

KMLP has stated that it would employ a qualified biologist to survey the work area during the 

2007 nesting season, and again immediately prior to construction (in areas where construction occurred 

during the nesting season) to determine the presence of colonial waterbird rookeries. In accordance with 

recommendations given by FWS and the NHP of LDWF, the survey would notate any colony of wading 

birds (herons, egrets, night-herons, ibis, roseate spoonbills, anhinga, and/or cormorants) within 1,000 feet 

of the work area, as well as any colony of nesting gulls, terns, and/or black skimmers within 1,312 feet of 

the work area. KMLP would further consult with FWS and the NHP of LDWF in order to determine 

mitigation measures to minimize potential impacts to these nesting areas, should they be found. 

4.6.2 Freshwater Aquatic Resources 

This section discusses freshwater aquatic resources. Estuarine waterbodies are discussed in 

section 4.6.3. A table identifying all waterbodies crossed by the Project, as well as their width, state 

waterbody classification, crossing location, and crossing method is included as appendix G of this EIS. 

4.6.2.1 Affected Environment 

The Project would cross a total of 298 freshwater waterbodies, each of which supports 

warmwater fisheries. Aside from the potential utilization of the Calcasieu River by some estuarine 

species in seasons of high salinity, the Project would cross only freshwater aquatic habitats after entering 

Calcasieu Parish. Freshwater fishes common within affected waterbodies are listed in table 4.6.2.1-1. 

TABLE 4.6.2.1-1 

Freshwater Aquatic Species Occurring Within Waterbodies Crossed 

by the Proposed KMLP Project 

Common Name Scientific Name 

Fish Gars Lepisosteidae 

Bowfins Amiidae 

Catfishes Ictaluridae 

Eels Anguillidae 

Carps and Minnows Cyprinidae 

Sunfishes, Basses, and Crappies Centrarchidae 

Creek Chubsucker Erimyzon oblongus 

Inland Silverside Menidia beryllina 

Red-eared Sunfish Lepomis microlophus 

Swamp Darter Etheostoma fusiforme 

Mosquitofish Gambusia affinis 

Crustaceans Red Swamp Crawfish Procambarus clarkia 

White River Crawfish Procambarus zonangulus 
 4-52 Environmental Analysis

Fisheries of special concern include areas containing exceptional recreational or commercial 

fisheries, specially designated streams or rivers, and waterbodies supporting rare or endangered aquatic 

species. Potential impacts to threatened and endangered species are discussed in section 4.7. No 

freshwater waterbodies that have been designated as fisheries of special concern would be crossed by the 

Project. However, eight waterbodies - the Black Bayou Cutoff, GIWW, Vinton Drainage Canal, Bayou 

Choupique, Calcasieu River, East Bayou Lacassine, Bayou Nezpique, and Bayou des Cannes - that would 

be crossed by the Project are designated to support fish and wildlife propagation. These waterbodies 

provide aquatic habitat, food, resting and reproductive opportunities, and/or travel corridors to aquatic 

species. 

Commercial and Recreational Fisheries 

Each of the waterbodies identified as supporting fish and wildlife propagation also supports 

recreational and/or commercial fisheries with crappie and catfish being the main catch. The Calcasieu 

River is further designated for oyster propagation. According to the LDWF, due to recent hurricane 

activity no recreational fishery is present in Bayou Lacassine. Although the Calcasieu River and the 

GIWW are considered primarily freshwater waterbodies, they do support a number of commercial 

estuarine species including brown and white shrimp, and recreational fisheries for spotted seatrout, red 

drum, and southern flounder. 

Crawfish are also an important fishery within Louisiana, both recreationally and commercially. 

In the south, the fishery is dominated by just two species, the red swamp crawfish and the white river 

crawfish (LSU Ag Center 2006). Crawfish farming was the most valuable aquaculture crop in Louisiana 

for 2005; however, the wild-caught crawfish are preferred by many consumers due to its larger size. The 

volume of wild crawfish harvest is almost completely constrained by the timing and duration of the 

annual floodwater event in the Atchafalaya Basin (LSU Ag Center 2005). East of the Calcasieu River, 

significant numbers of crawfish farms occur along the route. See section 4.8 for a discussion on land use 

with regard to crawfish farms. 

4.6.2.2 Impacts and Mitigation 

Construction Impacts 

The crossing methods proposed for each waterbody are identified in appendix G of this draft EIS. 

Depending on the construction method used, direct and indirect impacts could occur to the aquatic 

habitats and the species that utilize them. Open-cut and flume crossing methods would directly impact 

crossed waterbodies whereas the use of HDDs or bores would generally avoid impacts. As proposed, 56 

percent of minor and intermediate waterbodies would be crossed by either HDD or bore; the remaining 44 

percent would be crossed by open-cut or flume methods. Each of the 10 major waterbodies would be 

crossed by HDD. 

Of the eight waterbodies supporting commercial and/or recreational fisheries, all but two would 

be crossed by HDD, avoiding impacts to the fisheries. The exceptions, Bayou des Cannes and Bayou 

Lacassine, would be crossed by flume and/or open-cut. Construction through the approximately 108 

crawfish ponds along the route would be accomplished by typical upland construction methods, including 

clearing and trenching. KMLP has stated that it would try to schedule construction through these areas 

during times when the fields and ponds are not normally flooded, or negotiate with the landowners so that 

flooding of the crawfish ponds would be deferred for the season. 

Pipeline construction using open-cut methods would cause an increase in the turbidity and 

sedimentation of a given waterbody. The suspension of sediments decreases the amount of light that 
 4-53 Environmental Analysis

penetrates through the water. With a decrease in light, photosynthetic organisms produce less oxygen, 

thereby decreasing the amount of DO available for uptake by fish and other aquatic species. Additionally, 

organic materials resuspended with the sediment can increase the BOD, further decreasing the available 

DO. During periods of low DO, fewer organisms can be supported in a particular area. Those individuals 

that are not displaced can experience stress, decreased food availability, and mortality. Sedimentation can 

also cause increased mortality to relatively immobile benthic organisms and fish eggs as they are covered 

by the falling sediment. Loss of these organisms can cause a decrease in the prey species available for 

various species of fish and aquatic organisms. 

The flume crossing method would be used for three waterbody crossings; one crossing of East 

Bayou Lacassine (MP 84.9), and two crossings of Bayou des Cannes (MP 124.7 of Leg 1 and MP 1.6 of 

the FGT Lateral). The water in these streams would be routed so that trenching activities would be done 

in relatively dry conditions. This method would reduce the amount of turbidity and sedimentation 

associated with a conventional open-cut crossing. To further reduce the potential for impacts within 

Bayou des Cannes at the FGT Lateral crossing, we include a recommendation in section 4.3.2 that KMLP 

evaluate the feasibility of the FGT Lateral crossing Bayou des Cannes by HDD. 

In both the open-cut and flume methods, removal of vegetation from riparian areas along the 

waterbodies would be necessary, causing an increase in surface runoff and erosion, contributing to the 

impacts mentioned above. Additionally, loss of riparian vegetation would result in a slight increase in 

water temperature from increased exposure to the sun. 

Impacts of erosion would be minimized by use of our Procedures, which require the use of 

temporary and permanent erosion controls such as silt fences and slope breakers. Temporary erosion 

controls would be required immediately after the initial disturbance of the waterbody or adjacent upland 

area has occurred and would remain until either replaced by permanent erosion controls or restoration of 

the adjacent upland has been completed. Additionally, trees and shrubs would be allowed to reestablish 

themselves on the waterbody banks with the exception of a 10-foot-wide corridor that must be maintained 

in an herbaceous state, helping to curb both erosion and temperature elevation. 

Our Procedures also require that minor and intermediate waterbodies generally be crossed in 24 

and 48 hours, respectively, resulting in a limited period of elevated turbidity. The rapid construction 

through these waterbodies, along with the mitigation measures mentioned in our Plan and Procedures, 

would reduce the impacts of turbidity and sedimentation to fish and other aquatic species. Overall 

impacts to freshwater aquatic species would be localized and short-term as only a small area of a crossed 

waterbody would be affected. 

KMLP proposes a total of 18 HDDs for pipeline installation across waterbodies (see table 

4.3.2.1-3). An additional 147 crossings of intermediate and minor waterbodies would be made by 

horizontal bore, which like HDD, typically avoids habitat impacts. While HDD is the preferred crossing 

method for sensitive or important habitats because the method avoids or minimizes impacts to these areas, 

they are not without risk and can affect the habitat by release of drilling fluid or a frac-out. Frac-outs and 

releases of drilling fluid would increase turbidity and sedimentation, contributing to the impacts 

mentioned above. A draft HDD Contingency Plan is provided in appendix I and details the procedures 

KMLP would implement if release of drilling fluid or a frac-out occurred. 

Hydrostatic testing of the pipeline would require the withdrawal of large volumes of water from 

certain waterbodies as listed in table 4.3.2.2-1 to test the structural integrity of the pipeline. Water would 

be withdrawn from eight freshwater waterbodies, three of which support recreational and/or commercial 

fisheries. Significant withdrawals of water from any one waterbody could cause a reduction in flow or an 

overall decrease in volume, disrupting microhabitats as the water level drops below the boundary that is 
 4-54 Environmental Analysis

normally inundated. The intake of water would cause the mortality of non-motile species, or species 

unable to avoid the flow field, as they are impinged upon the screen or entrained through it. Discharge of 

the test water could cause the erosion of stream banks and their vegetation or scouring of the waterbody 

bottom substrate. Erosion and scouring would increase the turbidity and sedimentation at the discharge 

point, causing stress to individuals and decreasing their ability to detect prey and predators. Increased 

turbidity, withdrawal of oxygen-rich waters, and discharge of the organic material created by the 

entrained individuals would decrease the amount of DO remaining in the waterbody. KMLP would 

prevent or limit these impacts from hydrostatic testing by implementing our Procedures which include 

measures that require the screening of intake hoses to prevent the entrainment of larger fish and 

maintaining adequate flow rates for the protection of aquatic life. 

During construction, water pollutants also could be introduced into waterbodies by releases of 

fuel and oil spills from construction equipment, herbicides, and disturbance of contaminated sediments. 

The introduction of pollutants to aquatic species can cause acute or chronic toxicity, mortality, an increase 

in stress, and decreases in reproduction, growth, recruitment, and predator/prey detection abilities. As 

discussed in section 2.3, KMLP would develop and implement a project-specific SWPPP and SPRP that 

describes the containment and cleanup procedures that would be employed in the event of a spill or a leak 

of hazardous materials. To avoid contamination within waterbodies, KMLP has stated that BMPs 

addressing hazardous materials handling and storage, and spill prevention and response, would be 

developed as part of the SWPPP prior to construction. KMLP would also adhere to our Plan and 

Procedures. 

Disturbance and resuspension of contaminated soils and sediments would result in adverse 

impacts to water quality and instream habitat. As indicated in the EPA’s National Sediment Quality 

Survey report of 1997, the lower Calcasieu watershed contained APCs indicating that the areas would 

likely have adverse effects on aquatic and human life (EPA 1997). Later surveys indicated that those 

APCs are no longer present, although some areas still contained contaminated sediments (EPA 2004). 

KMLP has proposed the HDD crossing method for the Calcasieu River, which would avoid contact and 

disturbance of contaminated sediments. HDD frac-outs could impact local species through increased 

turbidity and sedimentation, but that would not cause chemical contamination in the affected waterbody. 

In case unidentified contaminated soils are discovered during construction, we are recommending in 

section 4.2.2.1 that KMLP develop a Plan for the Discovery and Management of Contaminated Soils and 

Groundwater. This plan would minimize the risk of adverse effects to aquatic species through the 

resuspendion of contaminated soils and sediments. 

Operation Impacts 

Impacts to fisheries and aquatic habitats resulting from maintenance of the permanent right-ofway would be relatively minor. Our Procedures require that a riparian strip at least 25 feet wide be 

allowed to revegetate to preconstruction conditions along all waterbodies, with the exception of the 

permanent right-of-way that may be permanently maintained in an herbaceous state to facilitate pipeline 

surveys. Contamination could occur during operations by spills from vehicles used to survey the pipeline 

route or from herbicide use to curb excessive growth along the pipeline right-of-way. 

Our Procedures include measures to avoid using herbicides or pesticides within 100 feet of a 

waterbody (unless authorized by a land manager or state agency). In addition, the SWPPP, SPRP, and 

BMPs to be implemented by KMLP address hazardous materials handling and storage, and spill 

prevention, and response measures. Therefore, we believe that these measures would minimize adverse 

impacts on aquatic resources. 
 4-55 Environmental Analysis

4.6.3 Marine Fishery Resources 

4.6.3.1 Affected Environment 

The Project would cross a total of 12 estuarine waterbodies, each of which contains warmwater 

fisheries. Of the 12 estuarine waterbody crossings, five are major waterbodies and seven are intermediate 

waterbodies. All but two of these waterbodies are perennial. A table identifying all waterbodies crossed 

by the Project, as well as their width, state waterbody classification, crossing location, and crossing 

method is included as appendix G of this draft EIS. Marine species common along the route are listed in 

table 4.6.3.1-1. 

TABLE 4.6.3.1-1 

Marine Species Occurring Within Waterbodies Crossed by the Proposed KMLP Project 

Common Name Scientific Name 

Fish Sand Seatrout Cynocion arenarius 

Threadfin Shad Dorosoma petenense 

Gizzard Shad Dorosoma cepedianum 

Bowfin Amia calva 

Spotted Gar Lepisosteus oculatus 

Southern Flounder Paralichthus lethostigma 

Spanish Mackerel Scomberomorus maculatus 

Black Drum Pogonias cromis 

Red Drum Sciaenops occellatus 

Atlantic Croaker Micropogonias undulates 

Bay Anchovy Anchoa mitchilli 

Spot Leiostomus xanthurus 

Spotted Seatrout Cynoscion nebulosus 

Sheepshead Archosargus probatocephalus 

Gafftopsail Catfish Bagre marinus 

Gulf Menhaden Brevoortia patronus 

Mollusks Atlantic Rangia Rangia cuneata 

Crustaceans Brown Shrimp Penaeus aztecus 

White Shrimp Penaeus setiferus 

Blue Crab Callinectes sapidus 

Fisheries of special concern within the estuarine systems of the Project area include Sabine Lake 

and the Sabine and Calcasieu Rivers, each of which contains EFH for various species of marine fishes. 

The Calcasieu River, although considered freshwater for the purposes of this draft EIS, is part of an 

estuarine system that also contains EFH for various species. Impacts to these waterbodies and the 

managed species that occur within them are discussed in detail in section 4.6.4. Three of the waterbodies 

that would be crossed by the Project are designated to support fish and wildlife propagation, and therefore 

potentially contain spawning locations for commercial and recreational fisheries. Additionally, LDWF 

(2006a) has indicated that adult paddlefish migrate up into Bayou Nezpique to spawn from January 

through April. 
 4-56 Environmental Analysis

The commercial and recreational fisheries found within the estuaries crossed by the Project 

include oysters, shrimp, crab, and various fish. Sabine Lake is the major waterbody that supports these 

fisheries. 

Sabine Lake 

Sabine Lake is designated by the Louisiana Administrative Code (Title 33, Part 6) to support 

oyster propagation. The designation indicates that Sabine Lake supports economically important species 

of clams, oysters, mussels, or other mollusks. Eastern oysters are an important commercial species in 

Louisiana. In 2004, 55 percent of the landings of eastern oyster within the Gulf of Mexico came from 

Louisiana. Oysters require some hard substrate, or cultch, to settle on. They may eventually build large 

reefs, or may occur singly or in clumps on any manmade or natural structures with hard surface. Shell 

reefs also provide a habitat for a variety of species for foraging and cover. Impacts to oyster reefs or 

substrate suitable for settlement could decrease the socioeconomic and ecological value of these areas. 

Sabine Lake is considered to be a public oyster seed ground and public oyster tonging area. 

Activities affecting productive public oyster areas require a CUP that can be obtained by the applicant 

after a water bottom assessment is provided to LDWF and approved. The LDWF requires that impacts to 

the water bottoms of the public oyster areas associated with construction activities be compensated. 

Compensation may be in the form of replacing impacted habitat using oyster cultch material (limestone, 

crushed concrete, oyster shell, etc.) or by making a payment directly to the Public Oyster Seed Ground 

Development Account (LDNR 2006). 

KMLP conducted a bottom survey of Sabine Lake in March and April of 2006 to determine the 

extent of suitable habitat for oysters. The survey was conducted in compliance with guidelines developed 

by LDWF for sampling in oyster seed grounds, seed reservations, and tonging areas in order to 

characterize and quantify the different substrate types and to determine the presence, quantity, condition, 

and demography of oyster reefs within the area of interest. The survey corridor, approximately 3,000 feet 

wide and centered over the pipeline route, was subjected to a side scan sonar with sub-bottom profiling 

and then ground-truthed by manual poling. A ponar dredge was also used to collect samples and identify 

species in the surveyed areas. 

From the results of this survey, the bottom substrate of Sabine Lake was broken into three main 

categories: Types I, II, and III, pertaining to the suitability as oyster substrate, and seven subcategories 

specifying the substrate type (see table 4.6.3.1-2). The assessment identified 522.8 acres of oyster reefs 

and cultch substrate (Types II and III) within the survey corridor. Current conditions within the survey 

TABLE 4.6.3.1-2 

Bottom Substrate Crossed by the KMLP Project within Sabine Lake 

Substrate Acreage within Survey Corridor Percentage of Survey Corridor 

Soft mud with buried shell (Type I) 4,552.2 87.9 

Firm mud (Type II) 187.6 3.6 

Soft mud with exposed scattered shell 

(Type II) 

172.1 3.3 

Moderately firm mud (Type II) 151.8 2.9 

Soft mud (Type I) 105.5 2.0 

Reef (Type III) 5.9 0.1 

Exposed shell (Type III) 5.4 0.1 
 4-57 Environmental Analysis

corridor result in 0.0 marketable sacks per acre of water bottom; however, seed and spat data indicate that 

70.8 marketable sacks of oysters would be available in the future from the reef areas found within the 

survey corridor. 

The mollusks or shells present were generally found within the bottom substrates designated as 

reef and exposed shell (Type III substrates), equating to a total area of 11.3 acres of bottom substrate 

suitable for or containing mollusks. The majority of the oyster resources were found at the southern shore 

of Sabine Lake, which would be avoided by the HDD construction method, although isolated patches 

occurred within the survey corridor out to approximately 3.5 miles from shore, the closest being 

approximately 500 feet away from the proposed pipeline right-of-way. The mollusk species noted most 

often along the corridor was the Atlantic rangia, an estuarine bivalve; only one eastern oyster was found 

during dredge sampling. 

Sabine Lake also supports both recreational and commercial fisheries for shrimp, crab, and 

various fish. The Sabine River and Burton Shell Slip support only recreational fisheries, but the species 

would likely be the same as all three waterbodies are part of the same estuarine system. The LDWF 

marine fisheries manager described the fishery in Sabine Lake as including recreational fishing for 

spotted seatrout, red drum, black drum, and southern flounder (LDWF 2006a). Incidental catch may also 

include croaker and hardhead. The recreational fisheries of the Sabine River and the Burton Shell Slip 

would be expected to include the same species, although fishing effort may be lower, as all three 

waterbodies are part of the same estuarine system. The inshore fishing seasons are typically from midMay to early-July and again from mid-August to December. 

4.6.3.2 Impacts and Mitigation 

Construction Impacts 

The crossing methods proposed for each estuarine waterbody are identified in appendix G of this 

draft EIS. Depending on the construction method used, direct and indirect impacts could occur to the 

aquatic habitats and the species that utilize them. Open-cut methods would directly impact crossed 

waterbodies whereas the use of HDDs would generally avoid impacts. Of the waterbodies supporting 

marine fisheries – Sabine Lake, the Sabine River, and the Burton Shell Slip – the Burton Shell Slip would 

be crossed by HDD, avoiding impacts to the fisheries. The Sabine River would not be crossed by the 

pipeline route, but temporary extra workspaces would protrude into the river at four places with only 

minor, temporary effects. The crossing of Sabine River and Sabine Lake would be accomplished by a 

combination of HDD and open-cut methods, causing direct impacts to the waterbody and the species that 

utilize it. Crossing methods of Sabine Lake and the Sabine River are described in section 2.3. 

General impacts to fishes and crustaceans through open-cut crossing methods and hydrostatic test 

water withdrawal and discharge include waterbody contamination, loss of habitat, and increased turbidity 

and sedimentation. These are described under section 4.6.2.2 on freshwater aquatic resources and are 

identical to impacts in estuarine environments. 

As discussed in section 4.6.3.1, the southern portion of Sabine Lake supports the majority of 

oyster resources found along the pipeline route. Isolated patches of oyster resources also occur within 

1,500 feet of the pipeline route, the closest being less than 500 feet away. As the majority of bottom 

substrate along the pipeline survey corridor is relatively soft bottom with no structure, the loss of any 

oyster resources would impact a variety of estuarine species that use the hard bottom area for foraging 

and cover. KMLP proposes to avoid impacts to the nearshore oyster resources by use of an HDD that 

would exit at MP 4.82 within the open water of Sabine Lake. Open-cut construction through Sabine Lake 
 4-58 Environmental Analysis

would require a 200- to 300-foot-wide construction right-of-way and require excavation of a pipe trench 

as well as a floatation channel for spud barges in waters less then 8 feet deep. These construction 

procedures would place spoil piles within 350 feet of oyster resources, increasing turbidity and 

sedimentation in the area. 

Oyster resources occurring in the project area such as rangia are filter-feeders and require low 

levels of sedimentation and adequate water movement to supply them with food and remove wastes. 

Similar to other mollusks, oysters can tolerate thin layers of sediment or partial burial. Complete burial 

by gradual, natural sedimentation or dredge material disposal would cause mortality (Britton and Morton 

1989).

The proposed construction through Sabine Lake would result in a temporary loss of soft bottom 

habitat due to the placement of the spoil piles, which would temporarily cover the habitat at that location. 

Due to the expanse of soft bottom habitat in Sabine Lake, mobile species utilizing this habitat would be 

expected to be temporarily displaced; however, less mobile species, such as the benthic invertebrates that 

utilize soft bottom habitat, would be smothered and experience mortality through placement of the spoil 

piles. 

KMLP states that it will compensate LDWF for the disturbance of each bottom type within 

Sabine Lake that occurs as a direct result of pipeline construction. The LDWF indicated that 

compensation for impacts to public oyster seed grounds shall be in the form of planting cultch material 

(i.e., crushed concrete, limestone, oyster shell, etc.) at the rate of one cubic yard per acre of impacted area 

for barren, non-supportive areas of the seed grounds, 50 cubic yards for supportive areas, and 187 cubic 

yards for reef areas plus the value of any living oyster resources destroyed (LDWF 2005). KMLP reports 

that there are no active oyster leases along the proposed route. In addition, KMLP conducted an oyster 

survey and the proposed route would largely avoid oyster resources. The primary area along the proposed 

route with marketable oysters was near the HDD exit pit at MP 4.82. KMLP has agreed to compensate 

LDWF for oysters lost due to sedimentation on the reefs within 1,500 feet of this HDD exit pit based on 

existing information or pre- and post-construction surveys. 

Operation Impacts 

The operational impacts for marine fisheries resources would be the same as those discussed 

under freshwater aquatic resources in section 4.6.2.2. 

Thus, there would be no significant impacts to marine fishery resources during construction or 

operation of the Project. 

4.6.4 Essential Fish Habitat 

EFH was defined by the MSA as “those waters and substrate necessary to fish for spawning, 

breeding, feeding, or growth to maturity.” The MSA granted NOAA Fisheries Service legislative 

authority for fisheries regulation in the United States within a jurisdictional area between 3 and 200 miles 

offshore. NOAA Fisheries Service was also granted legislative authority to establish eight regional 

fishery management councils, each responsible for the proper management and harvest of finfish and 

shellfish resources within their respective geographic areas. The statute includes a mandate that federal 

agencies must consult with the Secretary of Commerce on all activities or proposed actions that are 

authorized, funded, or undertaken by the agency that might adversely affect EFH. NOAA Fisheries 

Service recommends consolidated EFH consultations with interagency coordination procedures required 

by other statutes such as NEPA or the ESA (50 CFR 600.920[e][I]) to reduce duplication and improve 

efficiency. The mandatory contents of an EFH Assessment are detailed in 50 CFR 600.920(e)(3). 
 4-59 Environmental Analysis

The estuarine waters within the Project area are within the jurisdiction of the Gulf of Mexico 

Fishery Management Council (GMFMC), which has designated all estuarine habitat as EFH, including: 

emergent and mangrove wetlands; submerged aquatic vegetation (SAV); algal flats; mud, sand, shell, and 

rock substrates; and the water column. The GMFMC manages approximately 450 species within the 

Gulf, grouped into seven Fishery Management Plans (FMPs). Five of these FMPs (including the red 

drum, reef fish, coastal migratory pelagic, shrimp, and stone crab FMPs) have designated all estuarine 

systems on the Gulf coast as EFH. The estuarine systems crossed by the KMLP Project would include 

Sabine Lake and the Sabine and Calcasieu Rivers. 

The EFH within Sabine Lake, Sabine River, and Calcasieu River include emergent wetlands, mud 

bottom substrate, shell reefs, and the water column itself. Estuarine emergent wetlands are among the 

most productive ecosystems on earth (Teal and Teal 1969, Odum et al. 1982). They are integral parts of 

the estuarine system, serving as nursery habitats for the larval stages of many fish and invertebrate 

species. Estuarine wetlands are also important in the removal of contaminants, and a buffer to reduce the 

erosion of inland areas. The mud bottom substrates of these waterbodies provide a habitat for various 

invertebrates, which in turn creates foraging habitat for other invertebrates and fishes. Shell reefs are 

generally composed of an upper zone consisting of live oysters and associated species, over a core of 

buried shell and mud (Bahr and Lancer 1981). This provides a structural complexity to the aquatic habitat 

that is used for feeding, breeding, and growth by a variety of species, managed or otherwise. 

We have incorporated EFH consultations for the KMLP Project with the interagency coordination 

procedures required under NEPA. For purposes of reviewing this Project under NEPA, FERC is the 

lead federal agency. As such, FERC requests that NOAA Fisheries Service consider this document 

as notification of initiation of EFH consultation. An assessment of potential effects of the Project is 

included below.

4.6.4.1 Affected Federally Managed Species 

Of the species with EFH designations in estuarine waterbodies, the brown and white shrimp, red 

drum, Gulf stone crab, and dog and lane snappers have EFH designations within the region of the Project 

(NOAA 2006b). NOAA Fisheries Service also indicated in written correspondence that waters in the 

Project area have been designated as EFH for the late juvenile, subadult, and adult stages of the 

bonnethead shark. Although none of these species is considered to be threatened or endangered, the red 

drum population is classified as overfished, or below the desired threshold, in the Gulf of Mexico. 

Table 4.6.4.1-1 lists the species and life stages within the EFH occurring in the Project area. 

Table 4.6.4.1-2 summarizes seasonal abundance data of each of the managed species that occur in the 

Project area. 

Brown Shrimp 

Brown shrimp are found in a range of habitats from estuaries to offshore depths of approximately 

360 feet. Spawning occurs offshore with the pelagic larvae migrating to the estuaries and becoming 

bottom-oriented (GMFMC 2004). Postlarvae and juveniles are associated with shallow vegetated 

habitats, silty sand, and non-vegetated bottoms. The density of these stages are highest in marsh edge 

habitat and SAV, followed by tidal creeks, inner marsh, shallow open water, and oyster reefs (GMFMC 

2004). Larvae initially consume planktonic algae and zooplankton, but become opportunistic as they age, 

feeding upon detritus, plants, and small fish and invertebrates (Darnell 1958, Perez-Farfante 1969). 
 4-60 Environmental Analysis

TABLE 4.6.4.1-1 

Summary of EFH Categories Potentially Used by Specific Life Stages 

of Federally Managed Species 

EFH Categories 

Species/Life Stage Water Column 

Emergent 

Wetlands 

Mud Bottom 

Substrates Shell Reefs 

Brown Shrimp 

Larvae/Postlarvae X X X X 

Juvenile X X X 

White Shrimp 

Larvae/Postlarvae X X X 

Juvenile X X 

Red Drum 

Larvae/Postlarvae X X X 

Juvenile X X 

Adult X X X X 

Gulf Stone Crab 

Eggs X 

Larvae/Postlarvae X X X 

Juvenile X X X 

Dog Snapper 

Juvenile X 

Lane Snapper 

Larvae 

Juvenile X 

Bonnethead Shark 

Late Juvenile X 

Subadult X 

Adult X 

_______________ 

Source: NOAA 2006b.

White Shrimp 

Similar to the brown shrimp, white shrimp habitats range from estuaries to offshore depths of 

approximately 130 feet. This species is known to spawn offshore and have pelagic larvae that migrate to 

the estuaries and become bottom-oriented. Postlarvae and juveniles generally utilize mud and peat 

bottoms with large amounts of detritus or vegetative cover (GMFMC 2004). Larvae of white shrimp also 

consume planktonic algae and zooplankton, but as juveniles have been reported to feed on sand, detritus, 

mollusk fragments, and small invertebrates (Darnell 1958). 
 4-61 Environmental Analysis

TABLE 4.6.4.1-2 

Relative Abundance of Managed Species within the Project Area 

Relative Abundance 

Species 

Life 

Stagea Low Salinity 

(March-May) 

Increasing 

Salinity 

(June-July) 

High Salinity 

(Aug-Oct) 

Decreasing 

Salinity 

(Nov-Feb) 

Brown Shrimp Adult C C C/R R 

Juvenile A A A C 

White Shrimp Adult C C HA HA 

Juvenile HA HA HA HA 

Red Drum Adult R C/R C/R C/R 

Juvenile C C C C 

Gulf Stone Crab Adult R R R R 

Juvenile R R R R 

Dog Snapper Adult NA NA NA NA 

Juvenile NA NA NA NA 

Lane Snapper Adult NA NA NA NA 

Juvenile NA NA NA NA 

Bonnethead Shark Adult NA NA NA NA 

Juvenile NA NA NA NA 

_______________ 

a Life stages for which EFH is mapped include only adults and juveniles. b EFH habitat for this life stage is noted as reefs and submerged aquatic vegetation not occurring within the Project area. 

C = Common, R = Rare, A=Abundant, HA = Highly Abundant, NA = Not Available 

Source: NOAA 1998.

Red Drum 

Red drum commonly occur in the Gulf of Mexico, from offshore waters to very shallow estuarine 

waters. They occur in virtually all of the Gulf’s estuaries over a variety of substrates including seagrass, 

sand, mud, and oyster reefs. Spawning occurs in the mouths of bays, inlets, and on the Gulf side of the 

barrier islands, after which, larvae are transported into the estuaries. Estuarine wetlands are especially 

important EFH for larvae, juvenile, and subadult stages. Common prey species of red drum include 

several species that are also estuarine dependant such as shrimp, blue crab, striped mullet, and pinfish. 

Larval drum eat small prey species such as mysids and amphipods (GMFMC 2004). 

Gulf Stone Crab 

Adult stone crabs are benthic organisms that can be found on a variety of hard substrates and 

seagrass beds from the shoreline to depths of 200 feet (GMFMC 2004). Although larvae generally utilize 

the pelagic waters of the estuaries, all other life stages utilize sand/shell bottoms, oyster reefs, and/or soft 

bottom habitats (GMFMC 2003). Stone crabs are primarily carnivorous at each life stage, with larvae 

feeding primarily on plankton, juveniles on invertebrates and mollusks, and adults on mollusks, carrion, 

and other stone crabs. The species is basically dependant on the prey produced in the estuaries and 

seagrass beds where freshwater runoff results in higher phytoplankton productivity (GMFMC 2004). 
 4-62 Environmental Analysis

Dog Snapper 

Adult dog snapper may use submerged aquatic vegetation within estuaries as feeding areas, but 

generally occur within the coastal and offshore areas of the Gulf and are most commonly found on coral 

reefs (GMFMC 2004). Early juveniles, however, are found on shallow water seagrass beds of coastal 

waters and estuaries, as well as in estuarine emergent marshes, and may enter rivers (GMFMC 2003, 

GMFMC 2004). The region of the Project contains nursery habitat for early and late stage juveniles, 

which are known to utilize emergent marshes for growth (GMFMC 2003). 

Lane Snapper 

The lane snapper is demersal, occurring over all bottom types although it is most common in 

coral reef and sandy bottom areas. Nursery habitat includes mangrove and grassy estuarine areas in 

southern Texas and Florida as well as shallow areas with sandy and muddy bottoms off each of the Gulf 

states (GMFMC 2004). Early and late juvenile stages utilize sand/shell and soft bottom substrates in 

estuaries for feeding and growth (GMFMC 2003). 

Bonnethead Shark 

The bonnethead shark is the smallest member of the hammerhead family. It inhabits sandy or 

muddy bottoms of shallow coastal waters, feeding primarily on crabs, shrimp, mollusks, and small fishes 

(FWRI no date). This species is relatively resistant to overfishing due to a fast growth-rate, annual 

reproduction, and lack of a commercial fishery (NOAA 2006b). 

4.6.4.2 Impacts and Mitigation 

Sabine Lake, Sabine River, and Calcasieu River support EFH that includes emergent wetlands, 

mud bottom substrates, shell reefs, and water column habitats. The Calcasieu River would be crossed by 

HDD; thus, avoiding impacts to the EFH and the managed species that occur there. The Sabine River 

would not be crossed by the pipeline, but temporary extra workspaces associated with HDD operations 

would protrude into the river at four locations. These temporary extra workspaces would have a minor, 

temporary impact to EFH in the Sabine River. The crossing of Sabine Lake would be accomplished by a 

combination of HDD and open-cut methods, causing direct impacts to the lake and the species that utilize 

it. 

Construction through the first 50 miles of the pipeline route would impact approximately 99.5 

acres of EFH wetlands. Impacted areas are located at the northern and southern ends of Sabine Lake, on 

Shell Island, and along Sabine and Calcasieu Rivers and the GIWW. Disturbance of these habitats would 

temporarily reduce the amount of foraging habitat and cover available to these species. Disturbance of 

these wetlands would also temporarily decrease the habitat available for recruitment, leaving new recruits 

susceptible to increased predation as they search for alternative habitat or remain in open waters. The use 

of tracked vehicles through estuarine wetlands has the potential to permanently impact wetlands 

designated as EFH. In order to avoid permanent impacts, low-ground-pressure equipment or temporary 

board roads would be used. Marsh buggies would be used in saturated EFH wetlands where the use of 

board roads would not be practical (MP 1.5 to MP 3.9 and from MP 32.3 to MP 35.2). 

The proposed construction through Sabine Lake would result in a temporary loss of soft bottom 

habitat due to the placement of the spoil piles, which would cover the habitat at that location. Due to the 

expanse of soft bottom habitat in Sabine Lake, the more mobile managed species utilizing this habitat 

would be expected to be temporarily displaced; however, less mobile stages of managed species that 
 4-63 Environmental Analysis

utilize soft bottom habitat could be smothered and experience mortality through placement of the spoil 

piles. 

The southern portion of Sabine Lake supports the majority of oyster resources found along the 

pipeline route and would be avoided by HDD. Isolated patches of oyster resources also occur within 

1,500 feet of the pipeline route, the closest being less than 500 feet away. As the majority of bottom 

substrate along the pipeline survey corridor is relatively soft bottom with no structure, the loss of any 

oyster resources would impact managed species for which shell reefs are considered EFH. KMLP would 

compensate LDWF for any oyster resources lost during pipeline construction as described in 

section 4.6.3.2. 

Disturbance of the water column would occur in Sabine Lake during trenching activities. The 

managed species are mobile and would likely avoid the area during construction and return shortly after 

the completion of construction. The increased turbidity and sedimentation, disruption of wetlands, 

hydrostatic test water withdrawal, and other impacts from Project construction may displace or cause the 

mortality of prey species of managed species. Some of these species serve as prey for other fish species 

managed by NOAA Fisheries Service and the GMFMC. The wetlands within Sabine Lake also produce 

nutrients and detritus, important components of the aquatic food web, which contribute to the overall 

productivity of the Sabine estuary system as well as of the near-shore environments of the Gulf of 

Mexico. 

KMLP states that it would implement a variety of mitigation measures in addition to following 

our Procedures in order to minimize impacts to aquatic habitats and the species that utilize them. These 

include: 

• Waterbody restoration. KMLP would re-establish original contours and monitor affected 

waterbodies following construction, as well as restore any levees or barriers that were 

removed as part of the construction activities. 

• Erosion and sedimentation control. KMLP would implement BMPs to control erosion and 

sediment as part of a project-specific SWPPP. 

• Riparian restoration. Maintenance of the permanent right-of-way would be limited to a 10-

foot-wide corridor, allowing the stream bank to revegetate to pre-construction conditions. 

• Contamination control. Herbicides would not be used within 100 feet of any waterbody 

without the consent of the land manager or a state agency. 

There would be no need for operation right-of-way clearing within Sabine Lake, Sabine River, 

and Calcasieu River, eliminating impacts to the EFH categories within it. Maintenance-related 

operational impacts to EFH would be limited to a 10-foot-wide right-of-way within estuarine wetlands. 

Trees in excess of 15 feet in height, should they occur within 15 feet of the pipeline right-of-way, may be 

cut and removed. The estuarine wetlands would be subjected to a site-specific monitoring plan based on 

recommendations given by NOAA Fisheries Service. With regard to these recommendations, and as 

stated in the draft Aquatic Resources Mitigation Plan (appendix J), monitoring would be primarily 

photographic in nature and would be taken from the ground at the work sites. These activities would take 

place pre-construction, immediately post-construction, and one growing season post-construction with 

photos of all work sites. The photos would be taken every 500 feet (with pictures taken in both 

directions) with the location recorded on GPS to allow a return to the exact site, and the exact location 
 4-64 Environmental Analysis

and direction of the photo would be recorded in a tabular form and referenced to an aerial photo 

documenting photo numbers. 

4.6.4.3 Conclusions 

We believe that the Project would have minimal impacts on EFH with implementation of our 

Procedures, a finalized Aquatic Resources Mitigation Plan developed in coordination with federal and 

state agencies, and the approved alternative measures to our Procedures (as discussed in this draft EIS). 

These measures would reduce the potential for unanticipated long-term impacts, and the resulting impacts 

of the Project would be insignificant and short term. 
 4-65 Environmental Analysis

4.7 THREATENED AND ENDANGERED SPECIES 

To comply with section 7 of the ESA, Kinder Morgan consulted with the FWS and NOAA 

Fisheries Service regarding the presence of federally listed or proposed threatened or endangered species 

and their critical habitats in the project area. Kinder Morgan, as the FERC’s non-federal representative 

for the purposes of complying with the ESA, has been assisting the FERC in meeting its section 7 

obligations by conducting informal consultation with the FWS and NOAA Fisheries Service. We also 

contacted and consulted with the FWS and NOAA Fisheries Service about which species under their 

respective jurisdictions would be potentially affected by the project. In addition to these consultations, 

Kinder Morgan consulted with the Natural Heritage Program (NHP) of LDWF to obtain a list of statelisted special status species in the project area. 

4.7.1 Federally Listed Threatened and Endangered Species 

The FWS and NOAA Fisheries Service have identified 12 federally listed threatened or 

endangered species in southern Louisiana that should be considered when determining the potential 

effects of the KMLP Project. According to FWS (2006a), the West Indian manatee, piping plover, Gulf 

sturgeon, and the green, leatherback, loggerhead, Kemp’s ridley, and hawksbill sea turtles are not known 

to occur in the Project area and therefore no further consultation with FWS is required for these species 

unless the scope or location of the Project changes. NOAA Fisheries Service concurred that the Gulf 

sturgeon is rarely found as far west as the Project site and stated that neither the Gulf sturgeon nor the 

smalltooth sawfish (due to low area abundance) require further consultation (NOAA 2006c). The West 

Indian manatee, piping plover, Gulf sturgeon, and smalltooth sawfish have thus been eliminated from 

further consideration in this EIS. Although FWS has determined that no further consultation is needed 

regarding four of the five species of sea turtles, NOAA Fisheries Service has joint jurisdiction over the 

five species of sea turtles known to occur in the Gulf of Mexico and has requested that these species be 

assessed with regard to potential impacts from the Project. Each of the eight remaining species are 

discussed below and shown in table 4.7.1-1 with regard to their protected status and our determination of 

impact. 

Sea Turtles 

The only threatened or endangered reptiles known to exist in the Project area are sea turtles. 

NOAA Fisheries Service is generally responsible for marine threatened and endangered sea turtles and 

FWS is responsible for sea turtles that are coming ashore to nest. No critical habitat is designated for the 

green, hawksbill, loggerhead, Kemp’s ridley, or leatherback sea turtles in the Project area. 

Leatherback Sea Turtle 

The leatherback sea turtle is primarily a pelagic species, although it will forage in coastal waters, 

and is distributed in temperate and tropical waters worldwide (NOAA and FWS 1992). It is the largest, 

deepest-diving, and widest-ranging sea turtle; the species has been federally listed as endangered since 

1970 (FWS 2002a). Leatherbacks undergo extensive migrations from feeding grounds to nesting beaches 

(NOAA 2002a). Although southeast Florida only supports minor nesting colonies, the area represents the 

most significant nesting activity within the continental United States (NOAA no date), with the nesting 

period extending from March through July (FWS 2002a). Leatherback sea turtles feed primarily on 

jellyfish, but also on sea urchins, squid, crustaceans, tunicates, fish, blue-green algae, and floating 

seaweed (FWS 2002a). Significant threats to the species include incidental capture in fishing gear and 

harvest of adults and eggs (NOAA no date). 
 4-66 Environmental Analysis

TABLE 4.7.1-1 

Federally Listed Species Potentially Occurring in the KMLP Project Area 

Species 

Federal 

Status 

State 

Status Parish Preferred Habitat Determination 

Reptiles 

Leatherback Sea Turtle 

(Dermochelys coriacea) 

E E Cameron Open sea and coastal waters. 

Prefer sandy beaches with 

deepwater approach for 

nesting. 

Not likely to 

adversely affect 

Loggerhead Sea Turtle 

(Caretta caretta) 

T T Cameron Tropical and temperate 

waters with temperatures 

above 10°C. 

Not likely to 

adversely affect 

Hawksbill Sea Turtle 

(Eretmochelys imbricate) 

E E Cameron Tropical and subtropical seas, 

including southern Florida and 

the northern Gulf of Mexico. 

Coral reefs, rocky outcrops, 

high energy shoals. 

Not likely to 

adversely affect 

Green Sea Turtle 

(Chelonia mydas) 

T/E T Cameron Lagoons, bays, inlets, shoals, 

and estuaries, as well as coral 

reefs, rocky outcrops, and 

high-energy beaches. Found 

throughout the Gulf of Mexico 

and adjoining beaches where 

the seawater temperature is 

above 25°C. 

Not likely to 

adversely affect 

Kemp’s Ridley Sea Turtle 

(Lepidochelys kempii) 

E E Cameron Shallow coastal waters, tidal 

rivers, estuaries, and 

seagrass beds with 

substrates of sand and mud. 

Not likely to 

adversely affect 

Birds 

Brown Pelican 

(Pelecanus occidentalis) 

E E Cameron Shallow coastal waters within 

20 miles or less of the 

shoreline and in depths up to 

80 feet. Breeds on small 

coastal islands and forages 

for fish along coastal and 

inland waterways. 

Not likely to 

adversely affect 

Bald Eagle 

(Haliaeetus 

leucocephalus) 

T E Cameron, 

Calcasieu 

Areas with abundant sources 

of large open waterways such 

as lakes, reservoirs, 

seacoasts, and large rivers. 

In addition to waterways, the 

availability of perches, usually 

tall trees or cliffs, adjacent to 

foraging and nesting areas. 

Occasional transient on rivers 

for foraging or feeding. 

Not likely to 

adversely affect 

Red-cockaded 

Woodpecker 

(Picoides borealis)

E E Calcasieu, 

Evangeline 

Open pine forests with large, 

widely spaces trees. Nests in 

large, old pines (60+ years). 

Forages in pine or pinehardwood stands that are 

greater than 30 years of age. 

Determination 

pending 
 4-67 Environmental Analysis

Loggerhead Sea Turtle 

The loggerhead sea turtle is the most abundant sea turtle in the Gulf of Mexico, although it is still 

federally listed as threatened. Loggerhead turtles are a cosmopolitan species, inhabiting temperate and 

tropical waters in the estuaries and continental shelves of both hemispheres (NOAA 2002b). Within the 

eastern Gulf of Mexico, the species is usually found in water depths of less than 65 feet (Fritts et al. 1983; 

Lohoefener et al. 1990; Hildebrand 1982). 

In the southeastern United States, females nest from late April through early September (NOAA 

and FWS 1991). Nesting occurs primarily on barrier islands adjacent to continental landmasses in warmtemperate and sub-tropical waters. Nest sites are typically located on open sandy beaches, above the 

mean high tide, and seaward of well-developed dunes. In Louisiana, this species has been found 

throughout the coastal region but nesting has only been recorded from the Chandeleur Islands, which is 

over 250 miles east of the potential habitat (Sabine Lake) within the Project area (LDWF 2005). Adults 

occupy a variety of habitats, ranging from turbid bays to clear waters of reefs, whereas subadults occur 

mainly in nearshore and estuarine waters. Hatchlings move directly to sea after hatching, and often float 

in masses of Sargassum. The loggerhead diet consists of a wide variety of benthic and pelagic food items, 

including conches, shellfish, horseshoe crabs, prawns and other crustacean, squid, sponges, jellyfish, 

basket stars, fish, and hatchling loggerheads. The most significant threats to the loggerhead populations 

are coastal development, commercial fisheries (especially shrimping), and pollution. 

Hawksbill Sea Turtle 

The hawksbill sea turtle is primarily coastal and is seldom seen in waters deeper than 65 feet 

(FWS 2002b). It inhabits rocky areas, coral reefs, lagoons, oceanic islands, shallow coastal areas, and 

narrow creeks and passes (FWS 2002b). Hawksbill sea turtles are found in tropical and subtropical 

waters in the Atlantic, Pacific, and Indian Oceans (FWS 2002b) and have been federally listed as 

endangered throughout their range since 1970 (FWS 2002b). The nesting season for this species 

generally occurs between April and November (FWS 2002b). Nesting occurs on undisturbed deep-sand 

beaches which range from high energy beaches to tiny pocket beaches several meters wide bounded by 

crevices of cliff walls. These beaches are normally low-energy, with woody vegetation near the 

waterline. 

Hawksbill turtles are the least common sea turtle in the Gulf of Mexico (MMS 2002), although 

they have been recorded in waters of all the states along the Gulf of Mexico (NOAA and FWS 1991). 

Adults usually forage around coral reefs and other hard bottom habitats (NOAA 2002a), and primarily eat 

sponges (FWS 2002b). This diet and their dependence on hard bottom communities make the species 

especially vulnerable to deteriorating conditions on coral reefs. Due to the lack of suitable foraging 

habitat, there is low probability of this species occurring within the Project area. 

Green Sea Turtle 

The green sea turtle is generally listed as threatened with the exception being the breeding colony 

populations in Florida and on the Pacific Coast of Mexico, which are federally listed as endangered. This 

species nests in tropical and subtropical waters worldwide and inhabits shallow waters (except when 

migrating) inside reefs, bays, and inlets. Within the southeastern U.S., green turtles generally nest 

between June and September (FWS 2002c). Hatchlings eat a variety of plants and animals (FWS 2002c) 

and forage in areas such as coral reefs, emergent rocky bottom, Sargassum mats, lagoons, and bays 

(MMS 2001). The adults feed on seagrass and marine algae, including species of Cymodocea, Thalassia, 

and Zostera (FWS 2002c). Feeding grounds in the Gulf of Mexico include inshore south Texas waters, 

the upper west coast of Florida, and the northwestern coast of the Yucatan Peninsula in Mexico. 
 4-68 Environmental Analysis

Incidental capture in fishing gear and, in some areas of the world, the harvest of eggs and adults affect the 

recovery of the green sea turtle population. Nesting within the Project area is highly unlikely, as green 

sea turtles prefer to nest on high energy beaches with deep sand and little organic content. 

Kemp's Ridley Sea Turtle 

The Kemp’s ridley sea turtle is an endangered species that occurs mainly in the coastal areas of 

the Gulf of Mexico and northwestern Atlantic Ocean. Nesting occurs mainly in Mexico from April to 

June, but Kemp’s ridley turtles also nest in small numbers along the Gulf coast. Juveniles and sub-adults 

occupy shallow, coastal regions and are commonly associated with crab-laden, sandy, or muddy water 

bottoms. Small turtles are generally found in nearshore areas of the Louisiana coast from May through 

October. Adults may be abundant near the mouth of the Mississippi River in the winter. Between the 

east Gulf coast of Texas and the Mississippi River Delta, Kemp’s ridleys can be found in nearshore 

waters, ocean sides of jetties, small boat passageways through jetties, and dredged and nondredged 

channels. They have been observed within both Sabine and Calcasieu Lakes. No sightings have been 

reported in the Project area Major threats to this species include over-exploitation on their nesting 

beaches, drowning in fishing nets, and pollution. (FWS 2006a). 

Sea Turtle Impacts 

Sea turtles are vulnerable to adverse impacts from many of the construction activities that would 

occur in Sabine Lake including: increased noise; pile driving; increased vessel traffic; and habitat 

degradation associated with trenching activities. Potential responses to noises generated during 

construction activities could cause avoidance behavior in sea turtles, as well as disorientation and 

behavioral disturbance. Pile-driving activities often involve loud, repetitive noises that could cause a 

temporary reduction in hearing sensitivity or a temporary threshold shift (TTS) in sea turtles. 

Potential effects on sea turtles from construction of the Project could include avoidance of the 

area due to noise and activity, alteration or loss of habitat, effects on prey species composition and 

abundance, and changes in water quality. Increased traffic and project activities may result in the 

temporary displacement of sea turtles from foraging and resting habitats due to increased water turbidity. 

These impacts are expected to be temporary, localized and minor, and as such adverse impacts on 

foraging and nesting sea turtles is not expected. 

Local noise levels would be increased due to passage and use of construction equipment. Piledriving would be used only to situate the signs marking the spoil piles for boater safety. 

Increased construction traffic in an area increases the likelihood of vessel/sea turtle interaction. 

Sea turtles can experience mortality and injury from collision with vessels. KMLP proposes to excavate 

both a trench through Sabine Lake for the pipeline and, in places where the water is less than eight feet 

deep, an excavation channel for the spud barges. Individuals coming into contact with construction 

equipment may be killed or injured. In a letter dated April 15, 2006, NOAA Fisheries Service provided 

their standard construction guidelines for projects occurring in areas inhabited by sea turtles, entitled “Sea 

Turtle and Smalltooth Sawfish Construction Conditions” and “Vessel Strike Avoidance Measures and 

Injured or Dead Species Reporting.” These measures are provided in appendix K. KMLP has stated that 

it would implement these guidelines during construction of the Project. With the implementation of these 

measures the construction of the Project is not likely to adversely affect sea turtles. 
 4-69 Environmental Analysis

Birds 

Brown Pelican 

The brown pelicans is found along the Atlantic and Gulf of Mexico coasts, inshore to usually no 

more than 20 miles out from shore. They are federally listed as endangered in the U.S. except along the 

Atlantic coast, Alabama, and Florida where they have been delisted due to recovery (FWS 1995). Sand 

spits and offshore sand bars are used extensively as daily loafing and nocturnal roost areas. The preferred 

nesting sites are small coastal islands which provide protection from predators and sufficient elevation to 

prevent flooding of the nests (FWS 1995). In southwestern Louisiana, brown pelicans are currently 

known to nest on Rabbit Island in Calcasieu Lake. Although no brown pelican nesting sites are known to 

occur in the Project area, they may use the area and surrounding habitat for feeding and/or loafing. 

Brown pelicans feed in shallow estuarine waters (e.g., Sabine Lake) using sand spits and offshore sand 

bars as rest and roost areas (FWS 2006a). Brown pelican are asynchronous nesters. The nesting season 

can extend from January through October, although peak egg laying usually occurs in March or April and 

often through June (NPS 2006a). Major threats to this species include chemical pollutants, colony site 

erosion, disease, and human disturbance. There is no critical habitat listed for the brown pelican. 

Brown pelicans are known to use the habitat types that occur within the Project vicinity and could 

use Sabine Lake for feeding and loafing. The known nesting colony on Rabbit Island in Calcasieu Lake 

is approximately 18 miles from the pipeline and would not be disturbed during construction or operation 

of the Project. Although feeding and loafing pelicans may be temporarily displaced by construction 

activities, we have determined that the Project is not likely to adversely affect the brown pelican. 

Bald Eagle 

The bald eagle nests in Louisiana from October through mid-May. Eagles typically nest in bald 

cypress trees near fresh to intermediate marshes or open water in the southeastern parishes. Areas with 

high numbers of nests include the Lake Verret Basin south to Houma, the southern marsh/ridge complex 

from Houma to Bayou Vista, the north shore of Lake Pontchartrain, and the Lake Salvador area. Eagles 

also winter and infrequently nest near large lakes in central, southwestern, and northern Louisiana (FWS 

2006a). The population of bald eagles began declining prior to 1940 due to a decline in prey species, loss 

of habitat, direct killing, and later, from DDT use, but has recovered to the point that it is being proposed 

for delisting (FWS no date c). Currently the population is considered threatened throughout the 

continental U.S. and Alaska. No critical habitat has been designated for the bald eagle. 

Breeding bald eagles occupy “territories” that they will typically defend against intrusion by other 

eagles, and that they are likely to return to each year. A territory may include one or more alternate nests 

that are built and maintained by the eagles, but may not be used for nesting in a given year. Potential nest 

trees within a nesting territory may, therefore, provide important alternative bald eagle nest sites. In 

forested areas, bald eagles often select the tallest trees with limbs strong enough to support a nest that 

may weigh more than 1,000 pounds. Nest sites typically include at least one perch with a clear view of 

the water or area where the eagles usually forage. Shoreline trees or snags located near large waterbodies 

provide the visibility and accessibility needed to locate aquatic prey (FWS 2006a). 

Bald eagles are most vulnerable to disturbance during courtship, nest building, egg laying, 

incubation, and brooding (roughly the first 12 weeks of the nesting cycle). Disturbance during this 

critical period may lead to nest abandonment, cracked and chilled eggs, and exposure of small young to 

the elements. Human activity near a nest late in the nesting cycle may also cause flightless birds to jump 

from the nest tree, thus reducing their chance of survival (FWS 2006a). Although the general area of high 

nest occurrence would not be impacted by the Project, the pipeline route would cross numerous 
 4-70 Environmental Analysis

freshwater and intermediate marshes and open water areas along the first portion of Leg 1. Bald eagles 

nesting in these areas could be disturbed by passage of the construction spreads. 

KMLP did not identify any bald eagle nests during field surveys conducted along the pipeline 

route. Should a bald eagle nest be encountered during construction and the construction workspace 

encroach within 1,500 feet of the nest, KMLP states that the Lafayette, Louisiana FWS office would be 

consulted to establish measures to mitigate potential impacts during the nesting season. During operation 

of the Project, KMLP has stated that no right-of-way maintenance would occur within 1,500 feet of a 

known bald eagle nests during the nesting season. Due to the absence of nests along the route, the 

consultation proposed for nests seen at a later date, and the elimination of right-of-way maintenance 

within 1,500 feet of known nests, we have determined that the construction and operation of the Project is 

not likely to adversely affect bald eagles.

Red-cockaded Woodpecker 

The red-cockaded woodpecker (RCW) is federally listed as endangered. Historically, its range 

occurred from east Texas and Oklahoma to Florida, and north to New Jersey and Maryland. The 

populations have since been extirpated from Missouri, Maryland, Tennessee, Kentucky, and New Jersey, 

with the remaining populations fragmented (FWS 1983). The preferred habitat consists of longleaf pine 

although other species of southern pine are also used. The RCW excavates cavities in large (i.e., 10 

inches or greater in diameter at breast height) living pines that are often suffering from red heart disease 

that causes the inner wood to become soft (FWS 2006a; FWS 1983). Nesting occurs in mature (greater 

than 60 years old) pine trees containing little hardwood understory or midstory (FWS 2006a); RCWs are 

intolerant of dense hardwood midstories resulting from fire suppression. The cavity trees and the 

foraging area within 200 feet of those trees are known as a cluster. Foraging habitat is defined as pine 

and pine-hardwood stands (i.e., 50 percent or more of the dominant trees are pines) over 30 years of age 

that are located contiguous to and within one-half mile of the cluster (FWS 2006a). The decline of the 

RCW is attributed primarily to the reduction of pine forest and to the encroachment of hardwood midstory 

due to fire suppression (FWS 1983). There is no critical habitat designated for this species. 

KMLP has stated that if suitable habitat exists along the remaining portion of the pipeline route, 

all suitable nesting habitat within a 0.5-mile radius of the Project boundary would be surveyed by a 

qualified biologist for the presence of RCW clusters in accordance with the RCW recovery plan (FWS 

2003) survey protocol, as requested by FWS (2006b). FWS has also requested that KMLP provide a 

determination of the age of pine stands along the pipeline route to determine if they are greater than 30 

years of age. KMLP has been unable to obtain access from some landowners to complete surveys of all 

potentially suitable habitat areas for RCW. Landowners have the right to deny access to their property. 

However, if KMLP is issued a Certificate by the Commission, KMLP would have the authority to access 

the portions of the property within 0.5 mile of the project boundaries to complete any required surveys 

including RCW surveys. 

At this time, FWS has not received a RCW survey report from KMLP confirming the locations 

and/or results of surveys or habitat assessments. For this reason, we do not have adequate information to 

allow for a complete review of potential Project impacts on this species. Therefore, we recommend that: 

• KMLP consult with the FWS to determine the need for and methodology of additional 

surveys for red cockaded woodpecker (RCW) along the pipeline route or provide 

concurrence from the FWS that the project is not likely to adversely affect the RCW. 

The results of consultation with the FWS, any additional survey reports, and FWS 

comments on the survey should be filed with the Secretary as soon as they become 
 4-71 Environmental Analysis

available before the close of the comment period for this draft EIS. Survey reports 

should include the following information: 

a. name(s) and qualifications of the person(s) conducting the survey; 

b. method(s) used to conduct the survey; 

c. date(s) of the survey 

d. area surveyed (include the mileposts surveyed); and 

e. proposed mitigation that would substantially minimize or avoid the potential impacts. 

4.7.2 State-Sensitive Species 

The NHP of LDWF has identified the following 10 state species of concern that may occur in the 

Project area. 

Birds 

Roseate Spoonbill 

The roseate spoonbill is considered rare in the state of Louisiana and is a species of special 

concern. It is found throughout the entire Gulf of Mexico coastline, south to Central America, South 

America, and the West Indies. From March through October, roseate spoonbills prefer the bays, marshes, 

and estuaries along the Gulf Coast, with the mating season beginning in March and ending in June. Nests 

are built in thick vegetation above water, and are well-built and deeply cupped. In winter, most roseate 

spoonbills migrate to Central and South America. (NPS 2006b) 

The roseate spoonbill is a colonial wading bird and could experience nesting site disturbance by 

passage of the construction spreads. Although there are no known nesting sites in the project area, KMLP 

has stated that it would employ a qualified biologist to survey the proposed work area during the 2007 

nesting season and immediately prior to construction scheduled during the nesting season to determine the 

presence of colonial waterbird rookeries. In accordance with recommendations given by FWS and the 

NHP of LDWF, the survey would notate any colony of wading birds, including the roseate spoonbill, 

within 1,000 feet of the work area. KMLP has stated that it would further consult with FWS and NHP of 

LDWF in order to determine mitigation measures to minimize potential impacts to these nesting areas, 

should they be found. Operational impacts to the roseate spoonbill would be limited to temporary 

displacement during maintenance of the permanent right-of-way. 

Crested Caracara 

The crested caracara is considered critically imperiled in Louisiana and is limited to the 

southwestern corner of the state. It is a vulture-sized bird that spends much of its time on the ground 

hunting snakes, rodents, and other available prey. Preferred habitat for this species includes mixed 

coastal prairie and marshes that have been recognized as ecologically significant and in need of 

conservation efforts, as well as open country habitat such as pasturelands, cultivated land, and semidesert. Nesting occurs from late-December to early-April and the nests are typically located in trees, rock 

ledges, or on the ground in secluded areas. The species is non-migrating and the nests will often be 

reused from year to year. One of the main causes of decline is the loss of habitat due to development and 

agriculture, as well as illegal shooting and trapping (LDWF 2006b, c). The NHP of LDWF has 

recommended that KMLP use BMPs to minimize impacts to the coastal prairie and marsh habitats 

preferred by the crested caracara. While KMLP has not developed any project-specific BMPs for this 
 4-72 Environmental Analysis

purpose, it would implement our Plan and Procedures with accepted variances to minimize impacts to the 

general habitats used by the crested caracara. These measures include the minimization of 

erosion/sedimentation and impacts to wetlands as well as the restoration of uplands and wetlands. We 

also recommend that KMLP further consult with the NHP of LDWF to determine if any additional BMPs 

are needed for the protection of the crested caracara. Operational impacts to the crested caracara would 

be limited to temporary displacement during maintenance of the permanent right-of-way. 

Crustaceans 

Old Prairie Crawfish 

The old prairie crawfish is considered very rare globally and is imperiled in Louisiana due to its 

restricted range. It has been noted in the Project vicinity, occurring in roadside ditches flooded by heavy 

rains or in complex burrows carved into the sandy-clay soils of roadside ditches, with a home range that 

does not exceed 82 feet. It is non-migratory and males are reproductively active during January, July, and 

August. Little else is known about the life history of this species. Threats to the old prairie crawfish 

include residential, commercial, and petroleum development. (LDWF 2006a, b) 

Maintenance of the permanent right-of-way would not be required in the roadside ditches that the 

old prairie crawfish would utilize; therefore, no impacts would be expected to occur to this species during 

operational maintenance. However, roadside ditches, the preferred habitat for the old prairie crawfish, 

would be crossed numerous times during construction of the Project and could cause direct mortality of 

any individuals that are residing in that particular ditch. LDWF has recommended that habitat for this 

species be protected (LDWF 2006b, c). KMLP has not proposed any measures for the protection of the 

old prairie crawfish. Therefore, we recommend that: 

• KMLP consult with the NHP of LDWF and develop mitigation measures to protect the 

old prairie crawfish during construction through roadside ditches. KMLP should file 

with the Secretary copies of its consultation prior to construction.

Plants 

Several of Louisiana’s critically imperiled plant species and communities occur in the Project 

area. These include the saltflat-grass, wild coco, Oklahoma grass-pink, low nutrush, short-beaked 

baldsedge, Lindheimer’s bee-balm, and remnants of coastal prairie. Coastal prairies are considered 

critically imperiled in the state of Louisiana and imperiled globally. This prairie region of southwestern 

Louisiana was once very extensive (about 2.5 million acres) but today is limited to small remnant parcels. 

On the southern edge of its range, the community may occur on “islands” or “ridges” surrounded by 

marsh (LDWF 2006b). None of these critically imperiled species, however, are located within 0.5 miles 

of the Project. The nearest coastal prairie remnant community is located 0.6 miles away from the Project. 

4.7.3 Conclusions and Recommendations 

A variety of measures have been proposed by KMLP that would limit impacts on federal- and 

state-listed species, including implementation of our Plan and Procedures. These measures would reduce 

the loss of vegetated habitats, minimize impacts to water quality, and result in restoration of areas 

temporarily disturbed during construction. Additionally, KMLP has committed to implementing 

measures to avoid and minimize potential impacts to federally listed species as identified in NOAA 

Fisheries Service’ “Sea Turtle and Smalltooth Sawfish Construction Conditions” and “Vessel Strike 

Avoidance Measures and Injured or Dead Species Reporting.” Based on the information provided to 
 4-73 Environmental Analysis

date, we believe that except for RCW for which a determination is pending, the Project is not likely to 

adversely affect any federally listed threatened or endangered species. 

We have not completed consultation with FWS and NOAA Fisheries Service. Therefore, we 

recommend that: 

• KMLP not begin construction activities until: 

a. The FERC completes any necessary consultations with the FSW and NOAA Fisheries 

Service; and 

b. KMLP receives written notification from the Director of OEP that construction and/or 

implementation of conservation measures may begin. 
 4-74 Environmental Analysis

4.8 LAND USE, RECREATION, AND VISUAL RESOURCES 

In this section, we further identify and characterize the land requirements for construction and 

operation of the Project, describe the current land use or cover type of those lands (including special 

status lands), discuss how land needed for the Project would be acquired, evaluate visual resource 

impacts, and discuss the relevance of the Project to the Louisiana coastal zone management process. A 

detailed description of the pipeline facilities is provided in section 2.1.1 and facility maps are provided in 

appendix B. 

4.8.1 Land Use 

Table 4.8.1-1 summarizes the current land uses of the acreage that would be affected by 

construction and operation of the Project. Construction of the Project would affect a total of 3,030.7 

acres, including 2,274.1 acres for construction rights-of-way, 291.5 acres for extra workspaces, 12.3 acres 

for aboveground facilities, 74.2 acres for access roads, and 378.7 acres for pipe storage and contractor 

yards. Of the 3,030.7 acres, about 821.7 acres would be maintained as permanent right-of-way and 19.2 

acres permanently used for aboveground facilities and access roads. Of the acreage affected by 

construction, 1,472.1 acres (48.6 percent) would be agricultural land and 569.1 acres (18.8 percent) would 

be open water. The remaining land uses would include beaches, forest, developed land, open land, and 

other (including strip mines, quarries, and gravel pits) and would comprise approximately 989.5 acres 

(32.6 percent). 

Following construction, all temporary workspaces would be allowed to revert to preconstruction 

condition. During operation, KMLP would maintain a 50-foot-wide permanent right-of-way, except 

where Leg 1 and Leg 2 are collocated it would maintain a 100-foot wide right-of-way. The permanent 

right-of-way and other facilities would encompass 427.0 acres of agricultural land (50.8 percent) and 

107.0 acres of open water (12.7 percent), with the remaining 36.5 percent being composed of primarily 

forest, developed land, or open land. 

KMLP has proposed a 125-foot-wide construction right-of way for Leg 1 when in upland terrain 

and for wetland crossings greater than 100 feet long. Further, as discussed in section 2.2.1, when working 

in saturated wetland crossings less than 100 feet long, rights-of-way would be 100-feet wide. In areas 

where Legs 1 and 2 are within 50 feet of each other, KMLP proposes a total combined right-of-way width 

of 155 feet. In addition, KMLP has proposed a 300-foot right-of-way when constructing in the open 

water of Sabine Lake with depths less than 8 feet. That right-of-way width would be reduced to 200-feet 

when water depths exceed 8 feet. Following construction, KMLP would generally maintain a 50-footwide permanent right-of-way centered over the pipeline. 

Approximately 73.7 miles (54 percent) of the Project would parallel existing rights-of-way 

(table 4.8.1-2). To ensure safe distances are maintained between construction activity and in-service 

utilities and to avoid potentially negative impacts on adjacent pipelines, construction right-of-way overlap 

with existing rights-of-way would be limited to approximately 15 feet. 

4.8.1.1 Temporary Extra Workspaces 

As detailed in section 2.1.3, KMLP would use temporary extra workspaces at road crossings, 

railroad crossings, crossings of existing pipelines and utilities, wetland and waterbody crossings, and 

other areas where specialized construction techniques would be used. Approximately 291.5 acres would 

be affected by the use of temporary extra workspaces; 50.1 percent would be agricultural, 20.5 percent 

would be open water, and 22.5 percent would be open land. See appendix C for more details. Following 
 4-75 

TABLE 4.8.1-1 

Land Use Affected by Construction and Operation of the KMLP Project 

Agricultural 

(Acres) 

Open Water 

(Acres) 

Forest 

(Acres) 

Developed 

Land 

(Acres) 

Open Land 

(Acres) 

Beaches 

(Acres) 

Oth

(Acr

 C O C O C O C O C O C O C 

Leg 1Pipeline ROW 1,030.2 413.7 509.1 106.9 128.5 53.1 44.9 18.1 524.4 213.7 0.2 0.1 2.0 Workspaces 144.6 0.0 59.8 0.0 9.9 0.0 9.5 0.0 61.3 0.0 0.0 0.0 0.0 Aboveground Facilitiesa 7.5 7.5 0.0 0.0 0.0 0.0 0.0 0.0 1.9 1.9 0.0 0.0 0.0 Access Roads 0.1 0.1 0.0 0.0 0.6 0.0 70.9 6.4 1.0 0.0 0.0 0.0 0.0 P & C Yards 277.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 101.4 0.0 0.0 0.0 0.0 Leg 2Pipeline ROW 0.0 0.0 0.0 0.0 0.9 0.2 0.9 0.2 5.2 1.1 0.0 0.0 0.0 Workspaces 0.0 0.0 0.0 0.0 0.1 0.0 0.8 0.0 1.9 0.0 0.0 0.0 0.0 Aboveground Facilitiesa 0.0 0.0 0.0 0.0 0.0 0.0 1.7 1.7 0.8 0.8 0.0 0.0 0.0 FGT LateralPipeline ROW 10.9 5.4 0.2 0.1 10.6 5.4 0.3 0.1 5.9 2.9 0.0 0.0 0.0 Workspaces 1.3 0.0 0.0 0.0 0.0 0.0 0.1 0.0 2.3 0.0 0.0 0.0 0.0 Aboveground Facilitiesa 0.3 0.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 Access Roads 0.0 0.0 0.0 0.0 0.0 0.0 1.1 0.0 0.5 0.5 0.0 0.0 0.0 

Total 1,472.1 427.0 569.1 107.0 150.6 b 58.7c 130.2 26.6 706.6 221.0 0.2 0.1 2.0 

_______________ a Represents areas affected outside of construction or permanent rights-of-way. b This number includes 0.9 acres of Forested Wetland that KMLP reported as existing within the Sabine Pass LNG Terminal, but has since been cleared. c This number includes 0.2 acres of Forested Wetland that KMLP reported as existing within the Sabine Pass LNG Terminal, but has since been cleared. 

Notes: Due to rounding totals may not add up.  Agricultural includes cropland and pastureland. 

Open Water includes estuaries and bays, lakes, streams, and canals. 

Forest includes deciduous forest, evergreen forest, forested wetland, and mixed forestland. Developed Land includes industrial, residential, and transportation/communication/utility right-of-way. Transportation/communication/utility right-of-way may include m

Open Land includes rangeland, sandy (not beach) areas, transitional areas, and non-forested wetland. Other includes strip mines, quarries, and gravel pits. 

 C= Construction; O = Operation; Pipeline ROW = Pipeline Rights-of-Way; Workspaces = Temporary Extra Workspaces; Facilities = Aboveground Facilities; P & C Yar
 4-76 Environmental Analysis

TABLE 4.8.1-2 

Existing Rights-of-Way Paralleled by the KMLP Projecta

MP 

Begin 

MP 

End 

Approximate 

Length 

(Miles) Existing Parallel Facility 

Approximate 

Acreage 

Leg 1 and 2 

0.8 1.9 1.1 NGPL Pipelineb 2.0 

16.9 17.9 1.0 Foreign Pipeline 1.8 

22.6 22.8 0.2 36” Colonial Pipeline 0.4 

22.8 23.3 0.5 16” & 18” Sabine Pipeline 0.9 

23.3 23.7 0.5 36” Colonial Pipeline 0.8 

23.7 24.6 0.8 16” & 18” Sabine Pipeline 1.5 

24.6 25.5 0.9 16” & 18” Sabine Pipeline 1.7 

25.5 26.1 0.6 36” Colonial Pipeline 1.2 

26.1 26.4 0.2 16” & 18” Sabine Pipeline 0.4 

26.4 26.6 0.2 Shell Pipeline 0.3 

26.6 30.1 3.5 Enterprise Sabine Pipeline 6.4 

30.1 30.5 0.4 Strategic Pipeline 0.8 

31.3 40.2 8.8 Enterprise Pipeline 16.1 

44.3 45.3 1.0 4” Conoco Pipeline 1.7 

56.1 59.8 3.6 30” Trunkline Pipeline 6.6 

60.9 62.5 1.6 Gulf South Pipeline 2.9 

66.2 72.5 6.3 16” Dynegy Pipeline 11.5 

72.5 74.9 2.3 16” Texaco Petro-Chemical Pipeline 4.2 

74.9 76.3 1.4 16” Texaco Petro-Chemical Pipeline 2.6 

76.90 88.7 11.8 16” Texaco Petro-Chemical Pipeline 21.4 

89.0 89.7 0.6 16” Texaco Petro-Chemical Pipeline 1.2 

101.5 108.5 7.0 EHP Egan Pipeline 12.7 

108.5 111.3 2.8 26” ANR Pipeline 5.1 

112.0 112.4 0.5 30” ANR Pipeline 0.9 

118.3 122.0 3.7 Targa Pipeline 6.7 

122.0 131.9 9.9 30” Transco Pipeline 17.9 

FGT Lateral 

0.0 0.1 0.1 26" ANR 0.1 

0.1 2.3 2.2 24" FGT 4.1 

 Total 73.7 133.9 

_______________ 

a Construction right-of-way overlap with existing rights-of-way would be limited to approximately 15 feet. b Represents the only existing right-of-way along that portion of the project where Legs 1 and 2 would parallel one another. 
 4-77 Environmental Analysis

construction, all temporary extra workspaces would be allowed to revert to their preconstruction use and 

cover type. 

4.8.1.2 Aboveground Facilities 

KMLP would construct 14 aboveground facilities. Each of these facilities is an interconnect with 

an existing interstate or intrastate pipeline that would contain a mainline valve and a block valve. 

Typically, these facilities would be fenced and range in size from 0.3 to 1 acre (table 4.8.1.2-1). The total 

land requirements for the aboveground facilities would be 12.3 acres during construction and operation, 

the majority of which (63.4 percent) would be agricultural lands. All 12.3 acres would be permanently 

converted to commercial/industrial land use. 

TABLE 4.8.1.2-1 

Acres of Land Affected by Construction and Operation of the Aboveground Facilities 

Pipeline Facility MP 

Land Disturbed 

During Construction 

(acres) 

Land Required 

for Operation 

(acres) 

Leg 1 

Southwest Loop Interconnect Site 28.2 0.92 0.92 

Sabine Interconnect Site 61.4 0.92 0.92 

TGTPL Interconnect Site 87.5 0.97 0.97 

Trunkline Interconnect Site 91.5 0.94 0.94 

TGT Interconnect Site 110.0 0.92 0.92 

ANR #1 Interconnect Site 111.3 1.04 1.04 

ANR #2 Interconnect Site 112.0 1.02 1.02 

TET Interconnect Site 117.0 0.92 0.92 

Transco Interconnect Site 122.1 0.80 0.80 

CGT Interconnect Site 132.2 0.92 0.92 

Leg 2

NGPL Interconnect Site 1.2 0.84 0.84 

Bridgeline Interconnect Site N/Aa 0.86 0.86 

Southwest Loop Johnson’s Bayou Delivery Point N/Aa 0.86 0.86 

FGT Lateral 

FGT Interconnect Site 2.30 0.34 0.34 

Total 12.3 12.3 

_______________ 

a

 Located in Johnsons Bayou near the end of the existing UTOS system. 

4.8.1.3 Access Roads 

Appendix C lists the access roads, their location, modifications required, surface area potentially 

affected, and current land use of that area. Where feasible, KMLP would use existing public roadways, 

existing private roadways, and/or the pipeline right-of-way to gain access during construction and 

operation of the Project. KMLP has proposed the temporary use of 69 existing access roads of varying 

lengths. KMLP stated that 53 of the existing access roads, comprising a length of approximately 26.1 

miles, would require modifications to support construction-related traffic and equipment. Modifications 
 4-78 Environmental Analysis

may include grading and/or placement of additional gravel on the existing surface. Where possible, board 

matting would be used instead of constructing new roads. However, 6 new roads totaling 0.7 miles would 

be constructed. In total, the construction access roads would disturb a total of 74.2 acres. Following 

construction, 5 roads encompassing 6.9 acres would be maintained as permanent access roads. The 

remaining access roads would revert to their preconstruction uses. 

4.8.1.4 Pipe Storage and Contractor Yards 

KMLP has proposed the use of 12 pipe storage and contractor yards, encompassing 378.7 acres, 

during construction. Approximately 73.2 percent of this land would be agricultural and 26.8 percent 

would be open land. The general locations of these facilities are depicted in appendices B and C. All 

yards would be leased. Depending upon the condition of these yards and their current use, some surface 

grading, drainage improvements, placement of surface materials, and internal roadways may be required. 

Upon completion of construction activities, the pipe storage and contractor yards would be returned to 

their preconstruction condition or as specified by landowner agreement. 

4.8.2 Acquisition of Land through Easements and Eminent Domain 

KMLP would obtain easements from landowners to construct and operate the pipeline and 

associated facilities. The easements would give the company the right to construct, operate, and maintain 

the pipeline and establish a permanent right-of-way. In return, the company would compensate the 

landowner for use of the land. Easement agreements between the company and the landowner typically 

specify compensation for loss of use during construction, loss of non-renewable or other resources, and 

allowable uses and restrictions on the permanent right-of-way after construction. These terms can include 

restrictions on the construction of aboveground structures, including house additions, garages, patios, 

pools, or any other object not easily removable from the right-of-way, or the planting and cultivating of 

trees and orchards. 

KMLP could be granted the right of eminent domain (section 7(h) of the NGA and the procedures 

set forth under the Federal Rules of Civic Procedure [Rule 71A]) if easement agreements cannot be 

negotiated. Under these conditions, the landowner could receive compensation, but the compensation 

would be determined by the courts. 

4.8.3 Land Use Impacts and Mitigation 

4.8.3.1 Agricultural Areas 

The 1,472.1 acres of agricultural land affected by the Project would primarily include 

pastureland, land used for rice production, and areas used for crawfish production. The primary impact in 

these areas would be short-term loss of production due to construction-related activities. About 7.9 acres 

of agricultural land occupied by the aboveground facilities would be permanently converted to developed 

land. Agricultural land within the pipeline right-of-way would be allowed to revert to pre-construction 

conditions following construction. 

In accordance with our Plan, KMLP would implement special construction procedures in 

agricultural areas to minimize potential impacts. Topsoil would be removed and stockpiled separately 

from excavated subsoils and the natural flow patterns of all fields would be maintained by providing 

breaks in topsoil and subsoil stockpiles. KMLP would also work with landowners prior to construction to 

identify irrigation lines and drainage improvements in order to minimize construction-related impacts. In 

addition, crop yields would be monitored following construction to ensure that yields in areas affected by 

construction were similar to that in adjacent, undisturbed areas, as described in section 2.3. Finally, the 
 4-79 Environmental Analysis

owners of agricultural land would be compensated for the loss of agricultural production in accordance 

with the terms of landowner agreements. Therefore, we believe that impacts to agricultural land would be 

short term and offset by compensation agreed to during easement negotiations. 

4.8.3.2 Open Water 

Approximately 569.1 acres of open waters would be included in the construction right-of-way. 

The majority of that acreage would be in Sabine Lake (approximately 408.6 acres). Impacts to southern 

and northern shores of Sabine Lake would be avoided by use of HDD. Construction within the openwater portion of Sabine Lake would be conducted using shallow draft barges as described in 

section 2.3.1.3. This technique would require excavation of channels between existing navigation 

channels and the right-of-way and a channel along the right-of-way itself. To allow sufficient space for 

the storage of excavated spoil from the channels and pipe trenches, KMLP has requested a construction 

right-of-way width of 300 feet in water depths less than 8 feet and 200 feet in water depths greater than 

8 feet. 

To mitigate potential navigation impacts in Sabine Lake, KMLP has indicated that they would 

provide project-specific details to the U.S. Coast Guard such as the timing of and areas in which waterbased construction would occur, as well as the types of vessels that would be utilized. In addition, spaces 

would be left between spoil piles and KMLP would install timber piles with navigational lights and 

warning signals to allow shallow draft vessels to pass over the open trench. KMLP would comply with 

all navigation rules and regulations in the Project vicinity. Following construction, acreage within both 

the construction and permanent right-of-way would revert to their previous use. 

As discussed in section 4.6.3, Sabine Lake is a public oyster seed ground and public oyster 

tonging area in Louisiana. As such, KMLP has agreed to compensate LDWF for any construction-related 

impacts to oysters or shellfish in Sabine Lake. 

Therefore, we believe that impacts related to the temporary utilization of open water for 

construction would be minor and short term. 

4.8.3.3 Forest 

The 150.6 acres of forest that would be affected by the Project include deciduous forest, 

evergreen forest, mixed forest, and forested wetland. There are no pine plantations or other silviculture 

crops within the 150.6 acres. As detailed in section 4.5.2, impacts to forested land would be minor but 

would persist for the life of the Project. A total of 58.7 acres of currently forested land would be 

converted to maintained pipeline right-of-way. 

4.8.3.4 Developed Land 

About 130.2 acres of developed land would be crossed by the Project, consisting of congested 

pipeline corridors, transportation corridors, a marina on the east bank of the Calcasieu River, and the 

southern edge of the Trunkline LNG facility. Standard upland construction methods would be used in 

most of these areas and measures included in our Plan would be incorporated to minimize impacts to such 

developed lands. From MP 51.8 to MP 52.4 (see table 4.3.2.1-3), KMLP proposes to HDD under the 

marina on the east bank of the Calcasieu River. However KMLP has not provided its site-specific 

construction plans. We are recommending in section 4.3.2.3 that KMLP file site-specific construction 

plans for this area.
 4-80 Environmental Analysis

4.8.3.5 Open Land, Beaches, and Other 

The Project would affect 706.0 acres of open land, 0.2 acres of beaches, and 2.0 acres of other 

land uses within the construction right-of-way and temporary extra workspaces. In general, standard 

overland construction techniques would be used for installation of the pipeline and KMLP would use 

measures included in our Plan and Procedures to minimize impacts. Following construction, all open 

land, beach, and other acreage outside the permanent right-of-way would be allowed to revert to its 

preconstruction land use. The remaining 221.8 acres within the permanent right-of-way, primarily 

comprised of open land (221.0 acres), would be maintained as necessary for operation. With the use of 

our Plan and Procedures, impact to these areas would be minimal. 

4.8.3.6 Residences and Planned Residential Developments 

During pre-filing, a planned development called the South Forty Acre Subdivision was identified 

at approximately MP 114.0 of the Leg 1 route originally considered. As a result, KMLP modified the 

route to avoid this area as is further discussed in section 3.4.11 of this draft EIS). The currently proposed 

route would not impact any planned developments. 

KMLP identified 14 structures within 50 feet of the construction right-of-way (table 4.8.3.6-1). 

None of these structures were identified as residences. However, 9 of the 14 structures have been 

generically identified as buildings. Therefore, we recommend that: 

• KMLP revise table 4.8.3.6-1 and explicitly identify all structures and residences within 

50 feet of the construction work areas. KMLP should file the revised table with the 

Secretary prior to the close of the comment period on the draft EIS. 

To minimize potential disruptions to residential areas near construction work areas, KMLP would 

attempt to coordinate construction work schedules with affected landowners prior to starting construction. 

To further minimize impacts to residential areas within the vicinity of construction work areas, KMLP 

would implement the following measures on an as-needed basis: 

• notify land owners of the need to remove fences and gates; 

• install temporary safety fencing to control access and minimize the hazards associated with 

an open trench; 

• notify affected landowners in advance of any scheduled disruption of household utilities and 

limit the duration of any interruption to the smallest time possible; 

• repair any damages to residential property that result from construction activities or provide 

compensation at fair market value; and 

• restore all areas disturbed by construction work areas to “as before or better” conditions. 

As described in section 2.5, KMLP would be responsible for monitoring and ensuring compliance 

with all environmental mitigation measures required by the FERC Certificate. In fulfilling this 

responsibility, KMLP would be required to develop and implement an environmental complaint 

resolution procedure to provide landowners with clear and simple directions for identifying and resolving 

their environmental mitigation problems/concerns during construction of the Project and restoration of the 

right-of-way. In addition, in section 4.12 we are recommending that KMLP develop a noise mitigation 

and compliance plan for HDD in residential areas. 
 4-81 Environmental Analysis

TABLE 4.8.3.6-1 

Structures Within 50 Feet of the Construction Work Areas 

Structure MP Parish 

Distance from 

Pipeline 

Centerline 

(feet) 

Distance from 

the Construction 

Work Area 

(feet) 

Building 38.3 Calcasieu 40 75 

Barn 46.0 Calcasieu 25 100 

Building 48.3 Calcasieu 0 100 

Barn 48.4 Calcasieu 10 80 

Building 51.1 Calcasieu 5 75 

Building 51.1 Calcasieu 25 100 

Building 52.2 Calcasieu 25 100 

Building 52.2 Calcasieu 50 115 

Cattle Loading Pena 71.1 Calcasieu 0 20 

Building 87.7 Jefferson Davis 10 85 

Sheda 91.4 Jefferson Davis 0 5 

Shed 121.6 Evangeline 50 125 

Building 123.1 Evangeline 40 150 

Building 123.2 Evangeline 25 175 

_______________ 

a These structures, located entirely or partially within the construction workspace, would either be relocated or the landowner would

 be compensated accordingly. 

With the implementation of above measures, impact to residential areas would be minimal and 

these impacts would generally be limited to the construction period. 

4.8.3.7 Recreation and Special Use Areas 

Recreation and special use areas in the vicinity of the Project are defined to include inshore open 

waters with recreational uses; National Wildlife Refuges; scenic byways; Wetland and Hydrologic 

Restoration Projects; Conservation Reserve and Wetland Reserve Program lands; FWS Conservation 

Easements; national or state scenic rivers; levee crossings; and hazardous waste sites. For a detailed 

discussion of the Black Bayou Hydrologic Restoration Project, the Perry Ridge Shore Protection Project, 

Conservation Reserve Program Lands, and FWS Conservation Easements, see section 4.4. 

Inshore Open Waters 

Inshore waters of Louisiana, including Sabine Lake, provide recreational boating and fishing 

opportunities as well as means of transit to areas where these activities are pursued. Section 4.8.3.2 above 

summarizes the proposed construction methods in Sabine Lake along with the precautions that would be 

taken to avoid impacts to navigation. 

Assuming the construction spread occupies all of the approximate 13 miles of the pipeline route 

through Sabine Lake, at the maximum construction right-of-way width (300 feet), the decrease in the 

surface area of Sabine Lake available to recreational boaters would be less than 1 percent. This decrease 

in availability would be temporary, lasting only as long as the construction activities across Sabine Lake. 
 4-82 Environmental Analysis

Based on these factors, impacts to recreation on inshore waters are considered to be minor and 

short term. 

National Wildlife Refuges 

Sabine National Wildlife Refuge 

The SNWR occupies approximately 125,000 acres of marshes between Calcasieu and Sabine 

Lakes in southwest Louisiana. According to the FWS, the refuge provides habitat for migratory 

waterfowl and other birds, and was designated an “Internationally Important Bird Area” due to the 

abundant year-round populations of wading, water, and marsh birds. There are also large concentrations 

of alligators, muskrats, nutria, raptors, blue crabs, and shrimp. Approximately 280,000 people visit the 

area each year for a variety of recreational and educational activities such as hiking, fishing, boating, 

camping, and hunting (FWS no date a). 

The pipeline route does not cross the SNWR; at its closest points, between MP 15.0 and 17.0, the 

SNWR would be approximately 0.25 miles from the pipeline. During construction, noise associated with 

the installation of the pipeline may disturb wildlife; however, noise-related impacts would be short term 

and minor. Given the distance between the SNWR and the Project, construction and operation of the 

Project would not impact the SNWR. 

Lacassine National Wildlife Refuge 

The Lacassine National Wildlife Refuge (LNWR) encompasses about 35,000 acres, mostly 

freshwater marsh habitat that functions as a wintering site for waterfowl. Nesting colonies of wading 

birds, alligators, and furbearers such as mink, otter, and raccoon are found on the refuge. Threatened and 

endangered species that have used the refuge include bald eagles, peregrine falcons, and Louisiana black 

bears. The refuge is also used for recreational purposes, hunting and fishing being two of the most 

popular recreational activities (FWS no date b). 

The Project pipeline would not cross the Lacassine NWR. At its closest point, the pipeline would 

be approximately 2 miles southeast of the Vidrine Unit and more than 15 miles northwest of the main 

unit. Given this distance, construction and operation of the Project would not affect either unit of the 

LNWR. 

Scenic Byways 

The 180-mile Creole Nature Trail National Scenic Byway takes visitors through three different 

wildlife refuges and a bird sanctuary and offers drivers and their passengers a view of Louisiana's 

environment and wildlife. The roads that comprise the trail, SHs 82, 27, and 14, cut through the 

marshlands of southern Calcasieu and Cameron Parishes and then hug the coast of the Gulf of Mexico 

(MilebyMile 2006). 

The Project would cross the Creole Nature Trail National Scenic Byway at three locations: SH 82 

at MP 1.5; SH 27 at MP 47.8; and SH 14 at MP 64.7. The Project would cross these roadways using 

HDD or conventional boring construction methods, which would not require road closures or open cutting 

of the roadways. Impacts would be limited to potential short-term traffic disruptions associated with the 

construction equipment and alterations to the viewshed. Because KMLP would be required to maintain 

safe and accessible conditions at road crossings in accordance with our Plan, traffic disruptions would be 

minimal. See section 4.8.4 for a discussion of the minor visual impacts to the Byway. 
 4-83 Environmental Analysis

4.8.3.8 Wetland Restoration and Mitigation Projects 

Section 4.4 discusses the potential impacts to the Black Bayou Hydrologic Restoration Project 

and the Perry Ridge Shore Protection Project located in the Project vicinity. Section 4.4 also discusses 

the potential impacts to CRP lands. 

There would be no impacts to WRP lands because there are no such lands located in parishes that 

would be crossed by the Project. 

The FWS works with private landowners that voluntarily restore wetlands or other valuable 

wildlife habitats on their property by providing financial assistance from the federal government (FWS 

2006b). If such properties are along the route, KMLP would need to obtain a Compatible-Use 

Determination and ascertain the need for any Special Use Permit in association with the crossing of the 

conservation easement. Based on the most recent database currently available, which has not been 

updated since 1996, FWS indicates that there are no conservation easements in the project area (FWS 

2007). However, given the lack of updated information, FWS states that KMLP should conduct further 

consultation to determine if the Project could affect any conservation easements. Therefore, we 

recommend that: 

• KMLP consult with the FWS to determine if FWS conservation easement properties are 

crossed by the Project. KMLP should file with the Secretary documentation of its 

consultation with FWS, including any recommended mitigation measures, for review 

and written approval by the Director of OEP prior to construction. 

4.8.3.9 Natural and Scenic Rivers 

The Louisiana Natural and Scenic Rivers System was establish to preserve, protect, develop, 

retain, and enhance the wilderness qualities, scenic beauty, and ecological regime of certain streams or 

segments thereof. The program was also intended to preserve aesthetic, scenic, recreational, ecological, 

and other natural and physical features and resources found along these streams or segments thereof 

(LDWF 2006a). The Project would not cross any Natural or Scenic River. 

4.8.3.10 Hazardous Waste Sites 

During the pre-filing process, KMLP identified a Class C landfill approximately 990 feet north of 

the originally considered route. Subsequently, KMLP rerouted the pipeline route to avoid this facility 

(this route variation is discussed further in section 3.4.4 of this draft EIS). KMLP has reviewed both 

LDEQ and EPA websites to identify any known hazardous waste sites within 0.25 miles of the Project 

right-of-way. None have been identified. No sites were identified during environmental surveys of the 

Project route. 

In the unexpected event that construction of the Project encroaches on a contaminated area, 

KMLP would stop work, notify the appropriate state and federal agencies, and proceed in accordance 

with local, state, and federal regulations. As discussed in section 4.2.2.1, we are recommending that that 

KMLP develop a Plan for the Discovery and Management of Contaminated Soil and Groundwater. 

Development and implementation of this plan would ensure that any previously existing contamination 

that may be encountered during construction would be managed in accordance with applicable regulatory 

requirements. 
 4-84 Environmental Analysis

4.8.4 Visual Resources 

Visual resources refer to the composite of basic terrain, geologic features, hydrologic features, 

vegetative patterns, and anthropogenic features that influence the visual appeal an area may have for 

residents or visitors. The Project could alter existing visual resources in three ways: (1) construction 

activity and equipment may temporarily alter viewscapes; (2) construction and right-of-way maintenance 

would alter existing vegetation patterns; and (3) aboveground facilities would represent permanent 

alterations to the viewscape. The significance of these visual impacts would be primarily dependent upon 

the quality of the current viewshed, the degree of alteration of that view, the number of potential viewers, 

and the perspective of the viewer. 

Most of the Project would extend through open water and primarily rural areas that consist of 

agricultural lands and open lands with scattered residences. There are several existing pipelines in the 

vicinity of the Project, and the KMLP pipeline would parallel some of these existing rights-of-way. 

Many areas along the Project are either inaccessible or do not provide long-range unobstructed views, but 

public viewpoints are present along some of the roadways in the area. 

4.8.4.1 Pipeline Facilities 

Construction and operation of the pipeline may affect visual resources by altering the terrain and 

vegetation patterns during construction or right-of-way maintenance. The landscape setting along the 

pipeline route is generally flat, and views of the construction activities may extend for some distance. 

However, the construction work areas would be restored as near as possible to preconstruction contours 

and revegetated. Once revegetation is complete, there would be no significant alteration of the landscape 

of the region. 

As discussed in section 4.8.3.7, the pipeline would cross the Creole Nature Trail National Scenic 

Byway at three locations: SH 82 at MP 1.5; SH 27 at MP 47.8; and SH 14 at MP 64.7. While there are 

no federal or state regulations that protect the viewshed of the byway, it is an area that offers viewing 

opportunities for visitors and residents. KMLP would cross the Byway using HDD or conventional 

boring construction methods. Visual impacts would generally be temporary and minor, similar to those 

described above. 

4.8.4.2 Aboveground Facilities 

Aboveground facilities would be located within or immediately adjacent to the pipeline right-ofway. Most would either be constructed in areas whose existing viewsheds contain similar features, within 

existing utility rights-of-way or industrial facilities, or in areas where views would be screened by 

existing vegetation and/or topography. When not screened from view, aboveground facilities would 

appear as a small fenced area within a cleared right-of-way corridor or open field. The Transco 

Interconnect (MP 122.1) would be located near residences and would likely have a direct view of the site. 

Therefore, we recommend that: 

• KMLP develop a site-screening plan for the Transco Interconnect site (MP 122.1) and 

file that plan with the Secretary for review and written approval by the Director of OEP 

prior to construction. 
 4-85 Environmental Analysis

4.8.5 Coastal Zone Management 

The CZMA provides states the authority to review any project within that state’s coastal zone if it 

has a federally approved CZM program. Projects that require federal licenses or permits must draft a 

“consistency certification” to assure the project meets the state’s CZM program standards. 

Portions of the Project (MPs 0.0 to 23.1) fall within Louisiana’s coastal zone, which is managed 

by the Coastal Management Division (CMD) of the LDNR. KMLP has consulted with the CMD and will 

prepare and submit a Coastal-Use Permit application to the CMD as part of the Joint Permit Application 

with the COE. Upon receipt and review of that document, LDNR will determine if the Project is 

consistent with Louisiana’s coastal zone management program. A determination from the LDNR that the 

Project is consistent with the laws and rules of the CZM program must be received before we issue a 

notice to proceed. Therefore, we recommend that: 

• KMLP not begin construction on any facilities associated with the Project until it files 

with the Secretary a copy of the CZM Program consistency determination issued by the 

LDNR. 
 4-86 Environmental Analysis

4.9 SOCIOECONOMIC RESOURCES 

4.9.1 Region of Influence 

The Project would traverse five parishes in Louisiana (Cameron, Calcasieu, Jefferson Davis, 

Acadia, and Evangeline). For the purposes of our socioeconomic analysis, we define these parishes as the 

Project’s region of influence. Although an extra workspace has also been identified in Orange County, 

Texas (see section 2.2), this county was not included in the region of influence because quantifiable 

socioeconomic impacts would not be expected to result from the 50-foot by 4,200-foot floating prefabrication site alongside Goat Island in this area (approximately MP 17.9 to 18.6). 

4.9.2 Population 

Table 4.9.2-1 reports populations and selected demographic characteristics for Louisiana and the 

five Parishes that would be traversed. Based on census data for the year 2000 

(U.S. Census Bureau 2005a), the total population in these parishes is 321,341. Population levels were 

relatively stable between 2000 and 2005 with no parish having more than a 5 percent change in 

population over the five-year period. 

TABLE 4.9.2-1 

Population Conditions in the Vicinity of the Proposed Project 

Population Population Density 

State/Parish 2000 2005 Percent Change 2000 2005 

Louisiana 4,468,976 4,523,628 1.2% 102.6 103.8 

 Cameron Parish 9,991 9,558 -4.3% 7.6 7.3 

 Calcasieu Parish 183,577 185,419 1.0% 171.4 173.1 

 Jefferson Davis Parish 31,435 31,272 -0.5% 48.2 48.0 

 Acadia Parish 28,861 59,552 1.2% 89.8 90.9 

 Evangeline Parish 35,434 35,540 0.3% 53.3 53.5 

_______________ 

Based on 601 relocating (231 non-local workers and 2.6 peps per HH) 

0.21% pop change over project vicinity 

Population densities in the region of influence range from a low of 7.3 persons per square mile in 

Cameron Parish to a high of 173.1 persons per square mile in Calcasieu Parish. These densities are 

relatively low compared to urban area densities that typically range from 3,000 to 6,000 persons per 

square mile (FERC 2003) but are consistent with an area that is predominately rural and agricultural. 

Potential impacts to local populations from the Project would result from the influx of non-local 

workers for construction (temporary) and operation (permanent). As outlined in section 2.4. KMLP 

would make an effort to hire local workers where practical. This would mitigate any potential affects on 

population levels and or demographics. 

Construction of the Project would occur between November 2007 and November 2008 (see table 

4.9.2-2). The peak construction workforce is projected to be 385 workers. KMLP anticipates 
 4-87 Environmental Analysis

TABLE 4.9.2-2 

Estimated Workforce in the Vicinity of the Proposed Project

Project Component Parish 

Approximate Construction 

Dates 

Estimated

Workforce

Leg 1 Pipeline See comment below Nov 2007 Nov 2008 250 

Leg 2 Pipeline Cameron Nov 2007 April 2008 19 

FGT Lateral Acadia Sept 2008 Oct 2008 32 

Southwest Loop Delivery Point Calcasieu March 2008 April 2008 18 

Sabine Interconnect Site Calcasieu May 2008 June 2008 18 

TGTPL Interconnect Site Jefferson Davis July 2008 Aug 2008 18 

TLG Interconnect Site Jefferson Davis Sept 2008 Oct 2008 18 

TGT Interconnect Site Acadia Aug 2008 Sept 2008 18 

FGT Interconnect Site Acadia Oct 2008 Nov 2008 18 

ANR Interconnect Site Acadia April 2008 May 2008 18 

TET Interconnect Site Evangeline June 2008 July 2008 18 

Transco Interconnect Site Evangeline Aug 2008 Sept 2008 18 

CGT Interconnect Site Evangeline Oct 2008 Nov 2008 18 

NGPL Interconnect Site Cameron Nov 2007 Dec 2007 18 

Bridgeline Interconnect Site Cameron Jan 2008 Feb 2008 18 

Southwest Loop Johnsons Bayou Delivery Point Cameron Jan 2008 Feb 2008 12 

_______________ 

Leg 1, a 42-inch-diameter pipeline, would run 132 miles traversing five parishes in Louisiana (Cameron, Calcasieu, 

Jefferson Davis, Acadia, and Evangeline). 

that about 60 percent (231 employees at the peak) of the construction workforce would be made up of 

non-local workers who would temporarily locate to the Project vicinity. Although the construction phase 

is relatively short, some families may accompany non-local workers. Based on the peak non-local 

workforce of 231 persons and applying the U.S. Census Bureau’s 2000 statistic of 2.6 persons per 

household in Louisiana, as many as 601 people might temporarily relocate to the Project vicinity. If all 

workers were to reside in one parish at one time, moderate (up to 6 percent) population increases would 

occur. However, it is very unlikely that this would occur as KMLP has indicated that construction of the 

pipeline would entail the simultaneous activity of several individual construction spreads that would be 

distributed across the Project route. As such, workers would likely be distributed throughout the Project 

vicinity, resulting in negligible population and demographic alterations. 

During operation, KMLP estimates that the Project would employ approximately four full-time 

equivalent workers. This would represent a negligible, long-term change in population. 

4.9.3 Employment and Economy 

The civilian labor force within the Project vicinity includes about 137,485 individuals. The major 

employment sector in four of the five Parishes is education, health and social services. The exception is 

in Cameron Parish where the major employment sectors are agriculture, forestry, fishing and hunting, and 

mining. On average, the parishes within the Project vicinity report slightly lower unemployment and per 

capita income than the state-level values reported for Louisiana (table 4.9.3-1). 
 4-88 Environmental Analysis

TABLE 4.9.3-1 

Employment Conditions in the Vicinity of the Proposed Project 

State/Parish 

Per Capita 

Income 

1999

Civilian Labor 

Force 

2000

Unemployment 

Rate (percent) 

2000

Top Employment 

Industry 

2000

Louisiana $16,912 1,997,995 7.3 

Educational, health, 

and social services 

 Cameron Parish $15,348 4,384 4.6 

Agriculture, forestry, 

fishing and hunting, 

and mining 

 Calcasieu Parish $17,710 85,325 6.9 

Educational, health, 

and social services 

 Jefferson Davis Parish $13,398 12,597 7.9 

Educational, health, 

and social services 

 Acadia Parish $13,424 23,158 7.1 

Educational, health, 

and social services 

 Evangeline Parish $11,432 12,021 7.3 

Educational, health, 

and social services 

The actual workforce and proportion of local workers would depend on the capabilities of the 

contractor, available workforce, and maximized efficiencies. KMLP anticipates a total of 529 

employment opportunities would be necessary to construct the pipeline and that the peak construction 

workforce at any given point in time would be 385 employees. As indicated in section 4.9.2, KMLP 

expects that 40 percent of the construction workforce would be hired from the local workforce (i.e., 

existing residents of the region of influence), and 60 percent would come from outside the region of 

influence. Additional jobs could also be created as a result of secondary activity associated with 

construction of the Project, as purchases made by non-local workers on food, clothing, lodging, gasoline, 

and entertainment will have a temporary, stimulatory effect on the local economy. These jobs would 

represent a temporary, moderate increase in employment opportunities in the region of influence. 

During operation, four full-time equivalent positions would be created. Two of these positions 

would be stationed out the Sabine Pass LNG Terminal in Cameron Parish with the remaining serving as 

pipeline operators. These jobs would represent a negligible, permanent increase in the number of 

employment opportunities within the Project vicinity. 

4.9.4 Housing 

Tables 4.9.4-1 and 4.9.4-2 report selected housing statistics for Louisiana and the five parishes 

traversed by the pipeline. Table 4.9.4-1 reports total housing units, both occupied and unoccupied, 

median monthly rent rates and the rental vacancy rates. Table 4.9.4-2 provides further analysis of those 

units that are classified as unoccupied, or vacant, in 2000. 

There are approximately 7,479 vacant rental units and units used for seasonal, recreational, or 

occasional use. Additional hotel or motel rooms supplement this potential housing stock. Four of the five 

parishes in the Project vicinity have rental vacancy rates that exceeded Louisiana’s rental vacancy rate of 

9.3 percent in 2000. Median monthly rent is typically lower than the state average. In 2000 the number 

of unoccupied units ranged from a low of 1,522 in Evangeline Parish to a high of 7,382 in Calcasieu 

Parish. 
 4-89 Environmental Analysis

TABLE 4.9.4-1 

General Housing Conditions in the Vicinity of the Proposed Project 

State/Parish 

Total 

Housing 

Units 

Total 

Occupied 

Units 

Total 

Occupied 

Rental 

Units 

Total 

Unoccupied 

Units 

Median 

Monthly 

Rent 

Rental 

Vacancy 

Rate 

(percent) 

Louisiana 1,847,181 1,656,053 530,918 191,128 $466 9.3 

 Cameron Parish 5,336 3,592 536 1,744 $412 18.4 

 Calcasieu Parish 75,995 68,613 19,507 7,382 $465 14.1 

 Jefferson Davis Parish 12,842 11,480 2,883 1,344 $353 9.9 

 Acadia Parish 23,209 21,142 5,882 2,067 $332 9.9 

 Evangeline Parish 14,258 12,736 3,902 1,522 $289 6.4 

TABLE 4.9.4-2 

Unoccupied Housing Characteristics in the Vicinity of the Proposed Project 

State/Parish 

Vacant 

Rental 

Units 

Units

for 

Sale 

Units 

Rented 

or Sold, 

Not 

Occupied 

Vacant for 

Seasonal, 

Recreational,

or 

Occasional 

Use 

Vacant 

for 

Migrant 

Workers 

Other 

Vacant 

Total 

Unoccupied

Units 

Louisiana 54,485 18,097 18,144 39,578 525 60,599 

 Cameron Parish 121 52 57 1,331 0 183 1,744 

 Calcasieu Parish 3,191 849 607 684 27 2,024 7,382 

Jefferson Davis 

Parish 317 210 189 223 8 397 1,344 

 Acadia Parish 648 177 142 243 12 845 2,067 

 Evangeline Parish 267 149 83 472 3 548 1,522 

 Total 4,544 1,437 1,078 2,953 50 3,997 14,059 

At its peak, construction of the Project would require about 231 non-local workers, as described 

in section 4.9.2. If each worker required his or her own housing unit, the non-local work force would 

occupy about 16.4 percent of the temporary housing within the region of influence. Thus, the temporary 

housing available within the region of influence would be capable of meeting this temporary and 

moderate increased demand for housing resulting from construction of the Project. 

Housing demand for the four, permanent positions generated by operation of the Project would 

represent a permanent but negligible increase in housing demand. 
 4-90 Environmental Analysis

4.9.5 Infrastructure and Public Services 

Educational, medical, police, and fire protection employees in the counties and parishes traversed 

by the Project serve a population of approximately 320,000 people. 

Construction of the Project could temporarily increase demand for medical, police, and fire 

protection associated with permit issuance, traffic control, and potential response to accidents during 

construction. KMLP would work with local law enforcement and emergency response agencies to 

coordinate effective emergency response for the Project during construction and operation (see section 

4.13.1). 

We note that construction would occur during the school year. However, due to the nature of the 

construction and its relatively short duration (about a year), non-local workers are not expected to be 

accompanied by substantial numbers of children. 

Thus, any impact the provision of public services would be minor and temporary. The potential 

costs associated with this potential increase in demand would be offset by the Project-related increase in 

government revenues. 

During operation, workers filling the four full time positions and their associated family members 

would represent a minor, permanent increase in the demand for the provision of public services. 

However, this increased demand would be offset by the Project-related increase in government revenues 

associated with operation. 

4.9.6 Transportation and Traffic 

4.9.6.1 Land Transportation 

Potential short-term impacts to existing infrastructure would result from traffic delays due to 

deployment of equipment and construction personnel, and road crossings. The Project would primarily be 

accessed by SH 82, Route 27 and Interstate 10. Additional routes providing access to the pipeline off of 

Interstate 10 are SHs 397, 395, 385, 102, 101, 99, 97, 91, and 13. SHs 82 and 27 generally have light 

traffic levels given their rural location (FERC 2006b). Interstate 10 is subject to moderate levels of traffic 

with a 2001 average annual daily traffic count of 55,517 in the Lake Charles region (AA Roads 2006). 

A substantial increase in road traffic associated with transportation of construction equipment and 

pipe to the Project vicinity would result in traffic delays. However, such delays would be temporary and 

short-term. Upon delivery of construction equipment and pipe to the respective laydown areas and road 

crossings, construction based traffic would be limited to the right of way. 

Construction workers commuting to and from construction areas would likely have a minor 

impact on commuter traffic. Given the relatively short construction period, construction activities would 

utilize available daylight hours, resulting in off-peak hour commutes for workers. Further, construction 

workers would be dispersed across the pipeline right of way in five construction spreads, thus keeping 

disruptions in traffic to minor short-term impacts for any one location at any given time. 

Construction of new access roads would be limited to less than three quarters of a mile in total 

length, occurring primarily in Calcasieu Parish. The Applicant has indicated that upon completion of the 

pipeline, newly constructed access roads would be removed, and the land restored to its original contours 

and use. Exceptions may occur where requested by individual landowners or where the access road is 
 4-91 Environmental Analysis

required for ongoing maintenance of the pipeline right-of-way. This represents a short-term, negligible 

impact to the current land uses. 

KMLP indicates that most paved roads and railroads would be crossed using the boring or HDD 

method to mitigate traffic disruptions and direct surface impacts. Alternatively, unpaved roads and one 

abandoned railroad (approximate MP 74.9) would be crossed using the open cut method. This method 

can cause temporary traffic delays. However, through the use of adequate signs, safety barriers, and preestablished detours KMLP would minimize these interruptions to road traffic. During pipe installation at 

road crossings, which typical take only a day, construction practices include keeping one lane of traffic 

open where no reasonable detours are feasible or where construction takes place during peak traffic hours. 

KMLP has indicated that it would repair any significant damage done to transportation 

infrastructure that is a direct result of pipeline construction. Thus, impacts to land transportation facilities 

are expected to be minor and short-term. 

4.9.6.2 Marine Transportation 

Construction of the pipeline would cross Sabine lake, the Intracoastal Waterway, and the 

Calcasieu River. Potential impacts would be temporary impacts to commercial and recreational boats 

resulting from the construction activities associated with water crossings, as described in sections 4.8.3.2 

and 4.8.3.7. Impacts would be due to project-related marine traffic, including pipe and material delivery 

barges and construction barges. Project related impacts would primarily affect barges and smaller 

recreational vessels. 

In order to mitigate these potential impacts in Sabine Lake (approximate MP 4.8 to MP 18.0), 

KMLP has indicated that the pipeline would be installed using barges with anchor spuds. This procedure 

would minimize impacts resulting from construction operations. Furthermore, the Applicant has indicated 

that prior to construction it will provide project specific details to the U.S. Coast Guard such as the timing 

of, and areas in which, water-based construction would occur, as well as the types of vessels that would 

be utilized. The U.S. Coast Guard will then disseminate this information in a Notice to Mariners. In 

addition, construction practices within Sabine Lake would entail leaving spaces between spoil piles for 

navigational purposes. To facilitate passage through these areas KMLP would install timber piles with 

navigational lights and warning signals. Finally, the Applicant has indicated it would comply with all 

navigation rules and regulations in the Project vicinity. 

The pipeline would also cross the waters of the Intracoastal Waterway and Calcasieu River. 

These waters are important navigational channels for both commercial and recreational purposes. Leg 

one of the pipeline would cross the Intracoastal Waterway at several locations including approximate MP 

18.6 to MP 18.7, MP19.01 to MP 19.7, MP 21.4 to MP 22.0, and MP 30.7 to MP 31.0 and the Calcasieu 

River at approximate MP 49.6 to MP 49.8. These crossings would be accomplished using the HDD 

method, which will avoid or minimize potential impacts on vessel traffic in these areas. 

The operation of the pipeline in the waters of Sabine Lake, the Intracoastal Waterway, and 

Calcasieu River would not impact vessel traffic as the pipeline would be buried beneath the lake or river 

bottom. Thus, the pipeline would not impede vessel passage. 

4.9.7 Government Tax Revenue 

Tax revenue would be generated by the Project for the State of Louisiana and the respective 

parishes within the region of influence. KMLP has estimated annual taxes payable to local governments 

in the region of influence range from 1.1 million to 5.4 million. On average, operations-related taxes 
 4-92 Environmental Analysis

would represent approximately 2.0 percent of a parish’s total revenues. Thus, operation of the Project 

would provide a permanent, minor increase in government revenues. 

A portion of the estimated $65 million Project construction payroll would be spent locally for the 

purchase of housing, food, gasoline, and entertainment during construction by project employees. The 

exact amount spent would be dependent upon the proportion of the workforce that was local, the behavior 

of individual workers and the duration of their stay. In addition, KMLP has indicated that local suppliers 

would have the opportunity to submit proposals for Project-related work. To the extent that these local 

providers bid successfully, local expenditures during construction would increase. Construction-related 

expenditures made in Louisiana would be subject to Louisiana’s state sales tax of 4 percent. This increase 

in sales tax would represent a minor, short-term increase in government revenues. 
 4-93 Environmental Analysis

4.10 CULTURAL RESOURCES 

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

(including the issuance of permits or certificates) on “historic properties,” that is, properties listed on, or 

eligible for listing on, the NRHP. Section 106 also requires the FERC to provide the ACHP an 

opportunity to comment on the undertaking. KMLP, as a non-federal party, is assisting the FERC in 

meeting its obligations under section 106 and the implementing regulations in 36 CFR 800. 

KMLP provided the Louisiana State Historic Preservation Office (SHPO) with a plan for 

identifying historic properties and involving Indian tribes. KMLP sent letters to Indian tribes 

summarizing the results of archaeological surveys and requesting information about these or other sites 

that may have religious and cultural significance. KMLP will provide the SHPO with detailed cultural 

resources survey reports and request concurrence on its evaluations of NRHP eligibility of identified 

properties. These consultation efforts are described in more detail below. 

4.10.1 Consultation with Louisiana State Historic Preservation Officer 

Consultation regarding the Project with the Louisiana SHPO was initiated in January 2006, when 

a cultural resource scope of work was submitted to the Louisiana SHPO. In February 2006, the SHPO 

accepted the proposed scope of work, including the definition of the area of potential effects (APE), 

proposed survey methodology, and Native American groups to be contacted. KMLP submitted State of 

Louisiana Site Record forms to the SHPO in September 2006. Once Louisiana site numbers are assigned, 

KMLP will incorporate these into the survey report and submit it for the SHPO’s review and concurrence 

with eligibility evaluations. 

4.10.2 Native American Consultation 

KMLP submitted letters to the Alabama Coushatta Tribe of Texas, Caddo Nation, Chitimacha 

Tribe of Louisiana, Coushatta Tribe of Louisiana, Jena Band of Choctaw Indians, Mississippi Band of 

Choctaw Indians, Quapaw Tribe of Oklahoma, and Tunica-Biloxi Indians of Louisiana. Two letters were 

sent to representatives of these tribes, in April and August of 2006, informing them about the Project, the 

results of the initial cultural resources surveys, and requesting that they communicate any potential 

concerns they might have with respect to possible impacts to traditional cultural properties and historic 

properties. 

The Caddo Nation responded that it knows of no traditional cultural properties in the potentially 

affected parishes. The Nation requested notification and copies of reports, should any cultural resources 

or archaeological sites be discovered. The Chitimacha Tribe of Louisiana responded that Acadia Parish is 

part of the Chitimacha homeland. Their records and oral traditions do not indicate the presence of a 

specific Chitimacha archaeological site or traditional cultural property in the immediate vicinity of the 

Project. The Chitimacha requested notification to begin consultation if archaeological remains 

representing a village site or burial site are discovered during construction. Responses have not yet been 

received from the other tribes. 

4.10.3 Results of Cultural Resources Survey 

KMLP conducted background cartographic, archival, and archeological review, as well as 

pedestrian survey and systematic shovel testing of the proposed pipeline corridor and ancillary facility 

locations. The investigation also included an assessment of all standing structures 50 years old or older 
 4-94 Environmental Analysis

that were located in the pipeline corridor, access roads, aboveground facilities, and pipe storage and 

contractor yards. The gathered information was used to assess NRHP eligibility of cultural resources.

A total of 122 miles of the pipeline were surveyed for cultural resources, consisting of 108.6 

miles of terrestrial survey and 13.4 miles of underwater remote sensing. Ten interconnect sites that fell 

within the pipeline corridor were examined as part of the survey. Additionally, all 2.3 miles of the 24-

inch FGT Lateral pipeline were surveyed, as well as 10 pipe storage and contractor yards, 66 access 

roads, the surface of four HDD locations, and 44 extra workspaces immediately adjacent to the 

construction right-of-way. 

There remain 9.9 miles of the pipeline route, two pipe storage and contractor yards, four 

interconnect sites, and nine access road routes that have not been surveyed because permission from 

landowners to access these properties has not yet been obtained. KMLP has indicated that it will perform 

cultural resources surveys for the unsurveyed portions of the Project during subsequent investigations 

prior to construction. The surveys will include the inspection of the locations of three previously 

recorded archaeological sites that were not relocated during the initial survey, possibly because high 

water precluded thorough inspection. 

In total, the survey identified 21 cultural resources within or adjacent to the APE: 11 locations 

where cultural materials were found on or under the ground, one submerged cultural resource, six historic 

standing structures, two previously recorded archaeological sites, and a single historic cemetery. KMLP 

archaeologists assessed all of these sites as ineligible for NRHP listing, and recommended no further 

work for these cultural resources. SHPO review of the survey report and concurrence with the eligibility 

assessments and recommendations is pending. 

More specific information regarding the cultural resources survey results can be found in the 

sections below. 

Pipeline Corridors 

KMLP surveyed a 300-foot-wide corridor for the terrestrial portion of the pipeline route. A total 

of 15 cultural resources were discovered within the examined portion of the terrestrial section. In total, 

eight sites consisting of late nineteenth-century to early twentieth-century historic scatters, four early to 

mid-twentieth-century structures, and a single historic cemetery were encountered. Additionally, two 

previously recorded sites (16CM153 and 16CM154) between MP 4 and 5 were relocated and examined. 

Surveyors did not examine two previously recorded sites (16CM27 and 16CM59) between MPs 18 and 

20 because HDD would avoid ground disturbance in these areas. 

Because the pipeline corridor would be situated across an existing road from the cemetery, the 

historic cemetery would not be disturbed. KMLP proposes a HDD to avoid the two previously recorded 

archeological sites that were reexamined, as well as the two that were not reexamined. 

KMLP surveyed a 3,000-foot-wide corridor extending through Sabine Lake for 13.4 miles. The 

underwater survey identified 15 targets for further analysis along the proposed pipeline route, only one of 

which was designated as a potential submerged cultural resource after consultation with archaeologists. 

This target (Target 6) is located more than 1,000 feet from the pipeline center. All other identified targets 

appear to represent either casually discarded or lost debris, or structures related to the oil and gas industry, 

and require no further action. 

Gaps in data are present along the submerged pripeline route approximately 2,200 feet northeast 

of MP 6.0 near Tieline 401 and from approximately 900 feet north of MP 17 to landfall. Gaps are due 
 4-95 Environmental Analysis

primarily to the hazards of shallow water and the practical impossibility of operating remote sensing 

instruments in these waters. Significant underwater cultural resources are not anticipated in these shallow 

waters. 

KMLP archaeologists recommend either avoidance of Target 6 or further investigation in 

consultation with regulatory authorities. 

No cultural resources were identified within the current assessment of the FGT Lateral. 

Pipe Storage/Contractor Yards 

Of the 10 locations surveyed, a total of three cultural resource locations were encountered. Two 

consisted of late nineteenth-century to early twentieth-century historic scatters, and one was an early to 

mid-twentieth century historic standing structure. 

Aboveground Facilities 

No cultural resources were found on the 10 of the 14 interconnect sites surveyed. 

Access Roads 

KMLP anticipates that 75 temporary access roads would be required during construction. 

Cultural resource surveys have been completed for 66 of these routes, totaling 31.1 miles. The remaining 

nine access roads have not been surveyed because landowner permission has yet to be obtained. Two 

cultural resource locations were identified along access roads. One was a scatter of late nineteenth- to 

early twentieth-century historic materials, and one was an early to mid-twentieth century historic standing 

structure. 

4.10.4 General Impacts and Mitigation 

The results of cultural resources investigations to date have identified no properties eligible for 

the NRHP, and consequently no adverse effects to historic properties. The distance between the historic 

cemetery and pipeline trench is sufficient to avoid any ground disturbance to the cemetery. Pending 

SHPO review, KMLP has proposed avoidance or further investigations of one underwater target that may 

be a cultural resource. KMLP has also proposed to use HDD to avoid two previously recorded 

archaeological sites even though they are considered ineligible for the NRHP. 

KMLP has not yet completed cultural resources surveys for about 9.9 miles of the pipeline route, 

two potential pipe storage and contractor yards, four interconnect sites, and nine access road routes 

because landowner permission for access has not yet been obtained. The completion of surveys and 

evaluations within these areas, as well as review and concurrence from the Louisiana SHPO regarding 

NRHP eligibility and project effects, would be required to complete the process of compliance with 

section 106 of NHPA. 

Once cultural resources surveys and evaluations are complete, the FERC, in consultation with the 

Louisiana SHPO, would make determinations of NRHP eligibility and project effects. If any historic 

properties would be affected by the Project, we would seek ways to minimize or avoid adverse effects. 

KMLP has indicated that it would conduct the additional surveys required along the pipeline 

route and file appropriate reports prior to construction. To ensure that the Commission’s responsibilities 

under the NHPA and its implementing regulations are met, we recommend that:
 4-96 Environmental Analysis

• KMLP defer construction and use of facilities and staging, storage, and temporary work 

areas and new or to be improved access until it files with the Secretary cultural resource 

reports, as appropriate, and the SHPO's comments; and the Director of OEP reviews 

and approves all reports and notifies KMLP in writing that it may proceed. 

All material filed with the Commission containing location, character, and ownership

information about cultural resources must have the cover and any relevant pages 

therein clearly labeled in bold lettering: “CONTAINS PRIVILEGED INFORMATION-

-DO NOT RELEASE.” 

4.10.5 Unanticipated Discovery Plan 

As part of its application, KMLP provided its Unanticipated Discovery Plan to be used in the 

event that previously unidentified cultural resources such as archeological sites, historic features, or 

human remains are encountered during project construction. The Unanticipated Discovery Plan is 

acceptable. 
 4-97 Environmental Analysis

4.11 CUMULATIVE IMPACTS 

The CEQ (40 CFR 1508.7) defines a cumulative impact as “...the impact on the environment 

which results from the incremental impact of the action when added to other past, present, and reasonably 

foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such 

other actions. Cumulative impacts can result from individually minor but collectively significant actions 

taking place over a period of time.” The purpose of this cumulative impacts analysis is to identify and 

describe cumulative impacts to environmental resources that would potentially result from the KMLP 

Project when added to the impacts of other projects. This cumulative impact analysis follows the 

methodology set forth in CEQ’s guidance (CEQ 1997). 

We defined the scope of the cumulative impact analysis by determining the environmental impact 

issues associated with the proposed action; establishing a geographic scope for the cumulative impacts 

project area; establishing the time frame for the analysis; and identifying other past, present, or future 

actions that have affected, or could affect, the resources of concern within the project area. Each of these 

factors is discussed in turn below. 

With regard to the environmental impact issues to be evaluated, the scoping process conducted 

for the KMLP Project provided a useful means for determining the relevant cumulative impact issues 

associated with the KMLP Project and the surrounding area. We consulted with resource agencies and 

other interested parties to identify important environmental issues and resources within the project area, 

particularly those that could be affected by the KMLP Project. Through this process, we determined that 

water resources, wetlands, biological resources, and land use are especially important aspects of the 

affected environment from a cumulative impacts perspective. We also considered the cumulative effects 

of air quality, noise, socioeconomic, and shoreline erosion impacts. 

With regard to the geographic scope of the analysis, we considered the area over which the 

KMLP Project would directly or indirectly impact water resources, wetlands, biological resources, air 

quality, and other elements of the human environment. According to the direct and indirect impact 

analysis conducted in this draft EIS, most of the Project’s impacts would be localized, occurring in the 

immediate vicinity of the construction right-of-way. However, some impacts would extend beyond the 

construction right-of-way and temporary extra workspaces. Therefore, we used the boundaries of the 

watersheds crossed by the project to define the geographic area for the cumulative impacts analysis. 

Table 4.3.2.1-1 in section 4.3.2.1 of this draft EIS lists each watershed crossed by the KMLP Project,. 

With regard to the timeframe for the cumulative impacts analysis, we considered the duration of 

impacts associated with the Project. The majority of the impacts to environmental resources resulting 

from the Project would occur during periods of active construction. Most impacts to environmental 

resources associated with other projects would also occur during periods of active construction with some 

long-term and permanent impacts resulting from changes in land use. Projects associated with the 

recovery efforts in the Gulf Coast Region are already under construction or will be in the immediate 

future. Since the environmental impacts of the KMLP Project and most other projects located within the 

project area would occur within the next five years or less, the temporal span for this cumulative impacts 

analysis includes a five-year time period, 2005 to 2010. 

With regard to other past, present, or future actions to consider in this analysis, we included other 

actions based on their location in the project area and the likelihood that they would contribute impacts to 

environmental resources affected by the Project. Figure 4.11-1 shows existing and reasonably foreseeable 

gas pipeline and LNG projects in the cumulative impact analysis area. Consideration of past projects in a 

cumulative impacts analysis can assist in defining baseline conditions of the affected environment. 
4-98 

Non-Internet Public 

DRAFT ENVIRONMENTAL IMPACT STATEMENT 

KINDER MORGAN LOUISIANA PIPELINE PROJECT 

Docket No. CP06-449-000 

Page 4-98 

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

Cumulative Impacts 

Public access for this Non-Internet Public information is available only through 

Room, or by e-mail at public.referenceroom@ferc.gov. 
 4-99 Environmental Analysis

However, agencies are not required to list or analyze the effects of individual past actions unless such 

information is necessary to describe the cumulative effect of all past actions combined (CEQ 2005). 

Baseline environmental conditions described in other sections of this draft EIS reflect the cumulative 

impacts of past projects. Table 4.11-1 lists ongoing and reasonably foreseeable future activities and 

projects that could contribute impacts to resources that would be affected by construction and operation of 

the KMLP Project within the same geographic area and a similar timeframe. Table 4.11-2 depicts the 

resources that would be affected by the construction and operation of the activities/projects listed in table 

4.11-1. Construction and/or implementation schedules of future projects depend on factors such as 

economics, funding, and politics. 

With the scope thus defined, the anticipated cumulative impacts of the Project and other projects 

and activities are discussed in the sections that follow. The analysis draws on table 4.11-3 which 

summarizes the cumulative impacts on waterbodies, wetlands, and forested areas resulting from the 

KMLP Project and other projects within the project area. These anticipated cumulative impacts are based 

on NEPA documentation, agency and public input, and best professional judgment. 

4.11.1 Water Resources 

Past and ongoing activities like agriculture, industrial operations, and the development of 

commercial, residential, energy, and transportation infrastructure have affected and will continue to affect 

water resources, wetlands, biological resources, and other elements of the environment within the project 

area. For example, Ruth (2006) reports that as much as 99% of the original prairies and grasslands in the 

Coastal Prairies Physiographic Province, which includes the project area, have been converted to 

agriculture. 

Multiple projects in the area would result in 427 open-cut water body crossings and 23,064,684 

cubic yards of required dredging. The KMLP Project accounts for 133 of the 427 (approximately 31%) 

open-cut waterbody crossings, but none of the required dredging. Impacts to water quality resulting from 

the KMLP Project and other projects would be temporary or short-term and minor, limited to the periods 

of construction within the water bodies. Most of the waterbodies crossed by the KMLP Project are not 

the same ones crossed by the other projects, and where the same waterbodies are crossed, the crossing 

points are usually miles apart. 

The most significant cumulative impact would be associated with the combined crossing of 

Sabine Lake by both the Kinder Morgan pipeline and the Port Arthur pipeline. However, the construction 

schedule for these two projects would not overlap and the routes of these two pipelines across Sabine 

Lake are generally separated by more than 2.5 miles, although they would come within 1 mile of each 

other in the northernmost part of the lake. In both cases, the construction of the pipelines across Sabine 

Lake would result in temporary localized increases in turbidity, expected to be observed approximately 

1,500 feet away from the construction activity and to dissipate in a few hours after the construction 

activity ceased. The increased turbidity would not result in long-term effects on water quality and the 

increased turbidity levels associated with the construction would not exceed naturally occurring levels 

during tropical storms. 

Several projects included in the Long-Term Community Recovery Plan (Louisiana Speaks 2006) include 

construction activities that would cause similar impacts to water resources as those discussed above. 

Additionally, specific types of projects (e.g., roadways, buildings, parking lots, etc.) could also result in 

an increase in impervious cover that can reduce groundwater recharge and increase the volume and 

velocity of surface water runoff. Such projects can also indirectly introduce chemicals such as oil and 

grease into runoff that eventually enters surface water bodies and the aquatic environment. Other projects 
 4-100 Environmental Analysis

TABLE 4.11-1 

Existing, Approved, or Proposed Projects and Activities that 

Could Contribute to Cumulative Impacts with the KMLP Project 

Activity/Project Description 

Timing/ 

Construction

Schedule 

Ongoing Activities/Projects 

Manufacturing/ 

Refining 

Oil and gas extraction, processing, and transportation, both onshore and 

offshore. 

Ongoing 

Dredging Maintenance dredging of various surface water bodies such as Sabine 

Lake, the Sabine River, the GIWW, and the Calcasieu Ship Channel. 

Periodic 

Recreation Fishing, hunting, boating, and bird watching. Ongoing 

Shipping Commercial ship traffic within waterbodies such as Sabine Lake, the 

Sabine River, the GIWW, and the Calcasieu Ship Channel. 

Ongoing 

Transportation 

Infrastructure 

Construction and maintenance of roadway infrastructure like the repair of 

US Highway 82 damaged by the hurricanes. Projects include asphalt 

widening and overlays, bridge reconditioning, new bridge construction, 

intersection improvements, etc. 

Ongoing 

Utility Infrastructure Construction and maintenance of new and existing utility infrastructure 

(e.g., powerlines). 

Ongoing 

Commercial and 

Residential 

Development 

Business and housing construction projects like those associated with the 

reconstruction of Holly Beach. 

Ongoing 

Agriculture and 

Silviculture 

Agricultural practices, including animal grazing, crawfish farming, rice 

farming, and pine plantations and associated management practices. 

Ongoing 

Environmental 

Restoration 

Shoreline stabilization (e.g., Perry Ridge Shore Protection Project), 

hydrologic restoration (e.g., Black Bayou Hydrologic Restoration Project), 

and wetland mitigation banks (e.g., Gum Cove Mitigation Bank). 

Ongoing 

Louisiana Long-Term 

Community Recovery 

Plan Projects 

In the aftermath of Hurricanes Katrina and Rita, federal and state efforts 

are culminating in plans and projects to help devastated parishes recover 

from the storms, and to be better prepared for future storms. Plans and 

projects vary from parish to parish, depending upon the most pressing 

needs in a given location. 

Ongoing– 

Future 

Sabine Pass LNGa

Project 

Construction of three LNG tanks along the Sabine Ship Channel with a 

nominal output of up to 2.6 Bcfd and a new 16-mile-long natural gas 

pipeline originating at the Sabine LNG Terminal and terminating near 

Johnsons Bayou in Cameron Parish, Louisiana. 

2005-2007 

Sabine Pass LNGa

Project Expansion 

(Phase II) 

Expansion of Sabine Pass LNG Project (Phase I) to include construction 

and operation of three additional LNG tanks to increase sendout output 

up to 4.0 Bcfd. 

2006-2008 

Golden Pass LNGa

Project 

Construction of up to five LNG storage tanks with a nominal output of 1 

Bcfd for the first phase (three LNG tanks), increasing to 2 Bcfd in the 

second phase (five tanks) in Jefferson County, Texas, and about 122 

miles of pipelines located in Jefferson, Orange, and Newton Counties, 

Texas, and Calcasieu Parish, Louisiana. 

2006-2008 

Trunkline LNGa

Terminal Expansion 

Expansion of an existing LNG terminal in Lake Charles, Louisiana. 

Includes an infrastructure enhancement project and a natural gas liquids 

extraction plant. 

2005-2008 
 4-101 Environmental Analysis

TABLE 4.11-1 (cont’d) 

Existing, Approved, or Proposed Projects and Activities that 

Could Contribute to Cumulative Impacts with the KMLP Project 

Activity/Project Description

Timing/ 

Construction

Schedule

Cameron (Hackberry) 

LNG Project 

Construction and operation of an LNG terminal along the Calcasieu Ship 

Channel and associated 35.4-mile natural gas pipeline in Louisiana. 

2005-2008 

Liberty Gas Storage 

Project 

Construction and operation of two natural gas storage caverns, four 

injection wells, and associated 24.6-mile pipeline in Louisiana. 

2006-2007 

Reasonably Foreseeable Future Activities/Projects 

Louisiana Long-Term 

Community Recovery 

Plan 

See description for these projects under Ongoing Activities/Projects. Ongoing– 

Future 

Creole Trail Pipeline 

Segment 1 

Amendment 

Construction and operation of 18.1 miles of 42-inch-diameter highpressure natural gas pipeline to interconnect the previously certificated 

Creole Trail and Sabine Pass pipeline systems in Cameron Parish, 

Louisiana. 

2008-2009 

Creole Trail LNG 

Project 

Construction and operation of an LNG terminal at the mouth of the 

Calcasieu Ship Channel and an associated natural gas pipeline in 

Louisiana. 

2007-2009 

Cameron LNG 

Expansion Project 

Expansion of Cameron (Hackberry) LNG Project (described above) to 

construct and operate one additional LNG storage tank and other 

modifications to increase sendout capacity to 2.65 Bcfd. 

2007-2008 

Port Arthur LNGb

Project 

Port Arthur LNG proposes to construct and operate an LNG terminal 

along the Sabine-Neches Canal and associated natural gas pipeline in 

Texas and Louisiana. 

2007-2010 

Starks Gas Storageb

Pipeline Project 

Construction of about 35.6 miles of 16-inch and 30-inch-diameter natural 

gas pipeline and about 1.9 miles of 10-inch-diameter brine pipeline in 

Calcasieu and Beauregard Parishes, Louisiana. 

2006-2008 

_______________ 

a

 Projects have been approved by the FERC and are under construction. b

 Projects have been approved by the FERC but construction is pending.
 4-102 Environmental Analysis

TABLE 4.11-2 

Resources of Concern that Could be Affected by Construction or Development of Existing, 

Approved, or Proposed Projects or Activities in the Vicinity of the KMLP Project 

Primary Environmental Impact 

Activity/Project

Water Resources Wetlands Wildlife/Vegetation Aquatic Resources Recreation Socioeconomics Land Use Ship Traffic Transportation Air Quality/Noise 

Present Projects or Activities

Manufacturing/Refining X X X X X X X 

Dredging X X X X X X X X 

Recreation X X X X X 

Shipping X X X X X 

Transportation Infrastructure X X X X X X X X X 

Utility Infrastructure X X X X X X X X 

Commercial/Residential Development X X X X X X 

Agriculture and Silviculture X X X X X X X 

Environmental Restoration X X X X X X X 

Louisiana Long-Term Community Recovery Plan Projects X X X X X X X X X X 

Sabine Pass LNG Project X X X X X X X X X X 

Sabine Pass LNG Project Expansiona X X X X X 

Golden Pass LNG Project X X X X X X X X X X 

Trunkline LNG Terminal Expansion X X X X 

Cameron (Hackberry) LNG Expansion Project X X X X X X X X X X 

Liberty Gas Storage Project X X X X X X X 

Reasonably Foreseeable Future Projects or Activities

Louisiana Long-Term Community Recovery Plan X X X X X X X X X X 

Creole Trail Pipeline Segment 1 Amendment X X X X X X X 

Creole Trail LNG Project X X X X X X X X X X 

Cameron LNG Expansion Project X X X X X X 

Port Arthur LNG Project X X X X X X X X X X 

Starks Gas Storage Pipeline Project X X X X X X X 

_______________ 

a

 No other sources were considered regarding the Sabine Pass LNG Project Expansion because it would be within the same 

boundaries as the existing facility. 

included in the Long-Term Community Recovery Plan include environmental restoration activities that 

would improve the quality of water resources within the project area. 
 4-103 Environmental Analysis

4.11.2 Wetlands 

From a wetlands perspective, the KMLP Project would be within the Western Gulf Coastal Plain 

ecoregion, which historically contained vast areas of freshwater and tidal wetlands, intermixed with 

upland prairie and forest. This ecoregion has undergone significant alterations in the last several decades. 

In particular, the area of freshwater wetlands has significantly decreased due to saltwater intrusion caused 

by development, dredging, channelization, land subsidence, and other factors (Ruth 2006). The presence 

and ongoing spread of non-native vegetation species have reduced the vegetative diversity and wildlife 

habitat quality of freshwater and tidal wetlands in this region. 

The projects listed in table 4.11-3 would disturb a total of about 2,285 acres of wetlands during 

construction. The KMLP Project would disturb approximately 22% of the total wetlands impacted during 

construction. Including the KMLP Project, pipelines account for approximately 77% of the total acres of 

wetlands that would be disturbed during construction. To provide perspective, SNWR, which comprises 

a small portion of the project area, encompasses 124,511 acres of fresh, intermediate, and brackish 

marshes (FWS 2006c). The combined projects would result cumulatively in a short-term and minor 

impact associated with construction through emergent or scrub-shrub wetlands, which would revegetate 

quickly (generally within 1 to 3 years) after construction and right-of-way restoration. Construction 

through forested wetlands would contribute cumulatively to the long- term or permanent alteration of 

forested wetlands in southwest Louisiana and southeast Texas to shrub or emergent wetlands (although 

the KMLP Project would not contribute to wetland alteration in Texas). 

The construction and operation of the Project, along with the other potential projects and 

activities, could result in a cumulative reduction in the amount of wetlands within the project area. 

However, mitigation for wetlands affected by the Project and the other projects listed would be required 

by the COE and could result in a net increase and/or improvement in the regional coastal marsh resource. 

4.11.3 Biological Resources 

When projects are constructed at or near the same time, the combination of construction activities 

could have a cumulative impact on vegetation, wildlife, and aquatic organisms living in the immediate 

area. Clearing, grading, and other construction activities associated with pipeline construction and other 

similar activities in the vicinity (e.g., road and transmission line construction, silvicultural practices) 

would result in the removal of vegetation, alteration of wildlife habitat, displacement of wildlife, and 

other secondary effects such as increased population stress, predation, forest fragmentation, and 

establishment of invasive plant species. Similarly, the construction of multiple large industrial projects at 

or near the same time can result in a significant amount of land clearing activities that could have a 

cumulative impact on forest resources in the immediate area of the projects. However, most of the large 

industrial sites proposed or currently under construction in the project area (e.g., LNG terminals) are 

largely devoid of large stands of trees other than Chinese Tallow, an invasive species. 

About 598.9 miles of pipeline would be constructed for the projects listed in table 4.11-3 and 

would result in a total of about 9,074 acres of vegetation disturbance assuming a right-of-way width of 

125 feet. The construction of the LNG terminals would add to the total area of vegetation disturbance. 

Although the total amount of vegetation that would be affected by the KMLP Project and other potential 

projects in the area may be considered substantial, much of this would occur in areas that have been 

previously disturbed by existing rights-of-way. Also, this disturbance, alteration, or loss of habitat would 

be relatively small compared to the abundance of similar resources in the project area, the majority of it 

would be allowed to return to pre-construction conditions. 
 4-104 Environmental Analysis

TABLE 4.11-3 

Cumulative Impacts to Environmental Resources Resulting from the Construction and 

Operation of Projects in the Vicinity of the KMLP Project 

Dredging Required 

(cubic yards) 

Total Wetlands 

Disturbed During 

Construction 

(acres) 

Forest Cleared 

(acres)a

Project 

Pipeline 

Length 

(miles)b

Number of 

Open-Cut 

Waterbody 

Crossings 

Berth 

Area Lakec LNG 

Terminal Pipeline 

LNG 

Terminal Pipeline 

KMLP Projectd

Construction 135.5 133 NA NA NA 504.2 NA 150.6 

Operations NA NA NA NA NA NA NA 58.7 

Cameron (Hackberry) LNG Projecte 

Construction 35.4 97 4,900,000 NA 67.7 148.1 0.0 148.3 

Operations NA NA NA NA NA NA 0.0 74.2 

Cameron LNG Expansiond 

Construction NA 0 20,000 NA 1.8 NA 0.0 0.0 

Operations NA NA NA NA NA NA 0.0 0.0 

Creole Trail Projectf 

Construction 116.8 81 4,100,000 2,575,596 102.9 106.8 54.1 552.5 

Operations NA NA NA NA NA NA 22.9 299.7 

Creole Trail Segment 1 Pipeline Projectd 

Construction 18.1 7 NA NA NA 216.9 NA 0.0 

Operations NA NA NA NA NA NA NA 0.0 

Golden Pass LNG Projecte

Construction 122.4 54 5,700,000 NA 108.8 290.2 0.0 451.3 

Operations NA NA NA NA NA NA 0.0 238.7 

Liberty Pipeline Projecte

Construction 24.6 10 NA NA NA 40.9 NA 155.5 

Operations NA NA NA NA NA NA NA 82.4 

Port Arthur LNG Projectf 

Construction 73.0 34 820,000 310,088 82.5 308.3 0.0 201.0 

Operations NA NA NA NA NA NA 0.0 87.2 

Sabine Pass LNG and Pipeline Projecte 

Construction 16.0 5 4,569,000 NA 56.4 99.4 0.7 2.3 

Operations NA NA NA NA NA NA 0.7 0.8 

Sabine Pass LNG Project Expansion

Construction NA 0 NA NA 100.3 NA 0.0 0.0 

Operations NA NA NA NA NA NA 0.0 0.0 
 4-105 Environmental Analysis

TABLE 4.11-3 (cont’d) 

Cumulative Impacts to Environmental Resources Resulting from the Construction and 

Operation of Projects in the Vicinity of the KMLP Project 

Dredging Required 

(cubic yards) 

Total Wetlands 

Disturbed During 

Construction 

(acres) 

Forest Cleared 

(acres)a

Project 

Pipeline 

Length 

(miles)b

Number of 

Open-Cut 

Waterbody 

Crossings 

Berth 

Area Lakec LNG 

Terminal Pipeline 

LNG 

Terminal Pipeline 

Starks Gas Storage Pipeline Projectf 

Construction 34.7 6 NA NA NA 49.8 NA 149.2 

Operations NA NA NA NA NA NA NA 90.3 

Trunkline LNG Terminal Expansione 

Construction 22.2 0 70,000 NA 0.0 NA 0.0 NA 

Operations NA NA NA NA NA NA 0.0 NA 

Cumulative Totals 

Construction 598.9 427 20,179,000 2,885,684 520.4 1764.6 54.8 1,810.7 

Operations NA NA NA NA NA NA 23.6 932.0 

_______________ 

a

 Includes forested wetlands. 

b

 Includes mainlines, looplines, and laterals associated with the project. c

 Dredging required in Sabine Lake (Port Arthur) and Calcasieu Lake (Creole Trail) for pipeline construction. d

 Projects are currently under review by the FERC. 

e

 Projects have been approved by the FERC and are under construction. f

 Projects have been approved by the FERC but construction has not begun. g

 Includes dual pipeline. 

NA Not Applicable 

Construction of the projects in table 4.11-3 would affect a total of about 1,865.5 acres of forested 

land (including forested wetlands), of which about 956 acres would be maintained in a non-forested 

condition during project operations. Some of these forest lands consist of stands of planted timber grown 

for commercial use. Landowners would be compensated for raw timber removed from construction work 

areas, and would be allowed to replant areas outside of the permanent right-of-way following completion 

of construction. 

Although the total amount of forested land that would be affected by the KMLP Project and other 

potential projects in the project area may be considered substantial, the linear nature of the pipelines 

would not require clear cutting of large areas of timber. Additionally, where the pipelines would be 

parallel and adjacent to one another, additional forest impacts would be cumulative, but minimized by the 

overlapping rights-of-way. The loss of forested land in this area due to all of these projects would be 

relatively small compared to the abundance of similar resources in the project area. 
 4-106 Environmental Analysis

4.11.4 Land Use, Recreation, and Visual Resources 

Along the Project and other pipeline routes, most land uses would revert to prior uses following 

construction. Some land uses would be restricted or prohibited on the new permanent pipeline rights-ofway, to accommodate permanent aboveground structures and recurring maintenance activities. 

Recreational activities, such as fishing, boating, and bird watching occur throughout the coastal 

marsh, Sabine Lake, and the Sabine River in the vicinity of the KMLP Project. Other projects included in 

this analysis would contribute to effects on users of Sabine Lake and the Sabine River and could 

negatively affect recreation, primarily during periods of active construction. The presence and movement 

of construction equipment, materials, and workers may be disruptive temporarily to users of the local 

recreation areas, particularly if more than one project is under construction at any one time in the project 

area. Recreation-related cumulative impacts are expected to be localized, short-term, and minor. 

Construction and operation of the KMLP Project and other projects in the area may affect visual 

resources by altering the terrain and vegetation patterns during construction or right-of-way maintenance 

and through the installation of new aboveground facilities that change land use. However, the KMLP 

Project would result in minimal land use changes and would therefore not contribute significantly to 

adverse impacts on visual resources within the project area. 

4.11.5 Socioeconomics 

Present and reasonably foreseeable future projects and activities could cumulatively impact 

socioeconomic conditions in the project area. There may be both beneficial and detrimental effects on 

employment, housing, infrastructure, and public services. The Project would make a negligible 

contribution to these impacts. 

Employment and Housing 

In general, natural gas-related projects have a beneficial impact on local employment during the 

short construction period. Since the construction of the KMLP Project would overlap with the 

construction of other projects, the demand for workers could exceed the local supply of appropriately 

skilled labor. The increased demand for workers could reduce current unemployment and perhaps lead to 

higher wages for the duration of construction. Other indirect employment benefits could include 

temporary jobs in the local area (e.g., restaurants, motels, and convenience stores). 

Damage caused by Hurricane Rita in 2005 increased the need for construction workers in the 

project area. Prior to the hurricane, the project area would have been able to accommodate temporary 

construction workers who preferred to live there. However, as a result of the hurricane, accommodating 

temporary construction workers is likely to be a regional priority for several years. Nevertheless, given 

the vacancy rates in the area and the number of hotel/motel rooms in larger population centers in the 

project area, construction crews should not encounter difficulties in finding temporary housing. The 

degree of cumulative impacts on housing resources would depend upon the number of other projects 

being constructed simultaneously and the season, specifically when construction coincides with periods of 

peak recreation and tourism activity. If construction occurs concurrently with other projects and during 

the peak recreation and tourism periods, temporary housing would still be available but may be more 

difficult to find and/or more expensive to secure. Regardless, these effects would be temporary, lasting 

only for the duration of construction, and there would be no long-term cumulative effect on housing. 
 4-107 Environmental Analysis

Vehicular Traffic 

Since the construction of the KMLP Project would overlap with the construction of other 

projects, there could be increased congestion on local roads during the construction period. Kinder 

Morgan plans to cross most paved roads and railroads using the boring or HDD method to mitigate traffic 

disruptions and direct surface impacts. Alternatively, unpaved roads and one abandoned railroad would 

be crossed using the open cut method. This method can cause temporary traffic delays. However, the use 

of adequate signs, safety barriers, and pre-established detours would minimize these interruptions to road 

traffic. Pipe installation at road crossings typically takes a day to complete and includes construction 

practices that keep one lane of traffic open where no reasonable detours are feasible or during peak traffic 

hours. To the extent that construction occurs simultaneously in a given area, traffic impacts would be 

localized and short-term. 

Infrastructure and Public Services 

The cumulative impact of the KMLP Project and other activities in the project area on 

infrastructure and public services would depend on the number of projects under construction at one time. 

The small incremental demands of several projects occurring at the same time could become difficult for 

police, fire, and emergency service personnel to address. This problem would be temporary, and occur 

only for the length of construction. No long-term effects on infrastructure and public services are 

expected. 

Marine Traffic 

Once completed, other projects within the project area would cause an increase in marine traffic. 

The KMLP Project would cross Sabine Lake, enter the mouth of the Sabine River, and cross the GIWW 

and the Calcasieu River. Construction would temporarily impact commercial and recreational boats in 

these areas due to project-related marine traffic, including pipe and material delivery barges and 

construction barges. Project-related impacts would primarily affect barges and smaller recreational 

vessels and would only occur during periods of active construction in these areas. These impacts would 

result in a negligible contribution to the cumulative impacts on marine traffic when added to impacts of 

other projects in the area. 

4.11.6 Shoreline Erosion 

Average coastal erosion rates are 4.2 meters per year in Louisiana and 1.8 meters per year along 

the northern Gulf of Mexico shoreline. The most serious erosion and land loss are occurring in the eastern 

part of the coastal area, east of Atchafalaya Bay (USGS 2003). Marine traffic and the potential for 

shoreline erosion would increase as a result of other projects in the project area. Marine vessels 

associated with the KMLP Project would include barges used for material delivery and construction. The 

use of these vessels would be limited to periods of active construction. The KMLP Project would add 

negligible, if any, impacts to eroding shorelines within the area. 

4.11.7 Air Quality and Noise 

Ambient air quality in the project area is acceptable. The parishes crossed by the Project are in 

attainment for all criteria pollutants. 

Construction of the KMLP Project and other projects in the area would involve the use of heavy 

equipment that produces noise, air contaminants, and dust. Use of the access roads for maintenance of the 

pipeline and appurtenances would generate occasional, minor, and short-term increases in dust similar to 
 4-108 Environmental Analysis

that generated on other unpaved roads in the area. Construction of the KMLP Project and other projects 

in the project area would cause localized declines in ambient air quality. 

During operations, the KMLP Project would result in fugitive emissions at the aboveground 

meter stations and block valves. Such emissions would be below any established regulatory thresholds 

and therefore would not require any type of permit. Other sources of air pollutants within the project area 

include new LNG terminals and ships using those terminals, refineries, etc. These sources emit PM10, 

SO2, NOx, CO, and VOCs. In turn, NOx and VOC emissions contribute to regional ozone 

concentrations. Ambient air quality could decline as a result of the operation of other projects located 

within the project area. However, a decline in ambient air quality would be minimal and the project area 

is anticipated to remain in attainment for all criteria pollutants. 

Aside from noise associated with construction, pipeline projects do not typically result in elevated 

noise levels. Construction of the KMLP Project would increase sound levels in the vicinity of Project 

activities, and the sound levels would vary during the construction period, depending on the level of 

construction activity at any given time. Additional noise produced during construction of the KMLP 

Project and other projects could create short-term annoyances to nearby residences and could disrupt 

nesting birds and other wildlife in the project area. These noise impacts would be localized and would 

attenuate quickly as the distance from the noise source increases. Operation of the KMLP Project would 

not contribute to any increases in ambient noise levels within the project area. 

4.11.8 Cumulative Impacts Conclusions 

Environmental resources within the project area have experienced adverse impacts from oil and 

gas development, agriculture, silviculture, and a number of other human activities for decades. Human 

activity has resulted in a loss of ecologically significant habitat including coastal marsh and forested 

wetlands; introduced pesticides and other contaminants into surface water bodies and sediments; altered 

the hydrologic regime through channelization of surface water bodies and heavy groundwater 

withdrawals; and introduced invasive plants into the ecosystem. To mitigate the effects of these adverse 

impacts, many environmental restoration projects have been implemented within the project area (see 

section 4.8). Such projects have provided beneficial environmental effects such as restoring the functions 

and values of thousands of acres of wetlands and stabilizing eroding shorelines. 

The KMLP Project and other projects and activities within the project area would cumulatively 

impact water resources, wetlands, biological resources, land use, air quality, and other environmental 

resources. However, we believe that impacts associated with the KMLP Project would be relatively 

minor, and we have included numerous recommendations in this draft EIS to further reduce the 

environmental impacts associated with the Project. The environmental impacts associated with the Project 

would be minimized by careful project routing, utilization of HDD techniques to avoid and minimize 

impacts to sensitive resources, and implementation of appropriate mitigation measures. Based on the 

analysis conducted in this draft EIS, the impacts of the KMLP Project, when added to the impacts of other 

projects and activities, would not be expected to alter any environmental resource beyond its ability to 

return to a near-baseline condition. 
 4-109 Environmental Analysis

4.12 AIR QUALITY AND NOISE 

4.12.1 Air Quality 

4.12.1.1 Affected Environment 

The region between Cameron Parish, Louisiana and Evangeline Parish, Louisiana is characteristic 

of subtropical regions, with short mild winters and warm humid summers. The Gulf of Mexico plays an 

important part in moderating the local weather by producing a pronounced sea breeze effect in the 

summer and tempering the effects of polar outbreaks. Tropical cyclones (hurricanes) are not unusual for 

the Project area. 

The prevailing winds are generally from offshore to onshore from the south to south-southwest, 

except during winter months when passing cold fronts bring prevailing winds from the north to northnortheast. Wind speeds average 9 miles per hour throughout the year. 

Rainfall in Saint Charles, Louisiana, located at approximately the midpoint of the pipeline route, 

averages 57.19 inches annually. June is the wettest month averaging 6.07 inches, and February is the 

driest month averaging 3.28 inches. The warmest months are July and August with an average high 

temperature of 91o

F and average low temperature of 74oF. January is the coldest month with an average 

high temperature of 61o

F and average low temperature of 41oF. 

4.12.1.2 Regulatory Requirements 

The Clean Air Act of 1970 (CAA) designates six pollutants as criteria pollutants for which the 

National Ambient Air Quality Standards (NAAQS) are promulgated. The NAAQS for sulfur dioxide 

(SO2), nitrogen dioxide (NO2), particulate matter with an aerodynamic diameter less than 10 microns 

(PM10), particulate matter with an aerodynamic diameter less than 2.5 microns (PM2.5), carbon monoxide 

(CO), ozone (O3), and lead were set to protect human health (primary standards) and human welfare 

(secondary standards). State air quality standards cannot be less stringent than the NAAQS. Louisiana 

has adopted the NAAQS, as defined in 40 CFR 50; these standards are summarized in table 4.12.1.2-1. In 

addition to the NAAQS shown in table 4.12.1.2-1, Louisiana has adopted secondary CO standards that are 

equal to the primary NAAQS for CO. Areas where the ambient air quality is better than the NAAQS are 

designated as attainment areas and areas exceeding the NAAQS are designated non-attainment. The 

parishes in which the Project would be located are in attainment for all criteria pollutants. 

The CAA, 42 USC 7401 et seq. amended in 1977 and 1990, is the basic federal statute governing 

air pollution. The provisions of the CAA that are potentially relevant to the Project include the following 

and are discussed further below: 

• New source review (NSR); 

• Prevention of significant deterioration (PSD); 

• New source performance standards (NSPS); 

• Maximum achievable control technology (MACT) standards; and 

• Title V operating permits. 

In addition, the Project would be subject to applicable Louisiana state regulations that are more 

stringent than federal regulations. 
 4-110 Environmental Analysis

TABLE 4.12.1.2-1 

National Ambient Air Quality Standards 

Pollutant Time Frame Primary Secondary 

Annuala Particulate matter less than 10 microns in 50 μg/m3 50 μg/m3 

diameter 24-hourb

 150 μg/m3 150 μg/m3

Annualc 15 μg/m3 15 μg/m3 Particulate matter less than 2.5 microns in 

diameter 24-hourd

 65 μg/m3 65 μg/m3

Annual 0.030 ppm (80 μg/m3) N/A 

24-hourb 0.014 ppm (365 μg/m3) N/A 

Sulfur dioxide 

3-hourb

 N/A 0.5 ppm (1,300 μg/m3) 

8-hourb 9 ppm (10,000 μg/m3 Carbon monoxide ) None 

1-hourb

 35 ppm (40,000 μg/m3) None 

Nitrogen dioxide Annual 0.053 ppm (100 μg/m3) 0.053 ppm 

Ozone 8-houre 0.08 ppm (157 μg/m3) 0.08 ppm 

Lead Quarterly 1.5 μg/m3 1.5 μg/m3

_______________ 

μg = Microgram(s). 

m3

 = Cubic meter(s). 

NA = Not applicable. 

ppm = Part(s) per million. 

a

 To attain this standard, the 3-year average of the weighted annual mean particulate matter less than 10 microns in diameter 

concentration at each monitor within an area must not exceed 50 μg/m3

. b

 Not to be exceeded more than once per year. 

c

 To attain this standard, the 3-year average of the weighted annual mean particulate matter less than 2.5 microns in diameter 

concentrations from single or multiple community-oriented monitors must not exceed 15 μg/m3

. d

 To attain this standard, the 3-year average of the 98th percentile of 24-hour concentrations at each population-oriented monitor 

within an area must not exceed 65 μg/m3

. e

 To attain this standard, the 3-year average of the fourth-highest daily maximum 8-hour average ozone concentrations, 

measured at each monitor within an area over each year, must not exceed 0.08 ppm. 

New Source Review 

NSR refers to the preconstruction permitting programs under Parts C and D of the CAA that must 

be satisfied before construction can begin on new major sources or major modifications to existing major 

sources. The PSD program is the NSR permitting program for sources located in attainment areas and in 

areas for which there is insufficient information to determine attainment status (unclassified areas). For 

sources located in non-attainment areas, the applicable permitting program is the Nonattainment New 

Source Review (NNSR) program. NNSR is required for major sources locating or expanding in nonattainment areas. Since the Project would be located in an attainment area, NNSR is not applicable to the 

Project. 

Prevention of Significant Deterioration 

The PSD review regulations apply to proposed new major sources or major modifications to 

existing major sources located in an attainment area. The PSD regulations (40 CFR 52.21) define a major 

source as any source type belonging to a list of named source categories that emit or have the potential to 
 4-111 Environmental Analysis

emit 100 tons per year (tpy) or more of any regulated pollutant. A major source under PSD also can be 

defined as any source not on the list of named source categories with the potential to emit such pollutants 

in amounts equal to or greater than 250 tpy. Modifications to existing major sources have lower emission 

thresholds, called significant emission increases; amounts over any of these thresholds trigger PSD 

review. 

The PSD review evaluates existing ambient air quality and the potential impacts of the proposed 

source on ambient air quality (noting in particular whether the source would contribute to any violation of 

the NAAQS), and reviews the best available control technology (BACT) in order to minimize emissions. 

The PSD regulations contain restrictions on the degree of ambient air quality deterioration that would be 

allowed. These increments for criteria pollutants are based on the PSD review classification of the area. 

Air Quality Control Regions (AQCRs) are categorized as Class I, Class II, or Class III. Class I areas are 

designated specifically as pristine natural areas or areas of natural significance. Class III designations, 

intended for heavily industrialized zones, can be made only on request and must meet all requirements 

outlined in 40 CFR 51.166. The remainder of the United States is classified as Class II. The Project 

would be located in a Class II area. The nearest Class I area is the Breton National Wildlife Refuge 

located in the Gulf of Mexico east of New Orleans, Louisiana approximately 218 miles east of the 

Project.

The Project would not include facilities or operations included on the list of named source 

categories to which the 100-tpy trigger applies. The Project would have only negligible fugitive 

emissions and would not exceed emissions of 250 tpy of any criteria pollutant. Therefore, PSD 

permitting is not applicable to the Project. 

New Source Performance Standards 

NSPS regulations, which are codified at 40 CFR 60 and incorporated by reference in the 

Louisiana Administrative Code (LAC) 33.III.3303, establish requirements for new, modified, or 

reconstructed units in specific source categories. NSPS requirements include emission limits, monitoring, 

reporting, and record keeping. There are no NSPS requirements identified as potentially applicable to the 

Project. 

Maximum Achievable Control Technology Standards 

MACT standards are intended to reduce emissions of air toxics or hazardous air pollutants 

(HAPs) through installation of control equipment rather than enforcement of risk-based emission limits. 

Applicability is triggered if potential emissions are greater than 10 tpy of any single listed HAP or greater 

than 25 tpy combined total of listed HAPs. As potential HAP emissions resulting from the Project would 

be well below these thresholds, the MACT is not applicable. The Project would not have sources of HAP 

emissions so MACT is not applicable. 

Title V Permitting 

The Title V permit program, as described in 40 CFR 70, requires sources of air emissions with 

criteria pollutant emissions that reach or exceed major source levels to obtain federal operating permits. 

These permits list all applicable air regulations and include a compliance demonstration for each 

applicable requirement. The major source threshold level in attainment areas is 100 tpy of NOx, SO2, CO, 

PM10, PM2.5, and volatile organic compound (VOC). The Project would have only negligible fugitive 

emissions and would not exceed the 100-tpy criterion pollutant threshold. Therefore, the Project would 

not require a Title V permit. 
 4-112 Environmental Analysis

State Regulations 

In addition to the Federal regulations described above, Louisiana also has state air quality 

regulations. The LDEQ manages air quality issues in Louisiana. Subject to EPA approval, these agencies 

manage the statewide air permitting, compliance, and enforcement programs. The Project would be 

authorized under a LDEQ minor source permit or exemption. 

LDEQ regulates emissions of particulate matter arising from unpaved streets, access roads, 

construction, and similar facilities through LAC33.III.1305, which requires application of water or dust 

retardant chemicals or paving of roadways. KMLP indicates that if fugitive dust becomes a problem, it 

would employ LDEQ required practices, such as water sprays, to control fugitive dust. Water sprays have 

provided sufficient control to ensure protection of air quality during construction of similar pipeline 

projects. 

4.12.1.3 General Impacts and Mitigation 

Construction Emissions 

Construction of the pipeline and access roads would generate air emissions during grading, 

trenching, and backfilling, and while driving construction vehicles along unpaved areas. Use of existing 

roads would be maximized and facilities would be constructed adjacent to existing roads. New road 

construction would be limited to driveways from existing roads to new facilities. Where possible, 

permanent roadways would be avoided by installing temporary, removable wooden mats to protect the 

underlying surface. These activities could generate dust and particulate emissions from earth moving 

activities and construction equipment engine exhaust. Construction would be expected to cause a minor 

and temporary reduction in local ambient air quality as a result of fugitive dust and combustion emissions 

generated by construction equipment. Criteria pollutant emissions during the operation of the fossilfueled construction equipment would occur from combustion products resulting from use of gasoline and 

diesel fuels, primarily NO2, CO, VOCs, PM10, small amounts of SO2 and small amounts of HAPs (e.g., 

formaldehyde, benzene, toluene, and xylene) produced by the construction equipment engines. Impacts 

from construction equipment would be temporary, would be distributed along the length of the pipeline, 

and would be expected to result in an insignificant impact on air quality. Emissions of criteria pollutants 

during construction are shown in table 4.12.1.3-1. 

TABLE 4.12.1.3-1 

Emission from Construction Activities 

NOx Emissions 

(tpy) 

CO Emissions 

(tpy) 

VOC Emissions 

(tpy) 

PM10 Emissions 

(tpy) 

SO2 Emissions 

(tpy) 

319.62 169.91 42.78 33.55 25.12 

Operations Emissions 

Heaters would be installed to raise the temperature of the transported gas at 14 interconnect sites. 

The capacities of the heaters would range from 10 MMBtu/hour to 70 MMBtu/hour. Emissions from the 

heaters were calculated based on AP-42 chapter 1.4 factors and for NOx, CO, and VOC emission factors 

more conservative than AP-42 were used. Table 4.12.1.3-2 shows calculated emissions at each 

interconnect site. These sites will be permitted as minor sources as allowed under LAC 33 III:503(B). 
 4-113 Environmental Analysis

TABLE 4.12.1.3-2 

Emission from Heaters Located at Interconnect Sites 

Site 

NOx Emissions 

(tpy) 

CO Emissions 

(tpy) 

VOC Emissions

(tpy) 

PM10 Emissions 

(tpy) 

SO2 Emissions

(tpy) 

MP 1.23 36.06 34.32 17.74 2.28 0.18 

MP 2.30 7.73 7.36 3.80 0.49 0.04 

MP 28.24 10.30 9.81 5.07 0.65 0.05 

MP 61.35 5.15 4.90 2.53 0.33 0.03 

MP 87.48 7.73 7.36 3.80 0.49 0.04 

MP 91.45 7.73 7.36 3.80 0.49 0.04 

MP 110.04 12.88 12.26 6.34 0.82 0.06 

MP111.30 7.73 7.36 3.80 0.49 0.04 

MP 112.02 10.30 9.81 5.07 0.65 0.05 

MP 116.95 5.15 4.90 2.53 0.33 0.03 

MP 122.08 10.30 9.81 5.07 0.65 0.05 

MP 132 16 10.30 9.81 5.07 0.65 0.05 

Bridgeline 7.73 7.36 3.80 0.49 0.04 

SW Loop JB 7.73 7.36 3.80 0.49 0.04 

Operation of the above ground meter stations and block valves would not result in substantial air 

emissions under normal operating conditions. Typically, only minor emissions of natural gas, called 

fugitive emissions, occur from small connections at meter station and valve sites. Because such 

emissions are very small, they are not regulated by permit or source-specific requirements. Use of the 

access roads for maintenance would generate occasional, minor, and short term increases in dust similar 

to that generated on other unpaved roads in the area. Use of these roads by maintenance and operation 

personnel would have a negligible effect on air quality. Overall, operation of the Project would not result 

in significant impacts to air quality. 

4.12.2 Noise 

Construction, modification, and operation of the Project would affect the local noise environment. 

The ambient sound level of a region is defined by the total noise generated within the specific 

environment, and is usually comprised of sounds emanating from natural and artificial sources. At any 

location, both the magnitude and frequency of environmental noise may vary considerably over the 

course of a day and throughout the week. This variation is caused in part by changing weather conditions 

and the effect of seasonal vegetative cover. 

Two measurements used by some federal agencies to relate the time-varying quality of 

environmental noise to its known effects on people are the equivalent sound level (Leq) and the day-night 

sound level (Ldn). The Leq is an A-weighted sound level containing the same sound energy as the 

instantaneous sound levels measured over a specific time period. Noise levels are perceived differently, 

depending on length of exposure and time of day. The Ldn takes into account the duration and time the 

noise is encountered. Late night and early morning (10:00 pm to 7:00 am ) noise exposures are penalized 

+10 decibels, to account for people’s greater sensitivity to sound during the nighttime hours. 
 4-114 Environmental Analysis

In 1974, the EPA published its Information on Levels of Environmental Noise Requisite to 

Protect Public Health and Welfare with an Adequate Margin of Safety. This document provides 

information for state and local governments to use in developing their own ambient noise standards. The 

EPA has indicated that an Ldn of 55 decibels on the A-weighted scale (dBA) protects the public from 

indoor and outdoor activity interference. We have adopted this criterion and use it to evaluate the 

potential noise impact from operation of the compressor facilities. 

Louisiana does not regulate noise at the state level, however individual parishes have specific 

noise control ordinances. Calcasieu Parish and Cameron Parish prohibit operating construction 

equipment within 165 feet of a Noise Sensitive Area (NSA) between sunset and sunrise Monday through 

Saturday, and 9 pm to 8 am Sundays and holidays. Operation of vehicles including offroad vehicles 

without a muffler is also prohibited. (Calcasieu Parish Ordinances 18, VII, 18-100 and Cameron Parish 

Ordinances 15, III, 15-32). Cameron Parish also prohibits operating machinery within 300 feet of a place 

of worship that causes loud sounds that will interfere with worship services (Cameron Parish Ordinances, 

15, III, 15-33). Acadia Parish prohibits operating internal combustion engines and air compressors 

without a muffler and prohibits operation of construction equipment within 500 feet of a residential area 

from 10 pm to 7 am (Acadia Parish Ordinances, 13, V, 13-82 and 13-87). 

4.12.2.1 Affected Environment 

No compressor stations would be used for the Project, therefore no existing noise level surveys 

were performed. Existing noise levels in areas near Project facilities are expected to be similar to other 

pipeline projects in rural areas of Louisiana, which typically have ambient noise levels between 40 and 60 

dBA depending on proximity to area roadways. 

4.12.2.2 Impacts and Mitigation 

Construction Noise 

Construction of the Project is expected to be typical of other pipeline projects in terms of 

schedule, equipment used, and types of activities. Sound levels would increase in the vicinity of 

construction activities, and would vary depending on the construction phase. Pipeline construction 

generally would proceed at rates ranging from several hundred feet to one mile per day. However, due to 

the assembly-line method of construction, construction activities in any one area could last from several 

weeks to six months on an intermittent basis. Construction equipment would be operated as needed 

during those periods and would be maintained to manufacturers’ specifications to minimize noise 

impacts. 

Although individuals in the immediate vicinity of the construction activities could experience 

annoyance, the impact on the noise environment at any specific location along the route would be short 

term. Night-time noise levels would normally be unaffected since most construction would take place 

only during daylight hours. The possible exceptions would be at the HDD sites. At HDD locations, 

drilling equipment may operate on a 24-hour per day basis over a short period of time. Predicted noise 

impacts on NSAs near three HDD sites indicate that sound levels would exceed 55 dBA, as discussed 

below. 

An HDD entry pit near MP 44.5 on the west side of John Brannon Road is close to three NSAs, 

which are residences built in 2006. These residences are more than 50 feet away, but are less than 165 

feet from the proposed workspace. Given the Calcasieu Parish noise requirements defined above, KMLP 

has stated that it would request an exception from the Calcasieu Parish Police Jury to allow operation of 
 4-115 Environmental Analysis

the HDD equipment near MP 44.5 for 24 hours per day, and offer the residents temporary lodging at a 

nearby hotel for the duration of the HDD activities. 

The other two sites of concern are an HDD exit pit at MP 49.6, which is located 400 feet from the 

nearest NSA, and the HDD entry pit at MP 99.8, which is located 500 feet from the nearest NSA. 

Predicted sound levels due to HDD operations at these two sites are 72 dBA and 70 dBA, respectively. 

There are no applicable noise ordinances at MP 49.6 in Calcasieu Parish because the distance from the 

HDD site to the NSA, which is a fishing camp, exceeds 165 feet. The HDD site at MP 99.8 is located in 

Acadia Parish and is within 500 feet of a residence. Acadia Parish Ordinance 13-87 prohibits operation of 

construction equipment within 500 feet of a residential area between 10 pm and 7 am. KMLP has not 

specified what mitigation measures it would take to comply with all applicable rules and regulations at 

these two HDD sites. 

To ensure that no NSAs are exposed to excessive noise during drilling operations, we 

recommend that: 

• Prior to construction, KMLP file with the Secretary for review and written approval by 

the Director of OEP a noise mitigation and compliance plan for HDD operations at MP 

44.5, MP 49.6, and MP 99.8. This plan should identify mitigation measures such as 

noise barriers, temporary housing, etc. to be implemented prior to the start of drilling 

operations to reduce noise from HDD activities to below 55 dBA at these NSAs. 

Operational Noise 

During operation of the Project, the potential noise impacts would be limited to the vicinity of the 

new valve and metering stations. Principal noise sources would include gas flow through valves and 

metering equipment. Such gas flow noise is typically not noticeable more than a short distance from the 

equipment. Underground sections of the pipeline are not a substantial source of noise. 

If the recommended mitigation at MP 44.5, MP 49.6, and MP 99.8 occurs, we believe that 

project-related noise impacts at the nearest NSAs would not be significant. 
 4-116 Environmental Analysis

4.13 RELIABILITY AND SAFETY 

The transportation of natural gas by pipeline involves some risk to the public in the event of an 

accident and subsequent release of gas. The greatest hazard is a fire or explosion following a major 

pipeline rupture. 

Methane, the primary component of natural gas, is colorless, odorless, and tasteless. It is nontoxic but, possessing a slight inhalation hazard, is classified as a simple asphyxiate. If breathed in high 

concentration, oxygen deficiency can result in serious injury or death. 

Methane has an ignition temperature of 1,000°F and is flammable at concentrations between 

5.0 percent and 15.0 percent in air. Unconfined mixtures of methane in air are not explosive. However, a 

flammable concentration within an enclosed space in the presence of an ignition source can explode. 

Having a specific gravity of 0.55, it is buoyant at atmospheric temperatures and disperses rapidly in air. 

In 2005, Hurricanes Rita and Katrina dramatically illustrated the susceptibility of southern 

Louisiana to the devastation that can be caused by major storms. Much of the aboveground utility 

infrastructure and offshore oil and gas facilities were seriously affected. Most of the onshore damage was 

caused by high winds, with some storm surge damage near the coast. The offshore damage was primarily 

a result of high winds, waves, and currents. Heavy rainfall also caused localized inshore flooding. The 

Project would be located onshore, eliminating the storm-related hazards found in the Gulf of Mexico. 

The pipeline would be buried at depths equal to or exceeding DOT requirements, eliminating concerns 

from wind or surface flooding. In areas where the soils are, or could become, saturated, including Sabine 

Lake, the pipeline would be concrete coated to eliminate positive buoyancy. High rainfall rates 

associated with hurricanes would increase the volume and velocity of stream flows, elevating the risk of 

erosion and scour and the resulting exposure of the pipeline. For this reason, the Project would be 

installed by HDD under major waterbodies, providing at least 20 feet of cover between the pipeline and 

the bottom of the channel; at least 5 feet of cover will be provided at minor waterbodies. Sabine Lake 

does not have the water depth or fetch to generate the size of waves that were observed in the Gulf of 

Mexico, but some increased wave action and movement of bottom sediments would occur during storms. 

The depth of cover over the Project would be increased to at least 4 feet in Sabine Lake as added 

protection against exposure. Aboveground facilities would be limited to meter stations, each of which 

could be isolated from the pipeline if damaged, eliminating the potential for substantial releases of natural 

gas. These aboveground facilities, as well as the pipeline, would be continuously monitored and could be 

shut down remotely in the event of an emergency. It is also likely that the Sabine Pass LNG Terminal 

would be shut down, or at least it would no longer receive ships, upon detection of an approaching storm, 

substantially reducing the amount of gas that would be delivered by the pipeline during the storm. 

Finally, the pipeline right-of-way would be inspected immediately following the passage of a storm to 

ensure the pipeline had not been exposed or otherwise damaged. 

4.13.1 Safety Standards 

The DOT is mandated to provide pipeline safety under Title 49, USC Chapter 601. The Pipeline 

and Hazardous Materials Safety Administration’s (PHMSA’s), Office of Pipeline Safety (OPS), 

administers the national regulatory program to ensure the safe transportation of natural gas and other 

hazardous materials by pipeline. It develops safety regulations and other approaches to risk management 

that ensure safety in the design, construction, testing, operation, maintenance, and emergency response of 

pipeline facilities. Many of the regulations are written as performance standards that set the level of 

safety to be attained and allow the pipeline operator to use various technologies to achieve safety. 

PHMSA ensures that people and the environment are protected from the risk of pipeline incidents. This 
 4-117 Environmental Analysis

work is shared with state agency partners and others at the federal, state, and local level. Section 5(a) of 

the Natural Gas Pipeline Safety Act (NGPSA) provides for a state agency to assume all aspects of the 

safety program for intrastate facilities by adopting and enforcing the federal standards, while Section 5(b) 

permits a state agency that does not qualify under Section 5(a) to perform certain inspection and 

monitoring functions. A state may also act as DOT’s agent to inspect interstate facilities within its 

boundaries; however, the DOT is responsible for enforcement action. The majority of the states have 

either 5(a) certifications or 5(b) agreements, while nine states act as interstate agents. The DOT pipeline 

standards are published in Parts 190-199 of Title 49 of the CFR. Part 192 of 49 CFR specifically 

addresses natural gas pipeline safety issues. 

Under a Memorandum of Understanding on Natural Gas Transportation Facilities (Memorandum) 

dated January 15, 1993 between DOT and the FERC, DOT has the exclusive authority to promulgate 

federal safety standards used in the transportation of natural gas. Section 157.14(a)(9)(vi) of the FERC’s 

regulations require that an Applicant certify that it will design, install, inspect, test, construct, operate, 

replace, and maintain the facility for which a certificate is requested in accordance with federal safety 

standards and plans for maintenance and inspection, or shall certify that it has been granted a waiver of 

the requirements of the safety standards by DOT in accordance with Section 3(e) of the NGPSA. The 

FERC accepts this certification and does not impose additional safety standards other than the DOT 

standards. If the Commission becomes aware of an existing or potential safety problem, there is a 

provision in the Memorandum to promptly alert DOT. The Memorandum also provides for the referral of 

complaints and inquiries made by state and local governments and the general public involving safety 

matters related to pipelines under the Commission’s jurisdiction. 

The FERC also acts as a member of DOT’s Technical Pipeline Safety Standards Committee, 

which determines if proposed safety regulations are reasonable, feasible, and practicable. 

The pipeline and aboveground facilities associated with the Project must be designed, 

constructed, operated, and maintained in accordance with the DOT Minimum Federal Safety Standards in 

49 CFR Part 192. These regulations are intended to ensure adequate protection for the public and to 

prevent natural gas facility accidents and failures. Part 192 specifies material selection and qualification, 

minimum design requirements, and protection from internal, external, and atmospheric corrosion. 

Part 192 also defines area classifications, based on population density in the vicinity of the 

pipeline, and specifies more rigorous safety requirements for populated areas. The class location unit is 

an area that extends 220 yards on either side of the centerline of any continuous 1-mile length of pipeline. 

The four area classifications are defined as follows: 

• Class 1 locations include 10 or fewer buildings intended for human occupancy; 

• Class 2 locations include more than 10 but less than 46 buildings intended for human 

occupancy; 

• Class 3 locations include 46 or more buildings intended for human occupancy or where the 

pipeline lies within 100 yards of any building, or small well-defined outside areas occupied 

by 20 or more people on at least 5 days in a week for 10 weeks in any 12-month period; and 

• Class 4 locations where buildings with four or more stories aboveground are prevalent. 

Class locations representing more populated areas require higher safety factors in pipeline design, 

testing, and operation. Pipelines constructed on land in Class 1 locations must be installed with a 
 4-118 Environmental Analysis

minimum depth of cover of 30 inches in normal soil and 18 inches in consolidated rock. Class 2, 3, and 4 

locations, as well as drainage ditches of public roads and railroad crossings, require a minimum cover of 

36 inches in normal soil and 24 inches in consolidated rock. All pipelines installed in navigable rivers, 

streams, and harbors must have a minimum cover of 48 inches in soil or 24 inches in consolidated rock. 

Class locations also specify the maximum distance to a sectionalizing block valve (e.g., 

10.0 miles in Class 1, 7.5 miles in Class 2, 4.0 miles in Class 3, and 2.5 miles in Class 4). Pipe wall 

thickness and pipeline design pressures, hydrostatic test pressures, maximum allowable operating 

pressure (MAOP), inspection and testing of welds, and frequency of pipeline patrols and leak surveys 

must also conform to higher standards in more populated areas. 

The Project would be designed to account for planned population development. Table 4.13.1-1 

shows the area classifications for the Project. 

TABLE 4.13.1-1 

Area Classifications 

Parish MP Start MP End Area Classifications Reasons for Class 2 or 3 

Leg 1 

Cameron 0.00 1.5 3 Commercial/Industrial 

Cameron 1.5 24.6 1 

Calcasieu 24.6 47.6 1 

Calcasieu 47.6 48.9 2 Houses 

Calcasieu 48.9 50.5 1 

Calcasieu 50.5 51.3 3 Marina (HDD) 

Calcasieu 51.3 51.8 1 

Calcasieu 51.8 52.4 3 Industrial (HDD) 

Calcasieu 52.4 74.9 1 

Jefferson Davis 74.9 99.4 1 

Acadia 99.4 110.0 1 

Acadia 110.0 112.4 2 Houses/Industrial 

Acadia 112.4 112.5 1 

Evangeline 112.5 121.4 1 

Evangeline 121.4 123.3 2 Houses 

Evangeline 123.3 128.3 1 

Evangeline 128.3 129.9 2 Houses 

Evangeline 129.9 132.1 1 

Leg 2 

Cameron 0.00 1.2 3 Commercial/Industrial 

FGT Lateral 

Acadia 0.00 2.3 1 

If a subsequent increase in population density adjacent to the right-of-way indicates a change in 

Class location for a segment of pipeline, Sections 192.609 and 192.611 require that the pipeline operator 

confirm or revise the MAOP commensurate with the current Class location. If physical revisions are 

required, these revisions may be accomplished by reducing operating pressure, or replacing the segment 

with pipe of sufficient grade and wall thickness to comply with the DOT code requirements for the new 

Class location. 
 4-119 Environmental Analysis

In 2002, Congress passed an act to strengthen the Nation’s pipeline safety laws. The Pipeline 

Safety Improvement Act of 2002 (HR 3609) was passed by Congress on November 15, 2002, and signed 

into law by the President in December 2002. Gas transmission operators must develop and follow a 

written integrity management program that contains all the elements described in Section 192.911 and 

addresses the risks on each covered transmission pipeline segment. Specifically, the law establishes an 

integrity management program, which applies to all high-consequence areas (HCAs). DOT (68 FR 

69778, 69 FR 18228, and 69 FR 29903) defines HCAs as they relate to the different class zones, potential 

impact circles, or areas containing an identified site as defined in Section 192.903 of the DOT regulations. 

OPS published a series of rules from August 6, 2002 to May 26, 2004 (69 FR 29903) that define 

HCAs where a gas pipeline accident would do considerable harm to people and their property and 

requires an integrity management program to minimize the potential for an accident. This definition 

satisfies, in part, the Congressional mandate in 49 USC 60109 for OPS to prescribe standards that 

establish criteria for identifying each gas pipeline facility in a high-density population area. 

The HCAs may be defined in one of two ways. In the first method an HCA includes: 

• Current Class 3 and 4 locations; 

• Any area in Class 1 or 2 where the potential impact radius1

 is greater than 660 feet and there 

are 20 or more buildings intended for human occupancy within the potential impact circle;2

 or 

• Any area in Class 1 or 2 where the potential impact circle includes an identified site.3

In the second method, an HCA includes any area within a potential impact circle that contains: 

• 20 or more buildings intended for human occupancy ; or 

• An identified site. 

Once a pipeline operator has determined the HCAs on its pipeline, it must apply the elements of 

its integrity management program to those segments of the pipeline within HCAs. The DOT regulations 

specify the requirements for the integrity management plan at Section 192.911. The HCAs have been 

determined based on the relationship of the pipeline centerline to other nearby structures and identified 

sites. Of the approximately 135.5 miles of pipeline route, KMLP has identified approximately 0.8 mile 

that would be classified as an HCA. The pipeline integrity management rule for HCAs requires 

inspection of the entire pipeline for HCAs every 7 years. 

Part 192 prescribes the minimum standards for operating and maintaining pipeline facilities, 

including the requirement to establish a written plan governing these activities. Under 192.615, each 

 

1

 The potential impact is calculated as the product of 0.69 and the square root of the MAOP of the pipeline in psi 

multiplied by the pipeline diameter in inches. Based on an MAOP of 1,440 PSIG and a nominal diameter of 

42 inches, the calculated potential impact radius for Leg 1 of the Project would be about 1,100 feet. The 

potential impact radius for Leg 2 and the 24-inch FGT Lateral would be 943 feet and 628 feet, respectively. 

2

 The potential impact circle is a circle of radius equal to the potential impact radius. 

3

 An identified site is an outside area or open structure that is occupied by 20 or more persons on at least 50 days 

in any 12-month period; a building that is occupied by 20 or more persons on at least 5 days a week for any 10 

weeks in any 12-month period; or a facility that is occupied by persons who are confined, are of impaired 

mobility, or would be difficult to evacuate. 
 4-120 Environmental Analysis

pipeline operator must also establish an emergency plan that includes procedures to minimize the hazards 

in a natural gas pipeline emergency. Key elements of the plan include procedures for: 

• Receiving, identifying, and classifying emergency events, gas leakage, fires, explosions, and 

natural disasters; 

• Establishing and maintaining communications with local fire, police, and public officials, and 

coordinating emergency response; 

• Emergency shutdown of system and safe restoration of service; 

• Making personnel, equipment, tools, and materials available at the scene of an emergency; 

• Protecting people first and then property, and making them safe from actual or potential 

hazards; and 

• Safely restoring any service outage. 

Each operator must establish and maintain liaison with appropriate fire, police, and public 

officials to identify the resources and responsibilities of each organization that may respond to a gas 

pipeline emergency, and coordinate mutual assistance in responding to emergencies. The operator must 

also establish a continuing education program to enable customers, the public, government officials, and 

those engaged in excavation activities to recognize a gas pipeline emergency and report it to appropriate 

public officials. KMLP would provide the appropriate training to local emergency service personnel 

before the pipeline is placed in service. No additional specialized local fire protection equipment would 

be required to handle pipeline emergencies. KMLP would develop an Emergency Plan for the Project 

that incorporates these procedures as required by Part 192. 

4.13.2 Pipeline Accident Data 

Since February 9, 1970, 49 CFR Part 191 has required all operators of transmission and gathering 

systems to notify DOT of any reportable incident and to submit a report on form F7100.2 within 20 days. 

Reportable incidents are defined as any leaks that: 

• Caused a death or personal injury requiring hospitalization; 

• Required taking any segment of transmission line out of service; 

• Resulted in gas ignition; 

• Caused estimated damage to the property of the operator, or others, or both, of a total of 

$5,000 or more; 

• Required immediate repair on a transmission line; 

• Occurred while testing with gas or another medium; or 

• In the judgment of the operator was significant, even though it did not meet the above 

criteria. 

Since 1984, DOT has required operators to report within 20 days incidents that involve property 

damage of more than $50,000, injury requiring in-patient hospitalization, death, release of gas, or those 

considered significant by the operator. Table 4.13.2-1 presents a summary of incident data for the period 
 4-121 Environmental Analysis

TABLE 4.13.2-1 

Natural Gas Service Incidents by Cause 

Incidents per 1,000 miles of Pipeline (percentage) 

Cause 1970-1984 1986-2005 

Outside force 0.70 (53.8) 0.10 (38.5) 

Corrosion 0.22 (16.9) 0.06 (23.1) 

Construction or material defect 0.27 (20.8) 0.04 (15.4) 

Other 0.11 ( 8.5) 0.06 (23.1)

Total 1.30 (100) 0.26 (100) 

1970 to 1984, as well as more recent incident data for 1986 through 2005, recognizing the difference in 

reporting requirements. The 14.5-year period from 1970 through June 1984, which provides a larger 

universe of data and more basic report information than subsequent years, has been subject to detailed 

analysis, as discussed in the following sections (Jones et al. 1986). 

During the 14.5-year period, 5,862 service incidents were reported over the more than 300,000 

total miles of natural gas transmission and gathering systems nationwide. Service incidents, defined as 

failures that occur during pipeline operation, have remained fairly constant over this period with no clear 

upward or downward trend in annual totals. In addition, 2,013 test failures were reported. Correction of 

test failures removed defects from the pipeline before operation. 

Additional insight into the nature of service incidents may be found by examining the primary 

factors that caused the failures. Table 4.13.2-1 provides a percentage distribution of the causal factors as 

well as the annual frequency of each factor per 1,000 miles of pipeline in service. 

The dominant incident cause is outside forces, constituting 53.8 percent of all service incidents. 

Outside forces incidents result from the encroachment of mechanical equipment such as bulldozers and 

backhoes; earth movements due to soil settlement, washouts, or geologic hazards; weather effects such as 

winds, storms, and thermal strains; and willful damage. Table 4.13.2-2 shows that human error in 

equipment usage was responsible for approximately 75 percent of outside forces incidents. Since April 

1982, operators have been required to participate in "One Call" public utility programs in populated areas 

to minimize unauthorized excavation activities in the vicinity of pipelines. The "One Call" program is a 

service used by public utilities and some private sector companies (e.g., oil pipelines and cable television) 

to provide preconstruction information to contractors or other maintenance workers on the underground 

location of pipes, cables, and culverts. The 1986 through 2005 data show that the portion of incidents 

caused by outside forces has decreased to 38.5 percent. 

The pipelines included in the data set in table 4.13.2-1 vary widely in terms of age, pipe diameter, 

and level of corrosion control. Each variable influences the incident frequency that may be expected for a 

specific segment of pipeline. 

The frequency of service incidents is strongly dependent on pipeline age. While pipelines 

installed since 1950 exhibit a fairly constant level of service incident frequency, pipelines installed before 

that time have a significantly higher rate, partially due to corrosion. Older pipelines have a higher 

frequency of corrosion incidents, since corrosion is a time-dependent process. Further, new pipe 

generally uses more advanced coatings and cathodic protection to reduce corrosion potential. 
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TABLE 4.13.2-2 

Outside Forces Incidents by Cause (1970-1984)

Cause Percent 

Equipment operated by outside party 67.1 

Equipment operated by or for operator 7.3 

Earth movement 13.3 

Weather 10.8 

Other 1.5 

Older pipelines have a higher frequency of outside forces incidents partly because their location 

may be less well known and less well marked than newer lines. In addition, the older pipelines contain a 

disproportionate number of smaller diameter pipelines, which have a greater rate of outside forces 

incidents. Small diameter pipelines are more easily crushed or broken by mechanical equipment or earth 

movements. 

Table 4.13.2-3 clearly demonstrates the effectiveness of corrosion control in reducing the 

incidence of failures caused by external corrosion. The use of both an external protective coating and a 

cathodic protection system, required on all pipelines installed after July 1971, significantly reduces the 

rate of failure compared to unprotected or partially protected pipe. The data show that bare, cathodically 

protected pipe actually has a higher corrosion rate than unprotected pipe. This anomaly reflects the 

retrofitting of cathodic protection to actively corroding spots on pipes. 

TABLE 4.13.2-3 

External Corrosion by Level of Control (1970-1984) 

Corrosion Control Incidents per 1,000 miles per Year 

None-bare pipe 0.42 

Cathodic protection only 0.97 

Coated only 0.40 

Coated and cathodic protection 0.11 

4.13.3 Impact on Public Safety 

The service incident data summarized in table 4.13.2-1 include pipeline failures of all magnitudes 

with widely varying consequences. Approximately two-thirds of the incidents were classified as leaks, 

and the remaining third classified as ruptures, implying a more serious failure. 

Table 4.13.3-1 presents the average annual fatalities that occurred on natural gas transmission and 

gathering lines from 1970 to 2005. Fatalities between 1970 and June 1984 have been separated into 

employees and nonemployees, to better identify a fatality rate experienced by the general public. Of the 

total 5.0 nationwide average, fatalities among the public averaged 2.6 per year over this period. The 

simplified reporting requirements in effect after June 1984 do not differentiate between employees and 

nonemployees. However, the data show that the total annual average for the period 1984 through 2005 
 4-123 Environmental Analysis

TABLE 4.13.3-1 

Annual Average Fatalities - Natural Gas Transmission and Gathering Systemsa,b

Year Employees Nonemployees Total 

1970-June 1984 2.4 2.6 5.0 

1984-2005c - - 3.6 

1984-2005c - - 2.8d

_______________ 

a

 1970 through June 1984 – Jones et al,1986. 

b

 Pipeline and Hazardous Materials Administration, 2005. 

c

 Employee/nonemployee breakdown not available after June 1984. 

d

 Without 18 offshore fatalities occurring in 1989 - 11 fatalities resulted from a fishing vessel striking an offshore pipeline and 7 

fatalities resulted from explosion on an offshore production platform.

decreased to 3.6 fatalities per year. Subtracting two major offshore incidents in 1989, which do not 

reflect the risk to the onshore public, yields a total annual rate of 2.8 fatalities per year for this period. 

The nationwide totals of accidental fatalities from various manmade and natural hazards are listed 

in table 4.13.3-2 in order to provide a relative measure of the industry-wide safety of natural gas 

pipelines. Direct comparisons between accident categories should be made cautiously, however, because 

individual exposures to hazards are not uniform among all categories. Nevertheless, the average 2.6 

public fatalities per year is relatively small considering the more than 300,000 miles of transmission and 

gathering lines in service nationwide. Furthermore, the fatality rate is approximately two orders of 

magnitude (100 times) lower than the fatalities from natural hazards such as lightning, tornados, floods, 

earthquakes, etc. 

TABLE 4.13.3-2 

Nationwide Accidental Deathsa

Type of Accident Fatalities 

All accidents 90,523 

Motor vehicles 43,649 

Falls 14,985 

Drowning 3,488 

Poisoning 9,510 

Fires and burns 3,791 

Suffocation by ingested object 3,206 

Tornado, flood, earthquake, etc. (1984-93 average) 181 

All liquid and gas pipelines (1978-87 average)b 27 

Gas transmission and gathering lines, nonemployees only (1970-84 average)c 2.6 

_______________ 

a

 All data, unless otherwise noted, reflects 1996 statistics from the U.S. Department of Commerce, Bureau of the Census, 

"Statistical Abstract of the United States 118th Edition." 

b

 U.S. Department of Transportation, "Annual Report on Pipeline Safety - Calendar Year 1987." 

c

 Jones et al 1986. 

The available data show that natural gas pipelines continue to be a safe, reliable means of energy 

transportation. Based on approximately 301,000 miles in service, the rate of public fatalities for the 
 4-124 Environmental Analysis

nationwide mix of transmission and gathering lines in service is 0.01 per year per 1,000 miles of pipeline. 

Using this rate, the KMLP Project might result in a public fatality every 738-plus years. This would 

represent a slight increase in risk to the nearby public.