3-1 

3.0 ENVIRONMENTAL ANALYSIS 

The environmental consequences of constructing and operating the proposed Project would 

vary in duration and significance. Four levels of impact duration were considered: temporary, shortterm, long-term, and permanent. Temporary impacts generally occur during construction, with the 

resources returning to pre-construction conditions almost immediately afterward. Short-term impacts 

would continue for approximately three years following construction. Impacts were considered long-term 

if the 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 pre-construction 

conditions during the life of the proposed Project, such as with construction of a compressor station. 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, construction and operational impacts, and 

propose mitigation measures for each resource. We evaluated these measures as well as proposed 

mitigation measures to determine whether or not additional steps would be necessary to further reduce 

impacts. Additional measures that we have identified appear as bulleted, boldface paragraphs in the text 

of the EIS. We are recommending that these measures be included as specific conditions to the 

Certificate that may be issued to Gulf South for the proposed Project. 

Conclusions in this EIS are based on our analysis of environmental impacts and the following 

assumptions: 

• Gulf South would comply with all applicable laws and regulations. 

• The proposed facilities would be constructed as described in Section 2.0 of this EIS. 

• Gulf South would implement the mitigation measures identified in its application and 

supplemental filings to the FERC. 

3.1 GEOLOGY 

3.1.1 Geological Setting 

All proposed Project facilities, with the exception of the Delhi Compressor Station and the 

CenterPoint M/R Station, are located in the East Gulf Coastal Plain. The East Gulf Coastal Plain consists 

of flat to rolling topography broken by streams and river bottoms. The Delhi Compressor Station and 

CenterPoint M/R Station are located in the West Gulf Coastal Plain. The West Gulf Coastal Plain 

consists of low, rolling, slightly hilly terrain. The specific geologic formations traversed by the proposed 

Project are presented in Table 3.1.1-1. 

The surface of Louisiana on which the Delhi Compressor Station and CenterPoint M/R Station 

are located is underlain by geologically young sedimentary deposits in or near rivers and deltas, including 

Holocene sediment deposited by the Red and Mississippi Rivers, which is present at the compressor 

station and meter station sites. Most surface exposures in Louisiana consist of Quaternary sediment. 

Holocene sediment deposited by the Mississippi, Ouachita, and Red Rivers, as well as other rivers and 

coastal marsh deposits, make up approximately 55 percent of the surface of Louisiana. The proposed 

pipeline would cross approximately 10.3 miles of Pliocene fluvial channel and marine deposits consisting 

of sands, clays, and silt loams; 70.8 miles of Miocene alluvial channel and alluvial plain deposits 

consisting of sandy silt, silt, clay, limestone, and dolomitic limestone; and 29.7 miles of Eocene marine 

and deltaic deposits consisting of clay, sand, sandstone, and shale (Table 3.1.1-1). 
 3-2 

Within Mississippi, the proposed Project would lie within two sections of the East Gulf 

Coastal Plain Physiographic province: the Central Blacklands and Pine Hills Physiographic Districts. 

The Citronelle, Catahoula, Vicksburg Group-Forest Hill, Jackson, and Claiborne Formations (Mississippi 

Mineral Resources Institute [MMRI], 1976) underlie this area. Some rolling hills and other areas of 

ridges and valleys characterize the Central Blacklands Physiographic District with surface sediments 

consisting of sandy and silty loams. The Pine Hills District is characterized by rolling hills and steepsided ridges and valleys with surface sediments consisting of clays and sands (Stewart, 2003). 

Within Alabama, the proposed Project is located in the East Gulf Coastal Plain, south of the 

Fall Line that curves from the northwestern corner of Alabama to the Georgia border in east-central 

Alabama. The Fall Line is an important physical feature and separates the Coastal Plain from other 

regions to the north. Streams north of the Fall Line are generally swift with rocky bottoms, while streams 

south of this feature tend to be sluggish with muddy or sandy bottoms. The proposed Project extends into 

Alabama from Mississippi at the physiographic division known as the Timber Belt, which extends from 

the Gulf of Mexico northward for approximately 150 miles and is on the outer belt of the Coastal Plain. 

The area of Alabama where the proposed Project would cross, beginning at MP 104.4 and ending at 

MP 110.8, is underlain by the Gosport Sand and Lisbon Formation, Tallahatta Formation, Hatchetigbee 

Formation, alluvial, coastal, and low terrace deposits, and Tuscahoma sands geologic formations as 

shown on the Geologic Map of Alabama (Geological Survey of Alabama [GSA], 2006). 

The elevation along the proposed Project undulates throughout the proposed Project area from 

eastern Simpson County, Mississippi, to Choctaw County, Alabama. The topography consists of rolling 

hills with slight to moderate slopes to the west, level to nearly level floodplains, level to gently sloping 

stream terraces, and gently sloping to steep uplands on the eastern portion of the proposed Project. 

However, slopes along the proposed Project range from 1 percent to as much as 30 percent. The 

topography along the proposed Project is mainly rolling hills with an area from approximately MP 85.0 to 

MP 90.0 exhibiting the most level terrain. The elevations along the proposed Project in Mississippi and 

Alabama range from approximately 200 to 400 feet above mean sea level (msl), whereas the elevation 

throughout Richland Parish, Louisiana, where the proposed Delhi Compressor Station and CenterPoint 

M/R Station would be located, ranges from 60 to 70 feet msl. 

Some areas of moderately rugged topography would be encountered along the proposed 

Project route. As described in Section 2.3.2.5, Gulf South would use special two-tone construction 

techniques in these areas as listed in Table 2.3.2.5-1 to effectively work along these steeper slopes and all 

areas disturbed during pipeline construction would be finish-graded and restored as closely as possible to 

pre-construction contours during cleanup and restoration. 

The U.S. Department of Agriculture (USDA), Natural Resources Conservation Service 

(NRCS) defines shallow bedrock as bedrock occurring in the upper 60 inches of the soil profile. A 

review of soil survey databases for the Project area indicate that shallow bedrock would not likely be 

encountered along the proposed pipeline route. Additionally, Gulf South indicated that based on review 

of topographic maps, soil conditions, and geologic formations crossed, it would be unlikely that bedrock 

would be encountered within 5 to 7 feet below ground surface. Since no shallow bedrock has been 

identified and the shallow bedrock that could be encountered would most likely consist of loosely 

consolidated, weathered sandstone and shale that should be easily workable with standard construction 

equipment and techniques, it is unlikely that bedrock blasting would be needed for the proposed Project. 

Should blasting become necessary, Gulf South would notify the FERC before blasting and would conduct 

all blasting and disposal of bedrock material in accordance with Gulf South's plans and Procedures and in 

compliance with applicable federal, state, and local laws, permits, and authorizations. 
 3-3 

TABLE 3.1.1-1 

Geologic Formations Underlying the Proposed Southeast Expansion Project 

Cumulative 

Length 

Crossed 

(miles) Geologic Formation Description 

53.8 Catahoula-Alluvial Channel Sandy silt, silt, and clay, interbedded with fine-grained sandstone layers, mica, and smectite

and clay commonly display blocky to conchoidal rock fracture. 

0.7 Citronelle-Fluvial Channel Yellow and red sands and clays, locally gray weathering, with much gravel near landward m

17.0 

Vicksburg/ Chickasawhay-Alluvial Plain 

Highly porous limestone and dolomitic limestone, interbedded with porous to compact dolomlimestone. 

9.6 

Forest Hill/Red Bluff Clay Shallow Marine/Marine 

Soils are mainly deep, highly weathered silt loams with clays at varying depth. Broad ridges a loess cap, with occasional fragipans, sandstones, and dolomites occupying most ridges an

side slopes, while lower side slopes, especially near major streams, are in upper Gasconade 

materials. 

7.9 Jackson Group-Marine Composed of calcitic clay and less prominent sand and marl beds, divided into Yazoo clay m

and Moodys calcitic marl member below. 

10.5 Cockfield-Deltaic Massively bedded, very coarse to very fine grained, moderately sorted quartz sand. Colors 

moderate reddish-brown to white. 

4.4 Cook Mountain-Marine 

Clay and sandstone; slightly silty and lignitic, minor glauconite, brown to brownish-gray, weabrownish-gray to yellowish-gray; very fine grained, calcareous, glauconitic, gray to yellowishmarine fossils. 

0.5 Kosciusko-Marine Heterogeneous highly lenticular non-marine sections of sand and shale are dominant facies

cross-bedded sands colored red, brown, yellow, purple, pink, violet, gray, and white. 

6.4 

Kosciusko Cuestas-Marine 

Heterogeneous highly lenticular non-marine sections of sand and shale are dominant faciescross-bedded sands colored red, brown, yellow, purple, pink, violet, gray, and white. 

** Alluvium-Alluvial Plain Gray to brownish silt, silty clay, some very fine sand, reddish-brown along the Red River. S

on past and present course of major streams. 

_______________ ** Geologic Formation at the Delhi Compressor Station Source: United States Geological Survey (USGS), 2006c 
 3-4 

Gulf South would use the minimum charge explosives necessary to excavate the trench and place mats 

over the blast area to keep rock from becoming airborne. Additionally, Gulf South would implement all 

appropriate safety precautions to prevent injury to workers, livestock, and property, including safeguards 

such as flags, barricades, and warning signals. 

The primary effect of pipeline construction on geological resources would consist of 

disturbances to topographical features found along the construction right-of-way. These disturbances to 

topography would be most apparent in relatively steep areas, such as the areas discussed above in areas 

where Gulf South plans to use two-tone construction. However, since all topographic features disturbed 

by pipeline construction would be finish-graded and restored as closely as possible to pre-construction 

contours during cleanup and restoration, and aboveground facilities have been sited in areas without any 

significant topographic relief, we believe that construction and operation of the proposed Project would 

not result in significant alterations or negative impacts to the topography or overall geologic setting 

occurring within the proposed Project area. 

3.1.2 Mineral Resources 

Subsurface mineral resources in the proposed Project area include oil, gas, coal, clay, lime, 

sand, and gravel. These resources are discussed below. 

In Louisiana, Mississippi, and Alabama, petroleum and natural gas deposits are the main 

mineral resources. Petroleum resources are most common in the southern halves of Mississippi and 

Alabama. Louisiana ranks as one of the top energy producers in the nation. Gulf South consulted the 

Louisiana Department of Natural Resources (LDNR) Strategic Natural Resources Information System 

(SONRIS) (LDNR, 2006) database to identify active oil and gas areas along the proposed pipeline route. 

The proposed Delhi Compressor Station and CenterPoint M/R Station in Richland Parish are located near 

existing oil and gas fields; however, the wells within these fields are greater than 0.25 mile from these 

proposed facilities. 

Gulf South used the Mississippi Automated Resource Information System Technical Center 

database to identify oil and gas resources in the Project area. Gulf South determined that none of the 

proposed Project's aboveground facilities are located within 0.25 mile of active, producing gas/condensate 

wells or producing oil wells in Mississippi. However, Gulf South did determine that the pipeline occurs 

within 0.25 mile of active producing gas/condensate wells and producing oil wells in Mississippi. Gulf 

South determined that the proposed pipeline crosses within 0.25 mile of three active producing natural gas 

wells, 14 producing oil wells, seven enhanced oil recovery injection wells, four saltwater disposal wells, 

and one sand and gravel mining operation (see Table 3.1.2-1). Of the active wells in Mississippi, six 

occur at least 1,000 feet from the proposed pipeline centerline, six occur 1,000 to 750 feet from the 

proposed pipeline centerline, six occur 750 to 500 feet from the proposed pipeline centerline, seven are 

500 to 250 feet from the proposed pipeline centerline, two are 250 to 100 feet from the proposed pipeline 

centerline, and one is within 100 feet of the proposed pipeline centerline. The sand and gravel operation 

occurs approximately 240 feet from the proposed pipeline centerline. The one producing oil well that is 

within 100 feet would actually be 80 feet from the proposed Project near MP 69.6. Gulf South has 

indicated that they would work with the owner of this well to avoid disturbance to well operations. 

Gulf South found no sources of information to show any active, producing gas/condensate 

wells or producing oil wells within the area of the Project in Alabama. In addition, no areas with active 

wells were observed in Alabama during field surveys conducted by Gulf South. 

Because there would be little to no overlap regarding the depth of oil and gas operations and 

construction activity, affected oil and gas well operators would be compensated, if necessary, by new 
 3-5 

drilling operations that would be conducted outside of the permanent right-of-way, and Gulf South would 

prohibit future oil and gas exploration within the permanent right-of-way; we believe that construction 

and operation of the proposed Project would not impact existing and/or future mineral sites and oil and 

gas field development. 

Louisiana's leading non-petroleum minerals are salt and sulfur, lime, gypsum, crushed stone, 

and construction sand (Louisiana Geological Survey [LGS], 2006); however, Richland Parish where the 

proposed Delhi Compressor Station and CenterPoint M/R Station are located does not significantly 

contribute to these resources. The principal mineral resources for Mississippi include clay, lime, sand, 

gravel, and lignite. Lignite deposits occur at depths greater than 250 feet and are not economically 

recoverable at the present time in the area of the proposed Project. Currently, there are no underground or 

lignite surface mines in the area of the aboveground facilities and pipeline for the proposed Project 

(USGS, 1998). 

In Mississippi, agricultural lime, bentonite, common clay, and crushed stone are surface mined 

in Smith County; crushed stone, common clay, and construction sand and gravel are mined in Jasper 

County; and sulfur (a by-product of natural gas production) and construction sand and gravel are mined in 

Clarke County. Eleven mineral fields with multiple active leases were identified within 0.25 mile of the 

proposed Project in Mississippi. However, surface mining operations within the state are generally on a 

small scale (USGS, 2004). 

Gulf South has determined that five surface mining operations are located within 0.25 mile of 

the proposed Project's centerline of the pipeline. Of the five, one is not active based on aerial 

photography in September 2006. Active mineral leases were identified by reviewing Oil and Gas 

Production maps of Mississippi and Alabama State Oil and Gas Board (ASOGB) maps, and by 

performing field survey observations (MMRI, 2005; ASOGB, 2005). 

The four remaining mining operations are owned and operated by the same company and are 

noted to be extensions of one original sand and gravel pit. The northernmost extent of that surface mine 

occurs over 200 feet south of the centerline of the pipeline, approximately 165 feet south of the 

construction right-of-way at MP 75.4. This mining operation is not anticipated to be impacted by the 

proposed Project due to the distance that the mine occurs from the temporary construction right-of-way. 

Gulf South is currently corresponding with the surface mine operators concerning potential expansion of 

mining operations; however, with the noted southern expansion of the surface mine, it is unlikely that the 

mine would extend in a northerly direction. 

In Alabama, limestone, dolomite, marble, granite, sandstone, and quartzite are components of 

an important industry. However, no current data for active mineral field locations was available for 

Alabama. During field surveys conducted by Gulf South, no surface mines were identified within 

0.25 mile of the proposed Project in Alabama. Given that there are few mineral resources located in the 

immediate vicinity of the proposed Project, and that known sites are inactive or would be avoided, we 

believe that no significant impacts to mineral resources would occur. 

Table 3.1.2-1 presents the active mineral resources located within 0.25 mile of the proposed 

Project. 
 3-6 

TABLE 3.1.2-1 

Active Mineral Resources Within 0.25 Mile of the Proposed Southeast Expansion Pipeline 

Milepost 

(MP) County, State Mineral Resource 

Distance 

from the 

Proposed 

Centerline 

(feet) 

Direction 

from the 

Proposed 

Centerline 

Evaluation of 

Impacts from 

Construction and 

Operation 

22.6 Simpson, MS Oil – Production 259 South None 

22.7 Simpson, MS Saltwater Disposal – 

Injection 

417 South None 

22.7 Simpson, MS Enhanced Oil Recovery 

Injection (on standby) 

962 South None 

22.8 Simpson, MS Oil – Production 1,206 North None 

22.9 Simpson, MS Oil – Production 540 North None 

23.1 Simpson, MS Enhanced Oil Recovery 

Injection (on standby) 

1,277 South None 

23.4 Simpson, MS Oil – Production 491 South None 

23.4 Simpson, MS Enhanced Oil Recovery – 

Injection 

911 North None 

58.1 Jasper, MS Enhanced Oil Recovery – 

Injection 

660 North None 

58.4 Jasper, MS Oil – Production 247 North None 

58.8 Jasper, MS Oil – Production 469 South None 

59.2 Jasper, MS Oil – Production 503 South None 

69.4 Jasper, MS Saltwater Disposal – 

Injection 

1,181 North None 

69.5 Jasper, MS Enhanced Oil Recovery – 

Injection 

1,130 North None 

69.6 Jasper, MS Oil – Production 80 South Area would be flagged 

and barricaded. 

Necessary precautions 

would be taken to 

minimize impacts. 

69.7 Jasper, MS Oil – Production 502 South None 

69.7 Jasper, MS Oil – Production 174 North None 

69.8 Jasper, MS Enhanced Oil Recovery – 

Injection 

885 South None 

69.8 Jasper, MS Natural Gas – Production 841 North None 

69.9 Jasper, MS Oil – Production 393 South None 

70.0 Jasper, MS Oil – Production 1,044 South None 

70.0 Jasper, MS Enhanced Oil Recovery – 

Injection 

445 South None 

70.0 Jasper, MS Natural Gas – Production 885 South None 

70.0 Jasper, MS Natural Gas – Production 560 South None 

70.1 Jasper, MS Oil – Production 591 South None 

75.4* Jasper, MS Sand and Gravel 240 South None 

84.0 Clarke, MS Saltwater Disposal – 

Injection 

774 North None 
 3-7 

TABLE 3.1.2-1 

Active Mineral Resources Within 0.25 Mile of the Proposed Southeast Expansion Pipeline 

Milepost 

(MP) County, State Mineral Resource 

Distance 

from the 

Proposed 

Centerline 

(feet) 

Direction 

from the 

Proposed 

Centerline 

Evaluation of 

Impacts from 

Construction and 

Operation 

96.3 Clarke, MS Saltwater Disposal – 

Injection 

448 North None 

96.5 Clarke, MS Oil – Production 1,244 South None 

_______________ 

* Five surface mining operations owned by one entity, one is not active and the four remaining mining operations are noted to 

be extensions of one original sand and gravel pit. 

Source: MMRI, 2005; ASOGB, 2005.

3.1.3 Paleontological Resources 

Paleontological resources are the fossilized remains of prehistoric plants and animals, as well 

as the impressions left in rock or other materials as indirect evidence of the forms and activities of such 

organisms. 

The proposed Delhi Compressor Station and CenterPoint M/R station site in Richland Parish, 

Louisiana, is located on Holocene age alluvial deposits. Though the possibility of encountering fossilized 

remains exists, no paleontological resources have been identified within the proposed Project area. 

From a geological context, surface exposures in Mississippi and Alabama are very young, 

which affects the number and diversity of fossils. The oldest surface sediments are Cenozoic in age. The 

majority of sediments are Tertiary and Quaternary in age, which is older, lesser-used nomenclature for 

periods within the Cenozoic age; in addition, many sediments are less than 10,000 years old. Large 

portions of surface sediments were formed as parts of rivers, deltas, or swamps. These environments are 

less conducive to the preservation of fossils than marine environments. Thus, marine fossils are relatively 

uncommon in surface exposures. 

No paleontological resources have been identified within the proposed Project area. Because 

of the limited exposure of fossil-bearing rock units crossed by the proposed Project, possible fossilbearing formations within the proposed Project area are not likely to occur. However, if paleontological 

resources are discovered during the course of pipeline construction, Gulf South would follow its Plan for 

the Unanticipated Discoveries of Historic Properties, Human Remains, or Potential Paleontological 

Evidence During Construction. Based on the low probability of encountering these resources and Gulf 

South's adherence to its plans as necessary, we believe that construction and operation of the proposed 

Project would not significantly affect paleontological resources. 

3.1.4 Geologic Hazards 

Geologic hazards are defined by the American Geological Institute (Bates and Jackson, 1984) 

as "geologic conditions or phenomena that present a risk or are a potential danger to life and property, 

either naturally occurring or man-made." Geologic hazards potentially occurring in the vicinity of the 

proposed Project area include seismicity and faulting, soil liquefaction, slope failures/landslides, and 

ground subsidence, which are discussed below. Hazards such as volcanism are not relevant to the 

proposed Project area and are excluded from consideration here. 
 3-8 

3.1.4.1 Seismicity and Faults 

The USGS defines seismicity as "the geographic and historical distribution of earthquakes" 

(USGS 2006a). Louisiana, Mississippi, and Alabama lie within the geologic tectonic province known as 

the Gulf Coast Basin where thick sedimentary rocks overlie basement rock structures. Typical geologic 

structures of this province are generally characterized by southerly dipping and thickening sedimentary 

strata disrupted by salt domes and regional systems of relatively shallow, listric growth faults. These 

fault systems trend for considerable distances roughly paralleling the Gulf Coast. The growth faults are 

thought to have formed during periods of accelerated basin subsidence. Active movement is thought to 

have occurred during periods of rapid localized sediment deposition (Miocene and Oligocene epochs). 

Five earthquake epicenters have been recorded in Mississippi (USGS, 2006a) and 215 epicenters have 

been recorded in Alabama (GSA, 2006). The epicenters of these earthquakes occurred more frequently in 

the northern parts of Mississippi and Alabama and none were located 15 miles or less from the proposed 

Project area (NA.gov, 2006). Although it is difficult to quantify the probability of ground failure, it 

appears to be low in the proposed Project area. 

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

faults, and offset along normal, reverse, or strike-slip faults. Earthquakes are caused by active faults. 

Gulf South indicates that there are no active faults in the proposed Project area. 

Faulting can be especially hazardous to linear, rigid structures, such as pipelines, in which the 

ground is not moving the same distance or in the same direction. However, well-maintained pipelines 

constructed using modern arc-welding techniques have performed well in seismically active areas of the 

United States. Only large, abrupt ground displacements have caused serious impacts to those facilities. 

Based on the historical record and absence of active faults in areas near the proposed Project's corridor, 

we believe that the potential for seismicity and faulting does not represent a significant risk to the stability 

or safety of the proposed Project. 

3.1.4.2 Soil Liquefaction 

Soil liquefaction is a condition that occurs when loose, cohesionless, saturated soil (usually 

well-sorted sand) is subjected to vibration or shock waves. During liquefaction, pore water inhibits grainto-grain contact, and the strength of the soil is greatly reduced such that the soil may act like a viscous 

liquid with the ability to flow. Soil liquefaction can lead to landslides and earthflows, movement or 

failure of foundations and footings, and mobility of buried objects. 

Few soils along the proposed pipeline route are well-drained to poorly-drained, as discussed in 

Section 3.2. Thus, there is little added risk for soil liquefaction from saturated soil conditions. Because 

soil liquefaction risk is closely related to seismic risk, which was previously described as low within the 

proposed Project area, the potential for soil liquefaction is similarly low. Furthermore, the pipeline and 

associated facilities would be designed and constructed in accordance with the standards specified in 

49 CFR Part 192, Minimum Federal Safety Standards for the Transportation of Natural and Other Gas by 

Pipeline, which should adequately address the low potential for soil liquefaction. Given the low seismic 

risk in the area and the methods that would be used to construct the proposed pipeline and associated 

facilities, we believe that soil liquefaction does not represent a significant risk to the stability or safety of 

the proposed Project. 

3.1.4.3 Slope Failures/Landslides 

Several factors contribute to slope failures and subsequent landslides, including the degree of 

slope or tilt of geologic materials, the composition of the materials, the amount of man-made disturbance 
 3-9 

of the materials, proximity to seismic activity, and the amount of rainfall exposure. Generally flat areas 

were selected for the location of the proposed compressor and M/R sites; therefore, slope failure is not 

expected at aboveground facility locations. However, slope failures and landslides represent a potential 

hazard along portions of the proposed Project route that would traverse areas of side slopes and rolling 

terrain. Factors that would increase the potential for slope failures along slopes and rolling terrain include 

cutting along slopes, the weight of construction equipment, and unusually high precipitation. 

The proposed Project is located in recorded areas of moderate susceptibility/low landslide 

incidence in Simpson, Smith, and Jasper Counties, Mississippi. Portions of the pipeline would encounter 

recorded areas of high susceptibility/moderate incidence in Smith (from approximately MP 36.0 to 

MP 42.4), Jasper (from approximately MP 53.7 to MP 73.5), and Clarke Counties (from approximately 

MP 75.7 to MP 84.8), in Mississippi. Choctaw County, Alabama is reportedly in a low incidence area. 

Construction of the pipeline would be accomplished in accordance with Gulf South's plans, 

which includes measures to control runoff and erosion that would minimize the potential for slope failures 

(see Section 2.3). In addition, pre- and post-construction inspections would identify areas of risk, and 

continued monitoring along slopes would likely identify any significant landslide hazards before they 

develop. Gulf South would also implement specialized two-tone construction techniques to provide for 

safe working conditions in areas potentially susceptible to slope failures (see Section 2.3.2.5). Based on 

the characteristics of the proposed Project area and Gulf South's adherence to its identified construction 

and monitoring measures, we believe that potential impacts from slope failures and landslides would be 

prevented or effectively minimized. 

3.1.4.4 Ground Subsidence 

Ground subsidence is a lowering of the land-surface elevation that results from changes that 

take place underground. Common causes of land subsidence include dissolution of limestone in areas of 

karst terrain; collapse of underground mines; and pumping of water, oil, and gas from underground 

reservoirs. 

Three areas of karst topography were identified along the proposed Project in Smith, Jasper, 

and Clarke Counties, Mississippi. These flat-lying carbonate rock areas may produce solution sinkholes, 

collapse sinkholes, and cover-collapse sinkholes (NA.gov, 2006). These areas, which occur from 

MPs 36.0 to 42.4, MPs 53.7 to 73.5, and MPs 75.7 to 84.8, are further classified as fissures, tubes, and 

caves that are generally less than 1,000 feet long and 50 feet or less in vertical extent, and occur in gently 

dipping to flat-lying beds of carbonate rock beneath an overburden of non-carbonate material about 

10 feet to 200 feet in thickness. However, review of USGS topographic quadrangle maps in this area did 

not identify any active karst features such as sinkholes or springs at the land surface. Karst topography 

along the proposed Project was not present in Louisiana, Alabama, or Simpson County, Mississippi. 

As described in Section 3.1.2, the proposed Project would traverse areas in Louisiana, 

Mississippi, and Alabama where oil and natural gas extraction is common. Extraction of oil and gas from 

sources underlying the proposed Project facilities has the potential to cause ground subsidence (USGS 

2006b, USGS 2006c). 

Ground subsidence can affect pipelines and aboveground facilities by causing a loss of support 

that would result in bending or rupture of pipelines and weaken the foundations of aboveground facilities. 

However, the proposed Project facilities would be designed and constructed to meet or exceed the federal 

safety standards set forth in 49 CFR Part 192, Minimum Federal Safety Standards for the Transportation 

of Natural and Other Gas by Pipeline, which should ensure integrity of the Project facilities and minimize 

the potential for any pipe failures due to ground subsidence. Additionally, Gulf South would conduct 
 3-10 

regular patrols of the pipeline right-of-way during operations to identify conditions, including any areas 

of ground subsidence that might affect the safety or operation of the pipeline. Adherence to these 

standards and procedures would minimize the potential for any risk to the proposed Project posed by 

ground subsidence. 

3.1.5 Conclusions Regarding Impacts to Geologic Resources 

The proposed Project is unlikely to affect paleontological resources, and is also unlikely to 

encounter bedrock along the pipeline route. However, Gulf South has plans in place to address these 

issues should the need arise. Potential impacts to mineral sites and oil and gas producing areas would be 

largely avoided due to routing and through negotiations with affected parties, as applicable. The largest 

potential for effects would be related to alteration of topography, especially in steep or moderately rugged 

terrain. These potential effects would be effectively mitigated through use of special construction 

techniques and restoration of contours. Geologic hazards, such as seismic activity and liquefaction would 

not likely cause a significant threat to construction or operation of the proposed facilities. The potential 

for other hazards, such as slope failure and subsidence, would be minimized through the use of special 

construction techniques, restoration, and post-construction monitoring. Given the resources, level of 

impacts, and impact avoidance, minimization, and mitigation measures described above, we believe that 

the proposed Project would not have a significant impact on geological resources nor would there be more 

than a negligible risk to the proposed pipeline from geologic hazards. 

3.2 SOILS 

3.2.1 Existing Soils 

We analyzed data for soils traversed by the proposed Project using the USDA NRCS 

(formerly the Soil Conservation Service) Soil Survey Geographic (SSURGO) (NRCS, 2006a) databases 

for Richland Parish, Louisiana, Simpson, Smith, Jasper, and Clarke Counties, Mississippi, and Choctaw 

County, Alabama. These soil associations, along with a description of their major characteristics, are 

listed in Appendix C (Table C-1). Soils found at the location of the proposed aboveground facilities and 

their descriptions are listed in Appendix C (Table C-2). 

The proposed Project would be located in four Major Land Resource Areas (MLRA), 

including the Southern Mississippi River Alluvium (MLRA 131), the Southern Mississippi Valley Loess 

(MLRA 134), the Southern Coastal Plain (MLRA 133), and the Alabama and Mississippi Blackland 

Prairie (MLRA 135) (NRCS, 2006b). The Southern Mississippi River Alluvium MLRA is dominated by 

Alfisol, Vertisol, Inceptisol, and Entisol soils characterized as very deep, dominantly poorly-drained and 

somewhat poorly-drained, and dominantly loamy or clayey. The Southern Mississippi Valley Loess 

MLRA is dominated by Alfisol, Entisol, Inceptisol, and Ultisol soils characterized as very deep or deep, 

medium textured, having a thermic soil temperature regime, having an udic soil moisture regime, and 

having mixed mineralogy. The Southern Coastal Plain MLRA is dominated by Ultisol, Entisol, and 

Inceptisol soils characterized as very deep, somewhat excessively-drained to poorly-drained, and loamy. 

The Alabama and Mississippi Blackland Prairie MLRA is dominated by Inceptisol and Veritsol soils 

characterized as shallow to very deep, generally well-drained to somewhat poorly-drained, and loamy or 

clayey. 

3.2.2 Major Soil Characteristics 

Several soil characteristics have the potential to affect, or be affected by, construction and 

operation of the proposed Project, including the following: erosion hazard, drainage class, presence of 

hydric soils, compaction potential, presence of shallow bedrock, revegetation potential, and prime 
 3-11 

farmland designation. The characteristics of the various soil units crossed by the proposed pipeline are 

compiled in Appendix C (Table C-1), and discussed further below. 

3.2.2.1 Erosion Potential 

Erosion is defined as the wearing away of the land surface by water, wind, ice, or other 

geologic events (NRCS, 2006a). Erosion potential is defined based on land capability subclass as severe, 

moderate, and low. The potential for soil erosion varies along the proposed pipeline route, with about 

26 percent of the soils classified as having a low erosion potential, 31 percent as having a moderate 

erosion potential, and about 43 percent of the soils as having a severe erosion potential. Of the soils 

affected by the proposed aboveground facilities, approximately 1 percent have a low erosion potential, 

33 percent have a moderate erosion potential, and 66 percent have a severe erosion potential (see 

Appendix C). Severe erosion potential soils would generally be confined to areas of side slope and 

rolling terrain. 

3.2.2.2 Drainage Class 

The drainage class of a soil is the range of its relative wetness under natural conditions. Soils 

with good drainage lose water and have low wetness, while soils with poor drainage retain water and have 

high wetness. Differences in drainage properties are typically attributed to grain size and sorting. Wellsorted or coarse-grained soils have more pore space and thus are better drained. Poorly-sorted or finegrained soils have less pore space and water drains poorly. The NRCS recognizes seven natural soil 

drainage classes: excessively-drained, somewhat excessively-drained, well-drained, moderately welldrained, somewhat poorly-drained, poorly-drained, and very poorly-drained (NRCS, 2006a). 

There are very few, very poorly-drained soils (0.08 mile) crossed by the proposed pipeline. 

There are approximately 6.68 miles of poorly-drained soils that exist between MP 15.4 to MP 103.0. 

Approximately 13.75 miles of somewhat poorly-drained soils exist between MP 1.6 to MP 95.9. The 

Southern Natural M/R Station and MLV No. 4 are located in areas of somewhat poorly-drained soils 

(Appendix C). 

3.2.2.3 Presence of Hydric Soils 

Hydric soil is defined by the USDA as soil that formed under conditions of saturation, 

flooding, or ponding long enough during the growing season to develop anaerobic conditions in the upper 

part. These soils, under natural conditions, are either saturated or inundated long enough during the 

growing season to support the growth and reproduction of hydrophytic vegetation (NRCS, 2006c). Soils 

that formed under hydric conditions in their unaltered state are still considered hydric when artificially 

drained or altered for such purposes as agricultural use. Hydric soils are typically poorly-drained, and the 

presence of hydric soils is one of the criteria used for defining wetlands (NRCS, 2006c). Hydric soils 

may be prone to compaction and rutting. Approximately 88 percent of the soils that would be crossed by 

the proposed pipeline and 72 percent of the soils that would be affected by the aboveground facilities are 

classified as hydric (see Appendix C). Given that most of the soils along the Project would be in 

managed timber plantations, most hydric soils are likely to be relatively undisturbed. 

3.2.2.4 Compaction Potential 

Soil structure, including strength and drainage abilities, is altered when soils are compacted. 

The compaction of soils results from the decreasing of pore space and water-retention capacity. 

Susceptibility of soils to compaction varies based on moisture content, composition, grain size, and 

density of the soil. Poorly-drained and fine-grained silt and clay soils are the most likely soils to 
 3-12 

experience compaction. Consequently, soil compaction is of particular concern in agricultural areas 

where crop yields could be adversely affected. However, given that most soils crossed would be in 

uplands with topography unsuitable for the development of fine-grained silt and clay soils, no soils 

crossed by the proposed Project are listed as having severe compaction issues. 

3.2.2.5 Revegetation Potential 

Revegetation potential is the rating of the ability of a soil to support vegetation efforts 

following construction-related disturbance. Gulf South evaluated the potential for revegetation of each 

soil type that would be affected by construction of the proposed pipeline by assessing such factors as soil 

texture, drainage properties, wetness, and slope. Taking these factors into account, three general classes 

were defined for revegetation potential including good, fair, and poor (Appendix C). Gulf South 

determined that the soils crossed by the pipeline are rated as having good (47.6 miles) and fair 

(63.2 miles) revegetation potential. Of the soils that would be affected by the proposed aboveground 

facilities, 56 percent have good revegetation potential and 44 percent have fair revegetation potential. 

None of the soils that would be traversed have a poor revegetation potential. 

3.2.2.6 Prime Farmland Designation 

Prime farmland soils are defined by the USDA as those that are best suited for food, feed, 

forage, fiber, and oilseed crops. These soils have properties that favor the economic production of 

sustained high yields of crops (NRCS, 2006d). Prime farmland is represented by many soil associations 

and series and does not need to be actively cultivated to be classified as prime farmland. Any 

undeveloped land with high crop production potential can be included in this classification. Prime 

farmland is an important resource because it provides the highest crop yield per unit of energy expended. 

Approximately 58 percent of the soils that would be affected by the proposed pipeline, and 58 percent of 

the soils that would be affected by the proposed aboveground facilities, are classified as prime farmland 

(Appendix C). 

3.2.3 General Impacts and Mitigation 

Construction activities associated with the proposed Project, such as clearing, grading, 

trenching, backfilling, and restoration could temporarily and/or permanently affect one or several soil 

characteristics. Generally, the most significant effects to soils resulting from construction activities 

include increased erosion and compaction potential, reduced soil productivity and revegetation potential, 

and altered drainage abilities. 

With appropriate stabilization and revegetation, long-term or permanent impacts to soils 

would not occur during operation of the proposed Project except for loss of function under constructed 

impermeable structures such as buildings associated with compressor stations and M/R stations. 

To minimize and mitigate impacts to soils as well as other resources, Gulf South developed its 

plans, which include the following soils-related measures: 

• The deployment of at least one EI for each construction spread. The EI would have peer status 

with the other inspectors and would have the authority to stop activities that violate the 

environmental conditions of the FERC Certificate or other authorizations and order corrective 

action(s). 
 3-13 

• Limiting Project-related ground disturbance to the construction right-of-way, ATWSs, pipe 

storage and contractor yards, borrow and disposal areas, access roads, and other areas approved in 

the Certificate. 

• Minimizing the mixing of topsoil with subsoil by stripping topsoil from either the full work area 

or from the trench and subsoil storage area in actively cultivated or rotated croplands and 

pastures, residential areas, hayfields, wetlands and other areas at the landowner's or land 

managing agency's request. 

• Installing temporary erosion controls immediately after the initial disturbance of soil. Erosion 

controls would be properly maintained throughout construction and repaired within 24 hours, if 

found ineffective. Mulch, which can consist of straw, hay, or erosion control fabric, would be 

used to stabilize the soil surface. 

• Installing sediment barriers (such as silt fences and/or staked hay or straw bales, or sand bags) at 

the base of slopes adjacent to road crossings, to prevent siltation into waterbodies or wetlands 

crossed by or near the construction work area. These barriers would remain in place until 

revegetation is successful. 

• Testing topsoil and subsoil for compaction at regular intervals in areas disturbed by construction 

activities. If either the subsoil or topsoil is severely compacted, a paraplow or other deep tillage 

device would be used to break up the soils. In areas where the topsoil was segregated, the subsoil 

also would be plowed before replacing the segregated topsoil. 

• Revegetating or stabilizing areas disturbed by Project-related activities in accordance with written 

recommendations from local soil conservation authorities or the request of the landowner or land 

management agency. All turf, ornamental shrubs, and specialized landscaping would be restored 

in accordance with the landowner's request or the landowner would be compensated. 

• Confirming revegetation efforts through post-construction monitoring of all disturbed areas. 

3.2.3.1 Erosion 

Soil susceptibility to erosion varies along the proposed pipeline route and is a function of 

variables such as soil type, topography, vegetation, and climate. The majority of soils that would be 

crossed by the proposed pipeline and affected by the proposed aboveground facilities have severe erosion 

potential. Soil erosion could occur during construction. Vegetation clearing, grading, topsoil segregation, 

open trenching, and backfilling destabilize the soil material and make it susceptible to water and wind 

erosion. In general, the potential for soil erosion along the construction right-of-way would be more 

pronounced in areas of side slopes and rolling terrain. Soils are most susceptible to erosion after 

vegetation is removed and before reestablishment of a vegetative cover after the pipeline is installed. Soil 

erosion also would result from off-road vehicle traffic on the right-of-way following construction. Soil 

erosion would impact a soils ability to maintain its structure and support vegetation which would affect 

several other resources including wildlife and land use. 

To minimize the impacts of soil erosion, Gulf South would implement several erosion control 

measures (e.g., slope breakers, silt fencing, and mulch) described in its plans, which would control runoff 

and reduce the duration of soil disturbance. In addition to adhering to its plans, Gulf South would also 

develop and implement its SWPPP. The SWPPP would incorporate the requirements for minimizing and 

mitigating upland erosion and revegetation described in its plans, and would further detail the erosion 
 3-14 

control structural best management practices, inspection procedures, and reporting protocols to be 

implemented during construction of the proposed Project. 

3.2.3.2 Compaction Potential 

Compaction damages the structure of a soil and restricts the transport of air and water to plant 

roots. As a result, soil productivity and plant growth rates may be reduced. None of the soils that would 

be crossed by the proposed pipeline or affected by the aboveground facilities are considered prone to 

compaction due to the lack of hydric soils or poor drainage. Use of the construction right-of-way, 

ATWSs, and access roads by heavy construction equipment would result in soil compaction. The degree 

of compaction would depend on the composition, grain size, density, and moisture content of the soils at 

the time of construction. 

As described in Gulf South's plans and Procedures, measures such as restricting vehicular 

traffic, reducing loads, employing lower ground-pressure equipment, protecting topsoil in spoil piles 

separate from subsoil spoil piles, and rescheduling certain activities may be used when soil moisture is 

high to avoid and minimize compaction and rutting. 

3.2.3.3 Revegetation Potential 

Because all of the soils that would be disturbed during construction have fair to good 

revegetation potential, restoring vegetation in accordance with Gulf South's plans should not be of 

significant concern across most of the proposed pipeline route. Revegetation is necessary for stabilization 

and restoration of the soils in the construction right-of-way, ATWSs, and areas adjacent to access roads. 

Revegetation potential may be inhibited by soil erosion, loss of soil productivity through soil compaction, 

damage to soil structure, loss of soil fertility, damage to drainage systems, and unsuitable seed selection, 

methods, or planting conditions. 

To avoid or minimize these conditions, and as described above and in Section 2.3, Gulf South 

would return the construction right-of-way, ATWSs, and pipe storage and contractor yards to preconstruction contours to the extent feasible; control erosion by implementing the procedures in its plans; 

segregate and de-compact soils and spread topsoil on the right-of-way during final cleanup; repair any 

damaged drainage systems; place soil nutrients and lime in upland areas; and seed all disturbed areas. 

Furthermore, Gulf South would consult with the local soil conservation authorities to determine the 

appropriate seed mixtures for stabilization and permanent erosion control. We are recommending in 

Section 3.5 that Gulf South consult with the LDWF, the ADCNR, and the MNHP regarding seeding 

mixtures and revegetation. 

Gulf South would be responsible for successful revegetation of all disturbed areas, and it 

would follow its plans to ensure that all mitigation is sufficient. Gulf South would conduct at least two 

years of post-construction monitoring of all work areas to verify successful revegetation or determine the 

need for additional restoration. In accordance with its plans, revegetation would be considered successful 

if the density and cover of non-nuisance vegetation were similar in density and cover to adjacent 

undisturbed lands. If vegetation cover and density were not similar or if there were excessive noxious 

weeds after two full growing seasons, a professional agronomist would determine the need for additional 

restoration measures. In agricultural areas, revegetation would be considered successful if crop yields in 

areas affected by construction were similar to those in adjacent, undisturbed areas. 

Gulf South would take measures to control unauthorized vehicle access to the proposed 

pipeline right-of-way during operation. In forested lands, these measures may include signs, fences with 

locking gates, slash and timber barriers, or planting appropriate trees or shrubs to block access to the 
 3-15 

right-of-way. Gulf South would coordinate with affected landowners regarding the installation of access 

barriers on their property. 

3.2.3.4 Mixing of Topsoil and Subsoil 

Unless the landowner or a land management agency approves otherwise, Gulf South would 

prevent the mixing of topsoil with subsoil by stripping topsoil from either the full work area or the trench. 

This segregation of topsoil would occur in active croplands and pastures, residential areas, hayfields, and 

other areas as requested by landowners or land management agencies. A maximum of 12 inches of 

topsoil would be stripped, if available, and the entire topsoil layer would be segregated in areas with less 

than 12 inches of topsoil available. Topsoil would not be used to pad the proposed pipeline. 

3.2.3.5 Rocks 

Introduction of rock to surface soil layers would not be of concern across the proposed 

pipeline route as it is unlikely that shallow bedrock would be crossed by the proposed pipeline route. 

However, if shallow bedrock is encountered, trenching and mixing of the excavated materials in these 

areas could bring large rocks to the surface, which would adversely impact soil productivity and 

agricultural practices. In accordance with its plans, Gulf South would remove excess rock from at least 

the top 12 inches of soil in all rotated and permanent cropland, hayfields, pastures, residential areas, and 

other areas at the landowner's request. Following construction and restoration, the size, density, and 

distribution of rock in all construction work areas would be similar to that in adjacent areas not affected 

by construction. Thus, no significant impacts are anticipated as a result of pipeline construction through 

areas of shallow bedrock. 

3.2.3.6 Drainage Systems and Drainage Patterns 

Heavy equipment traffic and trenching along the construction right-of-way could damage 

existing drainage systems or affect existing drainage patterns, thereby affecting farm management by 

causing wet, unworkable soil conditions. Future crop production would likely be lowered if such 

damages were not corrected. Gulf South would be responsible for ensuring that all areas affected by 

construction activities were finish-graded and restored as closely as possible to pre-construction contours. 

Gulf South indicated that no known drainage structures would be crossed by the proposed Project. 

However, Gulf South would continue to work with property owners to identify locations of existing 

drainage structures that could be damaged during construction. If active drainage tiles, culverts, or other 

drainage facilities were damaged during construction, Gulf South would replace or repair them to a 

condition that is equal to or better than their pre-construction condition. Although damage to drainage 

structures and patterns would result in short-term impacts, the corrective procedures to be implemented 

by Gulf South would avoid or minimize any long-term impacts. 

3.2.3.7 Prime Farmland 

The NRCS defines prime farmland as "land that has the best combination of physical and 

chemical characteristics for producing food, feed, forage, fiber, and oilseed crops and that is available for 

these uses" (NRCS, 2006d). Soils classified as prime farmland have few or no rocks, a dependable water 

supply, a favorable growing season, are not saturated for long periods of time, typically do not flood 

during the growing season, and are permeable to air and water. Prime farmland is an important resource 

because it provides the highest crop yield per unit of energy expended. The NRCS determines the prime 

farmland status of all soil associations that have been surveyed, and therefore this information is available 

directly from the soil survey databases. Approximately 58 percent of the soils that would be affected by 
 3-16 

the proposed pipeline are classified as prime farmland; however, most of this is currently classified as 

either upland forest or pine plantation. 

Gulf South would implement the measures included in its plans to minimize and mitigate any 

impacts to prime farmland soils. Virtually all impacts to prime farmland soils resulting from construction 

and operation of the proposed pipeline would be temporary because the proposed pipeline would be 

buried, and disturbed areas within the construction and permanent rights-of-way would largely revert to 

their preconstruction uses following restoration. However, the footprint of aboveground facilities would 

permanently affect some prime farmlands. Operation of the Delhi Compressor Station would affect about 

69.5 acres of prime farmland. In addition, designated prime farmland located at the CenterPoint and 

Southern Natural M/R Stations, as well as at various valves and other minor facilities, would be lost as 

these areas would be converted to an industrial/commercial land use. 

Farmland Conversion Impact Rating documentation would not be required for the proposed 

Project since it would not be completed by or with assistance from a federal agency, as specified by the 

Farmland Protection Policy Act. Given the prevalence of prime farmland soils within the affected 

counties and parishes, the permanent impacts to prime farmland soils associated with construction and 

operation of the proposed Project aboveground facilities would be less than significant. 

3.2.4 Conclusion 

Construction of the proposed Project would result in several affects to soils. However, Gulf 

South would be required to control erosion, test and mitigate for compacted soils, protect topsoil, repair 

any damaged drainage systems, and revegetate disturbed areas. Furthermore, Gulf South would 

implement its SPCC Plan and manage contaminated soils should they be encountered. Although a small 

amount of prime farmland would be permanently affected at the proposed aboveground facilities, these 

impacts would be minor overall and potential impacts to prime farmland along the proposed pipeline 

route would be minor and temporary. Given the impact minimization and mitigation measures described 

above, we believe that soils would not be significantly affected by construction and operation of the 

proposed Project. 

3.3 WATER RESOURCES AND FISHERIES 

3.3.1 Groundwater 

3.3.1.1 Existing Groundwater Resources 

Along the proposed Project route, groundwater is a significant source of drinking water in 

selected areas. Groundwater is also used for agricultural, industrial, and municipal uses. Although depth 

to groundwater is variable along the proposed pipeline route, groundwater is often found near the ground 

surface, and the proposed Project is likely to encounter groundwater during construction activities. 

Major aquifers underlying the proposed Project include the Mississippi River Alluvial Aquifer 

System, the Coastal Lowlands Aquifer System, and the Mississippi Embayment Aquifer System (United 

States Department of the Interior [USDI], 2006). Although all of the listed aquifers are used, aquifers 

contributing major drinking water supplies underlain by the proposed Project include the Coastal 

Lowlands Aquifer, and to a much smaller extent, the Mississippi Embayment Aquifer. Additional 

information on the aquifers that occur along the proposed Project route, as well as sole-source aquifers, 

wellhead protection areas, wells, springs, and contaminated groundwater, is presented below. 
 3-17 

Mississippi River Alluvial Aquifer 

The proposed Delhi Compressor Station would be underlain by the Mississippi River Alluvial 

Aquifer in Richland Parish, Louisiana. The Mississippi River Alluvial Aquifer is hydraulically connected 

with the Mississippi River and its major tributaries and is recharged by direct infiltration of rainfall 

through the overlying silt and clay layers. Groundwater is typically encountered within 30 to 40 feet of 

the ground surface. Approximately 353.6 million gallons per day (mgd) are withdrawn from this aquifer 

for irrigation and industrial uses (LDEQ, 2003). The quality of water from this aquifer is considered 

relatively poor due to the presence of arsenic and poor taste and odor qualities. 

Coastal Lowlands Aquifer 

In Simpson, Smith, and Jasper Counties, Mississippi, proposed pipeline facilities would be 

underlain by the Coastal Lowlands Aquifer. Primary recharge of this aquifer occurs from direct 

infiltration of rainfall in the stream and upland outcrop areas. Water also moves between overlying 

alluvial and terrace aquifers according to hydraulic head differences. Groundwater in this aquifer occurs 

at maximum depths ranging from 200 feet above msl to 2,000 feet below msl. Approximately 1 billion 

gallons per day of water are withdrawn from this aquifer for agricultural, industrial, and municipal uses 

(USGS, 2005). 

Mississippi Embayment Aquifer 

In Jasper and Clarke Counties, Mississippi, and Choctaw County, Alabama, proposed pipeline 

facilities would be underlain by the Mississippi Embayment Aquifer. This aquifer is recharged by 

infiltration of rainfall in river valleys, lateral and upward movement of water from adjacent and 

underlying aquifers, and overbank stream flooding. The amount of recharge from rainfall depends on the 

thickness and permeability of the silt and clay layers. Approximately 433 mgd are withdrawn from this 

aquifer for agricultural, industrial, and municipal uses (USGS, 2005). 

Sole-Source Aquifers 

Sole-source or principal-source aquifers are defined by the EPA as those that supply 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. No sole-source aquifers would be 

crossed or otherwise impacted by the proposed Project (USEPA, 2006). 

Wellhead Protection Areas 

Wellhead protection areas have been established by the LDEQ, MDEQ, and ADEM to protect 

public drinking water supplies. Based on a search of LDEQ, MDEQ, and ADEM databases, no 

designated wellhead protection areas would be crossed or are located in the vicinity of the proposed 

Project. 

Wells and Springs 

Based on consultation with the Louisiana Department of Transportation and Development 

(LDTD), Public Works and Water Resources Division's Water Well Registration File (LDTD, 2007), 

MDEQ, ADEM, database searches, and field observations, two private wells have been identified on the 

Delhi Compressor Station land parcel in Louisiana and five private wells and four public wells have been 

identified within 150 feet of the construction right-of-way in Mississippi. No wells were located within 

150 feet of the construction right-of-way in Alabama. These wells and their locations relative to the 
 3-18 

proposed Project are listed in Table 3.3.1.1-1. Because the locations of wells listed in agency databases 

are not exact, prior to construction Gulf South would confirm that no wells are located within the 

construction right-of-way. Based on agency consultations and field surveys, no springs have been 

identified within 150 feet of the proposed construction right-of-way and aboveground facility boundaries. 

TABLE 3.3.1.1-1 

Wells Located Within 150 Feet of the Proposed Southeast Expansion Project 

Well Type 

County1

/

Parish2

Approximate 

MP3

/Associated 

Facility 

Approximate 

Well Depth 

(feet) 

Approximate 

Distance from 

Pipeline 

Centerline 

(feet) 

Distance from 

Construction 

Right-of-Way 

(feet) 

42-inch Mainline Pipeline 

Private Simpson, MS 14.0 247 166.4 126.4 

Public Simpson, MS 16.1 290 68.4 48.4 

Public Smith, MS 39.0 69 90.6 30.6 

Public Smith, MS 44.6 251 235.5 105.5 

Public Smith, MS 44.8 714 232.0 101.8 

Private Jasper, MS 52.9 65 202.7 47.7 

Private Jasper, MS 65.9 430 229.0 128.9 

Private Jasper, MS 68.9 416 52.7 6.7 

Private Clarke, MS 91.2 416 137.7 7.5 

Aboveground Facilities 

Private Richland, LA 

Delhi 

Compressor 

Station 

100 Within facility 

boundaries 

Within facility 

boundaries 

Private Richland, LA 

Delhi 

Compressor 

Station 

101 Within facility 

boundaries 

Within facility 

boundaries 

_______________ 

1 MS = Mississippi 

2 LA = Louisiana 

3 MP = Milepost 

Contaminated Groundwater 

Based on agency consultations with the MDEQ, a review of public databases maintained by 

the LDEQ, MDEQ, and ADEM, and a review of a private database (Banks Information Solutions, Inc., 

2006a and 2006b), which maintains state and federal records, Gulf South has identified 15 sites 

containing potentially contaminated groundwater within a 1-mile radius of the proposed Project facilities. 

These sites are described in Table 3.3.1.1-2. 
 3-19 

TABLE 3.3.1.1-2 

Potential Contaminated Groundwater Sites Within 1 Mile of the 

Proposed Southeast Expansion Project Centerline 

MP1 Parish/

County/State2 Name Type3 Distance/Direction Physical Location 

45.1 Smith, MS Shell Tallahala Creek 

Field 

UST 0.68 mile south of the 

centerline (3,585 feet) 

RT 2 Box 72-C 

Bay Springs, MS 39422 

49.5 Jasper, MS Mississippi Highway 

Department 

UST 0.16 mile north of the 

centerline (847 feet) 

RT 4 Box 338 

Carthage, MS 

51.1 Jasper, MS MDOT Meridian 

Area Headquarters 

UST 0.99 mile north of the 

centerline (5,241 feet) 

5409 1st Street 

Meridian, MS 

51.1 Jasper, MS MDOT Maintenance 

Area Headquarters 

UST 0.90 mile north of the 

centerline (4,772 feet) 

U.S. Highway 11 

Purvis, MS 

52.0 Jasper, MS Georgia Pacific Chip 

N Saw 

CERCLA 0.39 mile north of the 

centerline (2,033 feet) 

Data not listed 

57.24 Jefferson, MS MDOT UST 0.94 mile south of the 

centerline (4,959 feet) 

Highway 28 East 

Fayette, MS 

66.9 Jasper, MS Dixon S. Service 

Center 

UST 0.14 mile north of the 

centerline (727 feet) 

Highway 528 

Heidelberg, MS 39439 

68.94 Holmes, MS MDOT Durant 

Headquarters 

UST 0.22 mile south of the 

centerline (1,144 feet) 

Highway 51 South 

West, MS 

68.94 Hinds, MS MDOT Jackson 

Project 

Headquarters 

UST 0.60 mile south of the 

centerline (3,163 feet) 

2802 Kingswood Ave. 

Jackson, MS 

69.0 Jasper, MS Country Cash UST 0.62 mile south of the 

centerline (3,276 feet) 

Highway 528 

Heidelberg, MS 39439 

69.0 Jasper, MS Heidelberg Exxon UST 0.42 mile south of the 

centerline (2,206 feet) 

2507 North Pine Ave. 

Heidelberg, MS 39439 

69.0 Jasper. MS Heidelberg 

Warehouse 

UST 0.53 mile north of the 

centerline (2,815 feet) 

Highway 528 

Heidelberg, MS 39439 

69.5 Jasper, MS Reagan Equipment 

Co. 

UST 0.81 mile south of the 

centerline (4,268 feet) 

P.O. Box 285 

Heidelberg, MS 39439 

70.8 Jasper, MS MDOT Holly Springs 

Headquarters 

UST 0.86 mile north of the 

centerline (4551 feet) 

State Highway 7 

Holly Springs, MS 

95.34 Jackson, MS UHAUL 17868 UST 0.03 mile north of the 

centerline (156 feet) 

2903 Shortcut Road 

Pascagoula, MS 

_______________ 

Notes: 

1 MP = Milepost

2 MS = Mississippi 

3 CERCLA = Comprehensive Environmental Response, Compensation, and Liability Act 

 UST = Underground Storage Tanks, Leaking Underground Storage Tanks

4 Site listed as being within 1 mile of pipeline based on inaccurate data from the MDEQ Mississippi Automated Resource 

Information System. Per conversation with the MDEQ, Gulf South determined the site is not within 1 mile of the Project area; 

the true site location is listed in the "Physical Location" column.

3.3.1.2 General Impacts and Mitigation 

In general, the potential for temporary and permanent impacts to groundwater resulting from 

construction and operation of the proposed Project would depend primarily on any localized changes to 

existing groundwater flow paths. The proposed Project would not affect changes in the overall quantity 

of groundwater, which is determined by the quantity of recharge to the aquifer, except to the minimal 
 3-20 

extent resulting from impervious surfaces at the proposed aboveground facility sites and to the extent that 

clearing of vegetation reduces evapotranspiration. Increased surface runoff resulting from clearing of the 

construction right-of-way and reduced evapotranspiration would result in increased recharge to 

groundwater, thus increasing groundwater storage. 

Excavation and subsequent backfilling of the pipeline trench could also alter the quantity and 

quality of groundwater and groundwater flow paths. Additionally, if soils along the proposed Project 

route became compacted due to construction and operation of heavy machinery, infiltration and recharge 

of aquifers along the trench or right-of-way could also be adversely impacted. Altered groundwater flow 

paths in turn could result in changes to the quality of groundwater at specific locations, such as the 

shallow Mississippi River Alluvial Aquifer. However, most wells located along the pipeline receive 

water from deeper formations whose flow paths would not be affected by the trench. 

Excavation of the pipeline trench may expose relatively shallow aquifers, such as the 

Mississippi Alluvial Aquifer, but only to a depth of 6 to 8 feet in most upland and wetland areas. 

Dewatering of the pipeline trench during construction would be necessary where shallow groundwater is 

encountered. Dewatering would temporarily depress groundwater levels in the immediate vicinity of the 

trench. However, because trenching typically proceeds at a relatively rapid rate, the depression of the 

water table around the trench is expected to recover rapidly once the trench is backfilled. Therefore, 

dewatering would temporarily affect flow patterns in nearby springs and shallow wells if present, but such 

impacts would likely be minor and of a brief duration. 

Accidental spills and leaks of hazardous materials could impact groundwater resources 

through the introduction of contaminants, especially in highly permeable areas near water withdrawal 

wells. Gulf South's Procedures include spill prevention and control measures. Additionally, Gulf South 

has developed a SPCC Plan, which describes management of the hazardous materials, such as fuels, 

lubricants, and coolants, that would be used during construction. Given the measures described in Gulf 

South's Procedures and its implementation of an SPCC Plan, we believe the risk of accidental spills or 

other introductions of hazardous materials to groundwater would be effectively minimized. 

Gulf South indicated that it did not anticipate encountering any contaminated groundwater 

plumes during construction or operation of the proposed Project. In the event that hazardous materials 

were discovered during construction of the proposed Project, Gulf South would stop work, notify the 

appropriate state and federal agencies, and proceed in accordance with all applicable laws and regulations. 

Additionally, Gulf South would follow the procedures outlined in its Plan for the Unanticipated 

Discovery of Contaminated Environmental Media to ensure that any hazardous materials encountered 

during construction are properly identified, tested, and disposed of in accordance with the appropriate 

state and federal regulations. 

In order to minimize potential impacts to groundwater, Gulf South would implement the 

measures identified in its plans, which include: 

• Testing and, as applicable, mitigating for compacted soils (see Section 3.2 for additional 

discussion). 

• Installing trench breakers at specified intervals to reduce the potential for the trench to act as a 

preferential groundwater flow path. Trench breakers would reduce the ability of the trench to 

convey groundwater. No long-term impacts to the water table or groundwater migration patterns 

would be anticipated as a result of the proposed Project. 
 3-21 

• Implementing measures to reduce impacts resulting from trench dewatering, including 

discharging the pumped water to well vegetated areas or properly constructed temporary retention 

structures that would promote infiltration and minimize or eliminate runoff. 

• Installing trench plugs to prevent parallel flow in the trenches. 

Based on the anticipated impacts to groundwater, Gulf South's stated construction methods, 

and the measures described in its plans, we believe that construction and operation of the proposed 

Project would not change regional flow paths, discharge conditions, or groundwater quality because these 

are determined by larger-scale geologic features that form the hydrogeologic setting, and that aquifers 

such as the Coastal Lowlands Aquifer and the Mississippi Embayment Aquifer that are typically deeper 

or that are overlain by other aquifers with separating layers would not be directly affected because their 

upper margin would be located well below the depth of the pipeline trench. 

In order to protect and mitigate potential effects to water withdrawal wells, Gulf South would 

test the wells of landowners listed in Table 3.3.1.1-1 at the request of the landowner. The scope of any 

requested pre- or post-construction testing or monitoring would be negotiated on an individual basis with 

the landowners. However, we recommend that Gulf South offer, and conduct with permission from 

landowners, individual well testing that evaluates basic parameters such as well yield and water quality. 

To ensure that water withdrawal well testing and monitoring is performed in a manner that would 

adequately protect private and public water well resources, we recommend that:

• Gulf South should conduct, with the well-owner's permission, pre- and post-construction 

well monitoring of well yield and water quality for wells identified in Table 3.3.1.1-1. Prior 

to construction, Gulf South should file with the Secretary, for review and written approval 

by the Director of OEP, a well monitoring and mitigation plan that describes standard 

testing procedures, and the measures that would be taken should a well be impacted such 

that it is no longer operable or that it becomes impaired. Gulf South should offer this plan 

to the landowners before construction. Gulf South should also file a report with the 

Secretary, within 30 days of placing its pipeline facilities in service, identifying all private or 

domestic water wells or systems damaged by construction and describing how they were 

repaired. The report should include a discussion of any complaints concerning well yield or 

quality and how each problem was resolved. 

3.3.1.3 Site-Specific Impacts and Mitigation 

Sole-source and principal-source aquifers do not occur in the vicinity of the proposed Project 

and would therefore not be affected by the proposed construction and operational activities. Additionally, 

no springs or public wells were identified along the proposed Project route through resource agency 

consultations or environmental field surveys conducted by Gulf South. 

No wellhead protection areas were identified along the proposed pipeline route. Blasting is 

not anticipated in association with construction of the proposed Project; therefore, impacts to wells and 

other sensitive resources from blasting are not anticipated. Should the need for blasting arise, Gulf South 

would follow local and/or state requirements and use accepted safe construction blasting techniques and 

safeguards. 

3.3.1.4 Conclusion Regarding Groundwater Resources 

Aquifers typically would not be impacted by the proposed Project given their depth and the 

relatively shallow nature of construction activity. Impacts to more shallow aquifers and groundwater 
 3-22 

resources would be adequately avoided or minimized through Gulf South's implementation of its plans 

and Procedures, project-specific plans, and our recommendation. Given these measures, we believe that 

construction and operation of the proposed Project would not significantly affect groundwater resources. 

3.3.2 Surface Water Resources 

3.3.2.1 Existing Surface Water Resources 

Waterbody Crossings 

The proposed Project would traverse 308 waterbodies during construction and operation. 

Specifically, the proposed Project would cross 103 perennial streams, 196 intermittent streams, and 

9 ponds. In Mississippi, 292 waterbodies would be crossed, all of which have designated uses of fish and 

wildlife and recreation. In Alabama, 16 waterbodies would be crossed, all of which have been designated 

for fish and wildlife use. A table identifying these waterbodies, as well as their widths, locations along 

the proposed Project route, state waterbody classifications, and proposed crossing methods, is included as 

Appendix D of this EIS. 

As identified in Appendix D, each affected surface waterbody has been assigned a designated 

use by the respective state management agency responsible for its management which characterizes the 

best intended uses of that waterbody. Designated uses for waterbodies in Mississippi include fish and 

wildlife, and recreation (MDEQ, 2004a). Designated waterbody uses in Alabama include outstanding 

Alabama water, swimming, and fish and wildlife (ADEM, 2006). Designated waterbody uses in 

Louisiana include fish and wildlife propagation, primary contact recreation, and secondary contact 

recreation (EPS, 2007). 

In Mississippi, 292 waterbodies would be crossed, all of which have designated uses of fish 

and wildlife and recreation. In Alabama, 16 waterbodies would be crossed, all of which have been 

designated for fish and wildlife use. In Louisiana, one waterbody, designated for fish and wildlife, as 

well as primary and secondary contact recreation, may be potentially impacted 

Construction and operation of the Delhi, Harrisville, and Destin Compressor Stations may 

affect four waterbodies (see Appendix D). Since Gulf South has not indicated what measures would be 

taken to avoid impacts to these waterbodies; we recommend that: 

• Prior to construction, Gulf South should file along with its site-specific construction plans 

for the Delhi, Harrisville, and Destin Compressor Stations a description of the measures 

that it would take to avoid impacts to waterbodies affected by these facilities. 

Major and Navigable Waters 

The major waterbodies (greater than 100 feet wide) and navigable waterbodies, as defined by 

33 CFR Part 329, that would be crossed by the proposed Project are listed in Table 3.3.2.1-1. 

Sensitive Waterbodies 

Sensitive waterbodies include those designated as one or more of the following: having 

special status by federal or state resource agencies, providing habitats for threatened and endangered 

species, having potable water intakes within 3 miles downstream of the proposed pipeline crossing, or not 

attaining specified water quality uses. No streams within the proposed Project are designated as National 

Wild or Scenic Rivers (NPS, 2004). Based on consultations with the LDEQ, MDEQ, and the ADEM, no 
 3-23 

potable surface water intakes are located within 3 miles downstream of any proposed waterbody crossings 

in Louisiana, Mississippi, and Alabama. 

TABLE 3.3.2.1-1 

Major and Navigable Waterbodies That Would Be Crossed 

by the Proposed Southeast Expansion Project 

Waterbody 

County, 

State1 Begin 

MP2 End MP 

Major 

Waterbody 

Navigable 

Waterbody 

Proposed 

Crossing 

Method 

Pond Simpson, 

MS 1.3 1.4 X In work space only 

Leaf River Smith, MS 44.1 44.2 X X HDD 

West Tallahala 

River Smith, MS 45.3 45.3 X HDD 

Pond Clarke, MS 87.7 87.8 X HDD 

Chickasawhay 

River Clarke, MS 89.3 89.4 X X HDD 

Bucatunna 

Creek Clarke, MS 100.4 100.5 X HDD 

Okatuppa 

Creek 

Choctaw, 

AL 107.3 107.4 X HDD 

_______________ 

1 MS = Mississippi 

 AL = Alabama 

2 MP = Milepost 

N/A = Not Applicable 

The Strong River (MP 18.0) and the Chickasawhay River (MP 89.4) are designated by the 

National Park Service (NPS) as being listed on the NRI. Waterbodies included in the NRI are considered 

to possess "outstandingly remarkable natural or cultural values judged to be of more than local or regional 

significance" (NPS, 2006). Gulf South proposes to cross these rivers using HDD to avoid/minimize 

impacts. In response to our recommendation in the Draft EIS, Gulf South initiated consultation with the 

NPS (April 30, 2007) regarding impacts and mitigation measures for use of the HDD method, and with 

the MDWFP (May 22, 2007) regarding its plans/mitigation for withdrawing water from these waterbodies 

for hydrostatic testing purposes. Gulf South also submitted detailed crossing plans, construction 

measures, and hydrostatic test water withdrawal plans to the NPS and the MDWFP. 

Information for use of the HDD method included a description of the streamside vegetation 

impacts necessary for laying of the HDD guide wires and the drilling operations and use of bentonite as a 

drilling mud. In the event of a frac-out, Gulf South would implement its HDD Contingency Plan to avoid 

or minimize impacts. The proposed HDD entry and exit points for the Strong River would be located 

approximately 2,150 feet and 750 feet away from the stream edge, respectively. The proposed HDD 

entry and exit points at the Chickasawhay River crossing location would be located approximately 

480 feet and 2,150 feet from the stream edge, respectively. Given the distance between the proposed 

HDD work areas and both streams' edges, impacts to riparian areas and visual resources would be 

minimized. Information for withdrawing hydrostatic test water included the quantity of and manner in 

which hydrostatic test water would be withdrawn and discharged and is discussed in Section 3.3.2.3. 

The NPS indicated in a July 2, 2007, conversation with FERC staff that the HDD method 

being proposed would be acceptable and that these rivers were listed for their values for scenery, 
 3-24 

recreation, and fish and wildlife. Furthermore, the NPS considers Gulf South's Procedures sufficient to 

minimize and mitigate vegetation disturbance along these streams. However, because Gulf South has not 

yet completed consultations with the NPS regarding potential Project-related effects to designated NRIlisted streams, we recommend that: 

• Prior to construction, Gulf South should complete consultation with the NPS regarding 

its proposed HDD crossings of, and hydrostatic test water withdrawals from, the NRIlisted Strong and Chickasawhay Rivers, and file copies of those consultations with the 

Secretary. If applicable, Gulf South should also file plans to address any additional 

mitigation measures recommended by the NPS. 

The proposed Project would cross seven waterbodies that contain threatened or endangered 

species or critical habitat. Dabbs Creek, Leaf River, West Tallahala River, Chickasawhay River, 

Bucatunna Creek, and Strong River are designated as critical habitat for the Gulf sturgeon (Acipenser 

oxyrinchus desotoi). These rivers would be crossed using HDD methods to avoid/minimize potential 

impacts to the Gulf Sturgeon. The Little Creek is designated as critical habitat for the Natchez Stonefly 

(Alloperla natchez), which would be crossed using the open-cut method. Gulf South consulted with the 

Mississippi Museum of Natural Science (MMNS) and determined that habitat for this non-listed 

imperiled species is not likely to be present at this crossing. Additional discussion of endangered, 

threatened, and special status species and their habitats is provided in Section 3.7. 

Waterbodies that do not meet state water quality standards or do not support their designated 

uses are classified as impaired. Three impaired streams would be crossed by the proposed Project in 

Mississippi (Table 3.3.2.1-2) (MDEQ, 2004b). These include Tallahala Creek, Campbell Creek, and 

Dabbs Creek. The proposed Project would not cross any impaired waterbodies in Louisiana or Alabama 

(LDEQ, 2002; ADEM, 2006). Contaminated sediments are not known to occur along the proposed 

Project route. 

TABLE 3.3.2.1-2 

Impaired Waterbodies Crossed by the Proposed Southeast Expansion Project 

Waterbody 

County, 

State1 Impaired Use 

Scenic 

River Pollutant Cause 

Proposed Crossing 

Method 

Dabbs Creek Simpson, 

MS 

Aquatic Life 

Support 

No Biological Impairment HDD 

Campbell 

Creek 

Simpson, 

MS 

Aquatic Life 

Support 

No Biological Impairment HDD 

Tallahala Creek Jasper, MS Aquatic Life 

Support 

No Biological Impairment HDD 

_______________ 

Sources: ADEM, 2006; LDEQ, 2002; MDEQ, 2004b 

1 MS = Mississippi

3.3.2.2 General Impacts and Mitigation 

Waterbody crossings would be conducted using either open-cut or HDD methods, as described 

below and in Section 2.3.2. 
 3-25 

As proposed, 224 minor and intermediate waterbody crossings would be conducted using 

open-cut methods. Twenty-three minor and intermediate waterbody crossings would be conducted using 

HDDs in tandem with the crossing of larger waterbodies and other significant features. The remaining 

minor and intermediate waterbodies exist within the culverted waterbody crossings where no proposed 

changes or impacts to these features are anticipated. 

In addition to the 23 minor and intermediate waterbodies, Gulf South proposes to cross all 

major and navigable waterbody crossings via HDDs, as indicated in Table 3.3.2.1-1. 

TABLE 3.3.2.2-1 

Waterbodies Crossed Using the HDD Construction Method Along 

the Proposed Southeast Expansion Project 

Waterbody County, State1 Begin MP2 End MP 

Dabbs Creek Simpson, MS 12.4 12.4 

Unnamed Simpson, MS 12.6 12.6 

Campbell Creek Simpson, MS 16.1 16.2 

Strong River Simpson, MS 18.0 18.0 

Oakohay Creek Smith, MS 34.1 34.1 

Beaver Creek Smith, MS 34.6 34.6 

Leaf River Smith, MS 44.1 44.2 

Unnamed Smith, MS 44.2 44.3 

Tributary to West 

Tallahala River Smith, MS 45.3 45.3 

West Tallahala River Smith, MS 45.3 45.3 

Tallahoma Creek Smith, MS 55.8 55.9 

Tallahoma Creek Jasper, MS 55.9 55.9 

Tallahala Creek Jasper, MS 62.5 62.6 

Unnamed Jasper, MS 69.3 69.3 

Unnamed Jasper, MS 69.4 69.4 

Unnamed Jasper, MS 69.6 69.6 

Unnamed Pond Clarke, MS 82.6 82.6 

Unnamed Pond Clarke, MS 82.6 82.7 

Shubuta Creek Clarke, MS 82.7 82.7 

Unnamed Pond Clarke, MS 87.8 87.8 

Unnamed Clarke, MS 87.8 87.8 

Unnamed Clarke, MS 87.9 87.9 

Unnamed Clarke, MS 87.9 87.9 
 3-26 

TABLE 3.3.2.2-1 

Waterbodies Crossed Using the HDD Construction Method Along 

the Proposed Southeast Expansion Project 

Waterbody County, State1 Begin MP2 End MP 

Unnamed Clarke, MS 87.9 87.9 

Chickasawhay River Clarke, MS 89.3 89.4 

Unnamed Clarke, MS 94.9 94.9 

Unnamed Clarke, MS 100.4 100.4 

Buctunna Creek Clarke, MS 100.4 100.5 

Okatuppa Creek Choctaw, AL 107.3 107.4 

Gulf South has developed Procedures which are designed to minimize impacts associated with 

waterbody crossings. These measures include, but are not limited to: 

• The 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 instream 

trenching. 

• Using 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 using equipment bridges for passage of other construction equipment. 

• Placing spoil at least 10 feet from the water's edge, with installation of sediment barriers to 

prevent the flow of spoil or silt-laden water to the waterbody. 

• Completing all instream construction activity, including stabilization and recontouring 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. 

• Restoring activities, including restoration of pre-construction bank contours, installation of slope 

breakers, and revegetation of disturbed riparian areas. 

Gulf South indicated that it would construct the proposed Project during the period of 

September 1 through December 31, 2007, pending the Commission's approval of the proposed Project. In 

the Draft EIS, we recommended that Gulf South should file with the Secretary copies of approvals or 

concurrences from the MDWFP and the ADCNR indicating that instream construction between 

December 1 and May 31 is acceptable. On May 30, 2007, Gulf South received approval from the 

MDWFP to construct the proposed pipeline through waterbodies at any time of the year provided such 
 3-27 

activities are performed as outlined in project construction documents. To date, approval from the 

ADCNR regarding instream construction between December 1 and May 31 is pending, therefore, we 

recommend that:

• Prior to construction, Gulf South should file with the Secretary copies of approvals or 

concurrences from the ADCNR indicating that instream construction between December 1 

and May 31 is acceptable. 

General impacts to waterbodies, including sensitive waterbodies, potentially resulting from 

pipeline construction, accidental spills, and construction of aboveground facilities are discussed in more 

detail below. 

Pipeline Construction 

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

result in several temporary effects to water quality and instream habitat. The clearing and grading of 

stream banks, instream trenching, trench dewatering, and backfilling of the instream trench would affect 

water quality and instream habitat by increasing turbidity, sedimentation, water temperature, modifying 

aquatic habitat and decreasing dissolved oxygen (DO) levels. The use 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 could result in accidental spills during construction. 

The extent of the potential impacts resulting from increased sedimentation and turbidity would 

depend on the amount of material disturbed, the sediment grain size, stream velocity, and channel 

stability. These factors would determine the amount of suspended sediment and the downstream distance 

that the suspended sediment is transported. In general, where the streambed consists of fine materials 

such as sand and silt, as is likely along the proposed Project route, the increase in turbidity and suspended 

sediments would be relatively greater when compared to locations where the streambed consists of 

coarser materials such as gravel and cobble. However, stream gradients tend to be relatively low in the 

area of the proposed Project; thus, stream velocities also would tend to be low, indicating that suspended 

sediments within these streams would be transported only over short distances. 

Increased turbidity can reduce light penetration into the water and thereby reduce 

photosynthetic activity and levels of DO in the water column. Organic materials suspended in the water 

can further reduce DO by increasing the biochemical oxygen demand (BOD). Resuspension of sediments 

also can introduce contaminants, metals, and nutrients bound to the sediments into the water column. 

However, because there are no known contaminated sediments located along the proposed Project route, 

adverse effects resulting from resuspension of contaminants would be unlikely. 

If contaminated soils were encountered during construction, Gulf South would implement 

procedures to identify and properly manage the contamination as described in its Plan for the 

Unanticipated Discovery of Contaminated Media. 

The removal of vegetation from riparian areas would result in an increase in surface runoff 

and erosion from the pipeline corridor. However, as specified by its Procedures, the use of temporary and 

permanent sediment controls (e.g., silt fence and slope breakers) would minimize this impact by directing 

surface runoff to well-vegetated areas along the sides of the construction right-of-way. Removal of 

riparian vegetation and the loss of associated shading at waterbody crossings would result in elevated 

water temperatures. However, potential impacts on water temperature are not expected to be significant 

in most cases because of the limited amount of streambank canopy that would be cleared relative to the 
 3-28 

existing riparian vegetation. Following construction, trees and shrubs would also be allowed to 

reestablish themselves on waterbody banks, except for a 10-foot-wide corridor centered over the pipeline. 

We have identified numerous ponds located adjacent to or immediately downstream of the 

proposed pipeline construction right-of-way that would be susceptible to siltation if special attention is 

not given to the use of erosion and sedimentation controls during pipeline construction and restoration of 

the right-of-way. Therefore, we recommend that:

• Gulf South should prevent sediment and heavily silt-laden water from entering ponds 

adjacent to areas disturbed by construction activities. Gulf South should conduct the opencut crossing of the waterbodies feeding these ponds (at the following mileposts: 6.8, 12.5, 

15.0, 25.0, 40.9, 41.6, 51.2, 53.4, 59.5, 60.0, 63.5, 65.1, 75.1, 77.1, 86.9, 87.1, 98.6, and 110.0) 

in a manner that prevents sediment and heavily silt-laden water from entering the ponds. 

Construction Spills 

Gulf South has developed several measures regarding spill prevention, containment, and 

impact minimization in and near waterbodies. These measures include, but are not limited to: 

• Structuring overall operations to reduce the risk of accidental spills or exposure of fuels or other 

hazardous materials into the environment. 

• Properly training employees on handling fuels and other hazardous materials, including: 

o Regular inspection of all equipment to ensure it is in good operating order. 

o Storage of hazardous materials and refueling of equipment at least 100 feet from any 

waterbody or in an upland area at least 100 feet from any wetland. 

o General prohibition of concrete coating activities within 100 feet of a waterbody or wetland. 

o Provisions to have the necessary tools, equipment, and supplies on hand to contain and 

recover spilled materials at the job site. 

o Prompt reporting of any spills to the appropriate agencies. 

In those instances where refueling must be conducted within 100 feet of a waterbody, fueling 

locations must be preapproved by the EI. Gulf South would store adequate amounts of absorbent pads 

and keep containment barriers with each construction crew. These measures were identified as part of 

Gulf South's SPCC Plan, which describes the management of hazardous materials, such as fuels, 

lubricants, and coolants that would be used during construction. 

Aboveground Facilities 

Construction of the proposed aboveground facilities would affect one intermittent waterbody 

and would potentially affect two perennial and two intermittent waterbodies. An intermittent stream 

located on the Delhi Compressor Station site would be rerouted, therefore directly affected. An 

intermittent stream on the Harrisville Compressor Station site and another on the Southern Natural M&R 

Station site would not be crossed. Likewise, two perennial streams on the Destin Compressor Station site 

would not be crossed. To minimize potential indirect effect to waterbodies at these sites, Gulf South 

would implement the erosion control measures described in its plans. These measures include using 
 3-29 

erosion controls (e.g., slope breakers, silt fencing, and mulch) during construction to control runoff, 

reducing the time of soil disturbance, and reestablishing contours and vegetative cover as soon as 

practicable (see Section 3.2.3).

3.3.2.3 Site-Specific Impacts and Mitigation 

Sensitive Waterbodies 

Gulf South proposes to cross the three impaired waterbodies identified in Table 3.3.2.1-2 

using HDD methods. Use of the HDD method to cross these waterbodies would significantly minimize 

potential impacts to these resources; however, should the HDD method fail or a frac-out occur, Gulf 

South would implement its HDD Plan as discussed below. 

Gulf South indicated that there are no state or locally designated surface water protection areas 

within Alabama. Additionally, there are no surface water intakes located within 3 miles downstream of 

the proposed Project waterbody crossings, and no effects to these areas are anticipated. There are no 

known contaminated sediments in waterbodies that would be crossed by the proposed Project. Therefore, 

no impacts to such specially-designated areas are anticipated. There are no designated National Wild and 

Scenic Rivers crossed by the proposed Project. Potential impacts to the Strong River and Chickasawhay 

River, NRI-listed streams, would be avoided through the use of the HDD method and any additional 

measures noted in consultation with the NPS. 

Horizontal Directional Drill Crossings 

Gulf South proposes to use HDDs to install the proposed pipeline across 29 waterbodies, 

including the major waterbodies and all navigable streams, two NRI-designated streams, and streams 

containing potential habitat for listed threatened or endangered species (with the exception of Little 

Creek) as detailed in Appendix D. As described in Section 2.3, HDD is a trenchless crossing method that 

may be used to avoid direct impacts to sensitive resources, such as waterbodies, by directionally drilling 

beneath them. A successful HDD would result in little or no impact to the waterbody being crossed. 

The feasibility of each proposed HDD would be evaluated based on site-specific geotechnical 

data collected at each of the proposed HDD sites. The results of these geotechnical analyses would be 

provided to us for our review prior to construction. In the event of HDD failure, Gulf South could, 

following its HDD Plan, attempt to re-drill the crossing using a different location or profile, change the 

drilling procedures, or employ alternate crossing methods such as open-cut. We do not believe that the 

HDD methods are likely to fail; however, to account for the potential that the planned geotechnical 

analyses could indicate that an HDD crossing is not feasible or if HDD methods fail, we recommend 

that: 

• Gulf South should not begin an open-cut crossing of any of the waterbodies proposed to be 

crossed using HDD until it files an amended crossing plan with the Secretary for review and 

written approval by the Director of OEP. The amended crossing plan should include sitespecific drawings identifying all areas that would be disturbed using the proposed alternate 

crossing method. Gulf South should file the amended crossing plan concurrent with the 

appropriate state and federal applications required for implementation of the plan. 
 3-30 

Hydrostatic Testing 

The withdrawal of large amounts of water for hydrostatic testing of pipeline segments could 

result in several effects to waterbodies. Specifically, water supply, recreation, and aquatic habitat could 

be affected by hydrostatic test water withdrawals. 

The discharge of hydrostatic test water would contribute to a change in water quality of 

receiving waters if the source water quality is different than the receiving water, especially during lowflow or drought conditions when there is less water available in the receiving stream for dilution. Refer to 

Table 3.3.2.3-1 for a summary of hydrostatic test water requirements for the proposed Project. 

TABLE 3.3.2.3-1 

Hydrostatic Test Water Requirements for the Proposed Southeast Expansion Project 

Project Component Water Source 

Withdrawal 

Location 

(MP)5

Approximate 

Volume 

(gallons) 

Discharge 

Location 

(MP) 

Discharge 

Rate 

(gal/min)6

Pipeline 

 Dabbs Creek1,2 12.6 450,000 12.6 1,500 

 Campbell Creek1 16.1 300,000 16.1 1,500 

 Strong River2,3 18.0 6,795,000 18.0 3,000 

 Oakohay Creek 34.1 300,000 34.1 1,500 

 Leaf River 2,4 44.2 9,857,000 44.2 3,000 

West Tallahala 

River2 N/A 

(Trucked in) 

132,000 45.3 1,500 

Tallahoma Creek 55.9 7,200,000 55.9 3,000 

Tallahala Creek1

 62.6 110,000 62.6 1,500 

I-59/CR8 N/A 

(Trucked in) 

150,000 69.6 1,500 

Shubuta Creek 82.7 132,000 82.7 1,500 

Chickasawhay 

River1,2,3,4

89.3 15,605,000 89.3 3,000 

 Bucatunna River2,4 100.4 7,803,000 100.4 3,000 

 Okatuppa Creek4 107.3 300,000 107.4 1,500 

Aboveground Facilities 

Harrisville Compressor 

Station 

Trucked In N/A 50,000 0.0 1,500 

Destin Compressor 

Station 

Trucked In N/A 50,000 82.9 1,500 

Southern Natural M/R 

Station 

Trucked In N/A 10,000 45.7 1,500 

Tennessee Gas M/R 

Station 

Trucked In N/A 10,000 72.5 1,500 
 3-31 

TABLE 3.3.2.3-1 

Hydrostatic Test Water Requirements for the Proposed Southeast Expansion Project 

Project Component Water Source 

Withdrawal 

Location 

(MP)5

Approximate 

Volume 

(gallons) 

Discharge 

Location 

(MP) 

Discharge 

Rate 

(gal/min)6

Destin M/R Station Trucked In N/A 10,000 82.9 1,500 

Transco M/R Station Trucked In N/A 10,000 110.8 1,500 

_______________ 

* The discharge location would be located at the site of the proposed Delhi Compressor Station, which is 89.5 miles northwest 

of MP 0.0 

1 Impaired (biological) waterbody 

2 May contain habitat for threatened and endangered species 

3 Listed in National Rivers Inventory 

4 COE navigable waterbody 

5 MP = Milepost 

6 gal/min = gallons/minute 

7 N/A = Not Applicable

Gulf South would avoid or adequately minimize potential effects to waterbodies resulting 

from hydrostatic testing by implementing its Procedures, which include but are not limited to the 

following measures: 

• Obtaining and complying with all applicable water withdrawal permits and special-status stream 

permits. 

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

wetlands in the SPCC Plan. 

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

for all downstream uses. 

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

organisms. 

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

erosion, scour, turbidity, or excessive streamflow. 

Additionally, Gulf South indicates that biocides, chemical dewatering agents, and other 

potentially toxic hydrostatic test water additives would not be used during hydrostatic testing. Gulf South 

would obtain appropriate NPDES discharge permits prior to conducting hydrostatic testing, would sample 

all test water according to the permit to determine its suitability, and would implement treatment 

measures, if needed, prior to discharge. The MDWFP further requested in its May 30, 2007 approval that 

Gulf South notify prior to withdrawals from streams exhibiting a 7Q10 flow rate for an extended period to 

protect aquatic resources. 

Six waterbodies (Dabbs Creek, Leaf River, West Tallahala River, Chickasawhay River, 

Bucatunna Creek, and Strong River) are sensitive waterbodies that contain threatened or endangered 

species or critical habitat, including habitat for Gulf Sturgeon. Site access to these waterbodies for setting 

up and operating hydrostatic test water withdrawals may require disturbance to their associated riparian 

and wetland areas. In response to our recommendation in the Draft EIS, Gulf South initiated consultation 

with the MDWFP (May 22, 2007) regarding its plans/mitigation for withdrawing water from these 

waterbodies for hydrostatic testing purposes. Gulf South submitted detailed crossing plans, construction 

measures, and hydrostatic test water withdrawal plans to the MDWFP. Plans submitted included site-
 3-32 

specific drawings, descriptions of how these waterbodies would be accessed, alternative hydrostatic test 

water sources, and measures that would be employed to minimize impacts to these waterbodies and 

adjacent riparian and/or wetland resources. 

Gulf South states that access to each of these waterbodies would be obtained by using existing 

pipeline or road rights-of-way to avoid any additional clearing. Gulf South would withdraw and 

discharge to and from these sensitive waterbodies in compliance with its Procedures as well as other state 

and local agency requirements, and would include screened intakes to avoid entrainment of fish and 

energy dissipation devices to reduce erosion and sedimentation. In addition, Gulf South would locate 

hydrostatic testing equipment outside wetlands and riparian zones wherever possible. Site-specific 

drawings of the areas to be disturbed by each hydrostatic test water withdrawal were also submitted to the 

FERC in Gulf South's May 25, 2007, filing. In response to our recommendation in the Draft FEIS, Gulf 

South has provided site-specific plans for the withdrawal of hydrostatic test water from sensitive 

waterbodies. Gulf South's use of these plans should help to ensure that potential impacts to these streams 

and the habitats for rare species they support are adequately minimized. Based on Gulf South's proposed 

measures, compliance with its Procedures, and our requirement to address any additional mitigation 

measures that may result from continuing agency consultations, we believe that impacts to waterbodies 

resulting from hydrostatic testing would be adequately minimized. 

Given compliance with its Procedures, Gulf South's proposed measures and Procedures, and 

our requirement to address any additional mitigation measures that may result from continuing agency 

consultations, we believe that impacts to waterbodies resulting from hydrostatic testing would be 

adequately minimized. 

3.3.3 Conclusion Regarding Surface Water Resources 

The proposed Project would cross numerous waterbodies, but potential impacts to these 

waterbodies would be minimized or mitigated through the implementation of Gulf South's Procedures. 

Most minor and intermediate streams would be crossed using the open-cut method, but they would be 

crossed in less than 48 hours and restored and stabilized rapidly. Major or sensitive waterbodies and all 

designated NRI and navigable waterbodies, would be crossed by HDD and impacts to them would be 

avoided. In the event of HDD frac-out, Gulf South would implement its HDD Plan. Given the measures 

described above and our recommendations, we believe that construction and operation of the proposed 

Project would not significantly affect surface water resources.

3.4 WETLANDS 

Wetlands are areas that are inundated or saturated with 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 (Environmental Laboratory, 1987). Wetlands perform 

a number of valuable functions, including flood flow attenuation, surface water management, filtration of 

non-point source pollutants and compounds, sediment and nutrient retention, and providing wildlife 

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

Section 404 of the CWA of 1972 established standards to minimize impacts to wetlands under 

the regulatory jurisdiction of the COE. These standards require avoidance of wetlands where possible, 

and minimization and compensation for disturbance where impacts are unavoidable, to the degree 

practical. 
 3-33 

3.4.1 Existing Wetland Resources 

Gulf South conducted field investigations to identify, characterize, and survey the boundaries 

of wetland resources along the pipeline construction right-of-way and the areas identified for ancillary 

facilities. 

Using the Cowardin, et al. (1979) wetland classification system, Gulf South identified four 

wetland types within the proposed Project area: 

• Palustrine forested (PFO) 

• Palustrine scrub-shrub (PSS) 

• Palustrine emergent (PEM) 

• Palustrine Open Water (POW) 

Palustrine Forested Wetlands 

PFO wetlands are dominated by woody vegetation, including bottomland hardwoods, that is at 

least 20 feet tall (Cowardin, et al., 1979). These wetlands provide a diverse assemblage of vegetation and 

an abundance of food and cover for wildlife. A significant portion of the PFO wetlands found along the 

proposed route consist of regrowth hardwoods of various ages. Some PFO wetlands also contain mature 

bald cypress (Taxodium distichum) or water tupelo (Nyssa aquatica). Common vegetative species 

typically found in PFO wetlands observed within the proposed Project construction right-of-way include 

water oak (Quercus nigra), swamp chestnut oak (Quercus michauxii), willow oak (Quercus phellos), 

black willow (Salix nigra), water tupelo, bald cypress, American sycamore (Platanus occidentalis), green 

ash (Fraxinus pennsylvanica), sweetgum (Liquidambar styraciflua), red maple (Acer rubrum), tulip tree 

(Liriodendron tulipifera), river birch (Betula nigra), sweetbay magnolia (Magnolia virginiana), 

persimmon (Diospyros virginiana), poison ivy (Toxicodendron radicans), and buttonbush (Cephalanthus 

occidentalis). 

Palustrine Scrub-Shrub Wetlands 

PSS wetlands include all wetlands dominated by woody vegetation less than 20 feet tall 

(Cowardin, et al., 1979). PSS wetlands are typically not as structurally diverse as forested wetlands due 

to the lack of trees comprising the canopy. As with PFO wetlands, PSS wetlands supply an abundance of 

food and cover for wildlife. Common vegetative species found in the PSS wetlands observed within the 

proposed Project construction right-of-way include various bulrushes (Scirpus spp.), wool-grass (Scirpus 

cyperinus), buttonbush, wax myrtle (Myrica cerifera), baccharis (Baccharis halimifolia), swamp cyrilla 

(Cyrilla racemiflora), and sweet leaf (Symplocos tinctoria). 

Palustrine Emergent Wetlands 

PEM wetlands are characterized by erect, rooted, herbaceous hydrophytes, excluding mosses 

and lichens (Cowardin, et al., 1979). Wildlife typically use these areas for nesting and feeding during 

migratory periods. Common vegetative species found in the PEM wetlands traversed by the proposed 

Project construction right-of-way include needlerush (Juncus roemerianus), lizard's-tail (Saururus 

cernuus), narrow-leaved cattail (Typha angustifolia), and southern wild rice (Zizaniopsis miliacea). 

Persistent species found in palustrine systems include cattails (Typha spp.), bulrushes, beakrushes 

(Rhynchospora spp.), saw grass (Cladium jamaicense), sedges (Carex spp.), common reed (Phragmites 
 3-34 

australis), and goldenrod (Solidago spp.). There are also a variety of broad-leaved persistent emergent 

species, such as dock (Rumex mexicanus), waterwouldow (Decodon verticillatus), and smartweeds 

(Polygonum spp.). Non-persistent species found in emergent wetlands include sensitive fern (Onoclea 

sensibilis), cinnamon fern (Osmunda cinnamomea), arrow arum (Peltandra virginica), pickerelweed 

(Pontederia cordata), and arrowheads (Sagittaria spp.). 

Palustrine Open Water Wetlands 

POW wetlands are characterized by areas of open water less than 6.6 feet deep. There are 

often submerged or floating-leaved plants in the shallower portions along the edges of the waterbody 

(abbreviated OW). Common vegetative species found in the POW wetlands traversed by the proposed 

Project construction right-of-way include sedge (Carex sp.), goldenrod (Solidago sp.), giant reed grass 

(Phragmites australis), and soft rush (Juncus effusus). 

The location, wetland classification, crossing length, and affected acreage for each wetland 

that would be affected by construction and operation of the proposed Project is listed in Appendix E. A 

summary of the wetlands affected by the proposed Project is provided in Table 3.4.1-1. 

High-Quality, Sensitive, or Special-Status Wetlands 

PFO wetlands containing significant tupelo and bald cypress trees occur along the proposed route 

and may be considered a component of a relatively higher-quality forested wetland system, especially 

when the specimens are mature and large. Gulf South did not identify lands in the NRCS Wetland 

Reserve Program (WRP) or the associated Prior Converted Wetlands Program along the proposed route. 

TABLE 3.4.1-1 

Summary of Wetlands Affected by the Proposed Southeast Expansion Project 

Location1 Wetland 

Type2

Number of 

Wetland 

Crossings 

Permanent 

Operation 

Impacts 

(acres)3,4,5

Temporary 

Construction 

Impacts 

(acres)5

Estimated 

Crossing Length 

(miles) 

Pipeline

Simpson County, MS 

PEM 9 0 0.28 0.11 

PFO 24 4.43 10.75 1.55 

PSS 8 0 7.75 0.92 

PFO/PEM/PSS 1 0.12 0.24 0.19 

Smith County, MS 

PEM 2 0 0.94 0.21 

PFO 12 4.41 10.03 1.29 

PSS 8 0 0.71 0.27 

PEM/PFO 1 0.07 0.18 0.03 

Jasper County, MS 

PEM 5 0 2.07 0.30 

PFO 14 4.87 11.25 1.59 

PSS 3 0 5.99 0.69 

Clarke County, MS 

PEM 15 0 1.20 0.29 

PFO 16 2.41 5.93 1.84 

PSS 10 0 7.16 0.92 
 3-35 

TABLE 3.4.1-1 

Summary of Wetlands Affected by the Proposed Southeast Expansion Project 

Location1 Wetland 

Type2

Number of 

Wetland 

Crossings 

Permanent 

Operation 

Impacts 

(acres)3,4,5

Temporary 

Construction 

Impacts 

(acres)5

Estimated 

Crossing Length 

(miles) 

PEM/PFO 2 0.52 1.27 0.20 

PEM/POW 1 0 0.15 0.01 

Choctaw County, AL 

PEM 4 0 0.56 0.15 

PFO 1 0.26 0.67 0.03 

PSS 5 0 1.04 0.29 

PEM/PSS 1 0 0.22 0.03 

PEM/PFO 3 0.23 0.55 0.17 

Subtotal Impacts: 145 17.32 68.94 11.08 

Aboveground Facilities 

PEM 0 0 0 N/A 

PFO 0 0 0 N/A 

PSS 0 0 0 N/A 

Subtotal Impacts: 0 0 0 N/A 

Access Roads and ATWSs 

PEM N/A 0 0 N/A 

PFO N/A 0 0 N/A 

PSS N/A 0 0 N/A 

PEM/PFO N/A 0 0 N/A 

Subtotal Impacts: N/A 0 0 N/A 

Total Impacts: 145 17.32 68.94 11.08 

____________ 

1 MS = Mississippi 

 AL = Alabama

2 Wetland Type 

 PEM = Palustrine emergent 

 PFO = Palustrine forested 

 PSS = Palustrine scrub-shrub 

 POW = Palustrine open water 

3 Impact calculations are based on an operationally maintained 30-foot-wide corridor through wetlands. 

4 Permanently maintained forested wetland impacts would result only in a conversion to either PSS or PEM wetlands. PEM and 

PSS wetlands would be allowed to completely revegetate to pre-construction conditions and would result in no conversion or loss

of function. 

5 Permanent maintenance impacts and temporary construction impacts are avoided in wetlands crossed by HDD construction 

methods. Temporary construction impacts are based on a 75-foot-wide corridor through wetlands.

3.4.2 General Wetland Impacts 

The Louisiana portion of the Project does not impact any wetlands. The majority of the 145 

wetlands that would be affected by the proposed Project are located in Mississippi (approximately 

90 percent of the total number), with the remainder occurring in Alabama. As shown in Table 3.4.1-1, 

construction of the proposed Project would result in a total of approximately 68.94 acres of wetland 

disturbance during construction. These impacts would include approximately 38.01 acres of PFO 

wetlands, 2.91 acres of mixed-type wetlands that include a PFO component, and an additional 28.02 acres 

of PSS, PEM, and POW wetlands. The majority of the acreage of forested wetlands affected by this 

Project is associated with riparian zones. 
 3-36 

Construction and operation of the proposed pipeline would result in both short- and long-term 

effects to wetlands. In the short-term, construction activities, including clearing, trenching, spoil 

placement, vehicle traffic, and related construction disturbances, would diminish the recreational and 

aesthetic value of wetlands. Wetland functions, such as erosion control, buffering and flood flow 

attenuation, sediment retention, and nutrient retention, would also be affected by construction activities. 

Construction activities would also result in both short- and long-term loss of wildlife habitat and the 

reduction of habitat quality. 

Effects to wetlands would vary depending on wetland type. Due to the relatively long period 

required for PFO wetlands to regenerate—up to 30 years or more—impacts to these wetland types would 

be long-term. Impacts to PSS wetlands would be mostly short-term, as regeneration would likely occur 

within two to four years. PEM and POW wetlands, which can regenerate more rapidly, would be 

typically affected only temporarily as they may become reestablished in one or two growing seasons. 

During operation of the proposed Project, Gulf South's Procedures allow for annual 

maintenance of a 10-foot-wide strip centered over the pipeline. Additionally, trees that are within 15 feet 

of the pipeline and greater than 15 feet in height may be cut and removed. These activities would not 

affect PEM or POW wetlands as these herbaceous areas would not typically be maintained or mowed. 

However, mowing, clearing, and tree removal would affect PSS and PFO wetlands along the permanent 

right-of-way. Functions associated with these wetland types would be altered as PFO or PSS wetlands 

within the maintained portion of the permanent pipeline right-of-way would be permanently converted to 

an herbaceous state. However, the overall acreage of wetlands would not be significantly reduced. 

3.4.2.1 General Wetland Construction and Mitigation Procedures 

Wetlands affected by the proposed Project are identified in a table in Appendix E. Location 

by milepost, classification, crossing widths, acres of temporary and permanent impacts, and crossing 

methods are included in the table. 

Section 2.3.2 describes the specialized pipeline construction procedures that Gulf South would 

implement to minimize impacts to wetlands. Within the construction right-of-way, Gulf South would 

leave existing root systems intact where possible, would install erosion control devices to minimize 

sediment flow into the wetland, and would use special seed mixes during restoration. Gulf South 

proposes to maintain annually a 30-foot-wide herbaceous right-of-way in wetlands. 

Gulf South would use the minimum construction equipment necessary within wetlands for 

clearing, trench excavation, pipe fabrication and installation, trench backfilling, and restoration activities. 

If standing water or saturated soil conditions were present or if construction equipment caused ruts or 

mixing of the topsoil and subsoil, construction equipment operating in wetland areas would be further 

limited to the use of low ground pressure equipment or normal equipment operating from timber riprap or 

prefabricated equipment mats. Gulf South would also minimize impacts to wetlands by implementing the 

measures identified in its Procedures. These measures include, but are not limited to: 

• Clear marking of wetland boundaries and buffers in the field until construction is complete. 

• Limitation of tree stump removal and grading to the area directly over the pipeline, unless it is 

determined that safety-related construction constraints required grading or removal of tree stumps 

from under the working side of the construction right-of-way. 

• Stripping of topsoil from the area directly over the trench line to a maximum depth of 12 inches 

in unsaturated soils. 
 3-37 

• Minimization of the amount of time that topsoil is segregated and the trench is open. 

• Use of sediment barriers to prevent sediment flow into a wetland. 

• Dewatering of trenches in a way that does not cause sedimentation in a wetland. 

• Use of trench breakers to ensure maintenance of the original wetland hydrology. 

• Prohibition of the storage of hazardous materials and refueling within 100 feet of a wetland. 

• Restoration of pre-construction contours, vegetative restoration, and monitoring. 

In addition to these measures, the COE requires that all appropriate and practicable actions be 

taken to avoid or minimize those 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 proposed wetland crossings would be subject to review by the COE to ensure that wetland 

impacts are fully identified and that appropriate wetland restoration and mitigation measures are 

implemented. Gulf South would also comply with all conditions of the Section 404 authorizations that 

may be issued by the COE. See Section 3.4.4 for additional discussion of compensatory mitigation 

requirements. 

3.4.2.2 Alternative Measures to Our Procedures 

Gulf South has proposed as part of its Procedures, 50 site-specific alternative measures from 

Section V.B.2 (location of ATWSs near waterbodies) and VI.B.1 (location of ATWSs in wetlands) of our 

Procedures. Section V.B.2 of our Procedures states that all ATWSs, such as those used for staging and 

storing additional spoil, should be located at least 50 feet from the water's edge, except where the adjacent 

upland consists of actual cultivated or rotated cropland or other disturbed land. Section VI.B.1 of our 

Procedures states that access roads and ATWSs, such as those used for staging or storing additional spoil, 

should be located at least 50 feet outside of identified wetland boundaries, except where the adjacent 

upland consists of actively cultivated or rotated cropland or other disturbed land. Table 3.4.2.2-1 lists the 

locations and justifications associated with these proposed alternative measures to our Procedures. 

TABLE 3.4.2.2-1 

Proposed Site-Specific Alternative Measures to FERC's Procedures for the 

Proposed Southeast Expansion Project 

Milepost 

Affected 

Wetland 

Area 

(acres) 

Applicable 

FERC 

Procedures 

Section 

Justification 

for 

Alternative Measure 

1.7 0.0b VI.B.1.a ATWS needed for wetland and stream excavation 

5.5 0.0a V.B.2.a ATWS needed for stream bank excavation 

6.8 0.0a VI.B.1.a ATWS needed for side hill slope 

10.2 0.23 VI.B.1.a ATWS needed for road bore 

10.2 0.23 VI.B.1.a ATWS needed for road bore 

10.3 0.23 VI.B.1.a Stream in wetland & ATWS needed for bank excavation 

10.3 0.0a V.B.2.a ATWS needed for stream bank excavation 

12.8 0.0b VI.B.1.a HDD entry/exit next to wetland & ATWS needed for HDD 

13.0 0.32 VI.B.1.a Foreign Pipeline in wetland & ATWS needed for excavation 

14.6 0.0a V.B.2.a ATWS needed for stream bank excavation 

15.6 0.0b VI.B.1.a ATWS needed near wetland for excavation 
 3-38 

TABLE 3.4.2.2-1 

Proposed Site-Specific Alternative Measures to FERC's Procedures for the 

Proposed Southeast Expansion Project 

Milepost 

Affected 

Wetland 

Area 

(acres) 

Applicable 

FERC 

Procedures 

Section 

Justification 

for 

Alternative Measure 

15.8 0.55 VI.B.1.a HDD entry/exit in wetland & ATWS needed for HDD 

17.5 0.0b VI.B.1.a ATWS needed for road bore 

18.3 0.0b VI.B.1.a HDD entry/exit next to wetland & ATWS needed for HDD 

19.5 0.0b VI.B.1.a Foreign Pipeline in wetland & ATWS needed for excavation 

23.6 0.0a V.B.2.a ATWS needed for road bore 

25.8 0.0a V.B.2.a ATWS needed for stream bank excavation 

34.7 0.8 VI.B.1.a HDD entry/exit in wetland & ATWS needed for HDD 

39.8 0.0a V.B.2.a ATWS needed for stream bank excavation 

45.2 0.0b VI.B.1.a HDD entry/exit in wetland & ATWS needed for HDD 

51.8 0.0a V.B.2.a ATWS needed for stream bank excavation and railroad bore 

51.9 0.25 VI.B.1.a ATWS needed for railroad bore 

55.9 0.35 VI.B.1.a HDD entry/exit in wetland & ATWS needed for HDD 

56.2 0.58 VI.B.1.a HDD entry/exit in wetland & ATWS needed for HDD 

59.8 0.02 VI.B.1.a ATWS needed for road bore 

60.6 0.22 VI.B.1.a Stream in wetland & ATWS needed for bank excavation 

65.9 0.46 VI.B.1.a Ditch in wetland & ATWS needed for bank excavation 

66.4 0.6 VI.B.1.a Road in wetland & ATWS needed for road bore 

66.9 0.46 VI.B.1.a Stream in wetland & ATWS needed for bank excavation 

68.7 0.0a V.B.2.a ATWS needed for road bore 

69.6 0.0a V.B.2.a HDD entry/exit near stream & ATWS needed for HDD 

70.5 0.14 VI.B.1.a ATWS needed for road bore 

70.6 0.21 VI.B.1.a ATWS needed for road bore 

78.3 0.0c V.B.2.a ATWS needed for foreign pipeline crossing and side hill slope 

80.3 0.0a V.B.2.a ATWS needed for road bore 

82.2 0.01 VI.B.1.a ATWS needed for foreign pipeline crossing and side hill slope 

82.4 0.0c V.B.2.a HDD entry/exit near stream & ATWS needed for HDD 

83.0 1.19 VI.B.1.a ATWS needed for meter and compressor station construction 

83.3 0.01 VI.B.1.a ATWS needed for road bore 

89.0 0.28 VI.B.1.a HDD entry/exit in wetland & ATWS needed for HDD 

93.4 0.0b VI.B.1.a ATWS needed for road bore 

95.1 0.0c V.B.2.a HDD entry/exit near stream & ATWS needed for HDD 

99.9 0.24 VI.B.1.a Road in wetland & ATWS needed for road bore 

100.2 0.54 VI.B.1.a HDD entry/exit near stream & ATWS needed for HDD 

101.2 0.0a V.B.2.a ATWS needed for stream bank excavation 

102.9 0.14 VI.B.1.a Road next to wetland & ATWS needed for road bore 

104.8 0.0b VI.B.1.a ATWS needed for side hill slope 

104.9 0.0b VI.B.1.a ATWS needed for side hill slope 

106.6 0.0b VI.B.1.a ATWS needed for side hill slope 

110.8 0.77 VI.B.1.a ATWS needed for meter and compressor station construction 

Notes: 

a - No ATWS within stream but is less than 50’ from stream 

b – No ATWS within wetland but is less than 50’ from wetland 

c – Small intermittent stream within ATWS
 3-39 

Based on our review, we have determined that the proposed alternative measures as described 

in Table 3.4.2.2-1 appear reasonable and are adequately justified. Gulf South has provided preliminary 

site-specific drawings for the proposed ATWSs in wetlands. In accordance with its Procedures, Gulf 

South would be required to file these site-specific construction plans prior to the start of construction. 

3.4.3 Site-Specific Impacts and Mitigation 

3.4.3.1 High-Quality, Sensitive, or Special-Status Wetlands 

Gulf South indicates that old-growth tupelo trees occur within the proposed Project right-ofway at or adjacent to three wetland locations as listed in Table 3.4.3.1-1: Wetlands W1CSI004 at MP 

12.7-12.8; W1BJS004 at MP 62.1-62.2; and W9DCK001 at MP 101.1-101.2. No wetlands were 

identified as containing mature cypress trees. To minimize impacts to tupelo and/or cypress trees, Gulf 

South would avoid clearing mature tupelo and/or cypress trees that are greater than or equal to 24 inches 

in diameter at breast height (dbh) within buffer zones comprised of the outermost 10 feet of the spoil side 

of the Project's construction ROW. Mature trees in this buffer zone would not be cut, rather they would 

be avoided and spoil would be placed around them where feasible and where its usage would not 

negatively impact safe construction and operation.

As recommended in the Draft EIS, Gulf South re-surveyed these areas for trees larger than 24 

inches dbh and developed site-specific crossing plans including measures to minimize impacts to these 

mature trees. Approximately 27 mature trees were found to be outside the proposed construction right-ofway limits by 9 to 200 feet, one was found to be within five feet of these limits, and two were found to be 

within 10 feet of the centerline. Gulf South indicated that it could not avoid these two trees for safety 

reasons. Given that most identifiable mature trees are outside of Gulf South's construction work limits, 

and its proposed use of a buffer zone to protect a portion of the mature trees located within or adjacent to 

these wetlands, we believe that with the implementation of Gulf South’s proposed mitigation plan, 

impacts to mature tupelo and cypress trees would be minimized. 

TABLE 3.4.3.1-1 

Forested Riparian Zones along the Proposed 

Southeast Expansion Project 

Milepost 

Approximate 

Distance Crossed 

(feet) 

12.7 to 12.8 1,003 

62.1 to 62.2 211 

101.1 to 101.2 1,478 

3.4.4 Wetland Restoration and Compensatory Mitigation 

The requirements for wetland restoration measures identified in Gulf South's Procedures 

include: 

• Consultation with appropriate land management or state agencies to develop a Project-specific 

restoration plan that includes measures for reestablishing herbaceous and woody species. 
 3-40 

• Prohibition on the use of herbicides or pesticides within 100 feet of a wetland, except as allowed 

by the appropriate agencies. 

• Monitoring of the success of wetland revegetation annually for the first three years after 

construction or until wetland revegetation is considered successful. 

As noted above, Gulf South would complete wetland permitting, including development of 

measures for compensatory mitigation for all wetland impacts in consultation with the COE Mobile 

District. Based on the results of the consultations completed to date, Gulf South proposes to compensate 

for wetland impacts through purchase of wetland mitigation bank credits. Mitigation banking is an 

approved alternative to on-site mitigation and often provides for greater likelihood of success in 

replacement of wetland function and long-term management of restored wetland areas. 

3.4.5 Conclusion Regarding Impacts to Wetlands 

The proposed Project would impact a number of wetlands resulting in short- and long-term 

impacts to wetlands. However, wetland impacts would be minimized by the collocation of the proposed 

pipeline with existing rights-of-way, the use of HDDs, and the implementation of Gulf South's 

Procedures. Given the measures identified in Gulf South's Procedures and its adherence to COE 

permitting requirements, we believe that impacts to wetlands would be adequately minimized and 

mitigated. 

3.5 VEGETATION 

3.5.1 Existing Vegetation Resources 

Construction and operation of the proposed Project would affect five general upland 

vegetative communities: upland forest, pine plantation, open land (scrub-shrub), agriculture, and pasture. 

In addition to the upland vegetation types, the proposed Project would cross PFO wetlands, PSS wetlands, 

PEM wetlands, and POW wetlands, which are discussed in detail in Section 3.4. 

The upland vegetative communities and representative species crossed by the proposed Project 

are described in Table 3.5.1-1. 

TABLE 3.5.1-1 

Upland Vegetation Communities Occurring Along the Proposed Southeast Expansion Project 

Vegetation 

Community General Description Common Species 

Upland Forest Includes slope hardwood and mixed 

hardwood-loblolly pine. In mixed 

hardwood-loblolly pine (Pinus 

taeda) forests, loblolly pine 

comprises at least 20 percent of the 

overstory. These forests trend 

toward hardwood dominance when 

fire is suppressed. 

Drier locations – loblolly pine (Pinus taeda), shortleaf 

pine (Pinus echinata), southern red oak (Quercus 

falcata), red maple (Acer rubrum), cherrybark oak 

(Quercus pagoda), mockernut hickory (Carya 

tormentosa), winged elm (Ulmus alata), black gum 

(Nyssa sylvatica), white oak (Quercus alba). 

Wetter locations – laurel oak (Quercus laurifolia), 

southern magnolia (Magnolia grandiflora), water oak 

(Quercus nigra), blue beech (Carpinus caroliniana), 

eastern hop hornbeam (Ostrya virginiana), sweetgum 

(Liquidambar styraciflua). 

Understory in fire-suppressed areas – sassafras 

(Sassafras albidum), Japanese honeysuckle (Lonicera 
 3-41 

TABLE 3.5.1-1 

Upland Vegetation Communities Occurring Along the Proposed Southeast Expansion Project 

Vegetation 

Community General Description Common Species 

japonica), Sebastian bush (Sebastiania fruticosa), 

gallberry (Ilex glabra), hawthorn (Crataegus spp.), 

sweet leaf (Symplocos tinctoria), swamp cyrilla (Cyrilla 

racemiflora), yaupon (Ilex vomitoria), American holly 

(Ilex opaca), flowering dogwood (Cornus florida), wax 

myrtle (Myrica cerifera), poison ivy (Toxicodendron 

radicans), green briar (Smilax spp.), blackberry (Rubus

spp.), Carolina jasmine (Gelsemium sempervirens). 

Understory in fire-maintained areas – panicum 

(Panicum spp.), broomsedge (Andropogon spp.), 

three-awn (Aristida spp.). 

Pine Plantation Pine plantations are primarily 

managed for pulp and poles, with 

an average rotation time of 20 to 30 

years. 

Loblolly pine. Associated sedges (Carex spp.), 

blackberry, yaupon, greenbriar, and Carolina jasmine. 

Open Land 

(scrub/shrub) 

Includes clear-cut areas that have 

not been replanted and are 

overgrown, and maintained rightsof-way. 

Sapling stage of woody vegetation in upland forest, 

greenbriar, blackberry, peppervine (Ampelopsis 

arborea), holly (Ilex spp.). 

Agriculture Areas under active farming, 

including field crops. 

Wheat (Triticum aestivum) and hay. 

Pasture Improved or unimproved areas 

dominated by grasses and used by 

livestock for grazing. 

Bermuda grass (Cynodon dactylon), crabgrass 

(Digitaria spp.), broomsedge, bluegrass (Poa spp.), 

Bahia grass (Paspalum notatum). 

Pipeline Facilities 

Relatively large areas of upland forest, pine plantation, and open land vegetation, and to a 

lesser extent, agriculture and pasture vegetation, would be affected by construction of the proposed 

pipeline and associated ATWSs. Approximately 591.8 of the 1,580.3 acres (37 percent) that would be 

contained within the pipeline construction right-of-way and ATWSs consist of upland forest. Pine 

plantation (560.6 acres, 35 percent), open land (170.3 acres, 11 percent), pasture (56.3 acres, 4 percent), 

and agriculture (10.4 acres, 1 percent) account for most of the remaining areas that would be crossed (see 

Table 3.5.1-2) by the proposed Project. 

Aboveground Facilities 

The proposed aboveground facilities include three new compressor stations, five M/R stations, 

one side valve, and eight MLVs. Agriculture, upland forest, and pine plantation are the existing 

vegetation cover types at the proposed Delhi, Harrisville, and Destin Compressor Station sites, 

respectively (see Table 3.5.1-2). The CenterPoint M/R Station would be located within the Delhi 

Compressor Station site, and the Destin M/R Station would be located within the Destin Compressor 

Station site. The remaining proposed M/R station sites occur within the upland forest and open land 

vegetation types. MLV sites would impact an additional 0.5 acre of land currently classified as upland 

forest and open land. The remaining acreages impacted by MLV sites would all be located within the 

boundaries of the permanent right-of-way for the proposed pipeline facilities. 
 3-42 

Access Roads 

Gulf South proposes to use 138 access roads, 47 of which would be new and/or upgraded 

roads and 91 would be existing roads to be used without modification. Approximately 98 percent of the 

58.3 acres encompassing new or modified access roads would be within the other/roads category areas 

where vegetation is lacking. The remainder of the vegetation types affected by access roads would be 

comprised of upland forest and open land (see Table 3.5.1-2). 

Pipe Storage and Contractor Yards 

Gulf South indicated that the pipe storage and contractor yards would be located in existing 

commercial and industrial areas, thereby avoiding impacts to vegetation associated with those 

construction-related activities. 

3.5.1.1 Vegetative Communities of Special Concern or Value 

Based on a review of maps, field surveys, available information, and consultations with the 

resource agencies, only Conservation Reserve Program (CRP) lands were identified as lands containing 

vegetative communities of special concern or value. As described further in Section 3.8, the Farm 

Service Agency (FSA) administers the CRP, which is a voluntary program that allows owners of 

agricultural tracts to conserve environmentally sensitive lands with financial assistance from the federal 

government (USDA, 2006). Through the planting of native grasses, trees, and other cover, these 

easements are designed to reduce soil erosion, reduce sedimentation, improve water quality, and establish 

and improve aquatic and wildlife habitat. Vegetation found in these easements performs a critical role in 

providing these ecological values. 

TABLE 3.5.1-2 

Vegetative Communities Affected by the Proposed Southeast Expansion Project 

Pipeline Facilitiesa Aboveground Facilities Access Roads 

Vegetation 

Cover Type 

Temporary 

Construction 

Impact 

(acres) 

Permanent 

Operations 

Impact 

(acres) 

Temporary 

Construction 

Impact 

(acres) 

Permanent 

Operations 

Impact 

(acres) 

Temporary 

Construction 

Impact 

(acres) 

Permanent 

Operations 

Impact 

(acres) 

Upland Forest 591.8 301.2 54.4 34.9 0.4 -- 

Pine Plantationb 560.6 271.7 18.2 11.7 -- -- 

Open Landc 

(scrub-shrub) 

170.3 95.4 3.9 3.2 0.8 -- 

Agriculture 10.4 5.7 69.5 69.5 -- -- 

Pasture 56.3 31 -- -- -- -- 

Total 1,389.4 705 146 119.3 1.2 0.0 

_______________ 

Notes: 

a Acreages based on pipeline, pipe storage and contractor yards, and ATWSs. Acreages reflect a nominal 100-foot-wide 

construction right-of-way. Permanent impacts are based on Gulf South's 60-foot wide permanent right-of-way; however, 

we are recommending that Gulf South's permanent right-of-way be limited to a width of 50 feet. 

b Includes actively planted and harvested pine plantation forests. 

c Includes areas that have been clear-cut without replanting and maintained rights-of-way.

The MNHP identified the wooded seep, spring seep, and wet terrace habitat types as 

potentially occurring within the Project area. However, none of these habitat types were observed during 

field surveys conducted by Gulf South. 
 3-43 

3.5.1.2 Extensive Forested Tracts 

Based on a review of maps, aerial photographs, and field surveys, several areas of large, 

relatively non-fragmented forested tracts would be crossed by the proposed pipeline. Although these 

areas are relatively non-fragmented, Gulf South indicated that many of these tracts are subject to periodic 

harvest and/or thinning. The location of these tracts and the length of the associated crossings are 

identified in Appendix F. 

3.5.2 General Impacts and Mitigation 

The primary impacts of the proposed Project on the identified vegetative communities would 

arise from the removal of vegetation along the proposed pipeline route and at aboveground facility sites 

during construction and routine maintenance. Cutting or removal of vegetation for Project construction 

could lead to increased soil erosion, associated sedimentation and turbidity in streams and wetlands, an 

increase in invasive or exotic plant species, and a reduction in wildlife habitat. Clearing and construction 

activities along the proposed pipeline right-of-way and associated facilities could also result in soil 

compaction. Additionally, heavy machinery could damage riparian vegetation associated with 

waterbodies, whether the equipment is moving or parked for extended periods, thereby potentially 

reducing water quality in adjacent streams. All areas disturbed during construction, but not needed 

permanently as part of the pipeline or aboveground facilities or permanent access roads, would be allowed 

to revert to pre-construction vegetative conditions. 

In those areas where an HDD would be used to cross special features such as waterbodies, 

wetlands, and roads, Gulf South proposes to use hand-laid electric-grid guide wires to assist guidance of 

the drill bit along the proposed route. A small pathway approximately 2- to 3-feet-wide may be cut, using 

hand tools in heavily vegetated areas, in order to position these guide wires. This activity would result in 

minimal disturbance to vegetation along the path of the HDD, and no large trees would be cut as part of 

this process. 

The proposed 60-foot wide permanent right-of-way would be mowed or otherwise maintained 

every three years and a 10-foot-wide corridor over the pipeline centerline would be maintained annually 

in an herbaceous state; however, we are recommending in Section 2.0 that Gulf South should limit the 

width of its right-of-way to 50 feet. 

Periodic maintenance of the permanent pipeline right-of-way would prevent the regrowth of 

forested vegetative communities and would result in regular disturbance of vegetation. Construction of 

the aboveground facility sites would result in permanent conversion of some vegetated areas to a 

non-vegetated industrial/commercial use, either as standing structures or associated facilities such as 

parking and storage areas. 

The severity of the impacts described above would depend on the type of vegetation impacted, 

the size of the area cleared, and the time required for vegetation to become re-established. General 

impacts to vegetation communities are described in further detail below. 

The cutting or removal of vegetation could increase soil erosion potential, increase 

sedimentation and turbidity in streams and wetlands, increase invasive or exotic plant species, and reduce 

wildlife habitat. Additionally, heavy machinery could damage vegetation associated with waterbodies, 

whether the equipment is moving or parked for extended periods. Impacts to forested areas, including 

pine plantations, mixed hardwood-loblolly pine forests, and sloped hardwood forests, resulting from 

construction and operation of the proposed Project, would include a change in vegetative strata, a change 
 3-44 

in appearance, conversion of community type, and loss of habitat. Several of these impacts would be 

long-term as regrowth to pre-construction condition would take 30 years or more. 

Periodic maintenance of the 60-foot-wide, permanent pipeline right-of-way would prevent 

restoration of forested habitat as the area would be mowed or otherwise maintained every three years, and 

a 10-foot corridor over the pipeline centerline would be maintained annually in an herbaceous state. 

Clearing and construction activities along the pipeline right-of-way would also result in soil compaction 

and damage to the trunks, branches, or roots of adjacent trees left standing, thereby reducing their overall 

health and long-term survival. However, Gulf South has committed to implementing the measures 

identified in its plans, which include measures for testing and mitigating soil compaction. 

Permanent impacts would also occur at the proposed aboveground facility sites. Notably, 

permanent impacts to forested areas and/or pine plantations would occur at two of the three proposed 

compressor station sites and at three of the five proposed M/R stations. Permanent impacts to agricultural 

land and open land would also occur in association with construction of the Delhi and Harrisville 

Compressor Stations, and the CenterPoint and Transco M/R Stations. 

To minimize Project-related effects on vegetative communities, Gulf South would implement 

its plans, which identify baseline mitigation measures for minimizing erosion and enhancing revegetation 

in upland areas. Implementation of Gulf South's plans would aid vegetative restoration and prevent or 

minimize sedimentation and turbidity in streams and wetlands. Restoration and best management 

practices identified in Gulf South's plans include the following: 

• Use of at least one EI per construction spread, who would ensure compliance with the plans, 

Procedures, and other required conditions. 

• Segregation of topsoil. 

• Installation of temporary erosion control measures such as slope breakers, sediment barriers, and 

mulch. 

• Commencement of cleanup immediately after backfilling, and completion of restoration within 20 

days. 

• Installation of permanent erosion control devices, such as trench breakers and slope breakers. 

• Testing and mitigation for soil compaction. 

• Revegetation in accordance with the recommendations of the local soil conservation authority, 

other land management agencies, or the affected landowner. 

• Provision of barriers to control off-road vehicle activities. 

• Post-construction monitoring and maintenance of revegetated areas. 

Furthermore, Gulf South's Plan requires that all upland areas disturbed by construction be 

fertilized, limed, and seeded in accordance with the prescribed schedule and seed mixes specified by local 

soil conservation authorities or land management agencies. Gulf South indicates that it has begun 

discussions with state and federal agencies regarding seeding mixtures, but that these consultations are 

not yet complete. To ensure that appropriate vegetative restoration practices would be implemented, we 

recommend that: 
 3-45 

• Prior to construction, Gulf South should consult further with the MDWFP, the LDWF, the 

ADCNR, the NRCS, and other appropriate agencies regarding seeding and vegetation 

restoration practices for the proposed Project. Gulf South should file a report with the 

Secretary for review and written approval by the Director of OEP that describes the 

outcome of these consultations and identifies the agency-recommended seeding and 

vegetation restoration practices that Gulf South plans to implement. 

Project impacts to vegetative communities would vary depending upon disturbance duration, 

magnitude, and vegetation cover type. As described above, approximately 72 percent of the disturbed 

vegetation would be forested. Due to the nature of forest regrowth, the clearing of these areas may result 

in long-term to permanent effects in these areas. These long-term and permanent impacts to forested 

areas would be minimized by the measures described above. Additionally, Gulf South avoids forested 

areas to the extent possible through selective routing, and minimizes impacts to vegetation through 

extensive collocation with existing rights-of-way. Impacts to agricultural, open-land, or pasture lands 

would be minimal and limited primarily to the construction phase. Based on Gulf South's proposed 

measures to avoid and minimize impacts to forested areas, the relatively minor impacts to agricultural 

areas, pastures, and open lands, and the implementation of Gulf South's plans, we believe that impacts to 

general vegetative communities would be minimized.

3.5.3 Impacts and Mitigation to Vegetation Communities of Special Concern or Value 

Conservation Reserve Program Lands 

Most of the general construction impacts described above are applicable to specially 

designated vegetation types or conservation programs depending on the vegetation present. These 

specially designated areas include CRP lands, which may be grassland or forest. 

CRP lands occurring at MP 17.1 in Simpson County Mississippi, MP 37.5 and MPs 41.6 to 

42.4 in Smith County, Mississippi, and an undetermined amount in Clarke County, Mississippi would be 

released from the CRP. Impacts and mitigation for vegetation in CRP lands would be similar to those 

described above, depending on whether each site was forested or not. Impacts to CRP lands are discussed 

in more detail in Section 3.8. 

Extensive Forested Tracts 

The proposed Project may affect extensive forested tracts. The large forested tracts would be 

affected by clearing of the 100-foot-wide construction right-of-way and routine mowing, cutting, and 

trimming along the proposed 60-foot-wide permanent pipeline right-of-way. Cleared forested areas 

located outside of the permanent right-of-way would be allowed to revegetate, but effects to those areas 

would be long-term as vegetative strata would be altered for up to 30 years or more, until mature trees 

replace early herbaceous, shrub, and sapling strata. Forested areas within the 60-foot-wide permanent 

pipeline right-of-way would be permanently affected and replaced by herbaceous and shrubby areas. 

Gulf South attempted to minimize impacts to large, contiguous forested tracts by routing the proposed 

Project along existing rights-of-way to the extent possible (approximately 66 percent of the proposed 

route) and through other previously disturbed areas, such as agricultural and open lands, as well as other 

previously disturbed, fragmented, and/or managed forested areas. We have included a condition 

regarding minimization of impacts to individual trees within certain wetlands previously in Section 

3.4.3.1 
 3-46 

3.5.4 Exotic or Invasive Plant Communities 

Invasive species can out-compete and displace native plant species, thereby negatively altering 

the appearance, composition, and habitat value of affected areas. Chinese tallow tree (Sapium sebiferum) 

was observed at two locations along the route of the proposed pipeline, between MPs 50.74 to 50.84 and 

at MP 52.65. Chinese tallow tree is a deciduous tree reaching up to 60 feet in height that is fast growing, 

can thrive in both wet and dry sites, can displace native vegetation, and is able to successfully invade 

undisturbed forests (Invasive Species, 2006). 

The MNHP identified cogon grass (Imperata cylindrica) and itchgrass (Rottboellia 

cochinchinensis) as potentially occurring within the proposed Project area. Cogon grass is a perennial 

grass that spreads through wind-blown seeds and forms dense infestations by branching underground 

rhizomes, a thick system of mat-forming roots that sprout. Cogon grass competes with hardwood species 

for light, water, and nutrients and can grow so extensively that it decreases growth and increases mortality 

of young trees (Matlack, 2002). Itchgrass is an aggressive weed that is spread by water, animals, 

contaminated crop seed, and harvesting equipment. Needlelike hairs on its leaf sheath break off in the 

skin, which may cause painful infections to people coming into contact with itchgrass. 

In order to minimize the impacts of exotic and invasive species, Gulf South would implement 

its plans, which include measures to reduce erosion such as topsoil stripping and specific vegetation 

restoration measures. Furthermore, as described above, locally prescribed seed mixes and postconstruction monitoring measures would be implemented to further minimize the spread of exotics to and 

within the Project area. 

Gulf South indicates that it would continue to coordinate with federal and state resource 

agencies to identify appropriate control measures for invasive and exotic plant species. Because those 

consultations are not yet complete, we recommend that: 

• Prior to construction, Gulf South should file with the Secretary for review and written 

approval by the Director of OEP, an Exotic and Invasive Species Control Plan developed in 

consultation with the FWS, the LDWF, the MDWFP, the ADCNR, and the NRCS. This 

plan should identify the specific measures that Gulf South would implement during 

construction and operation to control exotic and invasive plant species. 

The temporary removal of vegetation may result in increased opportunities for invasive and 

exotic species to establish themselves in Project rights-of-way and ATWSs. Adherence to its plans in 

conjunction with consultations with local and state agencies would minimize the potential for the 

introduction or establishment of nuisance and exotic species within the proposed Project area. 

3.5.5 Conclusion Regarding Impacts to Vegetation 

The proposed Project would impact five upland vegetation communities (see Table 3.5.1-1) that 

would include CRP lands and extensive forested tracts. Long-term and permanent effects would occur 

within the permanent right-of-way within forested areas. However, vegetation impacts would be 

minimized by the collocation of the proposed pipeline with existing rights-of-way and the implementation 

of Gulf South's Procedures. Based on Gulf South's proposed measures to avoid and minimize impacts to 

forested areas, the relatively minor impacts to agricultural areas, pastures, and open lands, and the 

implementation of Gulf South's plans, we believe that impacts to general vegetative communities would 

be minimized.
 3-47 

3.6 WILDLIFE AND AQUATIC RESOURCES 

3.6.1 Wildlife 

3.6.1.1 Existing Wildlife Resources 

A variety of wildlife species and habitat types would be crossed by the proposed Project. 

Representative wildlife species commonly found with the proposed Project area are listed in 

Table 3.6.1.1-1. Upland forest, pine plantation, open land, PFO, PSS, PEM, and POW habitats would all 

be affected by construction and operation of the proposed Project. Threatened and endangered species 

and state-listed species are discussed in Section 3.7, and colonial nesting birds and migratory birds are 

discussed below. 

Wildlife Species 

Migratory Birds

The Migratory Bird Treaty Act regulates the taking of, or impacts to, migratory birds, 

including their nests. Gulf South identified 170 migratory bird species that could potentially occur along 

the proposed Project. Migratory birds would be expected to occur at least as transients in the proposed 

Project throughout most of the year. Although construction and maintenance of the pipeline right-of-way 

would benefit some species through the creation and maintenance of edge habitats, other species would be 

adversely affected, especially if nesting activities were disturbed by vegetative clearing activities 

associated with construction and maintenance of the proposed Project. 

The Project would be constructed between September and December, as proposed, thereby 

avoiding the major migratory bird spring nesting season. Additionally, Gulf South would not conduct 

routine vegetative maintenance of the full pipeline right-of-way more frequently than once every three 

years, except along a corridor not exceeding 10 feet in width, centered on the pipeline, which would be 

maintained annually in an herbaceous state to facilitate periodic corrosion and leak detection surveys. 

Furthermore, Gulf South indicates that routine vegetative maintenance clearing would not occur between 

April 15 and August 1 of any year to minimize the potential for Project-related disturbance of migratory 

bird nesting periods. The potential exists for Project-related construction activities to occur during the 

migratory bird nesting season if construction were delayed, but population-level impacts would not be 

expected if impacts did occur. 
 3-48 

TABLE 3.6.1.1-1 

Representative Wildlife Species That Occur Along the Proposed Southeast Expansion Projec

Upland Forest Wetlands 

Common Name Scientific Name 

Mixed 

Loblolly/

Hardwood 

Forests 

Slope 

Hardwood 

Forest 

Pine 

Plantation 

Forested 

(PFO) and 

ScrubShrub 

Wetlands 

Emergent 

Wetlands 

(PEM) 

Pine warbler Dendroica pinus X X X Brown-headed nuthatch Sitta pusilla X X X Red-headed woodpecker Melanerpes erythrocephalus X X Wild turkey Meleagris gallopavo X X X Mourning dove Zenaida macroura X X Northern bobwhite Colinus virginianus X X Wood duck Aix sponsa X X Louisiana waterthrush Seiurus motacilla X Green heron Butorides virescens X X Red-tailed hawk Buteo jamaicensis X X X Mississippi kite Ictinia mississippiensis X X X X Red-winged blackbird Agelaius phoeniceus X X White-tailed deer Odocoileus virginianus X X X X X Cottontail rabbit Sylvilagus spp. X X White-footed mouse Peromyscus leucopus X X X Hispid cotton rat Sigmodon hispidus X X X Opossum Didelphidae X X X Raccoon Procyon spp. X X X X X Gray squirrel Sciurus carolinensis X X Nine-banded armadillo Dasypus novemcinctus X X X River otter Lutra canadensis X X Nutria Myocastor coypus X X Three-toed box turtle Terrapene carolina triunguis X X Western cottonmouth Agkistrodon piscivorus 

leucostoma 

 X X 

Bullfrog Rana catesbeiana X X Southern leopard frog Rana sphenocephala X X Green tree frog Hyla cinerea X X 
 3-49 

Colonial Nesting Waterbirds

"Colonial nesting waterbirds" is a collective term used to refer to a variety of bird species that 

obtain all or most of their food from aquatic and wetland environments and gather in large colonies, or 

rookeries, during their respective nesting seasons (FWS, 2002). Colonial nesting waterbirds concentrate 

in these rookeries on sandbars and islands within or along riparian zones or major waterways. According 

to consultations with FWS, no colonial nesting birds are anticipated to occur within the Project area. 

Additionally, no colonial nesting water birds were noted in the survey corridor. However, Gulf South 

would include training material for construction workers to familiarize them with the identification of 

waterbird colonies, and all EIs would be trained to notify Gulf South immediately upon the unanticipated 

discovery of a waterbird colony in the proximity of the right-of-way. In the unlikely event that a 

waterbird colony is encountered, Gulf South would implement appropriate measures to meet site-specific 

needs and would coordinate with the FWS and applicable state agencies as necessary. 

Habitat Types 

Upland Forest

Approximately one-half of the proposed Project would cross upland forest habitat which 

consists of loblolly pine-hardwood/pine forests and slope hardwood forest. Although pine/hardwood 

forests can have an understory of small shrub species and herbaceous growth, the understory would 

naturally trend toward hardwood dominance without periodic fire suppression. This habitat type provides 

necessary food, cover, and young-rearing habitat for a wide variety of wildlife species. 

Pine Plantation

Pine plantations provide various elements necessary to support wildlife populations. Early 

and intermediate successional stages are typically the stages that are most highly used by wildlife. 

However, even after the canopy has closed, openings, edge habitat, and areas periodically subjected to 

prescribed fire can provide relatively good habitat and forage capable of sustaining a diverse wildlife 

assemblage. Many of the species that inhabit the mixed and slope forests use adjacent pine plantations at 

different times. The numbers and types of wildlife are usually greater along the edges. 

Open Land

Open lands include maintained utility rights-of-way, upland scrub-shrub areas, and other nonagricultural herbaceous areas. Plant species in these areas include saplings of many of the tree species 

listed above, along with smilax (Smilax spp.), dewberries (Rubus spp.), peppervine (Ampelopsis arborea), 

holly species (Ilex spp.), and various grasses. Open lands generally provide poor to moderate quality 

wildlife foraging habitat and moderate to good cover habitat; however, the open land cover type is 

important to many of the same species found in the forested habitats because it provides "edge" habitat 

that is important for feeding and raising young. Edge habitats are transition zone areas where two 

different habitat types meet, such as forested and open land or agriculture fields. These transition zones 

provide distinct changes in available food types, unique nesting or breeding habitats, and travel corridors. 

Typical edge species that are somewhat dependent on this type of land cover are the white-tailed deer 

(Odocoileus virginianus), red-tailed hawk (Buteo jamaicensus), eastern meadowlark (Sturnella magna), 

cotton mouse (Peromyscus gossypinus), raccoon (Procyon lotor), opossum (Didelphis virginianus), 

striped skunk (Mephitis mephitis), and various migratory birds. 
 3-50 

Wetlands

Wetland types crossed by the proposed Project include PFO, PSS, PEM, and POW 

communities. For a more detailed description of each of these wetland types, refer to Section 3.4. 

Although a number of the wildlife species noted above may occupy these wetland areas from time to time 

and depend on them for a portion of their normal habitat, several species are typically found only in these 

land cover types. Among the animals that are normally found only in wetland ecosystems are the wood 

duck (Aix sponsa), American wigeon (Anas americana), cottonmouth (Agkistrodon piscivorus), diamondbacked water snake (Nerodia rhombifer), southern leopard frog (Rana sphenocephalus), bullfrog (Rana 

catesbiana), beaver (Castor canadensis), green heron (Butorides striatus), various other reptiles and 

amphibians, and numerous neotropical migratory songbirds. During periods of flooding, these areas also 

provide important wintering habitat for migratory waterfowl such as mallard ducks (Anas platyrhynchos). 

3.6.1.2 General Impacts and Mitigation 

The extent and duration of impacts to wildlife and their habitats resulting from construction 

and operation of the proposed Project would depend on the species present in each habitat type and their 

individual life history requirements. 

Pipeline Facilities 

Construction of the proposed pipeline would require the clearing of vegetation within the 

construction right-of-way, which would temporarily remove and reduce the quality of cover, nesting, and 

foraging habitat for wildlife. The loss and reduction in quality of wildlife habitat would result in the 

temporary displacement and avoidance of wildlife, which would increase stress, injury, and the potential 

for mortality. Less mobile species may be affected by construction activities due to direct mortality or 

permanent displacement, potentially affecting reproduction, recruitment, and survival. 

Similar effects, although much less extensive, would result from routine maintenance of 

vegetation along the permanent right-of-way. Approximately 60 percent of the total upland forested area 

(including pine plantation) affected during construction, and approximately 42 percent of the affected 

PFO wetlands, would be permanently affected by maintenance of the pipeline right-of-way during 

operations. Areas within the permanent right-of-way would be permanently converted and maintained as 

PEM or PSS wetlands. 

Non-forested habitats that would be affected by construction and operation of the proposed 

Project include agricultural areas, pastures, open lands, PSS, and PEM wetlands. Refer to Section 3.8 for 

a summary of the acreage impacts to each of these habitats. The impact on these habitats and associated 

wildlife species would be relatively minor and either temporary or short-term. Temporary impacts to 

wildlife along the pipeline corridor and associated workspaces would be limited to the time of 

construction activities. However, these impacts would be of relatively short duration and species and 

their habitats should recover quickly. Due to the rapid pace of pipeline installation and the vegetation 

restoration measures included in Gulf South's plans and Procedures, the areas would generally be restored 

within one growing season or within three years after construction for scrub-shrub habitats. Following 

construction, all extra work areas outside the permanent right-of-way, including ATWSs, would be 

allowed to revert to pre-construction conditions. In wetlands, all workspace outside the 30-foot-wide 

permanently maintained right-of-way would likewise be allowed to revert to natural conditions. Gulf 

South's Procedures allow for periodic selective thinning of trees within 15 feet of the pipeline that grow 

taller than 15 feet in wetlands, and this selective thinning is anticipated to have minimal impact on 

wildlife. 
 3-51 

Effects to wildlife using forest habitats would be more severe than that to wildlife inhabiting 

other habitat types, as vegetative strata in those areas would undergo a more marked change. These 

changes include the conversion of forested habitat to non-forested habitat within the permanent right-ofway and competition with other species for food and foraging areas. Potential impacts to wildlife would 

include not only the broader loss of habitat in general, but also potential losses of den or nesting sites. 

The area of upland forest, pine plantation, and PFO habitats that would be affected by construction of the 

proposed Project would be considerable locally. With the exception of the 15-foot selective tree thinning 

mentioned above, disturbed areas located outside the permanent right-of-way would be allowed to revert 

to their pre-construction cover type, but this process would take 30 years or more in some forested 

habitats, representing a long-term impact. Construction would affect a relatively small percentage of the 

forested habitats in the general vicinity of the proposed Project, and routine maintenance activities during 

operations would be relatively infrequent and performed in accordance with Gulf South's Plan and 

Procedures. 

Gulf South would minimize impacts to wildlife species and habitats resulting from 

construction and operation of the proposed Project through the implementation of its plans and 

Procedures. Gulf South would also mitigate impacts to wildlife species and habitats through avoidance 

and minimization. Specifically, the proposed route would be collocated with or parallel existing utility 

rights-of-way where possible, thereby minimizing impacts to previously undisturbed wildlife habitats. 

The collocation and overlapping of rights-of-way would substantially reduce the amount of wildlife 

habitat clearing required as compared to construction in greenfield or other areas where overlapping was 

not possible. 

Aboveground Facilities, Pipe Storage and Contractor Yards, and Access Roads 

Construction of the aboveground facilities would permanently affect several wildlife habitats; 

however, these areas represent a small percentage of the land area and wildlife habitats affected by the 

proposed Project. Generally, wildlife occurring in these areas would be permanently displaced, which 

would result in increased stress, injury, and/or mortality. 

Construction of the proposed Delhi, Harrisville, and Destin Compressor Stations, M/R 

stations, ancillary valves, pig launchers, and receivers would permanently impact approximately 

46.6 acres of upland forested habitat (including pine plantation). Additionally, approximately 69.5 acres 

of agriculture and 3.2 acres of open lands would be permanently affected by operation of aboveground 

facilities. Areas temporarily disturbed during construction of the aboveground facilities would be allowed 

to revert to their pre-construction conditions. All disturbed areas associated with the aboveground 

facilities that would not contain infrastructure, such as buildings and other enclosures, would be finishgraded and seeded or covered with gravel, as appropriate. All roads and parking areas would be graveled. 

Thus, construction of the aboveground facility sites would result in the loss and permanent conversion of 

some existing wildlife habitat into potentially non-vegetated industrial/commercial uses. No wetlands or 

waterbodies would be affected by maintenance of these aboveground facilities. 

Three pipe storage and contractor yards would be used for storage and construction of pipeline 

materials and facilities and would affect approximately 41.0 acres of previously classified commercial/

industrial use. This acreage would only be temporarily impacted by construction. 

Gulf South stated that it would access the proposed pipelines and facilities using public and 

private roads to the extent practical. In addition, improvement or addition of access roads would cause 

temporary impacts to approximately 0.4 acre of upland forested areas and 0.8 acre of open land. There 

are also no anticipated construction impacts to agricultural or pasture habitats. Section 3.8 provides 

additional information on access roads planned in association with the proposed Project. 
 3-52 

3.6.1.3 Conclusion Regarding Impacts to Wildlife Habitats and Species 

The proposed Project would affect wildlife and wildlife habitats along the proposed route. 

Impacts would be temporary, long-term and permanent. Specifically, wildlife would be displaced, 

injured, or killed by construction activities, but these impacts would be minor on a population level. 

Based on the characteristics of identified wildlife and wildlife habitats, anticipated impacts to them, and 

measures proposed by Gulf South to avoid or minimize these impacts, we believe that construction and 

operation of the proposed Project would not significantly impact wildlife and wildlife habitats. 

3.6.2 Aquatic Resources 

3.6.2.1 Existing Aquatic Resources 

As described in Section 3.3.2, the proposed Project would cross a total of 308 waterbodies: 

103 perennial streams, 196 intermittent streams, and 9 ponds. Fishery classifications, timing restrictions, 

and other general information regarding the surface waterbodies crossed by the pipeline route were 

obtained from FWS, LDWF, MDWFP, MNHP, ADCNR, and ADEM. These waterbodies are classified 

as warmwater and support numerous aquatic species, including fish and mussels. Table 3.6.2.1-1 lists 

warmwater fish and mussel species commonly found in waterbodies affected by the proposed Project. 

Refer to Section 3.7.1 for more detailed information regarding potential impacts to threatened and 

endangered species potentially existing in waterbodies traversed by the proposed Project. 

No essential fish habitat (EFH), as managed by the National Marine Fisheries Service (NMFS) 

is located within the proposed Project area. 

TABLE 3.6.2.1-1 

Fish and Mussel Species Occurring in the Proposed 

Southeast Expansion Project Area 

Common Name Scientific Name 

Fish 

Alligator gar Atractosteus spatula 

Bigmouth buffalo Ictiobus cyprinellus 

Black crappie Poxomis nigromaculatus 

Bluegill sunfish Lepomis macrochirus 

Channel catfish Ictalurus punctatus 

Largemouth bass Micropterus salmoides 

Long-eared sunfish Lepomis megalotis 

Longnose gar Lepisosteus osseus 

Red-eared sunfish Lepomis microlophus 

Spotted gar Lepisosteus oculatus 

White crappie Poxomis annularis 

Mussels

Round pearlshell Glebula rotundata 

Bankclimber Plectomerus dombeyanus 

Bleufer Potamilus pupuratus 

Mapleleaf Quadrula quadrula 
 3-53 

TABLE 3.6.2.1-1 

Fish and Mussel Species Occurring in the Proposed 

Southeast Expansion Project Area 

Common Name Scientific Name 

Southern mapleleaf Quadrula apiculata 

Tapered pondhorn Uniomerus declivus 

Three ridge Amlema plicata 

Wabash pigtoe Fusconaia flava 

Washboard Megalonaias nervosa 

Threehorn Obliquaria reflexa 

Pondmussel Ligumia subrostrata 

Pistolgrip Tritogonia verrucosa 

Paper pondshell Utterbackia imbecillis 

Fisheries of Special Concern 

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. 

As described previously, the proposed Project would cross seven waterbodies that may contain 

threatened or endangered species or critical habitat; Little Creek (MP 7.1), Strong River (MP 18.0), 

Dabbs Creek (MP 12.4), Leaf River (MP 44.2), West Tallahala River (MP 45.3), Chickasawhay River 

(MP 89.3), and Bucatunna Creek (MP 100.5). Dabbs Creek, Leaf River, West Tallahala River, 

Chickasawhay River, Bucatunna Creek, and the Strong River are designated as critical habitat for the 

Gulf sturgeon (Acipenser oxyrinchus desotoi), and the Strong River is critical habitat for the Ringed Map 

Turtle (Graptemys oculifera). The Chickasawhay, Leaf, and Strong Rivers could provide suitable habitat 

for the threatened yellow-blotched map turtle (Graptemys flavimaculata). Little Creek is designated as 

critical habitat for the Natchez stonefly (Alloperla natchez). Each of these species is discussed in more 

detail in Section 3.7. 

3.6.2.2 General Impacts and Mitigation 

Gulf South's proposed waterbody crossing methods are listed in Appendix D of this EIS. 

Depending on the construction method used, direct impacts to aquatic habitats and species would either 

be avoided (e.g., through HDD) or would occur in localized areas. Waterbody crossings would be 

accomplished using open-cut or HDD methods, as described in detail in Section 2.3. The use of the opencut crossing method would result in several temporary effects to aquatic resources, including plankton, 

aquatic vegetation, amphibians, fish, and aquatic invertebrates including mussels. Impacts to water 

quality and associated aquatic habitats would include sedimentation, turbidity, altered water temperatures 

and dissolved oxygen levels, and introduction of contaminants, all of which can affect the ability of 

aquatic life to survive and reproduce. Impacts would also include the physical disturbance or destruction 

of in-stream habitat due to trenching and removal of riparian vegetation. Construction activities would 

also result in blockage of fish migrations, interruptions of spawning activities, as well as entrainment of 

fish or reduced stream flows during withdrawals for hydrostatic testing. These potential impacts are 

discussed below in more detail. 
 3-54 

Pipeline construction using open-cut methods would result in sedimentation and turbidity in 

surface waters and aquatic habitats. Sedimentation and turbidity-related impacts were previously 

described in Section 3.3.2.2. Resulting disruptions of aquatic life-support processes could include 

physical disturbance, interruptions to fish passage, altered water temperatures and dissolved oxygen 

levels, and the introduction of contaminants. Benthic macroinvertebrates, which typically provide a key 

food source for fish, may be buried under accumulated sediments along with fish nesting sites containing 

eggs or larvae. However, stream gradients tend to be relatively low in the area of the proposed Project; 

thus, stream velocities would also tend to be low, indicating that suspended sediments within these 

streams would only be transported over short distances. As described in Section 3.3.2.2, some of these 

impacts would be lessened or avoided by Gulf South's use of sediment and erosion controls during 

construction, hydrostatic test water discharge measures, the relative lack of riparian vegetation to be 

cleared along waterbody banks, and measures to revegetate riparian and wetland areas. Overall, the 

impact to aquatic species resulting from construction of the proposed Project would be minor, localized, 

and short-term, as most waterbody habitats would remain undisturbed. Additionally, many of the 

warmwater species that occur in the waterbodies crossed by the proposed Project route are accustomed to 

occasionally turbid conditions and are therefore resilient to such periodic impacts. 

Gulf South indicated that it would construct the proposed Project during the period of 

September 1 through December 31, 2007, pending the Commission's approval of the Project. The 

proposed schedule for construction is partially outside the standard period for construction in waterbodies 

containing warmwater fisheries (i.e., June 1 through November 30). In order to ensure that the proposed 

Project does not significantly affect fisheries resources we recommend in Section 3.3 that Gulf South 

consult with the FWS, MDWFP, and ADCNR regarding the timing of construction in waterbodies and 

file approvals with the Commission. As described above and in accordance with Gulf South's 

Procedures, erosion and sediment control best management practices would be implemented at all 

waterbody crossings during construction to reduce impacts to affected waterbodies. 

As described in Section 2.3, HDD is considered a preferred method for crossing sensitive 

habitats because stream bottom disruption and subsequent impacts to aquatic habitats along that portion 

of the pipeline route would be eliminated or minimized. HDD construction methods are discussed in 

Section 3.3.2.2. Gulf South has developed a HDD Plan that describes the procedures that would be 

implemented to monitor for, contain, and clean up any potential releases of drilling fluid during HDD 

operations. Given these protective measures, we believe the risk to aquatic habitats and species from a 

frac-out would be low. 

Overhanging vegetation in riparian and adjacent wetland areas, undercut banks, logs, and 

other streamside features provide cover for fish. These types of cover and instream habitats would be 

disturbed by clearing and open-cut trenching during construction, resulting in decreased shading, 

increased water temperatures, and displacement of fish from disturbed areas. However, streamside 

clearing would be localized and would occur immediately adjacent to the construction right-of-way. 

Overall, these impacts would be relatively minor, as they would affect a relatively small length of a much 

longer, linear, stream feature. 

Introduction of pollutants into waterbodies and aquatic habitats would occur through 

disturbance of contaminated soils or sediments, accidental spills, and inadvertent releases of drilling 

fluids during HDD operations. Pollutants would affect fish and other aquatic life through acute or chronic 

toxicity, and sub-lethal effects would affect reproduction, growth, and recruitment. Additionally, 

pollutants can be introduced during discharge of hydrostatic test waters. However, Gulf South has stated 

that biocides and other potentially toxic hydrostatic test water additives would not be used during 

hydrostatic testing for the proposed Project. The disturbance and resuspension of contaminated soils and 

sediments would result in adverse impacts to water quality and in-stream habitat. However, there are no 
 3-55 

known contaminated sediments along the proposed Project route, and adverse effects resulting from resuspension of contaminants is therefore unlikely. Given these conditions and protective measures, the 

risk to water quality and aquatic species from contaminated soils and sediments is low. 

Construction of the proposed Project would also affect fish by blocking migration pathways 

and interrupting spawning activities. Although construction disturbances would temporarily displace fish 

or hinder migrations in streams, we anticipate that these effects would be localized, temporary, and 

generally minor. We also anticipate that Gulf South's proposal to complete construction activities in fall 

and early winter would further limit or prevent impacts to most species of spawning fish. 

Entrainment of fish and other aquatic organisms could occur during withdrawals of 

hydrostatic test water from the source waterbodies listed in Table 3.3.2.3-1. Gulf South would prevent or 

adequately limit impacts from hydrostatic testing by implementing measures in its Procedures. These 

measures include screening to limit entrainment of fish and maintenance of adequate flow rates to protect 

aquatic life during withdrawals for hydrostatic testing. Although it is possible that fish eggs and larvae 

would be entrained through the screens, such impacts would most likely be minor during the proposed 

winter construction period. 

3.6.2.3 Conclusion Regarding Impacts to Aquatic Habitats and Species 

The proposed Project would result in minor, largely temporary impacts to aquatic habitats and 

species; however, the measures proposed by Gulf South, including the use of HDDs to cross many 

streams, would significantly limit impacts to aquatic species and habitat. Given these measures and the 

temporary and localized nature of impacts, we believe that the proposed Project would result in only 

minor impacts to aquatic habitat and species. 

3.7 THREATENED, ENDANGERED, AND SPECIAL STATUS SPECIES 

3.7.1 Federally Listed Threatened and Endangered Species 

Section 7 of the ESA requires federal agencies to ensure that any action authorized, funded, or 

carried out by the agency does not jeopardize the continued existence of federally listed endangered or 

threatened species or result in the destruction or adverse modification of designated critical habitat for any 

federally listed species. The FERC, as lead agency in the review of the proposed Project, is required to 

consult with the FWS to determine whether federally listed or proposed species or their designated critical 

habitat may occur in the proposed Project area, and to determine the proposed action's potential effects on 

these species and critical habitats. For actions involving major construction activities with the potential to 

affect listed species or designated critical habitats, the FERC must report its findings to FWS in a 

Biological Assessment (BA). 

Based on consultation with the FWS and a review of existing records, we have identified 10 

federally listed threatened or endangered species potentially occurring in the vicinity of the proposed 

Project (Table 3.7.1-1). A description of these species, their preferred habitats, and potential for 

occurrence, as well as our assessment of potential effects to them resulting from construction and 

operation of the proposed Project, is provided below. 
 3-56 

TABLE 3.7.1-1 

Federally Listed Species Potentially Occurring Along the 

Proposed Southeast Expansion Project 

Common Name/Scientific 

Name 

Federal 

Statusa Alabama Statusb Mississippi Statusc Louisiana Statusd

County/Parish (Portion 

of Potential Range 

Crossed by the 

Proposed Project)e

Gopher tortoiseg (Gopherus 

polyphemus)

T T E T Clarke, MS; Choctaw, AL 

Eastern indigo snakeh

(Drymarchon corais)

T T E -- Clarke, MS; Choctaw, AL 

Yellow-blotched map turtleh

(Graptemys flavimaculata)

T -- E -- Clarke, MS 

Ringed map turtleh

(Graptemys oculifera)

T -- E T Simpson, MS 

Louisiana black bearh

(Ursus americanus 

luteolus)

T -- E T Simpson, Smith, Jasper 

and Clarke, MS; Richland, 

LA 

Gulf sturgeonh

(Acipenser oxyrinchus 

desotoi)

T T E T Clarke and Simpson, MS; 

Choctaw, AL 

Bald eaglef, h

(Haliaeetus leucocephalus)

T T E E Statewide in Mississippi; 

Richland, LA; 

Choctaw, AL 

Wood storkh

(Mycteria americana)

E E E -- Choctaw, AL 

Red-cockaded woodpeckeri

(Picoides borealis)

E -- E E Jasper and Smith, MS 

Inflated heelsplitter musseli

(Potamilus inflatus)

T T E T Choctaw, AL 

_______________ 

Notes: 

a http://www.fws.gov/endangered/ 

b Letter dated August 17, 2006, from Penny Ragland (ADCNR) 

c http://www.mdwfp.com/museum/downloads/animal_tracking.pdf 

d http://www.wlf.louisiana.gov/experience/threatened/threatenedandendangeredtable/

 E = Endangered 

 T = Threatened 

e AL = Alabama 

 LA = Louisiana 

 MS = Mississippi 

f Delisted effective August 8, 2007 

g Determination of Effect – may affect 

h Determination of Effect – not likely to adversely affect 

i Determination of Effect – no effect 

Based on our review of these species, we have determined that construction and operation of 

the proposed project would result in no effect to the red-cockaded woodpecker and the inflated 

heelsplitter; is not likely to adversely affect the Louisiana black bear, eastern indigo snake, yellowblotched map turtle, ringed map turtle, Gulf sturgeon (including its critical habitat), bald eagle, and the 

wood stork; and may affect the gopher tortoise. 

With the issuance of the DEIS on April 13, 2007, we requested that the FWS accept the DEIS 

as our BA and requested the initiation of formal consultation as required by Section 7 of the ESA. In a 

letter dated April 23, 2007 to the Commission, the FWS Jackson Field Office acknowledged the receipt of 

the DEIS and accepted our request for initiation of formal consultation. Based on its review of the 

proposed Project and the BA provided by Staff, the FWS issued a Biological Opinion (BO) on July 6, 

2007. In its BO the FWS concurred with our determinations of "not likely to adversely affect" and 
 3-57 

determined that the proposed Project is not likely to jeopardize the continued existence of the gopher 

tortoise, is not likely to adversely modify designated critical habitat and issued an incidental take 

statement. The FWS also identified several non-discretionary terms and conditions applicable to the 

gopher tortoise which must be adhered to in order to be exempt from prohibitions of section 9 of the ESA. 

Additionally, three discretionary conservation recommendations were made by the FWS to further protect 

the gopher tortoise and its habitat. These non-discretionary terms and conditions and conservation 

recommendations have been incorporated into the gopher tortoise species description below. 

Since the issuance of the BO, Gulf South has modified its proposed route and identified new 

access roads and additional temporary workspaces. Gulf South has compiled additional information on 

species occurrence and habitat that has not been reviewed by the FWS; therefore, to ensure that these 

areas are properly reviewed for the presence or absence of federally listed species and their habitats, and 

that any mitigation or construction related to these areas is in accordance with applicable FWS 

requirements, we recommend that: 

• Gulf South should not begin construction activities on modified work areas until: 

a. the staff completes Section 7 consultations with the FWS; and 

b. Gulf South has received written notification from the Director of OEP that 

construction or use of mitigation may begin. 

3.7.1.1 Gopher Tortoise 

The gopher tortoise is a medium-sized turtle with a dark brown to grayish-black colored 

carapace ranging in size from 9 to 11 inches in length, 6 to 10 inches in width, and 8 to 10 pounds in 

weight. Typical gopher tortoise habitat consists of well-drained sandy soils that provide abundant 

herbaceous vegetation for food, and plentiful sunlit areas for nesting and foraging. Gopher tortoises 

excavate burrows in open landscapes such as roadsides, fence-rows, old fields, and the edges of 

overgrown uplands. The size of a gopher tortoise burrow varies depending on the size of the turtle; 

however, burrows are generally about 15 feet long and 6 feet deep with the entrance shaped in the form of 

a half moon. Gopher tortoises are territorial with well-defined home ranges that increase in size with age. 

Gopher tortoises also occur in colonies of two or more active burrows that are typically located within 

600 feet of each other. Gopher tortoises mate between May and July, with nesting taking place from midApril through mid-July (Nature Serve, 2006). 

Using approved FWS survey guidelines and methodologies as described in Appendix K, 21 

gopher tortoise burrows were identified within or adjacent to the proposed Project corridor. 

Construction of the proposed Project, including clearing and trenching, would adversely affect 

gopher tortoises and gopher tortoise habitat found within the temporary construction right-of-way. 

Specifically, as described in Appendix K, Gulf South would relocate gopher tortoises found within the 

proposed temporary construction right-of-way. Gulf South's relocation efforts would result in stress to 

gopher tortoises and could lead to injury and/or mortality. Following the relocation of found gopher 

tortoises, Gulf South would construct the proposed pipeline which would result in the permanent removal 

of existing gopher tortoise burrows and would temporarily affect gopher tortoise habitat by removing 

vegetation and disturbing soils. 

Operation of the proposed Project, including inspection and maintenance (i.e., mowing) 

activities that would require the use of light and heavy equipment, could adversely affect gopher tortoises. 

The general use of equipment could result in stress to gopher tortoises or modification of their habitat. 
 3-58 

Conversely, construction and operation of the proposed Project could also beneficially affect 

gopher tortoises by creating and maintaining habitat that gopher tortoises find favorable. 

In order to minimize potential adverse impacts to gopher tortoises during construction and 

operation of the proposed Project, Gulf South has developed a conservation strategy based on information 

provided by the FWS. Gulf South's conservation strategy is described in detail in Appendix K and 

includes measures to: educate construction personnel; survey for gopher tortoises prior to, during, and 

following construction; collect and relocate gopher tortoises; protect gopher tortoises adjacent to proposed 

construction areas; and monitor and report on these efforts. 

Based on known gopher tortoise characteristics, habitat requirements, proposed construction 

and operation measures and procedures, and Gulf South's conservation strategy, we determined that the 

proposed Project may affect this species, and as required by Section 7 of the ESA we initiated formal 

consultation with the FWS regarding this species. As described above, the FWS determined in its BO 

that the proposed Project is not likely to jeopardize the continued existence of the gopher tortoise, is not 

likely to adversely modify designated critical habitat, and issued an incidental take statement. 

Additionally, the FWS also provided the following non-discretionary terms and conditions regarding 

tortoise relocation efforts: 

a. All tortoise burrows found within the construction ROW, regardless of activity status 

(active, inactive, or abandoned), will be scoped first, then excavated using the backhoe 

method described in the BA to definitively determine that the burrow is unoccupied. 

b. Tortoises that cannot be relocated into an unoccupied burrow will be penned for a 

minimum of two weeks, at which time pens will be removed. 

c. Once released into an unoccupied burrow, or after the two-week penning period, tortoises 

will be monitored using radio-telemetry. The location of each tortoise will be determined 

once each day during the first two weeks, once each week until September 1, and then 

once each month (including dormant season) for one year (September 1 of the following 

year). 

d. If a tortoise moves outside of its original colony range within the first two weeks after its 

release into an unoccupied burrow (or after the two-week penning period), that tortoise 

will be recaptured and temporary-penned for two weeks. 

e. Tortoises collected between October 1 and October 15 will require these additional 

procedures: 

i. Tortoises will be relocated into suitable inactive or abandoned burrows unoccupied 

by another tortoise and enclosed by a suitable pen for the duration of the dormant 

season, until April 1. 

ii. Tortoises will be monitored late in the afternoon when the predicted nighttime low 

temperature will be below 60 degrees. Monitoring will be conducted for each of 

the first five nights when such low temperatures are predicted. Monitoring will 

identify any tortoise located aboveground outside the burrow. The air temperature 

at ground level will be recorded at the time any aboveground tortoise is observed. 

Also, the behavior of any aboveground tortoises will be recorded, noting whether 

animals are moving within the enclosure, digging at the enclosure walls, or whether 

they are stationary at the mouth of the burrow. 
 3-59 

iii. Monitoring will continue after sundown to determine if any aboveground tortoises 

observed during late afternoon have taken shelter in their burrow, or if they remain 

aboveground, or if they periodically emerge aboveground after sundown. If any 

tortoise is found aboveground, its behavior will be observed and recorded with the 

measured air temperature at ground level. If any tortoise is observed aboveground 

at or after sundown, the animal will be pushed into the burrow and the burrow will 

be staked to prevent the tortoise from emerging. Stakes will be removed the 

following morning by 10:00 AM. Monitors will observe special precautions to 

approach the burrows and enclosures quietly so as not to disturb tortoises or alter 

their behavior due to the monitors' presence. 

iv. Whenever a tortoise has been observed aboveground after sundown during such 

monitoring, the MS Field Office will be contacted the next day to report and 

evaluate the observed incident. One of three options will be implemented with 

concurrence of the MS Field Office. 

1. The first option will be a continuation of monitoring, as previously described. 

2. The second option will be to stake the entrance of the burrow closed with 

survey stakes during the late afternoon to prevent the tortoise from leaving the 

burrow at night, regardless of whether the animal is within the burrow when 

the opening is staked. Stakes will be removed during the day, from 10 AM to 

4 PM, to allow for normal basking behavior. On any day following a night 

when the burrow was staked closed, the behavior of the tortoise will be 

monitored and the air ground temperature recorded. If the tortoise remains 

aboveground the following night when temperatures are below 60 degrees, the 

tortoise will be placed in the burrow and the opening staked closed again. The 

MS Field Office must be contacted the next day to determine which of these 

options to continue. 

3. The third option will be a continuation of monitoring, but if the tortoise is 

observed aboveground again, it will be hand-captured from within the 

enclosure and removed to temporary captivity in a climate controlled indoor 

facility. Tortoises must be transported in a suitable container (not a wire cage) 

within the vehicle to the facility. The Service must approve the facility and the 

procedures for captive care for the duration of the dormant season. After 

March 31, any captive tortoises will be transported and released at the site as 

described by the BA. 

f. Following the relocation of tortoises, a report documenting the capture and displacement 

of gopher tortoises will include the following information: (1) names and qualifications 

of the investigators; (2) survey dates; (3) area surveyed; (4) specific burrow locations, 

including UTMs or lat/longs; (5) burrow size, condition, and activity level; (6) the 

individual marking used to identify each relocated tortoise and their associated original 

and relocated burrow sites; (7) date of relocation; and (8) monitoring results. The survey 

report will be sent to the MS Field Office. 

g. The Service will be notified if construction is completed without the capture (trapping or 

excavation) and relocation of gopher tortoises from construction workspaces. 
 3-60 

The FWS has also provided the following discretionary conservation recommendations to 

minimize or avoid adverse effects of the proposed action on listed species and critical habitats, and to help 

carry out recovery plans or to develop additional species information. 

1. Avoid identifying gopher tortoise burrow locations to the public. Undue public attention 

to gopher tortoise colonies may increase the risk of human harassment, injury, and/or 

capture. 

2. Develop a management plan for controlling cogongrass along the new ROW. The plan 

should include the following: 

(a) Gulf South maintenance personnel will be trained to identify cogongrass 

(b) Mowing equipment will be cleaned after mowing cogongrass infected areas 

(c) Cogongrass areas will be treated using appropriate herbicide treatments 

3. Conduct a gopher tortoise burrow inventory of all Gulf South ROWs within the range of 

the federally protected gopher tortoise. This inventory should be completed on a 3-5 year 

rotation, and the results should be sent to the FWS and the Mississippi Museum of 

Natural Science for inclusion into the state's tracking database. 

In order to ensure that the gopher tortoise is protected and to ensure compliance with FWS 

terms and conditions, we recommend that: 

• Gulf South should file a revised Conservation Strategy for the Gopher Tortoise and Eastern 

Indigo Snake that incorporates all non-discretionary terms and conditions of the FWS's BO 

for this Project, as well as conservation recommendations 1 and 2. 

Gulf South proposes to monitor the pipeline ROW for three years following the initial 

relocations of gopher tortoises. Since Gulf South proposes post construction monitoring that we believe 

is sufficient to assess project-related impacts of gopher tortoise relocations, we are not recommending the 

discretionary conservation recommendation 3. 

3.7.1.2 Eastern Indigo Snake 

In the vicinity of the proposed Project, the eastern indigo snake is typically associated with 

inactive gopher tortoise burrows. The eastern indigo snake is generally believed to be extirpated from the 

proposed Project area. However, since gopher tortoise burrows have been identified within and near the 

proposed Project, Gulf South would, based on its consultations with the FWS and to minimize potential 

affects to this species, adhere to Eastern Indigo Snake Protection Measures. These measures are: 

• If an eastern indigo snake is sighted during construction, the contractor would be required to 

cease all operation(s) that might cause harm to the snake. 

• If the snake does not move away from the construction area, a state or federal biologist would be 

contacted to capture and relocate the snake to suitable habitat either adjacent to the Project area or 

off-site to an acceptable donor site. 

• If an eastern indigo snake is killed or found dead within the construction area, the snake should be 

frozen and the FWS Jackson Field Office notified immediately. 
 3-61 

Based on the believed scarcity of the eastern indigo snake and Gulf South's adherence to its 

identified protection measures, we have determined that construction and operation of the proposed 

Project is not likely to adversely affect this species. 

3.7.1.3 Yellow-Blotched Map Turtle 

The yellow-blotched map turtle is a medium sized turtle reaching a maximum of 7 inches 

long. It is only known to exist in the Pascagoula River and its tributaries in Mississippi. The areas along 

the pipeline route that would be expected to contain this species include the Leaf and Chickasawhay 

Rivers (MNHP, 2006). 

The yellow-blotched map turtle's habitat requirements include strong currents and large 

sandbars. This turtle spends several hours each day basking on tree limbs, requiring abundant snags or 

downed trees in rivers wide enough for sunlight penetration. The species is threatened by the recreational 

use of nesting areas such as sand bars and beaches by humans, the colonization of nesting areas by nonnative vegetation, water pollution, and a relatively low reproductive frequency (Nature Serve, 2006). 

Gulf South proposes to cross the Leaf and Chickasawhay Rivers via HDD. In the event of a 

frac-out, Gulf South's HDD Plan would be implemented to minimize any impact to the species. 

Additionally, the drilling fluid that would be used by Gulf South would be non-toxic. Given the proposed 

crossing methods of these rivers and the HDD Plan, we determine that the proposed Project is not likely 

to adversely affect the yellow blotched map turtle. 

3.7.1.4 Ringed Map Turtle 

The ringed map turtle is a medium-sized turtle reaching a maximum of 8 inches in females, 

with a dark, olive green carapace and distinctive black spine-like projections along the middle ridge of the 

carapace. Within the Project area, the ringed map turtle is known to inhabit the Strong River in Simpson 

County, Mississippi (MNHP, 2006). 

Typical ringed map turtle habitat consists of medium- to large-sized rivers with strong currents 

and large, open sandbars suitable for nesting. Like the yellow-blotched map turtle, the ringed map turtle 

spends much of its time basking and requires abundant snags or downed trees in rivers that are wide 

enough to allow for ample sunlight penetration (Nature Serve, 2006). Nesting typically occurs in June 

with the female laying a clutch of three to four eggs. In some cases, nesting may take place twice a year 

(Nature Serve, 2006). The species is threatened by the recreational use of nesting areas such as sand bars 

and beaches by humans, the colonization of nesting areas by non-native vegetation, and water pollution 

(Nature Serve, 2006). 

Gulf South proposes to cross the Strong River via HDD. In the event of a frac-out, Gulf 

South's HDD Plan would be implemented to minimize any impact to the species. Additionally, the 

drilling fluid that would be used by Gulf South would be non-toxic. Given the proposed crossing method 

for the Strong River and the HDD Plan, we have determined that the proposed Project is not likely to 

adversely affect the ringed map turtle. 

3.7.1.5 Louisiana Black Bear 

The Louisiana black bear is closely related to other subspecies of black bear but has a longer, 

narrower skull and larger molars. The Louisiana black bear is primarily associated with forested 

wetlands; however, it may use a variety of habitat types, including marsh, spoil banks, and upland forests. 

Within forested wetlands, black bear habitat requirements include soft and hard mast for food, thick 
 3-62 

vegetation for escape cover, vegetated corridors for dispersal, large trees for den sites, and isolated areas 

for refuge from human disturbance (FWS, 2006b). 

The primary threats to this species are continued loss of bottomland hardwoods and 

fragmentation of remaining forested tracts. In addition to habitat loss, human-bear conflicts are a major 

threat to the conservation and protection of the Louisiana black bear. Losses of bears result from 

collisions with automobiles, intentional/illegal killing, and removal from the wild, which is often 

necessary when bears become habituated to humans (FWS, 2006b). 

Louisiana black bears, particularly pregnant females, normally den from December through 

April. Preferred den sites include bald cypress and water-tupelo trees with visible cavities that have a dbh 

of 36 inches or greater in or along rivers, lakes, streams, bayous, sloughs, and other waterbodies. In areas 

where suitable den trees are uncommon, Louisiana black bears often den in shallow burrows or 

depressions within areas of dense cover. To further protect denning bears, the FWS has extended legal 

protection to actual or candidate den trees. As the terms imply, "actual den tree" refers to any tree used 

by a denning bear during the winter and early spring seasons, and "candidate" den trees are defined in the 

final rule as bald cypress and tupelo gum with visible cavities having a dbh of 36 inches or greater in or 

along rivers, lakes, streams, bayous, sloughs, or other waterbodies. Results of recent research involving 

Louisiana black bears indicate that they use virtually any species of tree for a den site, if it is large enough 

and has a cavity as described above (FWS, 2006b). 

No Louisiana black bear were observed during the field surveys, and no candidate or actual 

denning trees were identified along the proposed Project route. Furthermore, Gulf South would 

implement any agency-recommended measures to mitigate potential impacts to Louisiana black bears 

should they be encountered during construction. Therefore, we have determined that the proposed Project 

is not likely to adversely affect the Louisiana black bear. 

3.7.1.6 Gulf Sturgeon 

The Gulf sturgeon is a large fish known to reach lengths in excess of 8 feet and weights over 

200 pounds. Historically, this species occurred from the Mississippi River to the Suwannee River in 

Florida. In Mississippi, it was found in the Pearl, Bogue Chitto, and Pascagoula River drainages and 

could occur in any of the larger tributaries (MNHP, 2006). 

The Gulf sturgeon is anadromous, spending much of its time in saltwater, but returning to 

freshwater to spawn. Mature adults enter freshwater in the spring to spawn and remain until autumn. 

They have not been recorded feeding while in freshwater and thus only grow in the marine environment. 

Spawning of Gulf sturgeon is not well documented, but the presence of larvae in April and May indicate a 

spring spawning cycle. Ultrasonically tagged females apparently choose stream areas with a rocky 

substrate in the immediate vicinity of springs for spawning. 

Based on consultations with and recommendations from the FWS, the Chickasawhay, Leaf, 

and Strong Rivers are believed to potentially support the Gulf sturgeon. Furthermore, the proposed 

Project traverses the Chickasawhay River within the officially-designated Gulf sturgeon critical habitat. 

Gulf South has indicated that the Chickasawhay, Leaf, and Strong Rivers would be traversed using HDD 

technologies. In the event of a frac-out, Gulf South's HDD Plan would be implemented to minimize any 

impact to the species. Additionally, the drilling fluid that would be used by Gulf South would be nontoxic. Given the proposed crossing methods of the Chickasawhay, Leaf, and Strong Rivers, and the HDD 

Plan, we have determined that construction and operation of the proposed Project is not likely to 

adversely affect the Gulf sturgeon. 
 3-63 

3.7.1.7 Bald Eagle 

The bald eagle is listed as a federally threatened species. However, effective 8 August 2007, 

the bald eagle will no longer be federally listed as threatened in the lower 48 states. However, protection 

provided to the bald eagle under the Bald and Golden Eagle Protection Act (BGEPA) and the Migratory 

Bird Treaty Act (MBTA) will continue to remain in place after the species is delisted. The BGEPA and 

MBTA, known collectively as the Eagle Act prohibit disturbance of eagles, their nests, or their eggs. 

The bald eagle is a large carnivorous bird whose range covers virtually all of North America. 

Bald eagles are large and distinctive birds, with wingspans of close to 7 feet and a body length of 

approximately 35 inches. Adult bald eagles have white heads and tails, yellow bills, feet, and legs, and 

dark brown bodies. Immature birds are brown and lack the white head and tail of the adults. Bald eagles 

are opportunistic foragers, and their diet varies based on prey species available. They prefer fish but 

would eat a great variety of mammals, amphibians, crustaceans, and birds, including many species of 

waterfowl. They frequently scavenge and are often seen with vultures feeding on carcasses. 

Bald eagles are relatively uncommon nesters in the area traversed by the proposed Project. 

They generally construct extremely large nests of sticks in the tops of tall trees, often selecting the tallest 

tree in a given area as a preferred site. Typically, the nest trees selected are in a riparian area, along a 

major river or near a lake. The nests are very conspicuous and are often reused for years and in some 

cases for generations. The southern bald eagle is a winter nester, with most nesting and rearing in the 

Project vicinity occurring from October to May. 

No individual bald eagles or bald eagle nests have been identified within the proposed Project 

area. Based on bald eagle habitat requirements, surveys conducted by Gulf South, the location of the 

proposed facilities, the absence of bald eagle sightings, the lack of suitable habitat, and our consultations 

with the FWS, we have determined that construction and operation of the proposed Project is not likely to 

adversely affect the bald eagle. 

3.7.1.8 Wood Stork 

The wood stork is a large, tall bird with a wingspan of up to 61 inches and a long, downcurved beak that averages 40 inches long. The wood stork has a very large range spanning from the 

southeastern U.S. to South America. 

The wood stork is a non-migratory species that is chiefly found in areas containing freshwater 

marshes, swamps, lagoons, ponds, and flooded fields capable of supporting various fish species and other 

small animals commonly associated with aquatic habitats. The wood stork typically nests in the tops of 

large cypress, mangrove, or dead hardwood trees. Nesting is directly tied to abundant food sources, 

regardless of season (Nature Serve, 2006). 

In Choctaw County, Alabama, it is believed that the wood stork occurs primarily in the eastern 

portion of the county and is unlikely to be found in the proposed Project area (Felder, 2006). 

Based on wood stork habitat requirements, surveys conducted by Gulf South, the location of 

the proposed facilities, the absence of wood stork sightings, the lack of suitable habitat, and our 

consultations with the FWS, we have determined that construction and operation of the proposed Project 

is not likely to adversely affect the wood stork. 
 3-64 

3.7.1.9 Red-Cockaded Woodpecker 

The red-cockaded woodpecker (RCW) requires open pine woodlands and savannahs with 

large, old pines for "cluster" nesting and roosting habitat. RCWs are generally found in colonies that 

consist of a breeding pair and one or more helpers. The helpers are generally young from previous broods 

that assist the breeding adults in feeding the young and in defending the territory against encroachment by 

other woodpeckers. 

Large, old pines are preferred by the RCW as cavity trees and must be in open stands with 

little or no hardwood midstory and few or no overstory hardwoods. As a general rule, the preferred trees 

are quite old, often in excess of 100 years old. They have significant crown volume and a dbh of 

15 inches or greater, although smaller and younger trees are occasionally used. Due to their longevity and 

tendency to develop red heart rot as they age, RCWs prefer longleaf pines (Pinus palustris) as cavity 

trees. They also use short-leaf and slash pines (Pinus elliotii) with some frequency. Loblolly pines are 

used less often due to their relatively short lifespan. 

RCWs also require abundant foraging habitat consisting of mature pines with an open canopy, 

low densities of small pines, little or no hardwood or pine midstory, few or no overstory hardwoods, and 

abundant native bunchgrass and groundcover. Fire suppression (resulting in hardwood encroachment) 

and lack of cavity trees are the foremost factors limiting suitable nesting habitat. Forest fragmentation is 

another primary factor directly limiting potential breeding groups because of the resultant isolation of 

those groups, disrupted dispersal of their helpers, and failure to replace breeders; consequently, areas of 

contiguous habitat represent preferred foraging habitat. 

Consultations with the FWS have indicated that RCW habitat within Jasper and Smith 

Counties, Mississippi, is limited to lands contained within national forests, and that no known suitable 

habitat exists within the proposed Project area (Felder, 2006). Observations made during Gulf South field 

surveys confirmed that forested habitats traversed by the proposed Project contain large percentages of 

hardwood species, or contain a dense understory layer, thus being unsuitable for RCW habitat. 

No RCWs were observed during field surveys along the proposed Project route, and most 

habitat in the proposed Project area is characterized as unsuitable for nesting/roosting and foraging. The 

majority of the pine plantations that would be crossed by the proposed Project consists of young, dense 

pine or older stands of pine in fire-suppressed forests, both of which contain too much midstory 

vegetation to be considered suitable for RCWs. Based on the lack of suitable RCW habitat and our 

consultation with the FWS, we have determined that construction and operation of the proposed Project 

would not affect RCWs. 

3.7.1.10 Inflated Heelsplitter 

The inflated heelsplitter is a small oval mollusk that may reach up to 5.5 inches as an adult. 

The shell is brown to black, and the inside of the shell is pink to purple. The inflated heelsplitter is 

known to occupy soft, stable substrata with slow to moderate current. It occurs in sand, mud, silt, and 

sandy gravel. 

The inflated heelsplitter is historically found in the Amite and Tangipahoa Rivers, Louisiana; 

the Pearl River, Mississippi; and the Tombigbee, Black Warrior, Alabama, and Coosa Rivers, Alabama. 

The current distribution in Alabama is limited to the Tombigbee and Black Warrior Rivers (Nature Serve, 

2006). 
 3-65 

Because the current range of the inflated heelsplitter is outside of the proposed Project area, 

we have determined that construction and operation of the proposed Project would result in no affect to 

this species. 

3.7.2 Special Status Species 

In addition to federally listed species, other special status species may also occur within the 

vicinity of the proposed Project facilities. Special status species include state-listed endangered, 

threatened, imperiled, or rare species, as well as other species of concern identified through consultation 

with MNHP, MDWF, LDWF, and ADCNR. 

State-Listed and Rare Species 

The MNHP, MDWFP, LDWF, and ADCNR have identified 46 species listed as either 

endangered or threatened that potentially occur within the proposed Project area. These species are listed 

in Table 3.7.2-1. No state-listed species were identified during field surveys conducted by Gulf South; 

however, suitable habitat for many of these species was observed within affected work areas. Of these 46 

species, 10 (bald eagle, wood stork, Gulf sturgeon, inflated heelsplitter, Louisiana black bear, gopher 

tortoise, yellow blotched map turtle, eastern indigo snake, RCW, and ringed map turtle) are discussed 

above and are not discussed in this section. As discussed in Section 3.7.1, the ADCNR was not able to 

make a determination as to which threatened or endangered species may potentially occur within the 

proposed Project area; however, a list of threatened or endangered species for Choctaw County, Alabama 

was provided. 

In general terms, impacts to state listed species would be similar to those described above for 

federally listed species. Birds could be affected by the loss of nesting or foraging habitat during clearing 

for the proposed Project, and they could also be disturbed by human activity. Fish and aquatic 

invertebrates could be affected by open-cut construction methods through the alteration of stream habitats 

along with associated increases of turbidity and sediment load. Although larger streams and rivers would 

typically be crossed by HDD methods that would avoid the impacts associated with open-cut crossings, 

frac-outs could occur resulting in turbidity and the deposition of drilling mud. Terrestrial wildlife, such as 

mammals and reptiles, could be subject to mortality or displacement during clearing and could lose 

habitat along the right-of-way. 
 3-66 

TABLE 3.7.2-1 

State Listed and Rare Species Potentially Occurring in the Proposed Southeast Expansion Project Areaa

Species 

Alabama 

Status/Rankb Mississippi Status/Rankb Louisiana Status/Rankb Habitat 

Amphibians 

Red salamander 

(Pseudotriton rubber)

-- S3 -- Cold, clear, rocky streams and springs in wooded or open 

areas. Adults occur in or near water in leaf litter and under 

rocks and in crevices and burrows near water. Adults 

sometimes disperse into woods. Eggs are attached to 

underside of rocks in water. Larvae occur in still pools. 

Bay Springs salamander 

(Plethodon ainsworthi) 

-- SH -- Prefers hardwood forests with fallen logs or debris. May 

occur in springhead litter. 

Birds 

Bachman's sparrow 

(Aimophila aestivalis)

S3 -- S3 Habitats include dry, open pine (southern states) or oak 

woods (e.g., western portion of range) with an undercover 

of grasses and shrubs, hillsides with patchy brushy areas, 

overgrown fields with thickets and brambles, grassy 

orchards, and large clear-cuts (usually at least 

20 hectares). In the southeastern U.S., Coastal Plain 

breeding habitat usually is open pine woods with thick 

cover of grasses or saw palmetto. 

Bewick's wren 

(Thryomanes bewickii) 

SH S2/E -- Brushy areas, thickets and scrub in open country, open 

and riparian woodland, and chaparral. More commonly in 

arid regions but locally also in humid areas (subtropical 

and temperate zones), including country towns and farms. 

Black-crowned night-heron 

(Nyycticorax nyycticorax) 

-- S3? -- Marshes, swamps, wooded streams, mangroves, shores of 

lakes, ponds, lagoons; saltwater, brackish, and freshwater 

situations. Roosts by day in mangroves or swampy 

woodlands. 

Cerulean warbler 

(Dendroica cerulean) 

S1 -- S1 Habitat is frequently described as mature deciduous forest, 

particularly in floodplains or other mesic conditions. 

Henslow's sparrow 

(Ammodramus henslowii) 

S2 -- -- Open fields and meadows with grass interspersed with 

weeds or shrubby vegetation, especially in damp or lowlying areas, adjacent to salt marsh in some areas. Uses 

unmowed hayfields (abandoned if cut). Found in a variety 

of habitats that contain tall, dense grass and herbaceous 

vegetation. 

White ibis 

(Eudocimus albus) 

S3 S3 -- Various saltwater and freshwater habitats: marshes, 

mangroves, lagoons, lakes, marsh prairie, pasture, coastal 

swamps. 

Fish 

Alabama shad 

(Alosa alabamae) 

S2 S1 -- Anadromous; adults live in saltwater and migrate into 

medium to large coastal rivers to spawn. 

Crystal darter 

(Crystallaria asprella) 

S3 S1/E S2S3 Small to medium rivers with expanses of clean sand and 

gravel. Usually in water more than 60 centimeters (cm) 

deep with strong current. 

Frecklebelly madtom 

(Noturus munitus) 

S2 S2/E -- Chiefly in rocky riffles, rapids, and runs of medium to large 

rivers. This small fish's movements are impeded by dams 

and impoundments. 

Pearl darter 

(Percina aurora) 

-- S1/E -- Pearl darters have been collected from gravel riffles and 

rock outcrops; deep runs over gravel and sand pools below 

shallow riffles; swift (90 cm/second), shallow water over 

firm gravel and cobble in mid-river channels; and swift 

water near brush piles. 

Invertebrates 

Natchez stonefly 

(Alloperla natchez) 

-- S2 -- Members of this genus and family are found in cold lotic 

habitats and are very sensitive to eutrophication. 

Prairie mole cricket 

(Gryllotalpa major) 

-- SH -- Inhabitant of prairie soil ranging from mesic to dry-mesic; 

southern tallgrass prairie of the United States. Not found 

in pastures. Some individuals are found in mixed grass 

prairie, although these sites may not be optimal habitat as 

much as habitat that is both acceptable and available. 
 3-67 

TABLE 3.7.2-1 

State Listed and Rare Species Potentially Occurring in the Proposed Southeast Expansion Project Areaa

Species 

Alabama 

Status/Rankb Mississippi Status/Rankb Louisiana Status/Rankb Habitat 

Mussels 

Alabama hickorynut 

(Obovaria unicolor) 

S1 S3 -- Sand/gravel substrates in moderately flowing water. 

Black sandshell 

(Ligumia recta) 

S1 S2 S1 Occur chiefly in flow refuges, or relatively stable areas that 

displayed little movement of particles during flood events. 

Spike 

(Elliptio dilatata) 

-- S1/E S2S3 Large rivers or creeks, medium rivers, and springs/spring 

brooks. 

Delicate spike 

(Elliptio arctata) 

S2 S1/E -- Large rivers and creeks of low gradient. Medium rivers 

with moderate gradient and riffle. 

Mississippi pigtoe 

(Pleurobema beadleianum) 

-- S3? -- Freshwater. 

Pyramid pigtoe 

(Pleurobema rubrum) 

-- S1/E S2 Inhabits large rivers but may occur in medium-sized lotic 

environments. It tends to occupy riffles or shoals in 

relatively shallow water and coarse-particle substrates, 

along sand bars, or in deep water (>4 meters) with mud 

and sand bottoms. 

Ebonyshell 

(Fusconaia ebena) 

-- -- S3 Freshwater. 

Snails 

Silty hornsnail 

(Pleurocera canaliculata) 

-- -- S2 Freshwater. 

Mammals 

Oldfield mouse 

(Peromyscus polionotus) 

-- S2 -- Favors dry, sandy fields and beaches with grass/shrub 

cover. 

Plants 

American Bladdernut 

(Staphylea trifolia) 

-- S3 -- Grows in average, dry to medium wet, well-drained soils in 

part shade to full shade. Tolerates wide variety of soils. 

Prefers moist soils. 

Black-stem spleenwort 

(Asplenium resiliens) 

-- S1 -- In semi-shade or full sun in well-drained calcareous 

substrates; often in cedar glades or on limestone cliffs. 

Canada wild-ginger 

(Asarum canadense) 

-- S2S3 -- Found in upland rich woods, typically higher pH soils and 

associated with calcareous rock outcrops or rich soils; it is 

also found in high nutrient-rich coves in mountains. This 

species is occasionally found in regenerating deciduous 

woodlands. 

Common hoptree 

(Ptelea trifoliate) 

-- S3S4 -- Prefers well-drained soil, full sun or shade, and moist soil. 

Crested coral-root 

(Hexalectris spicata) 

-- S2 -- Calcareous sandy or organic soils in oak, hickory, or 

conifer woods. 

Crested fringed orchid 

(Platanthera cristata) 

-- S3 -- Terrestrial in moist, open, acidic bogs, prairies, pine 

woods, and roadsides. 

Needle palm 

(Rhapidophyllum hystrix) 

-- S3 -- Prefers fairly moist, well-drained soils with abundant 

organic matter but is very adaptable to less than ideal 

conditions. 

Smoother sweet-cicely 

(Osmorhiza longistylis) 

-- S3 -- Rich, often alluvial woods and thickets. Woods often along 

the sides of streams. 

Purple coneflower 

(Echinacea purpurea) 

-- S3, S4 S2 Medium wet, well-drained soil in full sun. 

Yellow water-crowfoot 

(Ranunculus flabellaris) 

-- -- S1 Occurs mainly in wetlands. 

Yellowleaf tinker's-weed 

(Triosteum angustifolium) 

-- -- S2 Open prairies and near the edge of forests. 

Reptiles 

American alligator 

(Alligator mississippiensis) 

-- S4 -- Fresh and brackish marshes, ponds, lakes, rivers, 

swamps, bayous, large spring runs. 
 3-68 

TABLE 3.7.2-1 

State Listed and Rare Species Potentially Occurring in the Proposed Southeast Expansion Project Areaa

Species 

Alabama 

Status/Rankb Mississippi Status/Rankb Louisiana Status/Rankb Habitat 

Southern hognose snake 

(Heterodon simus) 

SH SH/E -- Inhabits open, xeric habitats with well-drained, sandy or 

sandy-loam soils such as sand ridges, stabilized coastal 

sand dunes, pine flatwoods, mixed oak-pine woodlands 

and forests, scrub oak woods, and oak hammocks; also 

old fields and river floodplains. This snake spends 

considerable time burrowed in the soil. 

_______________ 

a In Alabama, Mississippi, and Louisiana, the respective Natural Heritage Commissions have ranked species according to their imperiled status. 

b Rank S1 – Critically imperiled in the state because of extreme rarity (5 or fewer occurrences or very few remaining individuals or acres). 

 Rank S2 – Imperiled in the state because of rarity (6 to 20 occurrences or few remaining individuals or acres) or because of some factor(s) making it 

vulnerable to extirpation. 

 Rank S3 – Rare or uncommon in the state (21 to 100 known populations). 

 Rank S4 – Apparently secure in the state (101 to 1,000 known populations). 

 Rank SH – Historical occurrence; possibly extinct. 

 Rank E – A species that is in danger of extinction throughout all or a significant portion of its range. 

 "?" indicates status uncertain. 

Source: LDWF, 2006; MDWFP, 2006; MNHP, 2002; ADCNR, 2006; Nature Serve, 2006 

Gulf South has indicated that it would continue to consult with the LDWF, MDWFP, and the 

ADCNR to determine whether additional field surveys are warranted for any of the species listed in Table 

3.7.2-1 and, if required, develop mitigation measures to avoid or minimize potential impacts to theose 

species. Because thoese consultations have not yet been completed, we recommend that: 

• Gulf South should continue to consult with the LDWF, the MDWFP, and the ADCNR to 

determine the need for surveys or mitigation that would substantially minimize or avoid 

potential impacts to state-listed species. Gulf South should file copies of the results of these 

consultations, as well as any associated survey reports and mitigation plans, with the 

Secretary prior to construction. 

3.8 LAND USE, RECREATION AND SPECIAL INTEREST AREAS, AND VISUAL 

RESOURCES 

3.8.1 General Land Use Types 

In this section, we further quantify the land requirements for construction and operation of the 

proposed Project, describe current land use types, and evaluate the significance of Project-related impacts 

to those lands, as well as to specially designated areas, transportation corridors, visually sensitive areas, 

and hazardous waste sites. 

There are 10 land use types crossed by the proposed pipeline and affected by the proposed 

aboveground facility sites: agricultural, pine plantation, upland forest, pasture, open land, open water, 

residential land, industrial/commercial land, wetlands, and other roads. Table 3.8.1-1 identifies the 

amount of acreage by land use type that would be affected by construction and operation of the proposed 

Project. 

Construction of the proposed Project would affect approximately 1,726.5 acres (Table 

3.8.1-1). Approximately 1,240.3 acres (72 percent) of that acreage would be contained within the 

pipeline construction right-of-way. Construction of aboveground facilities would affect approximately 

146.2 acres (8 percent), and the remaining 340.0 acres (20 percent) would be affected by the use of 

ATWSs, access roads, pipe storage, and contractor yards. Approximately 646.6 acres (37 percent) of the 
 3-69 

land that would be affected during construction is currently characterized as upland forest, 578.8 acres 

(34 percent) would be pine plantation, and 175.0 acres (10 percent) would be open land. The remaining 

cover types reported in Table 3.8.1-1 collectively represent less than 20 percent of the proposed 

construction acreage. Following construction, lands temporarily used for construction (pipe storage and 

contractor yards, access roads, and ATWSs) would be able to revert to their original use type. 

As described in Section 2.0, the proposed Project would be collocated with existing pipeline 

rights-of-way for approximately 72.7 miles (approximately 66 percent) of its length. Gulf South proposes 

to parallel existing pipeline or utility corridors to the extent practical. This collocation would be adjacent 

to and abut a Denbury Resources (Denbury) pipeline for 0.2 mile (MP 30.3 to MP 30.5), a Crosstex 

Mississippi (Crosstex) pipeline for approximately 39.4 miles (MP 38.3 to MP 77.7), and a Transco 

pipeline for approximately 33.1 miles (MP 77.7 to MP 110.8). For the portion of the project paralleling 

existing foreign pipelines, Gulf South's new permanent right-of-way would be 60 feet wide, abutting the 

adjacent existing right-of-way. The additional 60 feet (40 feet in wetlands) of temporary construction 

right-of-way would be located on the opposite side of the new permanent right-of-way from the existing 

utility corridor. 

During operation of the proposed Project, the permanent pipeline right-of-way, aboveground 

facilities and permanent access roads would affect approximately 857.6 acres. About 39 percent of the 

land that would be affected during operation is currently classified as upland forest, 33 percent is pine 

plantation, and 11 percent is open land. The remaining land use types collectively represent less than 

20 percent of the acreage required during operation. 

Pipeline Facilities 

Approximately 1,240.3 acres of land would be impacted by construction of the proposed 

pipeline. Approximately 77 percent of this acreage would consist of pine plantation and upland forest. 

Open land, wetlands, pasture, industrial/commercial, residential, other/roads, agricultural, and open water 

accounts for the additional 23 percent of this acreage. 

Operation of the proposed pipeline would permanently affect approximately 731.4 acres of 

land. Similar to the construction right-of-way requirements, approximately 78 percent of the land that 

would be affected during operation is currently classified as upland forest and pine plantation, while open 

land, wetlands, industrial/commercial, residential, agricultural, and open water make up the remaining 

22 percent. 

Aboveground Facilities 

In addition to lands affected by construction of the proposed pipeline, construction of the 

proposed aboveground facilities would affect approximately 146.2 acres of land while operation would 

affect approximately 119.2 acres. Table 3.8.1-1 provides data regarding the land cover types that would 

be affected by construction and operation of the proposed aboveground facilities. Of the 119.2 acres 

required for operation of the aboveground facilities, approximately 29 percent would be upland forest, 

while 58 percent would be agricultural land and 10 percent would be pine plantation. Construction and 

operation of the proposed aboveground facilities would result in a conversion of those lands to a 

commercial/industrial cover type for the life of the proposed Project. 
 3-70 

TABLE 3.8.1-1 

Acres Potentially Impacted by the Proposed Southeast Expansion Project 

 Affected Land Use/Land Cover (acres)a

Agricultural Pine Plantation Upland Forest Pasture 

County/Parish Const Oper Const Oper Const Oper Const Oper 

Pipeline Facilitiesb 

 Simpson, MS 1.0 0.6 87.1 52.3 165.3 100.5 14.5 8.6 

 Smith, MS 3.9 2.4 80.0 48.3 94.6 59.0 11.3 7.0 

 Jasper, MS 0.8 0.5 66.2 40.2 142.8 88.7 19.5 11.6 

 Clarke, MS 2.8 2.2 178.0 105.6 90.2 53.0 6.2 3.8 

 Choctaw, AL 0.0 0.0 47.8 25.3 0.0 0.0 0.0 0.0 

Pipeline Facilities Subtotal 8.5 5.7 459.1 271.7 492.9 301.2 51.5 31.0 

Aboveground Facilitiesc 

Delhi Compressor Station Richland, LA 69.5 69.5 0.0 0.0 0.0 0.0 0.0 0.0 

Harrisville Compressor Station Simpson, MS 0.0 0.0 0.0 0.0 15.3 15.3 0.0 0.0 

Destin Compressor Station Clarke, MS 0.0 0.0 17.2 11.7 17.2 11.6 0.0 0.0 

CenterPoint Energy M/R Station Richland, LA 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Southern Natural M/R Station Smith, MS 0.0 0.0 0.0 0.0 3.5 0.9 0.0 0.0 

Tennessee Gas M/R Station Jasper, MS 0.0 0.0 0.0 0.0 3.2 0.8 0.0 0.0 

Destin M/R Station Clarke, MS 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Transco M/R Station Choctaw, AL 0.0 0.0 0.0 0.0 11.9 6.0 0.0 0.0 

Valves and Other Facilities Various 0.0 0.0 1.0 0.0 3.3 0.3 0.0 0.0 

Aboveground Facilities Subtotal 69.5 69.5 18.2 11.7 54.4 34.9 0.0 0.0 

Extra Work Areasb 

Pipe Storage and Contractor Yards Various 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Access Roadsd Various 0.0 0.0 0.0 0.0 0.4 0.0 0.0 0.0 

ATWSs Various 1.9 0.0 101.5 0.0 98.9 0.0 4.8 0.0 

Extra Work Areas Subtotal 1.9 0.0 101.5 0.0 99.3 0.0 4.8 0.0 

Total 79.9 75.2 578.8 283.4 646.6 336.1 56.3 31.0 

_______________ 

Notes: 

Const = Construction Impacts 

Oper = Operation Impacts. Permanent impacts are based on Gulf South's proposed 60-foot wide permanent right-of-way; however, we are 

recommending that Gulf South's permanent right-of-way be limited to a width of 50 feet. 

a Agricultural Land – Active cropland, pasture, and/or hayfields 

 Residential Land – Yards, subdivisions, mobile home parks, and planned developments 

 Commercial/Industrial Land – Power or utility stations, manufacturing or industrial plants, commercial or retail facilities, and roads 

b Construction acreage requirements for pipeline facilities includes ATWSs. Table G-1 of Appendix G provides a complete, itemized list of extra 

work areas and associated impacts. 

c Minor land requirements associated with mainline valves would be contained within the compressor station sites and the construction and 

permanent pipeline rights-of-way and are thus already included in the acreage estimates for those facilities. 

d Existing access roads that would be upgraded or otherwise modified in association with construction of the proposed Project traverse a variety of 

land uses and cover types. Land requirements of new and improved access roads based on a typical construction width of 40 feet. Table G-2 of 

Appendix G provides a complete, itemized list of construction access roads.
 3-71 

TABLE 3.8.1-1 (continued) 

Acres Potentially Impacted by the Proposed Southeast Expansion Project 

 Affected Land Use/Land Cover (acres)a

Open Land Open Water Residential 

Industrial/

Commercial 

County/Parish Const Oper Const Oper Const Oper Const Oper 

Pipeline Facilitiesb 

 Simpson, MS 38.7 23.3 0.0 0.0 2.5 1.3 2.1 1.8 

 Smith, MS 24.4 14.9 0.0 0.0 0.3 0.1 1.0 0.8 

 Jasper, MS 36.9 22.3 0.0 0.0 0.9 0.5 3.5 2.5 

 Clarke, MS 24.1 18.0 0.0 0.0 1.6 1.0 1.1 1.0 

 Choctaw, AL 22.3 16.9 0.0 0.0 0.0 0.0 0.0 0.0 

Pipeline Facilities Subtotal 146.4 95.4 0.0 0.0 5.3 2.9 7.7 6.1 

Aboveground Facilitiesc 

Delhi Compressor Station Richland, LA 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Harrisville Compressor Station Simpson, MS 0.9 0.9 0.0 0.0 0.0 0.0 0.0 0.0 

Destin Compressor Station Clarke, MS 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

CenterPoint Energy M/R Station Richland, LA 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Southern Natural M/R Station Smith, MS 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Tennessee Gas M/R Station Jasper, MS 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Destin M/R Station Clarke, MS 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

Transco M/R Station Choctaw, AL 2.0 2.0 0.0 0.0 0.0 0.0 0.0 0.0 

Valves and Other Facilities Various 1.0 0.3 0.0 0.0 0.0 0.0 0.3 0.0 

Aboveground Facilities Subtotal 3.9 3.2 0.0 0.0 0.0 0.0 0.3 0.0 

Extra Work Areasb 

Pipe Storage and Contractor Yards Various 0.0 0.0 0.0 0.0 0.0 0.0 41.0 0.0 

Access Roadsd Various 0.8 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

ATWSs Various 23.9 0.0 0.0 0.0 1.6 0.0 1.3 0.0 

Extra Work Areas Subtotal 24.7 0.0 0.0 0.0 1.6 0.0 42.3 0.0 

Total 175.0 98.6 0.0 0.0 6.9 2.9 50.3 6.1 

_______________ 

Notes: 

Const = Construction Impacts 

Oper = Operation Impacts. Permanent impacts are based on Gulf South's proposed 60-foot wide permanent right-of-way; however, we are 

recommending that Gulf South's permanent right-of-way be limited to a width of 50 feet. 

a Open Land – Non-forested lands, maintained utility rights-of-way, and shrub-scrub wetland 

 Forest – Tracts of upland or wetland forest 

 Pine Plantation – Planted/harvested pine plantation forest 

b Construction acreage requirements for pipeline facilities includes temporary ATWSs. Appendix G provides a complete, itemized list of extra work 

areas and associated impacts. 

c Minor land requirements associated with mainline valves would be contained within the compressor station sites and the construction and permanent 

pipeline rights-of-way and are thus already included in the acreage estimates for those facilities. 

d Existing access roads that would be upgraded or otherwise modified in association with construction of the proposed Project traverse a variety of 

land uses and cover types. Land requirements of new and improved access roads based on a typical construction width of 40 feet. Appendix G 

provides a complete, itemized list of construction access roads. 
 3-72 

TABLE 3.8.1-1 (continued) 

Acres Potentially Impacted by the Proposed Southeast Expansion Project 

Affected Land Use/Land Cover (acres)a

 Wetlands Other/Roads Total 

County/Parish Const Opere Const Oper Const Oper 

Pipeline Facilitiesb 

 Simpson, MS 19.0 4.6 0.0 0.0 330.2 193.0 

 Smith, MS 11.9 4.5 0.0 0.0 227.4 137.0 

 Jasper, MS 19.3 4.9 0.0 0.0 289.9 171.2 

 Clarke, MS 15.7 2.9 0.0 0.0 319.7 187.5 

 Choctaw, AL 3.0 0.5 0.0 0.0 73.1 42.7 

Pipeline Facilities Subtotal 68.9 17.4 0.0 0.0 1240.3 731.4 

Aboveground Facilitiesc 

Delhi Compressor Station Richland, LA 0.0 0.0 0.0 0.0 69.5 69.5 

Harrisville Compressor Station Simpson, MS 0.0 0.0 0.0 0.0 16.2 16.2 

Destin Compressor Station Clarke, MS 0.0 0.0 0.0 0.0 34.4 23.3 

CenterPoint Energy M/R Station Richland, LA 0.0 0.0 0.0 0.0 0.0 0.0 

Southern Natural M/R Station Smith, MS 0.0 0.0 0.0 0.0 3.5 0.9 

Tennessee Gas M/R Station Jasper, MS 0.0 0.0 0.0 0.0 3.2 0.8 

Destin M/R Station Clarke, MS 0.0 0.0 0.0 0.0 0.0 0.0 

Transco M/R Station Choctaw, AL 0.0 0.0 0.0 0.0 13.9 8.0 

Valves and Other Facilities Various 0.0 0.0 0.0 0.0 5.5 0.5 

Aboveground Facilities Subtotal 0.0 0.0 0.0 0.0 146.2 119.2 

Extra Work Areasb 

Pipe Storage and Contractor Yards Various 0.0 0.0 0.0 0.0 41.0 0.0 

Access Roadsd Various 0.0 0.0 57.1 7.0 58.3 7.0 

ATWSs Various 6.8 0.0 0.0 0.0 240.7 0.0 

Extra Work Areas Subtotal 6.8 0.0 57.1 7.0 340.0 7.0 

Total 75.7 17.4 57.1 7.0 1726.5 857.6 

______________ 

Notes: 

Const = Construction Impacts 

Oper = Operation Impacts. Permanent impacts are based on Gulf South's proposed 60-foot wide permanent right-of-way; 

however, we are recommending that Gulf South's permanent right-of-way be limited to a width of 50 feet. 

a Open Land – Non-forested lands, maintained utility rights-of-way, and shrub-scrub wetland 

 Forest – Tracts of upland or wetland forest 

 Pine Plantation – Planted/harvested pine plantation forest 

b Construction acreage requirements for pipeline facilities includes temporary ATWSs. Appendix G provides a complete, 

itemized list of extra work areas and associated impacts. 

c Minor land requirements associated with mainline valves would be contained within the compressor station sites and the 

construction and permanent pipeline rights-of-way and are thus already included in the acreage estimates for those facilities. 

d Existing access roads that would be upgraded or otherwise modified in association with construction of the proposed Project 

traverse a variety of land uses and cover types. Land requirements of new and improved access roads based on a typical 

construction width of 40 feet. Appendix G provides a complete, itemized list of construction access roads. 

e Operational wetland impacts only include impacts to PFO wetlands, as PEM and PSS wetlands would be allowed to return to 

pre-construction conditions.
 3-73 

Access Roads 

As described in Section 2.2.3.3, construction of the proposed pipeline right-of-way would 

require use of existing public and private roadways to gain access during construction and operation of 

the proposed Project. Where feasible, Gulf South would use existing public roadways, existing private 

roadways and the pipeline right-of-way itself to gain access during construction and operation of the 

proposed Project. Gulf South indicates that only three newly constructed or upgraded access roads would 

be permanently maintained during operations. The remaining access roads would be allowed to revert to 

their preconstruction uses. Gulf South has indicated that construction of the proposed pipeline would 

require the use of 138 access roads of varying lengths and construction. Of the 138 access roads, 91 

would be unmodified existing roads, and 47 (comprising approximately 34.8 miles of road) would be new 

or upgraded roads, of which 44 roads would be for temporary use, while three roads would be for 

permanent use (see Appendix G). Gulf South would upgrade access roads by placing gravel for stability, 

grading, replacing or installing culverts, clearing overhead vegetation, or by making minor widenings at 

sharp turns to facilitate passage by pipe trucks. 

Pipe Storage and Contractor Yards 

Gulf South proposes to use three pipe storage and contractor yards during construction, 

temporarily affecting approximately 41.0 acres of land (Table 3.8.1-1). Each of the identified pipe 

storage and contractor yards would consist of warehouses or open lots located in previously disturbed 

areas. 

3.8.2 Land Ownership and Easement Requirements 

Prior to initiating construction, Gulf South would secure an easement to convey both 

temporary (for construction) and permanent (for operation) rights-of-way. The easement acquisition 

process is designed to provide fair compensation to the landowners for the right to use the property for 

pipeline construction and operation. During the easement acquisition process, Gulf South would 

compensate landowners for loss of value to specific parcels. The easement agreement between the 

company and landowner typically specifies compensation for loss of use during construction, loss of 

nonrenewable or other resources, damage to property during construction, and allowable uses of the 

permanent right-of-way after construction. During negotiations, Gulf South and affected landowners 

would address the following: 

• Allowable uses within the right-of-way. 

• Mechanisms required to allow the pipeline to be traversed by heavy equipment such as log 

skidders. 

• Minor route adjustments to accommodate landowner needs (provided that the route adjustments 

do not affect environmentally sensitive areas or other non-consenting landowners). 

If an easement cannot be negotiated with a landowner and the proposed Project has been 

certificated by the FERC, Gulf South could use the right of eminent domain granted to it under 

Section 7(h) of the NGA and the procedure set forth under the Federal Rules of Civil Procedure 

(Rule 71A) to obtain the right-of-way and extra work areas. Although Gulf South would compensate the 

landowner for the right-of-way and for any damages incurred during construction, a court would 

determine the level of compensation if a Certificate were issued. In either case, the landowner would be 

compensated for the use of the land. Eminent domain would not apply to lands under federal ownership. 
 3-74 

3.8.3 General Impacts and Mitigation 

The general impacts to land use associated with construction of the proposed Project would be 

a function of the construction methods employed, the restoration actions implemented once construction 

has been completed, the nature of the land cover type affected before construction, and the allowable use 

of the land following construction. Section 2.3 provides a detailed discussion of the proposed 

construction methods and post-construction restoration actions for the proposed Project. 

Construction 

Following construction, areas outside the permanent pipeline right-of-way and other 

temporary work areas would be graded, seeded, or otherwise restored and would be allowed to revert to 

existing conditions, except where individual landowner agreements negotiated during the easement 

acquisition process dictate other acceptable restoration measures. As a result, land use impacts to these 

areas would be temporary. Because non-woody vegetation would be expected to return to preconstruction conditions within two growing seasons, impacts to lands currently classified as agricultural, 

pasture, open land, residential, or industrial/commercial and located outside the permanent pipeline rightof-way would be short-term and minor. 

Trees cleared within the temporary construction rights-of-way would be allowed to revert to 

pre-construction conditions and in some cases may be replanted. This process would take many years, 

with the duration of recovery dependent on the types and ages of trees removed. As a result, impacts to 

areas classified as PFO, forest, and pine plantation lands that are located outside the permanent right-ofway would be long-term. Additional discussion of general impacts and mitigation measures that would 

be implemented to minimize impacts to forested areas is provided in Sections 3.4 and 3.5. 

Operation 

Permanent land use changes would occur to those lands contained within the permanent 

pipeline right-of-way where reversion to the pre-construction cover type would not be compatible with 

operation of the proposed Project facilities. Activities typically not allowed in the permanent pipeline 

right-of-way would include aboveground construction, below ground construction, and the growth, 

planting, or cultivation of trees. Upland forest and pine plantation land covers and uses therefore would 

be precluded from the permanent pipeline right-of-way. Allowable land uses generally permitted within 

the permanent right-of-way would include use of farming equipment, cultivation of row crops, and 

utilization as pastureland. Permanent changes also would be associated with the proposed aboveground 

facilities and those access roads maintained during operations, as acreage required for these facilities 

would be converted to a commercial/industrial cover type for the life of the Project. Gulf South indicates 

that only three newly constructed or upgraded access roads associated with the aboveground facilities 

described above would be permanently maintained during operations. 

Permanent maintenance of rights-of-way relative to converted land uses and aboveground 

facilities would have a permanent, lasting affect for at least the life of the proposed Project. Overall, 

despite the permanent conversion of some land use types in the permanent rights-of-way and at 

aboveground facilities, we believe the overall Project impact would not be significant given the limited 

acreage involved. 

3.8.3.1 Land Use Type, Specific Impacts, and Mitigation 

Land use types including open land, open water, industrial/commercial lands, and other lands 

would not be converted by construction or operation of the proposed Project. Wetlands would be affected 
 3-75 

by the proposed Project, and these impacts are discussed in detail in Section 3.4. Other land use types, 

including agriculture, forested areas, pastures, and residential lands would be subject to impacts or 

conversion of land use and are discussed in more detail below. 

Agriculture, Timber, and Pasture Lands 

Construction could affect the productivity of agricultural, timber (upland forest and pine 

plantation), and pasture lands within the construction and permanent pipeline rights-of-way. During the 

Pre-filing and scoping periods, we received comments expressing concern for potential proposed Projectrelated effects to farming, as well as pasture and timber lands. Gulf South has proposed to accomplish 

pipeline construction between September and December 2007, which encompasses typical growing 

seasons. Thus, Project-related crop losses could occur. As applicable, Gulf South would work with 

landowners prior to construction to establish compensation agreements for crop damages and for loss of 

growing time. In accordance with its plans, Gulf South would implement construction procedures in 

agricultural areas to minimize potential impacts and restore the right-of-way to approximate preconstruction conditions (see Sections 2.3 and 3.2). Gulf South's plans require them to conduct follow-up 

inspections of the disturbed areas after the first and second growing seasons to determine if revegetation 

was successful. In agricultural areas, revegetation would be considered successful if crop yields are 

similar to adjacent undisturbed portions of the same field (see Section 3.2). 

Gulf South would implement special construction and monitoring procedures through 

agricultural lands, including pasture, to minimize adverse effects and ensure proper restoration. However, 

construction through pasture could temporarily affect some livestock operations, and some landowners 

could incur additional costs for supplemental livestock feed. Compensation for such losses would be 

accomplished through the easement negotiation process. To ensure the safety of livestock during 

construction, Gulf South would either construct temporary fencing to keep livestock away from 

construction areas or develop a grazing deferment plan to minimize impacts to pastureland during 

construction and restoration activities in accordance with its Plan. 

As discussed in Section 3.8.1, impacts to pine plantation and upland forests would range from 

long-term in areas outside the permanent right-of-way to permanent for areas within the permanent rightof-way. As such, timber production within the construction and permanent rights-of-way would be 

temporarily reduced or permanently precluded, respectively. As described in Section 3.8.2, Gulf South 

would negotiate with affected landowners to obtain an easement agreement that would effectively 

eliminate timber production within the permanent pipeline right-of-way. However, after Gulf South has 

completed restoration of the right-of-way, timber harvesting equipment would be able to move freely 

across the pipeline to access adjacent forested areas with no expected effect on pipeline safety or 

operations. Compensation for any losses or limitations on future timber production values within the 

construction and permanent pipeline rights-of-way would be addressed during easement negotiations. 

Prescribed burns are often used in the vicinity of the proposed Project to manage planted pines, and 

pipeline rights-of-way may in some cases serve as fire breaks. Gulf South has committed to coordinating 

with landowners to mitigate any potential impact to prescribed burning activity caused by the proposed 

Project. 

Appropriate landowner settlements, special construction measures, restoration, and postconstruction monitoring would ensure that landowners are able to resume pre-Project activities in 

construction easements or that such impacts would be mitigated. Furthermore, settlement negotiations 

would ensure that property owners are fairly compensated for any loss of revenue associated with the 

construction or operation of the Project. 
 3-76 

Existing Residences and Planned Developments 

The proposed pipeline would traverse primarily rural, unincorporated areas. Table 3.8.3.1-1 

identifies the residences within 50 feet of the construction work area. The pipeline route has otherwise 

been adjusted so that no displacements of residences would occur. Only three residences are located 

within 25 feet of the construction workspace, one of which may be abandoned. Approximately 6.9 acres 

of land classified as residential would be contained within the construction right-of-way or ATWSs, and 

2.9 of those acres would be retained for the permanent right-of-way. During the planning stages for the 

proposed Project, Gulf South consulted with county and parish planning agencies and reviewed 

development plans to identify currently filed proposals for residential or commercial developments within 

0.25 mile of the proposed construction right-of-way or associated aboveground facilities. From MP 10.6 

to MP 11.2, the Braxton Estates development, owned by Equity Development Group, Inc., is located 

adjacent to the north side of Gulf South’s proposed construction right-of-way. 

TABLE 3.8.3.1-1 

Residences Within 50 Feet of Construction Work Area and Proposed Mitigation 

MP1 County, State2 Number of 

Residences 

Distance from 

Construction 

Work Area 

(feet) 

Distance from 

Pipeline 

Centerline 

Direction 

from the 

Right-ofWay Proposed 

Mitigation 

 

 3.6 Simpson County, MS 1 27 116 South None 

 11.1 Simpson County, MS 1 15 55 North Yes* 

 11.6 Simpson County, MS 1 27 130 South None 

 14.1 Simpson County, MS 1 27 145 South None 

 14.9 Simpson County, MS 1 27 112 South None 

 30.3 Simpson County, MS 1 47 173 South None 

 36.4 Smith County, MS 1 36 116 South None 

 41.7 Smith County, MS 1 29 85 South None 

 52.9 Jasper County, MS 1 34 89 South None 

 53.0 Jasper County, MS 1 37 187 South None 

 94.8** Clarke County, MS 1 40 165 South None 

 98.9 Clarke County, MS 1 11 52 South Yes*** 

 99.1  Clarke County, MS 1 11 85 South Yes** * 

_______________ 

Mitigation Notes: 

* Immediately restore all lawn areas after backfilling the trench, fence the construction work throughout the open trench phase of 

construction, and use water trucks to minimize fugitive dust. 

** This residence would not be impacted by Gulf South’s proposed HDD of State Hwy. 511. 

*** Reduce the construction work area to maintain 25 feet between the residence and the construction work area. 

**** Residence appears to be abandoned. Gulf South would continue evaluation/monitoring of this property. 

1 MP = Milepost 

2 MS = Mississippi
 3-77 

General Construction and Operational Impacts to Residences 

The general impacts of construction and operation of the proposed Project on residences 

would result from construction-related disturbances, limitation of land use type within the permanent 

pipeline right-of-way, and alteration of future development patterns. Specifically, potential constructionrelated disturbances include inconvenience caused by increased noise and dust generated by construction; 

locally increased traffic; effects on landscaping (including alteration and loss of plantings), wells, and 

septic systems; and removal of objects such as sheds and trailers from the construction right-of-way. 

Uses and structures that would be precluded from the permanent pipeline right-of-way include 

construction of aboveground structures not associated with the proposed Project, construction of septic 

system leach fields, and planting or cultivation of trees or orchards. 

To minimize disruptions to residential areas near construction work areas, Gulf South 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, Gulf 

South would implement the following measures on an as-needed basis: 

• Maintain access to all residences except for brief periods essential to pipe-laying activities. 

• Where necessary, 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. 

• Restore all areas disturbed by construction work areas to "as before or better" conditions. 

Additionally, for all residence located within 50 feet of the construction work area Gulf South 

would: 

• Leave mature trees and landscaping up to the edge of the construction work area, unless 

necessary for safe operation of the construction equipment. 

• Restore all lawn areas and landscaping within the construction work area consistent with the 

requirements of its plans immediately after backfilling the trench. 

• Fence the edge of the construction work area adjacent to the residence for a distance of 100 feet 

on either side of the residence. 

• Try to maintain a minimum distance of 25 feet between the residence and the edge of the 

construction work area. 

Gulf South prepared site-specific residential construction plans, detailing the location of the 

proposed pipeline alignment, construction limits, and residential access for the three residences that 

would be located within 25 feet of the construction right-of-way. 

In the Draft EIS, we recommended that Gulf South provide an assessment of how the 

proposed Project's construction would affect or be affected by the Braxton Estates development between 
 3-78 

MPs 10.6 and 11.2. Gulf South has met with Equity Development Group, Inc., and has executed an 

easement agreement with the developer. As a result, Gulf South would install the pipeline farther away 

from Braxton Estates adjacent to the existing railroad right-of-way, along the southern boundary of the 

tract, to minimize impacts to potential future development. Currently, there is only one residence in the 

proximity of the construction corridor (15 feet outside of the workspace boundary). Gulf South has 

prepared a site-specific residential detail drawing for this residence that details the construction mitigation 

measures, which we have reviewed and find acceptable. Gulf South states that it has no indication from 

the developer that additional construction is planned prior to construction of the proposed pipeline. If 

additional residences are constructed within 25 feet of the construction corridor prior to or during the 

installation of the pipeline, Gulf South would provide a similar site-specific construction mitigation plan 

for review and approval by the Director of OEP. 

In general, Gulf South sought to avoid residences because construction activities could 

inconvenience residents, remove or damage shade trees, disrupt landscaping and gardens, and potentially 

damage structures. For example, operation of large construction equipment in the immediate vicinity of 

homes can create dust, noise, and/or muddy conditions. Precautions must also be taken to protect pets 

and small children. As described in Section 2.5, EIs would be responsible for monitoring and ensuring 

compliance with all environmental mitigation measures required by the Certificate, if granted, including 

those residential mitigation measures identified above. Additionally, the FERC staff is interested in 

ensuring that landowner issues are resolved in an effective and timely manner. Therefore, Gulf South 

would be required to develop and implement an environmental complaint resolution procedure that 

provides landowners with clear and simple directions for identifying and resolving their environmental 

mitigation problems/concerns during construction of the proposed Project and restoration of the right-ofway (see Section 5.2). 

We received comments during the Pre-filing and scoping periods indicating that the proposed 

Project route could interfere with plans for construction of homes or other structures. In Section 4.4, we 

list several route variations that Gulf South incorporated into the proposed Project route during the Prefiling phase in response to specific landowner requests. Additional minor reroutes to the proposed 

Project's pipeline alignment could be made during the easement negotiation process in accordance with 

landowner needs and requirements if they do not impact significant environmental resources or other 

landowners. Prior to construction, Gulf South would consult with the owners of all structures located 

within the construction work area, as part of the easement negotiation process, to develop a route or 

mitigation plan that would minimize impacts to those structures. If a minor reroute could not fully avoid 

the structures, Gulf South would relocate or replace the structures, or otherwise compensate the affected 

landowner per the terms of the agreement negotiated during the easement acquisition process. 

3.8.4 Special Interest Areas Impacts and Mitigation 

Delhi Municipal Airport 

The proposed Delhi Compressor Station is approximately 3,000 feet east of the Delhi 

Municipal Airport in Richland Parish, Louisiana. The airport has plans for a 2,000-foot runway 

expansion in the future. As described in the Final EIS that was issued for Gulf South's East Texas to 

Mississippi Expansion Project (CP06-446-000), the pipeline proposed in that project would be located 

about 1,070 feet north of the Delhi Municipal Airport runway at MP 148.2 in Richland Parish, Louisiana. 

In that proceeding we found out that the airport has plans for a 2,000-foot runway expansion in the future. 

Gulf South indicated that it was consulting with the Federal Aviation Administration (FAA), the airport, 

and the City of Delhi to determine whether the project would interfere with aircraft operations. We 

recommend that: 
 3-79 

• Prior to construction, Gulf South should consult with the Delhi Municipal Airport officials 

and the FAA regarding impacts of the proposed Project, specifically the proposed Delhi 

Compressor Station, on airport operations, and file a site-specific construction plan that 

addresses any concerns identified by those authorities with the Secretary. 

Gulf South now plans to locate and build the Delhi Compressor Station as described in this 

proceeding. The compressor station would be located almost 3,000 feet east of the north-south oriented 

runway, and also in proximity to the airport's planned expansion. We believe the consultation and 

construction plans as required by the above recommendation stated would prevent adverse impacts to the 

Delhi Municipal Airport.

Thigpen Field Airport 

The proposed pipeline route would be located approximately 500 feet south from current 

construction activities extending the north-south runway of Thigpen Field Airport at MP 55.1 near Bay 

Springs in Jasper County, Mississippi. The runway runs perpendicular to the proposed pipeline, which 

would be placed parallel to and on the south side of the Crosstex Pipeline's existing natural gas pipeline 

right-of-way. The runway's vegetative clear zone extends southward across the Crosstex Pipeline rightof-way for another approximately 1,300 feet. Gulf South has not indicated the results of any 

consultations it has had with the FAA, the airport, or the Town of Bay Springs to determine if the 

proposed Project would interfere with aircraft operations, the runway safety area, or the runway objectfree area. Gulf South has not indicated whether it is aware of applicable safety regulations it would abide 

by, or of any special construction procedures, such as deep pipeline installation, that might be required in 

the vicinity of the Thigpen Field Airport. Therefore, we recommend that:

• Prior to construction, Gulf South should consult with the Thigpen Field Airport officials 

and the FAA regarding impacts of the proposed Project on airport operations, and file a 

site-specific construction plan that addresses any concerns identified by those authorities 

with the Secretary. 

We believe the consultation and construction plans as required by the above recommendation 

stated would prevent adverse impacts to the Thigpen Field Airport. 

Hazardous Waste Sites 

Gulf South used Environmental Data Resources database reviews to identify any known 

hazardous waste sites within 1 mile of the proposed Project right-of-way and identified 10 sites. Three of 

these sites are located within 0.25 mile of the proposed route. Nine sites were underground storage tanks 

(UST), and one site is a Comprehensive Environmental Response, Compensation, and Liability Act 

(CERCLA) site. 

In the event that a hazardous waste site is discovered during construction of the proposed 

Project, Gulf South indicates that it would stop work, notify the appropriate state and federal agencies, 

and proceed in accordance with local, state, and federal regulations. Gulf South has developed a Plan for 

the Unanticipated Discovery of Contaminated Environmental Media that identifies the procedures that 

would be implemented during construction to identify, test, treat, and dispose of such materials in 

accordance with the appropriate state and federal regulations. 
 3-80 

Recreational Areas 

Recreation and special interest areas are defined to include lands administered by federal, 

state, county, or local agencies. Recreational areas along the proposed Project route consist of natural 

areas used for hunting, fishing, wildlife viewing, hiking, boating and canoeing, and other outdoor 

activities. No lands managed by The Nature Conservancy are located within the project area. These 

areas also include NRI streams and are discussed in detail below. 

Specially Managed Lands Impacts and Mitigation 

Specially managed lands are areas administered by federal, state, county, or local agencies; 

lands of historic or cultural significance; designated environmentally sensitive areas; national or state 

scenic rivers; and designated scenic areas or roads. This section quantifies potential land use type 

conversions and recreational impacts at the special interest areas that would be traversed by the proposed 

Project route. 

Sixteenth Section Lands 

The Mississippi Secretary of State informed the FERC about the proposed Project's potential 

effects on Sixteenth Section Lands in Mississippi. Title for Sixteenth Section lands is held by the State of 

Mississippi in trust to support public education (Mississippi Secretary of State, 2006). Sixteenth Section 

lands provide income to local school districts through the use or lease of lands for silviculture, agriculture, 

residential use, and/or hunting activities. By mandate, any revenues not used by local school districts can 

only be invested in federally secured investments. 

The Mississippi Secretary of State's Office, as the designated supervisory trustee for these 

areas, indicated a desire to minimize pipeline crossings of Sixteenth Section Lands to the extent practical. 

Impacts to these properties from pipeline crossings would result in a loss of land use flexibility, 

preventing certain future property uses within permanent easements. Unlike properties held by private 

individuals or companies, any settlement received through easement settlements for Sixteenth Section 

Lands would be required to be invested in federally secured investments, thereby potentially limiting or 

decreasing future revenue generation from these lands. The State requested that if it were deemed that 

these properties could not be avoided, that crossings occur near parcel boundaries to prevent land use 

fragmentation on these lands. 

The proposed Project would cross six Sixteenth Section Lands in Simpson, Jasper, and Clarke 

Counties, Mississippi (Table 3.8.4-1). Due to these tracts' extensive size and the Project's collocation 

with existing pipeline crossings at three of the six properties, avoidance of Sixteenth Section Lands would 

not be feasible. Deviation from the proposed Project alignment through these parcels would result in the 

clearing of new corridors, resulting in increased wildlife habitat and vegetation fragmentation. Given 

Gulf South's agreements with landowners, our examination of route alternatives, and attempts to 

minimize impacts through use of HDDs, we believe that impacts to Sixteenth Section Lands have been 

adequately minimized. 

Nationwide Rivers Inventory 

Streams included in the NRI are considered to possess "outstandingly remarkable natural or 

cultural values judged to be of more than local or regional significance" (NPS, 2006). The proposed 

Project would cross two NRI waterbodies: the Strong River at MP 18.0 in Simpson County, Mississippi; 

and the Chickasawhay River at MP 89.3 in Clarke County, Mississippi. The NRI reach of the Strong 

River extends from its confluence with the Pearl River upstream approximately 72 miles, to 1 mile below 
 3-81 

the Interstate 20 bridge. The Strong River is an unspoiled stream with riffles and rapids in overhanging 

vegetation, and the entire reach is floatable. The NRI-listed reach of the Chickasawhay River extends 

from its confluence with the Pascagoula River upstream approximately 145 miles. The Chickasawhay 

River is a quiet, remote stream distinctive for its clay and limestone bluffs (NPS, 2004). 

As described in Sections 2.3.2.1 and 3.3, Gulf South would use HDD installation techniques, 

in accordance with our Procedures, to avoid and minimize impacts to the waterbodies and adjacent 

riparian areas. As proposed, ATWSs associated with the Chickasawhay River HDD would result in some 

impacts to forested areas near this river. However, we believe these impacts would be relatively minor as 

the ATWSs would be located at least 1,650 feet from the edge of this stream. We have included a 

recommendation in Section 3.3.2.1 for Gulf South to complete consultations with the NPS regarding these 

crossings and withdrawal of hydrostatic test waters, and to file plans for additional mitigation measures, if 

needed. Gulf South's Procedures also include measures to prevent or minimize impacts resulting from the 

withdrawal or discharge of hydrostatic test waters. 

TABLE 3.8.4-1 

Sixteenth Section Lands Crossed by the Proposed Southeast Expansion Project 

Mileposts 

Begin End Landowner Routing and Crossing Information 

8.8 9.4 Simpson County School District Gulf South's proposed pipeline is not collocated with an 

adjacent right-of-way through this area. Any alternative 

route would also not be collocated. The only alternatives 

to the proposed crossing would involve non-collocated 

routes that would create a new cleared corridor to the 

north of the property. 

20.8 21.8 Simpson County School District Gulf South's proposed pipeline is not collocated with an 

adjacent right-of-way through this area. Any alternative 

route would also not be collocated. The only alternatives 

to the proposed crossing would involve non-collocated 

routes. In addition, there are environmental constraints to 

the west of this property that would be impacted should an 

alternative to the west be identified. 

26.8 26.9 Simpson County School District Gulf South's proposed pipeline is not collocated with an 

adjacent right-of-way through this area. However, the 

proposed pipeline is just traversing the southwest corner 

of the section. 

64.8 65.5 Jasper County School District Gulf South's proposed pipeline would be adjacent to the 

CrossTex pipeline easement through this property. Any 

alternative route would not be collocated. The only 

alternatives to the proposed crossing would involve noncollocated routes that would create a new cleared corridor 

through the property. 

84.5 85.5 Clarke County School District Gulf South's proposed pipeline would be adjacent to the 

Transco pipeline easement through this property. Any 

alternative route would not be collocated. The only 

alternatives to the proposed crossing would involve noncollocated routes that would create a new cleared corridor 

through the property. 

103.7 104.4 Clarke County School District Gulf South's proposed pipeline would be adjacent to the 

Transco pipeline easement through this property. Any 

alternative route would not be collocated. The only 

alternatives to the proposed crossing would involve noncollocated routes that would create a new cleared corridor 

through the property. 
 3-82 

Given the avoidance and minimization measures that would be implemented by Gulf South, as 

well as the recommended consultation with the NPS, we believe that construction of the proposed Project 

would not result in a significant impact to the NRI-listed Strong or Chickasawhay Rivers. 

Farm Service Agency Managed Lands 

The CRP program is a voluntary program administered by the FSA. The CRP allows owners 

of agricultural land to conserve those lands through planting of native grasses, trees, and other cover, with 

financial assistance from the federal government (USDA, 2006). Typically, these easements retire 

croplands with erodable soils or otherwise sensitive croplands from production for a period of 10 to 15 

years. Gulf South indicates that at least three CRP lands would be crossed by the proposed pipeline route 

as listed in Section 3.5.3. 

The proposed pipeline route is collocated with other existing rights-of-way in many places 

where FSA managed lands would be crossed. Collocation tends to reduce environmental impacts overall, 

by reducing the need for clearing of entirely new corridors in greenfield areas. We are recommending in 

Section 2.0 that Gulf South accept a 50-foot-wide permanent right-of-way. 

As a result of the disturbance caused by the construction of the proposed Project, as well as 

operations, landowners may no longer be eligible to participate in the CRP or to receive the payments that 

they currently obtain from the FSA due to modified land use or modified vegetation type or strata. Since 

lands included in the construction or permanent pipeline rights-of-way would potentially be no longer 

eligible for inclusion in the CRP program, affected landowners could experience an associated financial 

loss. As part of the right-of-way procurement process, Gulf South would negotiate with the affected 

landowners to obtain an easement agreement for the construction and permanent pipeline rights-of-way. 

Compensation for any losses or limitations associated with CRP lands would be addressed during those 

easement negotiations. 

Gulf South continues to consult with FSA regarding the crossing of FSA managed lands, as 

well as considerations for routing, construction methods, revegetation, and other impact minimization 

measures. Based on our consultations with FSA, we believe a series of impact minimization or mitigation 

measures may be appropriate in easements managed by FSA including reduced right-of-way widths and 

implementation of the elements of Gulf South's Procedures as appropriate, regardless of whether the sites 

meet COE wetland delineation requirements. Gulf South would be required to obtain Subordinate-Use 

Permits authorizing the crossing of any lands managed by FSA. Since consultations with the FSA are not 

complete, we recommend that: 

• Gulf South should consult with the FSA to determine appropriate seed mixes and/or 

revegetation efforts that should be implemented on CRP lands to minimize and mitigate 

construction and operations impacts. Gulf South should also retain and have available for 

inspection any records of consultation(s) with the FSA indicating specific measures agreed 

upon by Gulf South and the FSA that would be implemented on CRP lands. 

Based on the characteristics of FSA managed lands, Gulf South's proposed construction 

measures, and our above recommendation, we believe that impacts to FSA managed lands would be 

adequately minimized. 
 3-83 

3.8.5 Transportation 

Construction of the proposed Project would result in temporary and minor traffic delays 

related to road closures and lane blockages. The proposed Project area is predominantly comprised of 

low-density rural areas. As such, existing transportation infrastructure in the area traversed by the 

proposed Project route includes mostly rural roads and highways. As such, congestion-related delays 

would not be anticipated in association with construction of the proposed Project. 

The proposed pipeline route would cross approximately 15 major U.S. or state highways, 

including Interstate 59, as well as numerous railroads and lightly-traveled paved and unimproved, 

unpaved rural roads. As described in Section 2.3, all railroads, major highways, and interstates would be 

crossed using subsurface boring techniques to avoid road and lane closures. Most major road crossings 

would be bored; however, crossings at US 49 (MP 12.6), Campbell Creek Road (MP 16.0), State 

Highway 13 (MP 18.2), and Interstate 59 (MP 69.4) would be accomplished via HDD associated with the 

crossing of adjacent waterbody features, which would also avoid closure of those roadways. Pipeline 

crossings of more lightly-traveled paved and unimproved, unpaved rural roads typically would be 

accomplished via open-cut installation, which could require temporary lane blockages and closures and 

implementation of detours, where feasible. In the absence of a reasonable detour, construction across the 

roadway would be staged to allow at least one lane of traffic to remain open except for the limited periods 

required for installing the pipeline. Efforts would also be made to schedule lane closures outside of peak 

traffic periods. 

Construction across all roadways would be accomplished in accordance with Gulf South's 

Plan and the requirements of all applicable crossing permits and approvals. Therefore, any effects to local 

transportation patterns or infrastructure would be temporary and minor. As periodic maintenance and 

inspection activities along the proposed pipeline route would involve only infrequent light vehicle 

movement, no impacts to transportation would be expected during operation of the proposed Project. 

3.8.6 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 of an area for residents or 

visitors. The proposed 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 primarily depend on the 

quality of the current viewshed, the degree of alteration of that view, the number of potential viewers, and 

the perspective of the viewer. 

3.8.6.1 Current Viewshed 

Most of the proposed Project would extend primarily through rural areas that consist of pine 

plantation, forested lands, pastures, and agricultural lands with scattered residences. Most areas along the 

route do not provide long-range, unobstructed views, in part because of the topography and in part 

because much of the land adjacent to the proposed route is forested. However, public viewing points are 

present along some of the roadways in the Project area. 
 3-84 

3.8.6.2 General Impacts and Mitigation 

Pipeline Facilities 

During construction, there would be temporary impacts to visual quality for viewers in the 

vicinity of the construction right-of-way due to the presence of construction equipment, work crews, and 

construction activities. Pipeline construction would represent a short-term, localized alteration to visual 

resources of the Project area. 

After completion of construction, the temporary right-of-way would be restored to 

approximate pre-construction contours and would be allowed to revert to pre-construction uses and cover 

type. About 18 percent of the proposed pipeline route would traverse agricultural, pasture, open lands, 

residential, and industrial/commercial land use types. Pipeline installation in these areas would not result 

in a significant change to visual resources, as existing vegetative patterns would not be affected during 

operation of the proposed Project. However, affected forested areas outside the permanent pipeline rightof-way could take many years to recover, and forested land within the permanent right-of-way would be 

maintained in a condition free of woody vegetation for the life of the proposed Project. To reduce visual 

impacts related to the permanent pipeline corridor, Gulf South's proposed route would be collocated with 

or parallel existing utility rights-of-way where possible, thereby minimizing impacts to previously 

undisturbed vegetation. In these areas where the proposed pipeline would be collocated with existing 

rights-of-way, the visual impacts of the proposed Project would be minor because widening of the 

existing corridor would not significantly alter existing visual resources. The long-term visual impacts 

resulting from views of the corridor in existing forested areas where the proposed route would not be 

collocated with existing rights-of-way generally would be limited to a relatively small number of 

individuals, or brief observations afforded in areas where the corridor intersects roadways. As a result, 

we believe the visual impact of the permanent pipeline corridor would be minor. 

Gulf South has avoided crossing state and federally managed lands and has also avoided most 

scenic vistas. As described in Section 3.8.4, however, the proposed Project route would cross two NRIlisted rivers, which have been noted for their visual character. The crossing of these resources would be 

accomplished via HDD; therefore, construction and operation of the proposed Project would not result in 

creation or expansion of an existing corridor, and long-term visual impacts to these features should be 

minimal. Furthermore, we have included recommendations in Section 3.3 for Gulf South to complete 

consultations with NPS and identify any plans to address additional mitigation measures that may be 

recommended by those agencies. 

Aboveground Facilities 

The proposed Project would include installation of three compressor stations, five meter and 

regulator facilities, one side valve and eight mainline valves. Most of the aboveground facilities would 

either be constructed in areas where existing viewsheds contain similar features or where views would be 

occluded by existing vegetation or topography. Given the limited visibility of these sites, screening 

provided by existing vegetation or landscaping, and frequent collocation with existing utility rights-ofway or industrial facilities, the aboveground facilities as a group would represent a minor visual alteration 

that would persist for the life of the Project. The potential site-specific visual impacts of each 

aboveground facility are described below. 

Compressor Stations 

The proposed compressor station sites would typically contain several buildings, including 

those housing compressor units and other associated equipment. Aboveground features outside the 
 3-85 

buildings themselves would include piping and pig launcher/receiver facilities. Portions of these sites 

may be paved, covered with gravel, or landscaped, depending on facility operations and maintenance 

requirements. A chain-link fence would surround the perimeter of each compressor station site.

In the Draft EIS, we recommended that Gulf South file a description of the surrounding 

landscape, potential for visual impacts to nearby residents from, and the need for visual screening for, the 

proposed Delhi Compressor Station and the associated CenterPoint M/R Station. The proposed Delhi 

Compressor Station would be located in an area of active row-cropping. Gulf South would purchase and 

permanently maintain approximately 69.5 acres of land in this area. The landscape surrounding the 

proposed Delhi Compressor Station is currently comprised of agricultural fields, pastures, thin strips and 

patches of forested land, several residences, and a small cemetery. Some residences to the southwest of 

the site would have minimal sight barriers in the form of scattered strips of trees along State Highway 17 

and the fence along the proposed compressor station boundary. We believe that the direct line of sight to 

residences along Highway 17 poses a long-term significant adverse visual effect that could be addressed 

with minimal vegetation measures to reduce visual impacts to nearby residents on the part of Gulf South. 

Therefore, we recommend that: 

• Prior to construction, Gulf South should file with the Secretary for review and written 

approval by the Director of OEP a visual screening plan to reduce the long-term 

adverse effects on the visual quality of residences located along Highway 17 that would 

result from installation of the Delhi Compressor Station. 

The proposed Harrisville Compressor Station would be located in an area dominated by 

upland forest. Gulf South would purchase and permanently maintain approximately 16.2 acres in this 

area. The proposed site is completely surrounded by upland forest that would visually screen the 

compressor station. No residences or businesses are within view of the Harrisville Compressor Station. 

The proposed Destin Compressor Station and Destin M/R Station would be located in an area 

dominated by pine plantation and upland forest. Gulf South would purchase and temporarily disturb 

approximately 20 acres in this area, and would permanently maintain only about 23.3 acres. The 

remaining 11.1 acres would be allowed to revert to natural conditions. The proposed site is completely 

surrounded by planted pine trees, which would visually screen the compressor station. No residences or 

businesses are within view of the Destin Compressor Station. 

Overall, we believe the change in visual quality in the vicinity of the compressor stations 

would affect few viewers and would result in a minor, long-term impact. 

MLV and M/R Stations 

MLV sites would consist of an area surrounded by a chain link fence within the confines of 

the permanent pipeline right-of-way. Approximately 0.5 acre of land currently designated upland forest 

and open land would be permanently impacted outside of the permanent pipeline right-of-way. 

Aboveground elements of each MLV site would include 12-inch piping with valving extending 

aboveground and connected on each side of the 42-inch valve with a crossover. 

Based on review of aerial alignment sheets and information provided by Gulf South, it is 

likely that components of the proposed Project would be visible from nearby residences in two locations 

(MP 30.3 and MP 110.8). The MLV at MP 30.3 would be located adjacent to County Road 503. This 

facility would be visible to residences located approximately 300 feet to the southwest, 375 feet south, 

and 525 feet northwest of this proposed facility. The MLV located at MP 110.8 would be located in an 

open area, adjacent to the proposed Transco M/R Station and the existing Transco right-of-way. The 
 3-86 

facilities at MP 110.8 would be visible to a residence located approximately 350 feet to the northeast. To 

reduce the potential for visual impacts to residences, Gulf South proposes to add vegetative buffers 

wherever they may be viewed by nearby residences. 

M/R stations would be constructed adjacent to the cleared pipeline right-of-way at each of the 

proposed Project receipt and interconnect points to meter the flow and adjust the pressure of natural gas 

received from or delivered to those systems. Each M/R station would include meter and regulator 

equipment, flow pressure control equipment, and a customer facility housed within a fenced perimeter. 

The Transco M/R Station (MP 110.8) would also include a pig receiver. Sizes of the proposed Southern 

Natural and Tennessee Gas M/R stations would each be approximately 1 acre, and the Transco M/R 

station would be approximately 8 acres. 

The Southern Natural (MP 45.7) and Tennessee Gas (MP 72.5) M/R Stations would be 

constructed in areas lacking nearby residences. Additionally, these stations would be constructed wholly 

or partially within, and largely screened by, forested land, further limiting the visual impact of these 

facilities. 

With the recommendations discussed above, combined with the lack of proximate residences 

to other above ground facilities, we believe the proposed Project would not result in any significant 

impact on local viewsheds. 

3.8.7 Conclusion Regarding Impacts to Land Use, Recreation and Special Interest Areas, and 

Visual Resources 

The proposed Project would affect multiple land use types, with long-term or permanent 

impacts to forested areas. However, these impacts would not be significant overall given the amount of 

forested lands in the vicinity of the proposed Project. Additionally, most of the impacts to other land use 

types would not result in a permanent conversion of use. Several special interest areas and specially 

managed lands would also be affected by the proposed Project, but based on Gulf South's proposed 

measures and plans, ongoing consultations with managing authorities, and our recommendations, we 

believe that potential impacts would be adequately minimized. Visual resources would generally not be 

affected by the proposed Project, and we have included a recommendation that would minimize impacts 

at the Delhi Compressor Station. 

3.9 SOCIOECONOMICS 

3.9.1 Region of Influence 

The proposed Project would consist of an approximately 110.8-mile-long, 42-inch-diameter, 

interstate natural gas pipeline, three new compressor stations, and associated ancillary facilities, as 

described in Section 2.1. The proposed pipeline would traverse four counties in Mississippi (Simpson, 

Smith, Jasper, and Clarke), and one county in Alabama (Choctaw). Additionally, a proposed compressor 

station is located in Richland Parish, Louisiana. For the purposes of our socioeconomic analysis, we 

define these counties and parishes as the region of influence for the proposed Project. 

If the proposed Project were constructed, several potential socioeconomic effects could 

manifest themselves within the region of influence. Construction-related effects could include alteration 

of population levels or local demographics, increased demand for housing or public services, and 

increased employment opportunities. In addition, construction would result in increased government 

revenue associated with sales and payroll taxes. Potential socioeconomic impacts associated with 

operation of the proposed Project would include employment opportunities, ongoing local expenditures 
 3-87 

by the operating company, an increased tax base, and an increase in the demand for provision of public 

services. 

3.9.2 Population 

Table 3.9.2-1 reports populations and selected demographic characteristics in the states, 

counties, and parish that would be traversed by the proposed Project. Based on census data for the year 

2000 (U.S. Census Bureau, 2000), the total population in these counties and parish is 116,828. 

Populations in Louisiana experienced a growth between 1990 and 2000, with a 5.9 percent increase in 

population over the 10-year period. Richland Parish was relatively stable during this time period with a 

0.5 percent decrease in population. Mississippi experienced considerable growth in the 10-year period, 

with increases between 2.1 and 16.7 percent occurring in the counties affected by the proposed Project. 

Although Alabama in general experienced growth over the 10-year period, the county affected by the 

proposed Project experienced a 7.6 percent decrease from 1990 to 2000. 

TABLE 3.9.2-1 

Existing Population and Demographic Conditions in the 

Region of Influence for the Proposed Southeast Expansion Project 

Parish/County, 

State 

2000 

Population 

Population 

Change 

Since 

1990 (%) 

Population 

Density 

per 

Square 

Mile 

White, 

NonHispanic 

(%) 

Black or 

AfricanAmerican 

(%) 

Hispanic 

(%) 

Asian 

(%) 

Native 

American 

(%) 

Louisiana 4,468,976 5.9 102.6 2,794,391 

(63) 

1,443,390 

(32) 

107,738 

(2) 

54,256 

(1) 

24,129 

(<1) 

 Richland, LA 20,981 -0.5 37.6 12,667 

(60) 

7,927 

(38) 

227 

(1) 

36 

(<1) 

26 

(<1) 

Mississippi 2,844,658 10.5 60.6 1,727,908 

(61) 

1,028,473 

(36) 

39,569 

(1) 

18,349 

(<1) 

11,224 

(<1) 

 Simpson, MS 27,639 16.7 46.9 17,686 

(64) 

9,432 

(34) 

318 

(1) 

35 

(<1) 

32 

(<1) 

 Jasper, MS 18,149 6.1 26.8 8,378 

(46) 

9,561 

(53) 

117 

(<1) 

12 

(<1) 

11 

(<1) 

 Smith, MS 16,182 8.5 25.4 12,268 

(76) 

3,728 

(23) 

96 

(<1) 

15 

(<1) 

1 

(<1) 

 Clarke, MS 17,955 2.1 26.0 11,518 

(64) 

6,220 

(35) 

120 

(<1) 

19 

(<1) 

17 

(<1) 

Alabama 4,447,100 72.8 87.6 3,125,819 

(70) 

1,150,076 

(26) 

75,830 

(2) 

30,989 

(<1) 

1,059 

(<1) 

 Choctaw, AL 15,922 -7.6 17.4 8,724 

(55) 

6,985 

(44) 

107 

(<1) 

6 

(<1) 

24 

(<1) 

_______________ 

Source: U.S. Census Bureau, 2000 

Population densities in the region of influence range from a low of 17.4 persons per square 

mile in Choctaw County, Alabama, to a high of 46.9 persons per square mile in Simpson County, 

Mississippi. These densities are relatively low compared to urban area densities that typically range from 

3,000 to 6,000 persons per square mile (FERC, 2006), but are consistent with an area that is 

predominantly rural and agricultural. 

The number of residents within the region of influence would increase temporarily during 

construction, which would occur for approximately four months between September 2007 and December 

2007, as proposed. The peak construction workforce would be 1,400 workers, of which about 98 percent 
 3-88 

(1,372) would be non-local. Assuming 0.8 family members (FERC, 2006) would accompany each nonlocal worker, total construction-related immigration would be approximately 2,470 persons. Gulf South 

indicates that construction of the pipeline would entail the simultaneous activity of three individual 

construction spreads over the proposed Project route. Additional work crews would also be employed at 

each of the proposed aboveground facilities. As such, these workers would be distributed along the 

length of proposed Project route and throughout the region of influence, thereby minimizing the potential 

population level and demographic effects to any individual county or parish. 

As described above, construction-related immigration would be spread across the length of the 

proposed pipeline. Based on the miles of pipeline in each county, population impacts associated with 

non-local workers and their families are expected to range from, 2.1 to 0.1 percent, on average. This 

would represent a minor, temporary population increase confined to the period of proposed Project 

construction. The FERC does not believe the work force would have a significantly different 

demographic profile than that observed within the region of influence. As such, changes to local 

demographics would not be anticipated. 

During operation, Gulf South estimates that the proposed Project would employ 

approximately three full-time workers. This would represent only a negligible, long-term population and 

demographic alteration. 

3.9.3 Economy and Employment 

The civilian labor force within the region of influence includes about 47,000 individuals 

whose major employment sector is education, health, social services, retail trade, and manufacturing. 

With the exception of Smith County, Mississippi, some of the counties and the parish within the region of 

influence report that the average unemployment is slightly higher and the average per capita income is 

slightly lower than the state-level values reported. In Smith County, Mississippi, the per capita income is 

considerably higher and unemployment is considerably lower than the state values (Table 3.9.3-1). 

Construction of the proposed Project would result in the hiring of approximately 28 local 

workers. Additional jobs would also be created as a result of secondary activity associated with 

construction of the proposed Project, as purchases made by non-local workers of food, clothing, lodging, 

gasoline, and entertainment would have a temporary, stimulatory effect on the local economy. These jobs 

would represent a temporary, moderate increase in employment opportunities within the region of 

influence. 

During operation, the proposed Project would create three full-time positions. This would 

represent a minor, permanent increase in the number of employment opportunities within the region of 

influence. 

3.9.4 Housing 

Table 3.9.4-1 reports selected housing statistics for the region of influence. Within this region 

there are approximately 2,148 rental units and units used for seasonal, recreational, or occasional use. 

Approximately 16,635 hotel or motel rooms supplement this potential housing stock, but most are located 

in the areas presented in Table 3.9.4-1. 

At its peak, construction of the proposed Project would require about 1,372 non-local workers, 

as described in Section 3.9.2. If each worker required his or her own housing unit, the non-local work 

force would occupy about 8.2 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 the temporary 
 3-89 

and moderate increased demand for housing resulting from construction of the proposed Project. Housing 

demand for the three permanent positions generated by operation of the proposed Project would represent 

a negligible increase in housing demand. 

3.9.5 Property Values 

The FERC frequently receives comments regarding Project impacts on property values. These 

concerns generally center on four topics: devaluation of property if encumbered by a pipeline easement; 

identification of the party responsible for property taxes within a pipeline easement; the potential for 

Project effects on landowner insurance premiums; and the potential for reduced property values 

associated with lost timber and agricultural production. 

TABLE 3.9.3-1 

Existing Income and Employment Conditions Within the 

Region of Influence for the Proposed Southeast Expansion Project 

County/Parish 

Per Capita 

Income 

($) 

1999 

Population 

Below Poverty 

Level 

(%) 

Civilian Labor 

Force 

Unemployment 

Rate 

(%) Major Industry 

Louisiana $16,912 19.6 3,381,306 7.3 

Richland Parish $12,479 23.4 8,249 6.9 Education, health, and social 

services 

Mississippi $15,853 19.9 2,165,089 7.4 

Simpson County $13,344 19.7 11,389 6.3 Retail trade 

Smith County $25,137 16.4 6,996 6.6 Manufacturing 

Jasper County $12,889 20.8 7,228 8.3 Retail trade 

Clarke County $14,288 18.9 7,312 8.5 Manufacturing 

Alabama $18,189 16.1 3,479,035 6.2 

Choctaw County $14,635 23.4 6,019 8.8 Retail trade 

_______________ 

Notes: 

U.S. Census Bureau, 2000
 3-90 

TABLE 3.9.4-1 

Housing Statistics Within the Region of Influence 

for the Proposed Southeast Expansion Project 

City, County, State 

Number Hotel/Motel 

Rooms 

Jackson, Hinds County, Mississippi 5,643 

Hattiesburg, Forrest County, 

Mississippi 

 2,122 

Meridian, Lauderdale County, 

Mississippi 

 1,312 

Laurel, Jones County, Mississippi 952 

Richland Parish, Louisiana 665 

_______________ 

Notes: 

Hattiesburg Convention and Visitors Bureau, 2006 

Meridian Chamber of Commerce, 2006 

Jones County Economic Development Authority, 2006

The impact that a natural gas project may have on the value of any land parcel depends on 

many factors. These include the size of the parcel, the parcel's current value and land use, and the value 

of other nearby properties. However, subjective valuation is generally not considered in appraisals. This 

is not to say that the proposed Project would not affect resale values. Potential purchasers may make a 

decision based on intended future use and, if the presence of the proposed Project would make that use 

infeasible, it is possible that that potential purchaser may not acquire the parcel. However, each potential 

purchaser has differing criteria and means. 

Landowners are responsible for all property taxes levied against parcels, and this 

responsibility would be independent of the existence of any Project-related pipeline easement. However, 

if a landowner felt that the proposed Project, should it be constructed, reduced the value of their property, 

he or she would appeal the assessment and subsequent property taxation to the local property taxation 

agency. If the parcel were reappraised, the landowner would then be responsible for property taxes based 

upon an appraisal that directly incorporated the easement. 

As described in Section 3.8, construction and operation of the proposed Project would result in 

a temporary loss of timber and agricultural productivity and a permanent conversion of some lands 

currently used for forestry operations to a maintained utility right-of-way. During easement negotiations, 

compensation for any loss of current or future agricultural and timber production would be considered. 

3.9.6 Government Revenue 

A portion of the estimated $60.5 million Project construction payroll would be spent locally 

for the purchase of housing, food, gasoline, and entertainment during construction. The exact amount 

would be dependent upon the proportion of the workforce that was local, the behavior of individual 

workers, and the duration of their stay. The majority of construction-related expenditures would be 

subject to either Louisiana's state sales tax of 4 percent, Mississippi's state sales tax of 7 percent, or 

Alabama's state sales tax of 4 percent (American Institute of Certified Public Accountants [AICPA], 

2006). This increase in sales tax would represent a minor short-term increase in government revenues. 
 3-91 

Table 3.9.6-1 contains Gulf South's estimate of the annual taxes that would be payable to each 

county and parish traversed by the proposed Project. Operation of the proposed Project would provide a 

permanent, minor increase in government revenues. 

TABLE 3.9.6-1 

Estimated Annual Taxes for the Proposed 

Southeast Expansion Project 

County/Parish Estimated Annual Taxes 

Louisiana 

Richland Parish $501,105 

Mississippi 

Simpson County $1,871,749 

Smith County $1,013,896 

Jasper County $1,316,551 

Clarke County $1,708,542 

Alabama 

Choctaw County $118,875 

Total $6,530,718 

3.9.7 Public Services 

Table 3.9.7-1 summarizes the number of full-time equivalent medical, police, and fire 

protection employees in the parish and counties affected by the proposed Project. These employees serve 

a population of approximately 116,828. 

Construction of the proposed Project would temporarily increase demand for medical, police, 

and fire protection services. Gulf South has consulted with the counties and parish in the region of 

influence and believes that sufficient public services exist to meet Project-related needs. Furthermore, 

Gulf South would work with local law enforcement and emergency response agencies to coordinate 

effective emergency response for the proposed Project during construction and operation (see 

Section 3.12.1). 

We note that construction of the proposed Project would occur during the school year, and a 

significant influx of students would place a considerable strain on the region's educational workers. 

However, due to the nature of the proposed construction and its relatively short duration (four months), 

non-local workers are not expected to be accompanied by substantive numbers of children. Thus, any 

impact would be minor and temporary. 

During operation of the proposed Project, workers filling the three permanent 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. 
 3-92 

TABLE 3.9.7-1 

Emergency Staff and Facilities in the Parish and Counties Affected 

by the Proposed Southeast Expansion Project 

County/Parish Police Protection Fire Protection Health and Hospitals 

Total Full-time 

Equivalent 

Louisiana 

Richland Parish Parish Sheriff's 

office and each 

municipality have 

their own law 

enforcement 

offices. 

Six fire departments 

within the county. 

One hospital with 

emergency 

capabilities. 

911 service is available 

as well as medical air 

transport. 

Mississippi

Simpson County Seven fire stations; 

five have medical 

capabilities. All 

stations are 

manned by 

volunteers. 

Two hospitals with 

emergency 

capabilities. 

Police department is 

responsible for four 

cities. Sheriff's 

department covers the 

entire county. 

911 and ambulance 

service throughout the 

county. Air service is 

available from Jackson, 

requiring about 

5 minutes' air time. 

Agreements in place 

with neighboring 

counties for HazMat 

personnel. 

Smith County One volunteer fire 

department in 

Taylorsville, 

Mississippi. 

One hospital with 

emergency 

capabilities. 

Two city police 

departments and one 

Sheriff's office within 

the county. 

911 service is available 

throughout the county. 

Jasper County Eight volunteer fire 

departments within 

the county. 

Jasper County 

Hospital is available 

with 66 beds and a 

trauma center. 

Sheriff and city police 

departments are 

located in Bay 

Springs, Mississippi. 

Jasper County First 

Responders 

601-764-2820 (EMS). 

Clarke County Fifteen volunteer 

fire departments. 

H. C. Watkins 

Memorial Hospital has 

50 beds and 

emergency 

capabilities. 

County Sheriff's office 

and each municipality 

have their own law 

enforcement offices. 

Ambulance service and 

paramedics available 

throughout the county. 

Alabama

Choctaw County Six fire 

departments within 

the county. 

One hospital with 

emergency 

capabilities. 

County Sheriff's office 

and two cities have 

their own law 

enforcement offices. 

911 service throughout 

the county. 

3.9.8 Impacts on Specific Economic Sectors 

To date, Gulf South has not received any comments from landowners or other interested 

parties requesting information regarding specific economic sectors. 

Below, we consider the potential for the proposed Project to result in significant effects to the 

agriculture and forestry economic sectors. These sectors are defined to include activities associated with 

harvested crops, timber production, livestock pasturing, and dairy production. This analysis focuses on 

the effects of potential land use changes (i.e., incorporation of agricultural lands into the construction or 

permanent rights-of-way) on regional economic sectors. Additional discussion of the potential for site-
 3-93 

specific effects to agricultural or forestry lands that would be crossed by the proposed pipeline route is in 

Sections 3.2 and 3.8. 

As described in Section 3.8, construction and operation of the proposed Project would 

permanently affect approximately 75.2 acres of agricultural land and 283.4 acres of lands currently used 

for commercial forestry practices (pine plantation), as these areas would be contained within the 

permanent pipeline right-of-way. As discussed throughout this EIS, agricultural operations within the 

vast majority of permanent pipeline right-of-way would not be precluded during operations. As affected 

agricultural lands would largely return to their preconstruction condition and use, no significant effect to 

that economic sector would be anticipated in association with construction and operation of the proposed 

Project. Commercial forestry practices would be permanently precluded within the permanent pipeline 

right-of-way. However, given the magnitude of the land potentially affected relative to the total amount 

of land dedicated to sector production, no quantifiable impacts to the forestry economic sector would be 

expected. 

3.10 CULTURAL RESOURCES 

Section 106 of the NHPA, as amended, requires the FERC to take into account the effect of its 

undertakings (including the issuance of Certificates) on any properties listed in, or eligible for listing in, 

the NRHP and to provide the ACHP an opportunity to comment on the undertaking. Gulf South, as a 

non-federal party, is assisting the FERC in meeting its obligations under Section 106 of the NHPA and 

the ACHP's regulations set forth at 36 CFR 800. 

3.10.1 Results of the Cultural Resources Survey 

3.10.1.1 Louisiana 

Information about the Delhi Compressor Station (the only portion of the project in Louisiana) 

was provided to the Louisiana State Historic Preservation Office (SHPO) in November 2006. The 

Louisiana SHPO advised on December 4, 2006 that no survey was needed for the Delhi Compressor 

Station site. No significant cultural resources or historic properties would be affected by project 

construction in Louisiana. 

3.10.1.2 Mississippi 

Gulf South conducted an initial cultural resource survey between August and November 2006, 

and January and March 2007, for the proposed pipeline, compressor station sites, associated aboveground 

ancillary facilities, and extra work areas (ATWSs, access roads, and pipe storage and contractor yards) 

within the Mississippi portion of the proposed Project. Additional surveys performed for three new 

contractor/storage yards identified by Gulf South in its May 29, 2007, response to the May 7, 2007, Data 

Request have yet to be filed. 

The Mississippi survey identified 43 prehistoric sites. Nine of those sites are considered 

potentially eligible for listing in the NRHP. The remaining 34 prehistoric sites are not considered eligible 

for listing in the NRHP, and no further work was recommended. A total of 21 historic sites, four of 

which are standing structures, were identified in the Mississippi portion of the proposed Project. Of those 

historic resources, one historic standing structure is considered potentially eligible for listing in the 

NRHP. Finally, three sites were identified as multi-component sites and two are considered eligible for 

listing in the NRHP. Gulf South has adopted route variations that avoid impacts to all cultural resource 

sites identified as potentially eligible for listing in the NRHP. 
 3-94 

The Mississippi Cultural Resource survey results are currently in review by the SHPO. Gulf 

South would need to develop plans for additional investigations at potentially significant sites to 

determine if they could be adversely affected by project construction. In the event that significant 

archaeological deposits or structures could not be avoided, treatment plans for data recovery and 

recording would need to be developed in consultation with the SHPO. 

3.10.1.3 Alabama 

Gulf South surveyed the 6.4-mile Alabama portion of the proposed pipeline, identifying no 

historic or prehistoric cultural resources. Gulf South has submitted a cultural resources survey report to 

the Alabama SHPO. To date, the Alabama SHPO has not submitted a response. 

3.10.2 Unanticipated Discoveries Plan 

Gulf South has filed an acceptable Unanticipated Discoveries Plan with the FERC that 

outlines the procedures that would be followed in the event that unanticipated cultural resources or human 

remains are encountered during construction of the proposed Project. 

3.10.3 Native American Consultation 

Gulf South contacted two Native American groups regarding the proposed Project. Those 

groups contacted include the Mississippi Band of Choctaw Indians and the Poarch Band of Creek Indians 

of Alabama. Letters were sent to representatives of each of these tribes on August 21, 2006, requesting 

comments on the proposed Project and the identification of any cultural or religious sites significant to the 

tribe. As of May 2007, no replies have been received from these tribes. 

3.10.4 General Impacts and Mitigation 

Gulf South has completed most of the necessary cultural resources surveys and submitted the 

required cultural resource survey reports to the Mississippi and Alabama SHPOs. Cultural resource 

surveys performed for modified work areas are still under review by the Mississippi and Alabama 

SHPOs. No response from either agency has been received to date. To ensure that required cultural 

resource studies and consultations are completed for all proposed Project components and that the FERC's 

responsibilities under Section 106 of the NHPA are met, we recommend that: 

• Gulf South should defer implementation of any treatment plans/measures (including 

archaeological data recovery), construction of facilities, and use of all staging, storage, or 

temporary work areas and new or to-be-improved access roads until: 

a. Gulf South files with the Secretary cultural resources survey and evaluation reports, 

any necessary treatment plans, and the Mississippi and Alabama SHPO comments 

on the reports and plans; and 

b. The Director of OEP reviews and approves all cultural resources survey reports and 

plans and notifies Gulf South in writing that treatment plans/procedures may be 

implemented and/or construction may proceed. 

 All material filed with the Secretary 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." 
 3-95 

3.11 AIR QUALITY AND NOISE 

3.11.1 Air Quality 

Air quality would be affected by construction and operation of the proposed Project. Though 

air emissions would be generated by operation of equipment during construction of the pipeline and 

aboveground facilities proposed by Gulf South, most air emissions associated with the proposed Project 

would result from the long-term operation of the proposed and modified compressor stations. 

Gulf South proposes to construct the Delhi Compressor Station near Delhi in Richland Parish, 

Louisiana; to construct the Harrisville Compressor Station near Harrisville in Simpson County, 

Mississippi; and to construct the Destin Gas Transmission pipeline interconnect near Shubuta in Clark 

County, Mississippi. 

At the Delhi Compressor Station, Gulf South proposes to install four Caterpillar 3616TALE 

engines equipped with oxidation catalyst, with a planned compression capacity of 18,940 Hp, one gasfired 1,155-Hp Waukesha VGF standby generator engine limited to 500 hours/year, one 0.75 MMBtu/hr 

fuel gas heater, a condensate tank, condensate truck loading point, and an ESD blowdown stack. 

At the Harrisville Compressor Station, Gulf South proposes to install four Caterpillar 

3616TALE engines equipped with oxidation catalysts, with a planned compression capacity of 18,940 

Hp, one gas-fired 470-Hp Waukesha VGF 24GL standby generator engine limited to 500 hours/year, a 

condensate tank, condensate truck loading point, and an ESD blowdown stack. 

At the Destin Compressor Station, Gulf South proposes to install two Caterpillar 3612 engines 

equipped with oxidation catalysts with a planned compression capacity of 7,100 Hp, one gas-fired 425-Hp 

Waukesha VGF 18GL standby generator engine limited to 500 hours/year, one 0.75-MMBtu/hour fuel 

gas heater, one condensate storage tank, condensate truck loading point, and an ESD blowdown stack. 

3.11.1.1 Existing Air Quality 

The proposed Project would be constructed in portions of Richland Parish in Louisiana; 

Simpson, Smith, Jasper, and Clarke Counties in Mississippi; and Choctaw County in Alabama. These 

counties and parishes are characterized by a temperate climate. Rainfall at Jackson, Mississippi, located 

near the center of the proposed pipeline route, averages 55.95 inches annually (Weather.com). April is 

the wettest month in Jackson, averaging 5.98 inches of precipitation; and September is the driest month, 

averaging 3.23 inches. The warmest month is July, with an average high temperature of 91o Fahrenheit 

(F) and an average low temperature of 71o F. January is the coldest month, with an average high 

temperature of 55o F and an average low temperature of 35o F. 

The 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. Both Louisiana, and Mississippi have 

adopted the NAAQS, as defined in 40 CFR 50; these standards are summarized in Table 3.11.1.1-1. 
 3-96 

Air Quality Control Regions and Attainment Status 

Air quality control regions (AQCR) are areas established for air quality planning purposes in 

which implementation plans describe how ambient air quality standards will be achieved and maintained. 

AQCRs were established by the EPA and local agencies, in accordance with Section 107 of the CAA, as a 

means to implement the CAA and comply with the NAAQS through state implementation plans. The 

AQCRs are intra- and interstate regions such as large metropolitan areas where improvement of the air 

quality in one portion of the AQCR requires emission reductions throughout the AQCR. Each AQCR, or 

portion thereof, is designated based on compliance with the NAAQS. AQCR designations fall under 

three categories as follows: "attainment" (areas in compliance with the NAAQS); "nonattainment" (areas 

not in compliance with the NAAQS); or "unclassifiable", which refers to areas with insufficient data to 

make a determination. The counties and parishes in which the proposed Project would be located are 

designated as "attainment" or "unclassifiable" for all criteria pollutants. 

TABLE 3.11.1.1-1 

National Ambient Air Quality Standards 

Pollutant Timeframe Primary Secondary 

 Particulate matter less than 

10 microns in diameter 24-houra 150 μg/m3

 150 μg/m3

Annualb 15 μg/m3 15 μg/m3

Particulate matter less than 

2.5 microns in diameter 24-hourc 35 μg/m3 35 μg/m3

Annual 0.030 ppm (80 μg/m3) N/A 

24-houra 0.014 ppm (365 μg/m3 Sulfur dioxide ) N/A 

3-houra N/A 0.5 ppm (1,300 μg/m3

) 

8-houra 9 ppm (10,000 μg/m3) None 

Carbon monoxide 

1-houra 35 ppm (40,000 μg/m3

) None 

Nitrogen dioxide Annual 0.053 ppm (100 μg/m3) 0.053 ppm 

Ozone 8-hourd 0.08 ppm (157 μg/m3) 0.08 ppm 

Lead Quarterly 1.5 μg/m3 1.5 μg/m3

____________ 

Notes: 

μg = Microgram(s) 

m3

 = Cubic meter(s) 

N/A = Not applicable 

ppm = Part(s) per million 

a Not to be exceeded more than once per year. 

b 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 15.0 μg/m3. 

c 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. 

d 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. 
 3-97 

3.11.1.2 Regulatory Requirements 

Federal Regulations 

The CAA, 42 USC 7401 et seq. amended in 1977 and 1990, and 40 CFR Parts 50 through 99 

are the basic federal statutes governing air pollution. The provisions of the CAA that are potentially 

relevant to the proposed Project include the following: 

• New Source Review (NSR)/Prevention of Significant Deterioration (PSD) 

• New Source Performance Standards (NSPS) 

• National Emission Standards for Hazardous Air Pollutants (NESHAP) 

• Title V operating permits 

• General Conformity 

New Source Review/Prevention of Significant Deterioration

New Source Review 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 located in attainment or unclassified areas. This review may 

include a PSD review. This review process is intended to keep new air emission sources from causing 

existing air quality to deteriorate beyond acceptable levels codified in the federal regulations. For sources 

located in non-attainment areas, the Nonattainment New Source Review (NNSR) program is implemented 

for the pollutants for which the area is classified as nonattainment. The proposed Project would be 

located in attainment areas. Consequently, NNSR is not applicable to the proposed Project. 

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 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 these thresholds trigger 

PSD review. The proposed Project would not include facilities or operations included on the list of 

named source categories to which the 100 tpy trigger applies. Also, the proposed Project does not include 

any existing major sources under the PSD program; therefore the proposed Delhi, Harrisville, and Destin 

Compressor Stations are all subject to the 250 tpy threshold. 

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. 

None of the new facilities or additions to existing facilities would exceed emissions of 250 tpy 

of any criteria pollutant (see Tables 3.11.1.2-1 through 3.11.1.2-3 and the discussion under "Operations 

Emissions"). Therefore, PSD permitting is not applicable to the proposed Project. 
 3-98 

Air Quality Control Regions and PSD

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 and have the lowest increment of 

permissible deterioration, which essentially precludes development near these areas. 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. 

Class II areas are designed to allow moderate, controlled growth. The proposed Project would be located 

in a Class II area. The nearest Class I areas are the Caney Creek Wilderness, located south of Mena, 

Arkansas, and the Breton Sound Wilderness Area, located southeast of New Orleans. The proposed Delhi 

Compressor Station is approximately 215 miles south of the Caney Creek Wilderness Area. The 

proposed Harrisville and Destin Compressor Stations are approximately 170 miles north of the Breton 

Sound Wilderness Area. 

TABLE 3.11.1.2-1 

Proposed Emissionsa

 for the Delhi Compressor Station 

Emissions Source 

NOx 

(TPY) 

CO 

(TPY) 

VOC 

(TPY) 

PM10

(TPY) 

PM2.5 

(TPY) 

SO2

(TPY) 

HAPs 

(TPY) 

Compressor Engine #1 32.01 8.00 22.40 1.41 1.41 0.08 3.70 

Compressor Engine #2 32.01 8.00 22.40 1.41 1.41 0.08 3.70 

Compressor Engine #3 32.01 8.00 22.40 1.41 1.41 0.08 3.70 

Compressor Engine #4 32.01 8.00 22.40 1.41 1.41 0.08 3.70 

Emergency Backup Generator 1.66 1.11 0.48 0.02 0.02 0.00 0.18 

Condensate Storage Tankb -- -- 6.61 -- -- -- 0.49 

Truck Loading of Condensateb -- -- 1.14 -- -- -- 0.17 

Fuel Gas Heater 0.33 0.28 0.02 0.02 0.02 0.00 0.01 

Piping Components (Fugitives) -- -- 3.27 -- -- -- 0.01 

Unpaved Roads (Fugitives) -- -- -- 0.43 0.06 -- -- 

Engine Blowdown Stack -- -- 6.29 -- -- -- 0.32 

Area Releases -- -- 5.33 -- -- -- 0.27 

Total 130.03 33.39 112.74 6.11 5.74 0.32 16.25 

_______________ 

Notes: 

a Based on full load and continuous operation. Emergency generator based on 500 hours/year. 

b Estimated using GRI-GlyCalc3.01. 
 3-99 

TABLE 3.11.1.2-2 

Proposed Emissionsa

 for the Harrisville Compressor Station 

Emissions Source 

NOx 

(TPY) 

CO 

(TPY) 

VOC 

(TPY) 

PM10

(TPY) 

PM2.5 

(TPY) 

SO2

(TPY) 

HAPs 

(TPY) 

Compressor Engine #1 32.01 8.00 22.40 1.41 1.41 0.08 3.70 

Compressor Engine #2 32.01 8.00 22.40 1.41 1.41 0.08 3.70 

Compressor Engine #3 32.01 8.00 22.40 1.41 1.41 0.08 3.70 

Compressor Engine #4 32.01 8.00 22.40 1.41 1.41 0.08 3.70 

Emergency Backup Generator 1.66 1.11 0.48 0.02 0.02 0.00 0.18 

Condensate Storage Tankb -- -- 6.61 -- -- -- 0.49 

Truck Loading of Condensateb -- -- 1.14 -- -- -- 0.17 

Fuel Gas Heater 0.33 0.28 0.02 0.02 0.02 0.00 0.01 

Piping Components (Fugitives) -- -- 3.27 -- -- -- 0.01 

Unpaved Roads (Fugitives) -- -- -- 0.43 0.06 -- -- 

Engine Blowdown Stack -- -- 6.29 -- -- -- 0.32 

Area Releases -- -- 5.33 -- -- -- 0.27 

Total 130.03 33.39 112.74 6.09 5.74 0.32 16.25 

_______________ 

Notes: 

a Based on full load and continuous operation. Emergency generator based on 500 hours/year. 

b Estimated using GRI-GlyCalc3.01. 

TABLE 3.11.1.2-3 

Proposed Emissionsa

 for the Destin Compressor Station 

Emissions Source 

NOx 

(TPY) 

CO 

(TPY) 

VOC 

(TPY) 

PM10

(TPY) 

PM2.5 

(TPY) 

SO2

(TPY) 

HAPs 

(TPY) 

Compressor Engine #1 24.00 6.00 16.80 1.06 1.06 0.06 2.78 

Compressor Engine #2 24.00 6.00 16.80 1.06 1.06 0.06 2.78 

Emergency Backup Generator 0.61 0.41 0.18 0.01 0.01 0.001 0.07 

Condensate Storage Tankb -- -- 6.61 -- -- -- 0.49 

Truck Loading of Condensateb -- -- 1.14 -- -- -- 0.17 

Fuel Gas Heater 0.33 0.28 0.02 0.02 0.02 0.002 0.01 

Piping Components (Fugitives) -- -- 3.27 -- -- -- 0.01 

Unpaved Roads (Fugitives) -- -- -- 0.43 0.06 -- -- 

Engine Blowdown Stackc -- -- 6.29 -- -- -- 0.32 

Area Releases -- -- 5.33 -- -- -- 0.27 

Total 48.94 12.69 56.44 2.58 2.21 0.12 6.90 

_______________ 

Notes: 

a Based on full load and continuous operation. Emergency generator based on 500 hours/year. 

b Estimated using GRI-GlyCalc3.01. 

c The engine blowdown stack is for venting of natural gas from the compressor during maintenance activities. 
 3-100 

New Source Performance Standards

The NSPS, codified in 40 CFR 60 and incorporated by reference in Louisiana Administrative 

Code (LAC) 33.III.3303, and the Mississippi Commission on Environmental Quality (MCEQ) regulations 

APC-S-1 Section 6.3, establish requirements for new, modified, or reconstructed units in specific source 

categories. NSPS requirements include emission limits, monitoring, reporting, and record keeping. The 

following NSPS requirements were identified as potentially applicable to the specified sources at the 

compressor stations. 

Subpart Kb of 40 CFR 60, Standards of Performance for Volatile Organic Liquid Storage 

Vessels, lists affected emission sources as storage vessels containing volatile organic liquids. Regulatory 

applicability is dependent on the construction date, size, and vapor pressure of the storage vessel and its 

contents. Subpart Kb applies to new tanks, unless otherwise exempted, that have a storage capacity 

between 75 square meters (m3

) (19,813 gallons) and 151 m3 (39,890 gallons) and contain volatile organic 

compounds (VOCs) with a maximum true vapor pressure greater than or equal to 15.0 kilopascals (kPa). 

Subpart Kb also applies to tanks that have a storage capacity greater than or equal to 151 m3

 and contain 

VOCs with a maximum true vapor pressure greater than or equal to 3.5 kPa. Each proposed compressor 

station would be equipped with a condensate tank, which is below the regulated capacity. Therefore, the 

proposed Project would not be subject to NSPS Subpart Kb standards. 

On June 12, 2006, EPA proposed a new NSPS (40 CFR 60 Subpart JJJJ) for stationary spark 

ignition (SI) internal combustion engines. The proposed compressor stations each contain natural gasfired compressor engines and emergency generators that may be potentially subject to 40 CFR 60 Subpart 

JJJJ. The proposed standard for stationary SI engines applies to all new, modified, and reconstructed 

stationary SI engines regardless of size. The pollutants to be regulated by the proposed NSPS for 

stationary SI engines are nitrogen oxides (NOx), CO, and non-methane hydrocarbons (NMHC). Gulf 

South would comply with any applicable standards of EPA's proposed rule once it is finalized. 

No other NSPSs are applicable to the proposed Project. 

National Emission Standards for Hazardous Air Pollutants 

The NESHAP, codified in 40 CFR Parts 61 and 63, regulates hazardous air pollutant (HAP) 

emissions. Part 61 was promulgated prior to the 1990 Clean Air Act Amendments (CAAA) and regulates 

only eight types of hazardous substances (asbestos, benzene, beryllium, coke oven emissions, inorganic 

arsenic, mercury, radionuclides, and vinyl chloride). 

The 1990 CAAA established a list of 189 HAPs, resulting in the promulgation of Part 63. 

Part 63, also known as the Maximum Achievable Control Technology (MACT) standards, regulates HAP 

emissions from major sources of HAP emissions and specific source categories that emit HAPs. Part 63 

defines a major source of HAPs as any source that has the potential to emit 10 tpy of any single HAP or 

25 tpy of HAPs in aggregate. MACT standards are intended to reduce emissions of air toxics or HAPs 

through installation of control equipment rather than enforcement of risk-based emission limits. The 

proposed Delhi, Harrisville, and Destin Compressor Stations each would emit less than 25 tpy of total 

HAPs, as shown in Tables 3.11.1.2-1, 3.11.1.2-2, and 3.11.1.2-3, and no more than 10 tpy of any single 

HAP as reflected in Gulf South's emission estimates. Potential HAP emissions resulting from the 

proposed Project would be well below the 10/25 tpy thresholds at each station; therefore, MACT is not 

applicable. 
 3-101 

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 VOC. Emissions of NOx and VOC at the Delhi and Harrisville Compressor Stations would 

exceed the 100 tpy criteria pollutant threshold, as shown in Tables 3.11.1.2-1 and 3.11.1.2-2. Therefore, 

the Delhi and Harrisville Compressor Stations would require a Title V permit. None of the criteria 

pollutants would be emitted at the 100 tpy level at the Destin Compressor Station; therefore, a Title V 

permit would not be required for this facility. 

General Conformity

40 CFR parts 51 and 93 define the requirements for determining conformity for federal actions 

to state or federal implementation plans. A conformity analysis is required for each criteria pollutant 

where the total of direct and indirect emissions in a nonattainment or maintenance area caused by a 

federal action would equal or exceed any of the rates specified in the applicable implementation plan. 

The proposed Project would not be located in a nonattainment area and therefore, the general conformity 

requirements do not apply to the proposed Project. 

State Regulations 

In addition to the federal regulations described above, both Louisiana and Mississippi have 

state air quality regulations. The LDEQ manages air quality issues in Louisiana and the MDEQ manages 

air quality issues in Mississippi. Subject to EPA approval, these agencies manage the statewide air 

permitting, compliance, and enforcement programs. The Delhi Compressor Station would be authorized 

under the LDEQ Part 70 program, and the Harrisville and Destin Compressor Stations would be 

authorized under the MDEQ construction permit program. The Harrisville Compressor Station would file 

for a Title V permit with the MDEQ within a year after construction is completed. 

3.11.1.3 General Impacts and Mitigation 

Construction Emissions 

Construction of the pipeline and access roads would generate air emissions during grading, 

trenching, backfilling, and during operation of construction vehicles along unpaved areas. The proposed 

Project would use existing roads to the extent possible. Some roads used for access would be improved 

during construction by widening or adding drain pipes, gravel, or grading; and some new roads and road 

extensions would be constructed. The roads would remain after construction to provide access to the 

pipeline for maintenance purposes. These activities could generate dust and particulate emissions from 

earth-moving activities and construction equipment engine exhaust. 

Construction of the compressor stations would be performed with mobile equipment similar to 

that typically used for pipeline and road construction. In addition to the compressor stations, Gulf South 

would construct other aboveground facilities consisting of metering and regulation stations. 

Construction would be expected to cause a minor and temporary impact to local ambient air 

quality as a result of fugitive dust and combustion emissions generated by construction equipment. 

Criteria pollutant emissions during operation of the fossil-fueled construction equipment would occur 
 3-102 

from combustion products resulting from the 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 and would be expected to result in an insignificant impact on air quality. 

LDEQ regulates the emissions of particulate matter arising from unpaved streets, access roads, 

construction activities through LAC33.III.1305, which requires application of water or dust-retardant 

chemicals, or paving of roadways. MDEQ does not have a specific regulation for fugitive dust from 

roadways. Gulf South indicates that if fugitive dust becomes a problem it would use proven construction 

practices such as water sprays to control fugitive dust. Water sprays have provided sufficient control to 

ensure protection of air quality during construction of projects similar to the proposed Project. 

Operations Emissions 

Emissions from the engines at all locations would be minimized through the use of Clean 

Burn technology, oxidation catalysts, and the use of clean burning natural gas fuels. As described in 

Section 3.11.1.2, the compressor stations would be operated in compliance with federal and state air 

quality regulations driven by the CAA. As stated previously, the proposed project would not be subject to 

PSD. 

Each compressor station would include an emergency shut down (ESD) system, pursuant to 

DOT requirements. Activation of the ESD system would vent the piping (expel the natural gas) to the 

atmosphere in case of an emergency. The ESD would be used only in the event of an emergency. 

Compressor unit blowdowns would occur as needed to relieve pressure when a unit is taken off line. 

Natural gas blowdowns are not part of routine operation. 

Tables 3.11.1.2-1 through 3.11.1.2-3 list the anticipated emissions of criteria pollutants and 

HAPs from the operation of each compressor station. Gulf South is completing air permit applications for 

the Delhi, Harrisville, and Destin Compressor Stations. Gulf South will provide the FERC copies of these 

applications upon submittal to the state permitting authorities. 

Following the Draft EIS, Gulf South filed a revised screening analysis (using SCREEN3) for 

NOx emissions for the Harrisville and Destin Compressor Stations. Emissions from the Delhi 

Compressor Station were not modeled. SCREEN3 is a conservative model used to determine if refined 

modeling is needed. It does not take into account specific local terrain or meteorological data. Since the 

equipment and emissions from the Delhi Compressor Station would be the same as the equipment and 

emissions from the Harrisville Compressor Station, NO2 concentrations would be expected to be similar 

to the SCREEN3 modeled results for the Harrisville Compressor Station. 

Gulf South used typical conversion factors in calculating the various concentrations for 

different averaging times as recommended in EPA's "Screening Procedures for Estimating the Air Quality 

Impact of Stationary Sources, Revised" (EPA-454/R-92-019, October 1992), a document for applying 

screening techniques to estimate the air quality impact of stationary sources. 

The Destin analysis included the NOx emissions from the two new gas compressor engines 

and the emergency generator engine. Emissions from the small heater were not considered in this 

analysis since the potential to emit is less than 1/2 tpy. The worst-case hourly impact for the two engines 

and the emergency generator was estimated to be 200.04 μg/m3. The estimated annual NOx impact is 

16.0 μg/m3. Background NO2 concentrations at this location were not available; however, background 

concentrations of NO2 were available for Jackson County, Mississippi, averaging 13.16 μg/m3 over the 

past three years. Assuming this is a worst-case background concentration, when added to station impacts 
 3-103 

this results in a total off-site NOx concentration of 29.16 μg/m3

. This is well below the NAAQS of 

100 μg/m3 for NO2. In addition, this finding is conservative since it does not include an NO2/NOx 

reduction ratio. Based on these results, refined modeling is not needed. 

The Harrisville analysis included the NOx emissions from the four new gas compressor 

engines and the emergency generator engine. Emissions from the small heater were not considered in this 

analysis since the potential to emit is less than 1/2 tpy. The worst-case hourly impact for the four engines 

and the emergency generator was estimated to be 275.66 μg/m3. The estimated annual impact is 

22.05 μg/m3. Background NO2 concentrations at this location were not available; however, background 

concentrations of NO2 were available for Jackson County, Mississippi, averaging 13,16 μg/m3over the 

past three years. Assuming this is a worst-case background concentration, when added to station impacts, 

this results in a total off-site NOx concentration of 35.21 μg/m3. This is well below the NAAQS of 

100 μg/m3 for NO2. In addition, this finding is conservative since it does not include an NO2/NOx 

reduction ratio. Based on these results, refined modeling is not needed. 

Operation of the aboveground 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; and 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. 

Construction of the proposed Project would be expected to result in temporary minor impacts 

to air quality. Operation of the proposed Project would be expected to result in long-term minor impacts 

to air quality. 

3.11.2 Noise Quality 

Noise quality can be affected both during construction and operation of pipeline projects. The 

magnitude and frequency of environmental noise may vary considerably over the course of the day and 

throughout the week, in part due to changing weather conditions and the effects of seasonal vegetative 

cover. Two measures used by federal agencies to relate the time varying quality of environmental noise 

to its known effect on people are the 24-hour equivalent sound level (Leq) and day-night sound level (Ldn). 

The Leq is the level of steady sound with the same total (equivalent) energy as the time-varying sound of 

interest, averaged over a 24-hour period. The Ldn is the Leq with 10 decibels on the A-weighted scale 

(dBA) added to nighttime sound levels between the hours of 10 p.m. and 7 a.m. to account for people's 

greater sensitivity to sound during nighttime hours. The A-weighted scale is used because human hearing 

is less sensitive to low and high frequencies than mid-range frequencies. The human ear's threshold of 

perception for noise change is considered to be 3 dBA. 

3.11.2.1 Regulatory Requirements 

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. EPA 

has determined that an Ldn of 55 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. 
 3-104 

Mississippi and Louisiana do not regulate noise at the state level. Similarly, no noise 

regulations or ordinances that govern noise pollution from construction or industrial activities have been 

identified for any of the counties or local municipalities to be traversed by the proposed Project. 

3.11.2.2 Existing Noise Levels 

Impacts are determined at receptors known as noise sensitive areas (NSAs). NSAs include 

residences, schools and daycare facilities, hospitals, long-term care facilities, places of worship, libraries, 

and parks and recreational areas specifically known for their solitude and tranquility, such as wilderness 

areas. The following NSAs and background noise levels have been evaluated at each compressor station. 

The Delhi Compressor Station would be located in Richland Parish, Louisiana, on the south 

side of Delhi, Louisiana. The land surrounding the site consists of pasture and active agriculture. There 

are currently no existing facilities at the site although there is a natural gas compressor station (i.e., 

Columbia Gulf Transmission Corporation's (CGTs) Delhi Compressor Station) near the site of the 

proposed Delhi Compressor Station. The closest NSA (NSA #1) consists of homes located approximately 

1,100 feet west of the anticipated location of the compressor building (i.e., site center), and the next 

closest NSA (NSA #2) consists of two homes located approximately 1,500 feet northwest of the site 

center. NSA #3, while located only 900 feet northwest of the site, is not expected to be present after 

installation of the compressor station, and is therefore not evaluated as the nearest NSA. On 

September 26, 2006, Gulf South conducted an ambient sound-level survey at NSA #1. Noise sources 

during the sound-level survey included traffic on local roads, insects, birds, and wind. Measured noise at 

NSA #1 ranged from 45.0 to 53.6 dBA, with a calculated Ldn of 54.2 dBA (Table 3.11.2.2-1). Measured 

noise at NSA #2 ranged from 45.0 to 60.9 dBA, with a calculated Ldn of 59.5 dBA. Measured noise at 

NSA #3 ranged from 40.0 to 40.2 dBA, with a calculated Ldn of 46.4 dBA. 

The Harrisville Compressor Station would be located in Simpson County, Mississippi, 

approximately 9 miles south of Florence, Mississippi. The land surrounding the site consists primarily of 

forest. The nearest NSAs are residences 4,200 feet east (NSA #1), 5,600 feet south-southeast (NSA #2), 

and 4,800 feet northwest (NSA #3) of the proposed station. On September 20, 2006, Gulf South 

conducted an ambient sound-level survey at the NSAs. Noise sources during the sound-level survey 

included traffic on local roads, insects, birds, and wind. Measured noise at NSA #1 was determined to be 

37.1 dBA, with a calculated Ldn of 43.5 dBA. At NSA #2, measured noise was determined to be 

42.1 dBA, with a calculated Ldn of 48.5 dBA. At NSA #3, measured noise was determined to be 

38.2 dBA, with a calculated Ldn of 44.6 dBA. On June 15, 2007, Gulf South submitted a revised 

acoustical analysis for the Harrisville Compressor Station. The revised analysis was required since the 

potential noise impact of the Station on the Twin Lakes Camping Area (owned by the First Presbyterian 

Church of Jackson, Mississippi) was not addressed in the initial acoustical analysis (September 20, 2006) 

for the station. The three NSAs at the Twin Lakes Camping Area include NSA #4 (Wilderness Camp 

Area, 2,600 feet northwest), NSA #5 (Area of Restrooms/Cabins, 3,700 feet north-northwest,) and NSA 

#6 (Ropes Course, 4,000 feet north-northwest). At NSAs #4, #5, and #6, measured noise was determined 

to be 38.2 dBA at each location, with a calculated Ldn of 44.6 at each location (Table 3.11.2.2-1). 

The Destin Compressor Station would be located in Clarke County, Mississippi, 

approximately 8 miles northwest of Shubuta, Mississippi. The land surrounding the site consists 

primarily of forest. The nearest NSA is a residence located approximately 1,400 feet east-northeast of the 

anticipated location of the compressor station. On September 22, 2006, Gulf South conducted an ambient 

sound-level survey at the NSA. Noise sources during the sound-level survey included traffic on local 

roads, insects, birds, and wind. Measured noise at NSA #1 was determined to be 41.9 dBA, with a 

calculated Ldn of 48.3 dBA (Table 3.11.2.2-1). 
 3-105 

3.11.2.3 General Impacts and Mitigation 

Construction Noise 

Construction of the proposed Project is expected to be typical of other pipeline projects in 

terms of schedule, equipment used, and types of activities. Construction would increase sound levels in 

the vicinity of proposed Project activities, and the sound levels would vary during the construction period, 

depending on the construction phase. Pipeline construction generally would proceed at rates ranging 

from several hundred feet to 1 mile per day. However, due to the assembly-line method of construction, 

construction activities in any one area could last from several weeks to several months on an intermittent 

basis. Construction and modifications at the compressor stations would be concentrated in the vicinity of 

the construction activity. Construction equipment would be operated on an as-needed basis during those 

periods and would be maintained to manufacturers' specifications to minimize noise impacts. 

TABLE 3.11.2.2-1 

Existing Noise Levels at Nearest Noise-Sensitive Areas 

from the Proposed Southeast Expansion Project Compressor Stations 

Noise Sensitive 

Area (NSA) 

Distance/Direction of 

NSA to Compressor 

Station Site 

(feet) 

Measured Ld

(dBA) 

Estimated Ln

(dBA) 

Calculated Ldn

(dBA) 

Delhi Compressor Station 

NSA #1 1,100 – west 53.6 dBA 45.0 dBA 54.2 dBA 

NSA #2 1,500 – northwest 60.9 dBA 45.0 dBA 59.5 dBA 

NSA #3 900 – northeast 40.2 dBA 40.0 dBA 46.4 dBA 

Harrisville Compressor Station 

NSA #1 4,200 – east 37.1 dBA 37.1 dBA 43.5 dBA 

NSA #2 5,600– south southeast 42.1 dBA 42.1 dBA 48.5 dBA 

NSA #3 4,800 – northwest 38.2 dBA 38.2 dBA 44.6 dBA 

NSA #4 2,600 – northwest 38.2 dBA* 38.2 dBA* 44.6 dBA* 

NSA #5 3,700 – north-northwest 38.2 dBA* 38.2 dBA* 44.6 dBA* 

NSA #6 4,000 – north-northwest 38.2 dBA* 38.2 dBA* 44.6 dBA* 

Destin Compressor Station 

NSA #1 1,400 east northeast 41.9 dBA 41.9 dBA 48.3 dBA 

_______________ 

Notes: 

Ld = daytime sound levels 

Ln = nighttime sound levels 

Ldn = day-night equivalent sound level 

dBA = decibels on the A-weighted scale 

* Ambient sound level not measured but should be similar to measured ambient sound level at NSA #3 

Nighttime noise levels would normally be unaffected because most pipeline construction 

would take place only during daylight hours. The possible exceptions would be at the HDD sites (e.g., at 

the crossings of water bodies and highways). At HDD locations, drilling equipment may operate on a 

24-hour-per-day basis. In addition to the EPA's 55 dBA (Ldn) standard, noise level changes are 

categorized as follows: a 3 dBA increase is considered noticeable, a 6 dBA increase is considered clearly 

noticeable, and a 10 dBA increase is considered significantly noticeable. An acoustical assessment was 

prepared for all of the planned HDD sites with NSAs within 1 mile of HDD locations to show existing 

sound levels at each site location and the project levels from HDD activity. Predicted noise impacts on 

NSAs indicate that sound levels could exceed 55 dBA (Ldn) at two of the 24 HDD entry and exit sites due 

to HDD operations. Predicted sound levels ranged from 57.3 to 59.21 dBA (Ldn) at these two sites, as 
 3-106 

shown in Table 3.11.2.3-1. Based on the acoustical assessment, all HDD locations would contribute 

below a 10 dBA noise increase above the ambient sound levels. 

To ensure that NSAs are not exposed to excessive noise during nighttime drilling operations, 

Gulf South developed a plan for HDD operations that have the potential to exceed 55 dBA (Ldn), as listed 

in Table 3.11.2.3-1 below. The plan would install a temporary noise barrier system around the primary 

area of equipment at either the HDD entry side or HDD exit side. The barrier could be installed around 

two or three sides of the HDD equipment area. For example, the barrier could be constructed of 3/4-inchthick plywood panels (e.g., barrier height should be at least 16 feet). If a plywood-type barrier is 

employed, it is also recommended that at least 60 percent of the inside surface of the barrier (i.e., surface 

facing the equipment) should be sound absorptive (e.g., attach 2-inch-thick fiberglass duct board). In 

addition, it is recommended that any diesel engines used to drive generators/pumps associated with HDD 

operations should include an adequate exhaust muffler (e.g., minimum, hospital-grade exhaust silencer). 

It should be noted that reducing the noise of mobile equipment, such as a crane or backhoe, is much more 

difficult than stationary engines and equipment since mobile equipment may have to work outside the 

general HDD equipment area. 

Table 3.11.2.3-1 summarizes the projected Ldn at the closest NSA at each HDD site in which 

the benchmark sound criterion could be exceeded assuming that a temporary noise barrier is not 

employed successfully. For reference, a barrier system, if properly employed, could provide 

approximately 6 to 8 dB reduction of the noise associated with HDD stationary equipment. Based on the 

projected HDD noise levels, distances from HDD activity to the nearest NSAs, and Gulf South's HDD 

plan described above, HDD activity impacts would be minor and temporary at all nearby NSAs. 

TABLE 3.11.2.3-1 

Summary of the Estimated A-Weighted Level and Calculated Ldn at the Closest NSA for 

Each HDD Site That Could Exceed the Benchmark Sound Criterion, Assuming That a 

Temporary Barrier is Not Employed 

HDD 

No. 

Location of HDD in 

Which Benchmark 

Criterion Could Be 

Exceeded 

Entry or 

Exit 

Point 

Distance and 

Direction of 

Closest NSA 

Calculated Ldn

Due to Drilling 

Activity 

Estimated Ldn With a 

Temporary Noise 

Barrier Employed 

01 Dabbs Creek and Hwy. 

49 

Entry 1,200 ft. (west) 57.3 dBA 51.2 dBA 

08 Interstate 59 Entry 1,000 ft. (SW) 59.1 dBA 53.0 dBA 

Operational Noise 

During operation of the proposed Project, potential noise impacts would be limited to the 

vicinity of the new compressor stations. Principal noise sources would include the air inlet, exhaust, and 

casing of the turbines. Secondary noise sources would include yard piping and valves. Noise from the 

relief valves, blowdown stacks, and emergency electrical generation equipment would be infrequent. 

All compressor stations would include design measures to minimize sound generation. 

Silencers or mufflers would be installed on the turbine exhausts, and silencers would be installed on the 

turbine air intakes. The walls and roof of each compressor building would be comprised of acoustical 

panels consisting of a 22-gauge metal outer skin and 4 inches of fiberglass insulation with a perforated 

liner. The building ventilation system vents would be equipped with acoustical louvers or duct silencers. 
 3-107 

The expected Ldn at NSA #1 closest to the Delhi Compressor Station would be 51.0 dBA due 

to sound generated by operation of the new station. When combined with the existing ambient noise 

level, the Ldn would be about 55.9 dBA at NSA #1, as shown in Table 3.11.2.3-2. The expected Ldn at 

NSA #2 is an estimated 47.6 dBA and 59.8 dBA when combined with the existing ambient noise level. 

Expected noise levels for NSA #3 is estimated to be 52.9 dBA and 55.5 dBA when combined with 

existing ambient noise levels. Predicted noise at the NSAs attributable to the Delhi Compressor Station is 

below the FERC specification of 55 dBA (Ldn). It should be noted that although NSA #3 is located 

900 feet from the compressor station, this site is not expected to exist at the time of operation. As a result, 

no significant impact on the noise environment is anticipated as a result of typical operations at the Delhi 

Compressor Station. 

The expected Ldn at NSA #4 closest to the Harrisville Compressor Station would be 42.3 dBA due to 

sound generated by operation of the new station. When combined with the existing ambient noise level, 

the Ldn would be about 44.6 dBA at NSA #4. Table 3.11.2.3-3 provides the ambient sound level at each 

NSA, the estimated contribution of the proposed station operating at full load at each NSA, the calculated 

sum of the two, and the potential noise increase at each NSA due to the station's contribution. The 

predicted noise attributable to the Harrisville Compressor Station at all NSAs is below the FERC 

specification of 55 dBA (Ldn). As a result, no significant impact on the noise environment is anticipated 

as a result of typical operations at the Harrisville Compressor Station. 

The expected Ldn at NSA #1 closest to the Destin Compressor Station would be 49.0 dBA due 

to sound generated by operation of the new station. When combined with the existing ambient noise 

level, the Ldn would be about 51.7 dBA at NSA #1, as shown in Table 3.11.2.3-4. This level is below the 

FERC specification of 55 dBA (Ldn). As a result, no significant impact on the noise environment is 

anticipated as a result of typical operations at the Destin Compressor Station. 

Minor short-term noise impacts are expected during the proposed Project construction, 

provided that equipment is maintained to the manufacturers' specifications to minimize noise. This 

assessment assumes that temporary noise barriers would be installed at the HDD sites listed in Table 

3.11.2.3-1, and that hospital-grade mufflers would be installed on engines that do not move while 

operating at HDD sites listed in Table 3.11.2.3-1. 

Minor long-term noise impacts are expected from compressor station operation during the life 

of the proposed Project and would not result in a significant effect on the noise environment. These 

minor impacts would result from the normal operation of compressor station equipment, as well as from 

blowdown events. 
 3-108 

TABLE 3.11.2.3-2 

Predicted Noise Contribution of the Delhi Compressor Station at NSAs 

Noise-Sensitive 

Area (NSA) 

Distance/Direction of 

NSA to Compressor 

Station Site (feet) 

Existing 

Ambient Ldn

(dBA) 

Estimated 

Project Ldn

(dBA)a 

Total 

Estimated 

Ldn (dBA)b

Predicted 

Noise 

Increase 

(dBA)c

Delhi Compressor Station 

NSA #1 1,100 feet (W) 54.2 dBA 51.0 dBA 55.9 dBA 1.7 dB 

NSA #2 1,500 feet (NW) 59.5 dBA 47.6 dBA 59.8 dBA 0.3 dB 

NSA #3 900 feet (NE) 46.4 dBA 52.9 dBA 55.5 dBA 3.6 dB 

_______________ 

Notes: 

Ldn = day-night equivalent sound level 

dBA = decibels on the A-weighted scale 

a Estimated Ldn sound levels are based on operation of compressor units at compressor station with noise 

control measures installed as proposed. 

b Estimated total Ldn = 10 log (10(Ambient Ldn/10) + 10 (Predicted Ldn/10)). 

c Estimated increase in the ambient Ldn sound levels due to operation of compressor units at compressor 

station. 

TABLE 3.11.2.3-3 

Predicted Noise Contribution of the Harrisville Compressor Station at NSAs 

Noise Sensitive 

Area (NSA) 

Distance/Direction of 

NSA to Compressor 

Station Site (feet) 

Existing 

Ambient Ldn

(dBA) 

Estimated 

Project Ldn

(dBA)a 

Total 

Estimated 

Ldn (dBA)b

Predicted 

Noise 

Increase 

(dBA)c

Harrisville Compressor Station 

NSA #1 4,200 feet (E) 43.5 dBA 36.9 dBA 44.4 dBA 0.9 dB 

NSA #2 5,600 feet (SSE) 48.5 dBA 33.6 dBA 48.6 dBA 0.1 dB 

NSA #3 4,800 feet (NW) 44.6 dBA 35.5 dBA 45.1 dBA 0.5 dB 

NSA #4 2,600 feet (NW) 44.6 dBA 42.3 dBA 44.6 dBA 2.0 dB 

NSA #5 3,700 feet (NNW) 44.6 dBA 38.4 dBA 45.5 dBA 0.9 dB 

NSA #6 4,000 feet (NNW) 44.6 dBA 37.6 dBA 45.4 dBA 0.8 dB 

_______________ 

Notes: 

Ldn = day-night equivalent sound level 

dBA = decibels on the A-weighted scale 

a Estimated Ldn sound levels are based on operation of compressor units at compressor station with noise 

control measures installed as proposed. 

b Estimated total Ldn = 10 log (10(Ambient Ldn/10) + 10 (Predicted Ldn/10)). 

c Estimated increase in the ambient Ldn sound levels due to operation of compressor units at compressor 

station. 
 3-109 

TABLE 3.11.2.3-4 

Predicted Noise Contribution of the Destin Compressor Station at NSAs 

Noise Sensitive 

Area (NSA) 

Distance/Direction of 

NSA to Compressor 

Station Site (feet) 

Existing 

Ambient Ldn

(dBA) 

Estimated 

Project Ldn

(dBA)a 

Total 

Estimated 

Ldn (dBA)b

Predicted 

Noise 

Increase 

(dBA)c

Destin Compressor Station 

NSA #1 1,400 feet (ENE) 48.3 dBA 49.0 dBA 51.7 dBA 3.4 dB 

_______________ 

Notes: 

Ldn = day-night equivalent sound level 

dBA = decibels on the A-weighted scale 

a Estimated Ldn sound levels are based on operation of compressor units at compressor station with noise 

control measures installed as proposed. 

b Estimated total Ldn = 10 log (10(Ambient Ldn/10) + 10 (Predicted Ldn/10)). 

c Estimated increase in the ambient Ldn sound levels due to operation of compressor units at compressor 

station. 

To ensure that noise levels from operation of the Project facilities do not adversely impact 

surrounding areas, we recommend that: 

• Gulf South should file noise surveys with the Secretary no later than 60 days after placing 

each of the Delhi, Harrisville, and Destin Compressor Stations in service. If the noise 

attributable to operation of all of the equipment at any compressor station at full load 

exceeds an Ldn of 55 dBA at any nearby NSA, Gulf South should file a report on what 

changes are needed and should install the additional noise controls to meet the level within 

one year of the in-service date. Gulf South should confirm compliance with the above 

requirement by filing a second noise survey with the Secretary no later than 60 days after it 

installs the additional noise controls. 

If Gulf South provides assurance that any noise impacts have been mitigated, as required by 

the above recommendations, we believe that Project-related operations would not result in a significant 

effect on the noise environment. 

3.12 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 not 

toxic but is classified as a simple asphyxiate, possessing a slight inhalation hazard. If breathed in high 

concentration, oxygen deficiency can result in serious injury or death. 

Methane has an ignition temperature of 1,000o F and is flammable at concentrations between 5 

and 15 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. It is buoyant at 

atmospheric temperatures and disperses rapidly in air. 
 3-110 

3.12.1 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) 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 

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, the 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 would 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 the 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 referring complaints and inquiries made by state and local governments and the general 

public involving safety matters related to pipeline under the Commission's jurisdiction. 

The FERC also participates as a member of the DOT's Technical Pipeline Safety Standards 

Committee, which determines whether proposed safety regulations are reasonable, feasible, and 

practicable. 

The pipeline and aboveground facilities associated with the proposed Project must be 

designed, constructed, operated, and maintained in accordance with the DOT Minimum Federal Safety 

Standards in 49 CFR Part 192. The 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: 
 3-111 

Class 1 Location with 10 or fewer buildings intended for human occupancy. 

Class 2 Location with more than 10 but less than 46 buildings intended for human 

occupancy. 

Class 3 Location with 46 or more buildings intended for human occupancy or where the 

pipeline lies within 100 yards of any building, or small well-defined outside area 

occupied by 20 or more people on at least 5 days a week for 10 weeks in any 

12-month period. 

Class 4 Location where buildings with four or more stories above ground 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 

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 and 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, MAOP, inspection and testing of 

welds, and frequency of pipeline patrols and leak surveys must also conform to higher standards in more 

populated areas. Preliminary class locations for the proposed Project have been developed based on the 

relationship of the proposed pipeline centerline to other nearby structures and man-made features. Gulf 

South has reported that the following segments of the proposed pipeline would be designated as Class 2: 

• MP 29.2 to MP 30.4 (6,448 feet)

• MP 36.2 to MP 36.5 (1,745 feet)

• MP 54.2 to MP 55.0 (3,967 feet)

• MP 75.5 to MP 76.3 (3,008 feet)

• MP 87.1 to MP 88.0 (4,545 feet)

• MP 88.1 to MP 88.6 (2,643 feet)

• MP 94.4 to MP 95.4 (5,075 feet)

The remainder of the proposed pipeline would be designated as Class 1. 

If a subsequent increase in population density adjacent to the right-of-way indicates a change 

in class location for the pipeline, Gulf South would reduce the MAOP or replace the segment with pipe of 

sufficient grade and wall thickness, if required to comply with the DOT code of regulations for the new 

class location. 

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. No later than December 17, 2004, gas transmission 

operators must develop and follow a written integrity management program that contains all the elements 
 3-112 

described in §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 (HCA). The 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 

§192.903 of the DOT regulations. 

OPS published a series of rules from August 6, 2002, to May 26, 2004, (69 FR 29903) that 

defines 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 20 or 

more buildings are intended for human occupancy within the potential impact circle2

• Any area in Class 1 or 2 where the potential impact circle includes an identified site3

In the second method, an HCA includes any area within a potential impact circle that contains: 

• 20 or more buildings intended for human occupancy 

• 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 § 192.911. The HCAs have 

been determined based on the relationship of the pipeline centerline to other nearby structures and 

identified sites. HCAs along the proposed Project route include the following locations: 

• MP 7.3 to MP 7.8 (2,839 feet) 

• MP 51.3 to MP 52.0 (3,897 feet) 

The pipeline integrity management rule for HCAs requires inspection of the entire pipeline 

HCAs every seven 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 radius 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. 

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. 
 3-113 

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 the 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 

Part 192 requires that each operator must establish and maintain a liaison with appropriate fire, 

police, and public officials to learn the resources and responsibilities of each organization that may 

respond to a natural gas pipeline emergency and to coordinate mutual assistance. 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. Gulf South 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. 

3.12.2 Pipeline Accident Data 

Since February 9, 1970, 49 CFR Part 191 has required all operators of transmission and 

gathering systems to notify the 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 

• In the judgment of the operator was significant, even though it did not meet the above criteria 

The DOT changed reporting requirements after June 1984 to reduce the amount of data 

collected. Since that date, operators must only report incidents that involve property damage of more than 

$50,000, injury, death, release of gas, or that are otherwise considered significant by the operator. 

Table 3.12.2-1 presents a summary of incident data for the 1970 to 1984 period, 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 
 3-114 

information than subsequent years, has been subject to detailed analysis, as discussed in the following 

sections.4

TABLE 3.12.2-1 

Natural Gas Service Incidents by Cause 

 Incidents per 1,000 Miles of Pipeline (Percent Distribution) 

Cause 1970 through 1984 1986 through 2005 

Outside forces 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 0.26 

_______________ 

Sources: Jones et al. (1986); USDOT, OPS, http://ops.dot.gov/stats.htm (2006). 

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 (Jones et al. 1986). 

Additional insight into the nature of service incidents may be found by examining the primary 

factors that caused the failures. Table 3.12.2-2 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 (Jones et al. 1986). Data 

presented for the period extending from mid 1986 through 2003 were gathered from the DOT's OPS. 

TABLE 3.12.2-2 

Outside Forces Incidents by Cause 

(1970 through 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 

_______________ 

Source: Jones, et al. (1986)

 4

 Jones, D. J., G. S. Kramer, D. N. Gideon, and R. J. Eiber, 1986. "An Analysis of Reportable Incidents for Natural 

Gas Transportation and Gathering Lines 1970 through June 1984." NG-18 Report No. 158, Pipeline Research 

Committee of the American Gas Association. 
 3-115 

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 3.12.2-2 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 3.12.2-1 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. Furthermore, new pipe 

generally uses more advanced coatings and cathodic protection to reduce corrosion potential. 

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 3.12.2-3 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 shows 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 3.12.2-3 

External Corrosion by Level of Control (1970 through June 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 

_______________ 

Source: Jones, et al. (1986)
 3-116 

3.12.3 Impact on Public Safety 

The service incident data summarized in Table 3.12.2-1 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 3.12.3-1 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 non-employees, 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 

non-employees. However, the data show that the total annual average for the period 1984 through 2005 

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 3.12.3-2 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, tornadoes, floods, 

and earthquakes. 

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 nationwide mix of transmission and gathering lines in service is 0.01 per year per 1,000 miles of 

pipeline. Using this rate, the proposed Project might result in a public fatality every 901 years. This 

would represent a slight increase in risk to the nearby public. 

TABLE 3.12.3-1 

Annual Average Fatalities 

Natural Gas Transmission and Gathering System 

Year Employees Non-Employees Total 

1970–June 1984 2.4 2.6 5.0 

1984–2005a - - 3.6 

1984–2005a - - 2.8b

_______________ 

Notes: 

a Employee/non-employee breakdown not available after June 1984. 

b Without 18 offshore fatalities occurring in 1989 (11 resulting from a fishing vessel striking an 

offshore pipeline and 7 from an explosion on an offshore production platform). 

Sources: Jones et al. (1986); USDOT, OPS, http://ops.dot.gov/stats.htm (2006).
 3-117 

TABLE 3.12.3-2 

Nationwide Accidental Deaths 

Type of Accident Fatalities 

All accidents 90,523 

Motor vehicle 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 to 1993 average) 181 

All liquid and gas pipelinesa

(1978 to 1987 average) 27 

Gas transmission and gathering linesb

(non-employees only, 1970 to 1984 average) 2.6 

_______________ 

Notes: 

a USDOT, "Annual Report on Pipeline Safety – Calendar Year 1987." 

b Jones et al. (1986). 

Source: All data, unless otherwise noted, reflect 1996 statistics from the U.S. Department of 

Commerce, Bureau of the Census, "Statistical Abstract of the United States, 118th Edition." 

3.12.4 Additional Security and Safety Issues 

During the scoping period, we received comments regarding the susceptibility of the proposed 

Project to terrorist attack. Due to the various motivations and abilities of terrorist organizations in 

conjunction with the extensive natural gas infrastructure within the United States, the likelihood of future 

acts of terrorism occurring at the Project site is unpredictable. The FERC has taken measures to limit the 

distribution of information to the public regarding facility design to minimize the risk of sabotage. 

Facility design and location information is removed from the FERC's website to ensure that sensitive 

information filed under Critical Energy Infrastructure Information is not readily available. Furthermore, 

the Commission, in cooperation with other federal agencies, industry trade groups, and interstate natural 

gas companies, is working to improve pipeline security practices, strengthen communications within the 

industry, and extend public outreach in an ongoing effort to secure pipeline infrastructure. 

Despite the ongoing potential for terrorist acts along any of the nation's natural gas 

infrastructure, the continuing need for the construction of these facilities is not eliminated. Given the 

continued need for natural gas conveyance and the unpredictable nature of terrorist attacks, FERC, DOT, 

and the Office of Homeland Security's efforts to continually improve pipeline safety, would minimize the 

risk of terrorist sabotage of the Project to the maximum extent practical, while still meeting the nation's 

natural gas needs. 

3.13 CUMULATIVE IMPACT 

In accordance with NEPA and the FERC policy, we considered the cumulative impacts of the 

proposed Southeast Expansion Project and other projects in the general Project area. Cumulative impacts 

represent the incremental effects of the proposed action when added to other past, present, or reasonably 

foreseeable future actions, regardless of what agency or person undertakes such other actions. 

Cumulative impacts can result from individually minor, but collectively significant, actions taking place 
 3-118 

over a given period of time. The direct and indirect impacts of the proposed project are discussed in other 

sections of this EIS. 

The purpose of this cumulative impact analysis is to identify and describe cumulative impacts 

that would potentially result from implementation of the proposed Project. This cumulative impact 

analysis generally follows the methodology set forth in relevant guidance (CEQ, 1997; USEPA, 1999). 

Under these guidelines, inclusion of other projects within the analysis is based on identifying 

commonalties of impacts from other projects to potential impacts that would result from the proposed 

Project. An action must meet the following three criteria to be included in the cumulative impacts 

analysis: 

• Impact a resource area potentially affected by the proposed project. 

• Cause this impact within all, or part of, the proposed project area. 

• Cause this impact within all, or part of, the time span for the potential impact from the proposed 

project. 

For the purposes of this cumulative impact analysis, we considered the project area to be the 

counties and parish traversed by the proposed project. Most effects of more distant projects we identified 

are not assessed because their impact would generally be localized and not contribute significantly to 

cumulative impact in the proposed project area. 

The actions considered in the cumulative impact analysis may vary from the proposed project 

in nature, magnitude, and duration. These actions are included based on the likelihood of completion, and 

only projects with either ongoing impacts or that are "reasonably foreseeable" future actions were 

evaluated. Existing or reasonably foreseeable actions that would be expected to affect similar resources 

during similar time periods as the proposed project were considered further. The anticipated cumulative 

impacts of the proposed project and these other actions are discussed below, as well as any pertinent 

mitigation actions. 

We identified three types of past, present, and reasonably foreseeable future projects that 

would potentially result in a cumulative impact when considered with the proposed Project. These are: 

(1) other natural gas pipeline projects; (2) facilities that would be associated with construction of the 

proposed Project but that are not under the FERC's jurisdiction; and (3) unrelated projects that are either 

in place, are under construction in the vicinity of the proposed Project, or are proposed (Table 3.13.1-1). 

3.13.1 Other Natural Gas Pipeline Projects 

The FERC has applications for two other proposed natural gas pipeline projects that would 

traverse the same general areas as the proposed Southeast Expansion Project in Louisiana, Mississippi, 

and Alabama. They include (1) CenterPoint Energy and Spectra Energy's Southeast Supply Header 

(SESH) Project, and 2) Gulf South's East Texas to Mississippi Expansion (ETM) Project. In addition, the 

FERC recently issued a Certificate for CenterPoint Energy Gas Transmission Company's (CEGT's) 

Carthage to Perryville Project (CTP Project), which is also located in northern Louisiana. See Figure 

3.13.1 and Tables 3.13.1-1 and 3.13.1-2 for illustration of the locations and comparative impacts of these 

three projects along with the proposed Project. 

We have identified the tentative construction schedules of these projects, as available, but the 

actual construction schedules would depend on factors such as economic conditions, the availability of 

funds, and the issuance of permits. The potential impacts associated with these projects that are most 
 3-119 

likely to be cumulatively significant are related to wetlands and waterbodies, vegetation and wildlife 

(including federally and state-listed endangered and threatened species), land use, air quality, and noise. 

TABLE 3.13.1-1 

Existing or Proposed Natural Gas Projects that Would Cumulatively Impact 

Resources in the Southeast Expansion Project Area 

Project Description 

Anticipated 

Construction 

Date Counties/Parishes within Project Area 

Natural Gas Pipeline Projects 

Carthage to 

Perryville 

Construct and 

operate 172 miles 

of 42-inch-diameter 

natural gas pipeline 

2006-2007 Panola County, Texas 

Caddo, DeSoto, Red River, Bienville, Jackson, 

Ouachita, and Richland Parishes, Louisiana 

East Texas to 

Mississippi 

Expansion 

Project 

Construct and 

operate 242 miles 

of 42-inch-diameter 

natural gas pipeline 

2007 Panola County, Texas 

DeSoto, Red River, Bienville, Jackson, 

Ouachita, and Richland Parishes, Louisiana 

Warren, Hinds, Copiah, Simpson, and Walthall 

Counties, Mississippi 

Southeast 

Supply Header 

Project 

Construct and 

operate 104 miles 

of 42-inch-diameter 

and 165 miles of 

36-inch-diameter 

(269 miles total) 

natural gas pipeline 

2008 Richland and Madison Parish, Louisiana 

Warren, Claiborne, Copiah, Lawrence, 

Jefferson Davis, Covington, Jones, Forrest, 

Perry, Greene, George, and Jackson 

Counties, Louisiana 

Mobile County, Alabama 

Southeast 

Expansion 

Project 

Construct and 

operate 111 miles 

of 42-inch-diameter 

natural gas pipeline 

2007-2008 Simpson, Smith, Jasper, Clarke Counties, 

Mississippi 

Choctaw County, Alabama 

Richland Parish, Louisiana 

Gulf Crossing 

Project 

Construct and 

operate a 351-milelong, 42-inchdiameter natural 

gas pipeline, and 

16 miles of 42-inchdiameter looping 

2008 Grayson, Fannin, Lamar, Delta, Hopkins, 

Franklin, Titus, Morris, and Cass Counties, 

Texas 

Bryon County, Oklahoma 

Caddo, Bossier, Webster, Claiborne, Lincoln, 

Union, Ouachita, Morehouse, Richland and 

Madison Counties, Louisiana 

Looping (Hinds, Copiah, Simpson, Mississippi) 

MidContinent 

Express Project 

Construct and 

operate 262 miles 

of 42-inch-, 

193 miles of 

36-inch-, and 

40 miles of 30-inchdiameter (495 miles 

total) natural gas 

pipeline 

2008 Bryan County, Oklahoma 

Lamar, Red River, Franklin, Titus, Morris, and 

Cass Counties, Texas 

Caddo, Bossier, Webster, Claiborne, Lincoln, 

Union, Ouachita, Morehouse, Richland, and 

Madison Counties, Louisiana 

Warren, Hinds, Rankin, Simpson, Smith, 

Jasper, and Clarke Counties, Mississippi 

Choctaw County, Alabama 

_______________ 

Notes: 

N/A = Not Available 

Associated proposed lateral pipelines not included
Non-Internet Public 

 

 

 

 

 

 

ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED SOUTHEAST EXPANSIONPROJECT 

Docket No. CP07-032-000 

Page 3-120 

Figure 3.13-1 

Approximate Location of Natural Gas Pipeline Projects Near the 

Proposed Southeast Expansion Project 

Public access for this Non-Internet Public information is 

available only through the Public Reference Room, or by email at public.referenceroom@ferc.gov. 
 3-121 

While it is not certain if or when these actions will occur, its similarity and proximity to the 

proposed Project merits further consideration. The FERC (1989) considers that the general impacts of 

building multiple pipelines would be primarily additive. Based on the project scope, geographic location, 

and preliminary information, we anticipate that the SESH Expansion, ETM Expansion and CTP Projects 

would result in environmental impacts similar to those of the proposed Project. 

CEGT's Carthage to Perryville Project 

CEGT completed construction of its CTP Project in June 2007, a 42-inch-diameter natural gas 

pipeline system that would extend from Carthage in Panola County, Texas to near Delhi in Richland 

Parish, Louisiana. The project consists of 172 miles of pipeline and two compressor stations that total 

41,240 hp. The pipeline connects multiple receiving points in east Texas with CenterPoint's Perryville 

Hub and four new interstate pipeline interconnections. The FERC issued CEGT its Certificate on October 

2, 2006. 

The CTP Project is considered here with respect to the potential for cumulative impacts to the 

natural and human environments of Texas and Louisiana. Detailed information regarding the 

environmental impacts that would be associated with construction and operation of the CTP Project are 

included in the EIS (FERC 2006) prepared by the FERC and can be viewed on the FERC website under 

Docket No. CP06-85-000. 

East Texas to Mississippi Expansion Project 

The ETM Expansion Project, also proposed by Gulf South, is an approximate 242-mile, 

36-inch and 42-inch OD natural gas pipeline. This project includes the addition of 40,302 Hp of 

additional compression at one existing compressor station, and two new compressor stations with 

30,000 Hp and 40,302 Hp. The ETM Expansion Project runs from Panola County, Texas in an easterly 

direction across Louisiana and ends in Simpson County, Mississippi. The terminus of the pipeline is Gulf 

South's existing Index 130, which is also the beginning of the proposed Southeast Expansion Project. The 

ETM Expansion Project was approved by the Commission on June 18, 2007, and is currently under 

construction. 

The ETM Expansion Project is considered here with respect to the potential for cumulative 

impacts to the natural and human environments in Louisiana (Delhi area) and Mississippi. The proposed 

project has been filed and a Final EIS was issued in May 2007 and is being evaluated by the FERC. 

Detailed information regarding the environmental impacts that would be associated with construction and 

operation of the ETM Expansion Project can be viewed on the FERC website under Docket No. CP06-

446-000. 

Southeast Supply Header Project 

Spectra Energy Gas Transmission (SEGT) and CEGT have proposed construction of a new 

36-inch-diameter natural gas pipeline system that would extend approximately 269 miles southeast from 

Delhi, Louisiana in Richland Parish, Louisiana to near Coden, Alabama, in Mobile County, Alabama. In 

addition to the 270 miles of pipeline construction, the SESH Project would add three new compressor 

stations totaling 51,385 Hp. The pipeline would connect onshore gas supplies from Texas and Louisiana 

to the markets in the southeast, as well as interconnect with interstate systems in Mississippi and 

Alabama. 

The SESH Project is considered here with respect to the potential for cumulative impacts to 

the natural and human environments of Louisiana and Mississippi. The project has been filed and is 

being evaluated by the FERC. The Draft EIS was issued on April 27, 2007. Detailed information 
 3-122 

regarding the environmental impacts that would be associated with construction and operation of the 

SESH Project can be viewed on the FERC website under Docket No. CP07-44-000.
 3-123 

TABLE 3.13.1-2 

Environmental Resources That Would Be Cumulatively Affected During Construction and Operation o

in the Vicinity of the Proposed Southeast Expansion Project 

Project 

(Anticipated 

Construction 

Date) 

Total Length/

Length of 

Collocation 

(miles) 

Total Land 

Disturbance 

(acres) 

Pipeline 

Diameter 

and 

Proposed 

Perm ROW 

Width 

Open-Cut 

Waterbody 

Crossings 

Wetlands 

Disturbed 

During 

Construction

Forested 

Wetlands 

Disturbed 

Forestland 

Cleared 

Federally 

Listed 

Endangered, 

Threatened, 

or Candidate 

Species 

Carthage to Perryville (2006-2007) 

172 

40 

2,498 

(1,248 

permanently) 

42-inch 

60 feet 

104 perennial 

136 intermittent

127 wetlands 

50 acres 

86 acres 1,316 acres 6 

East Texas to Mississippi Expansion Project (2007) Docket No. CP06-446 

242 185 

4,034 

(1,542 

permanently) 

42-inch 

50 feet 

780 301 wetlands 

115 acres 

81 acres 1,838 acres 10 

Southeast Supply Header Project (2008) Docket No. CP07-44, 45 

269 

0 

3,417 

(1,631 

permanently) 

36-inch for 

165 miles 

42-inch for 

104 miles 

50 feet 

177 perennial 

448 intermittent

246 wetlands 

239 acres 

249 acres 2,171 acres 19 

Southeast Expansion Project (2008) Docket No. CP07-32 

111 

73 

1,727 

(857 

permanently) 

42-inch 

50 feet 

92 perennial 

159 intermittent

129 wetlands 

89 acres 

48 acres 1,329 acres 9 

Gulf Crossing 

Project (2008) 

Docket No. 

CP07-398 

367 212 

5651 

(2698 

permanently) 

42-inch 

60 feet 

245 perennial 

627 intermittent

147 wetlands 

163 acres 

127 acres 2,398 acres 16 
 3-124 

Gulf Crossing Project 

Boardwalk Pipelines has proposed construction of a new 42-inch-diameter natural gas pipeline 

system that would extend approximately 351 miles southeast from Grayson County, Texas, to Madison 

Parish, Louisiana. Additionally, the Gulf Crossing Project would include 4.5 miles of 42-inch-diameter 

pipeline looping in Madison Parish, Louisiana, and 11.2 miles of 42-inch-diameter pipeline looping in 

Hinds, Copiah, and Simpson Counties, Mississippi. The route would be collocated for 289 miles with the 

proposed MidContinent Express Project. 

The Gulf Crossing Project is considered here with respect to the potential for cumulative 

impacts to the natural and human environments of Louisiana. The project was filed with the Commission 

on June 19, 2007, and is being evaluated by the FERC, but has not yet been approved. Detailed 

information regarding the environmental impacts that would be associated with construction and 

operation of the Gulf Crossing Project can be viewed on the FERC website under Docket No. CP07-398.

MidContinent Express Project 

Kinder Morgan has proposed construction of a new 24-inch and 36 -inch-diameter natural gas 

pipeline system that would extend approximately 495 miles southeast from Bryan County, Oklahoma to 

Choctaw County, Alabama. The route would be entirely collocated with the SESH Project, then the ETM 

Expansion Project, and finally with the proposed Project. Landowners along the proposed Project could 

be (or may have already been) approached by Kinder Morgan representatives regarding an additional 

easement on their land. If the MidContinent Express Project is constructed as presently envisioned, this 

would represent a cumulative land use effect along with the proposed Project's right-of-way. 

The MidContinent Express Project is considered here with respect to the potential for 

cumulative impacts to the natural and human environments of Louisiana, Mississippi and Alabama. The 

project is in the Pre-filing stage and is being evaluated by the FERC, but has not yet been approved. 

Detailed information regarding the environmental proceedings of the MidContinent Express Project are 

on the FERC website under Docket No. PF07-004-000. 

3.13.2 Unrelated Projects 

Local government planning officials were contacted to determine whether any new 

development is scheduled to occur in the vicinity of the Southeast Expansion Project. One proposal for 

new residential development was found to be pending within 0.25 mile of the construction right-of-way at 

MP 11 (Section 3.8.3). Based on our own research, no road projects are known to be located in the area 

of the proposed Project. The FERC would have no authority over permitting, licensing, funding, 

construction, or operation of highway projects. Federal, state, and local agencies must review highway 

projects for compliance with requirements for construction of facilities at sites or places where a 

governmental license or permit may be required. Expansion or construction of intrastate pipelines and 

highways would require state or federal permits and approvals to ensure compliance with Section 7 of the 

ESA; Sections 401, 402, and 404 of the CWA; and the CAA. Issuance of the necessary permits and 

approvals would reduce or avoid significant impacts from these facilities to wetlands and waterbodies, 

vegetation and wildlife (including threatened and endangered species), land use, and air quality and noise. 

3.13.3 Potential Cumulative Impacts of the Proposed Action 

Impacts to wetlands, waterbodies, vegetation, wildlife (including federally and state-listed 

endangered and threatened species), land use, and air quality and noise could contribute to larger 
 3-125 

cumulative impacts. See Tables 3.13.1-1 and 3.13.1-2 for a comparative summary of the proposed 

construction projects in the vicinity of the proposed Project. 

3.13.3.1 Wetlands and Waterbodies 

Construction and operation of the proposed Project would result in both short-term and longterm impacts to waterbodies and wetlands. The short-term impacts such as soil or sediment disturbance 

would dissipate over a period of weeks, while longer term impacts, such as regrowth of forested wetlands 

within the temporary construction rights-of-way, would persist for months or years. The primary impacts 

to wetlands and waterbodies during operation of the proposed pipeline would be associated with routine 

right-of-way maintenance. All maintenance activities would comply with applicable federal regulations 

and Gulf South's plans (see Section 3.2) and Procedures (see Sections 3.3 and 3.4), but would continue 

throughout the life of the proposed Project. 

If approved and constructed, the proposed Project and other reasonably foreseeable future 

projects would impact wetlands and would include permanent loss or conversion of some existing 

wetlands (see Table 3.4.1-1). Elements of these projects with the potential to affect wetlands and 

waterbodies would be subject to review and approval under Section 404 of the CWA, as administered by 

COE, as well as state and local wetland regulations (see Section 1.3). Any permanent or long-term 

impacts to wetlands and waterbodies would require appropriate mitigation. Construction of the proposed 

Project would affect 145 wetland areas, resulting in a total of approximately 68.94 acres of wetland 

disturbance, including approximately 17.85 acres of PFO wetland impacts. In Section 3.4.3, we are 

recommending the development of site-specific wetland crossing plans in select areas to further minimize 

forested wetland effects. Gulf South indicates that compensatory mitigation for wetland impacts 

associated with the proposed Project would be provided through the purchase of wetland mitigation bank 

credits in the area of the proposed Project. Furthermore, discharges to wetlands and other surface waters 

associated with construction and operation would require review, approval, and mitigation (if necessary) 

under the, LDEQ, MDEQ and ADEM stormwater discharge programs. 

Construction of the proposed Project would result in 308 individual waterbody crossings. 

Gulf South proposes to use 15 HDDs to accomplish pipeline installation, including the following five 

major waterbodies: the Leaf River (MP 44.1), the West Tallahala River (MP 45.3), the Chickasawhay 

River (MP 89.3), and one unnamed pond (MP 87.8). The Chickasawhay River is also one of the NPSdesignated Nationwide Rivers Inventory (NRI) streams that would be crossed. The use of the HDD 

method would avoid direct impacts to waterbodies and minimize impacts to riparian vegetation at those 

crossings. Any inadvertent release of drilling fluids (frac-out) or accidental fuel and chemical spills 

would be greatly reduced by the implementation of Gulf South's HDD Plan and SPCC Plan. 

Because most of the projects listed in Tables 3.13.1-1 and 3.13.1-2 are located within the same 

major watersheds crossed by the proposed Project pipeline, and because some of these projects would 

likely involve direct and indirect waterbody impacts, the proposed Project and other reasonably 

foreseeable future projects would result in some cumulative impacts to waterbodies. These temporary 

impacts would include runoff from construction areas, temporary and localized increases in turbidity and 

sedimentation associated with in-water construction, and withdrawal and discharge of surface waters for 

hydrostatic testing of pipeline segments. As described in Section 3.3, these effects would be relatively 

minor and would be further minimized by implementation of Gulf South's plans and Procedures and our 

recommendations; therefore, we believe that cumulative impacts to wetlands and waterbodies would be 

adequately minimized. 
 3-126 

3.13.3.2 Vegetation and Wildlife 

Construction of the proposed Project and other reasonably foreseeable future projects would 

cause a cumulative impact on native vegetation and associated wildlife. These cumulative impacts would 

be most significant if the projects were constructed at or near the same time and within close proximity of 

one another. Either circumstance would increase the impacts and would lengthen the recovery time for 

affected vegetative communities. The proposed Project, if approved, would impact native vegetative 

communities during construction, including approximately 646.6 acres of upland forest (slope hardwood 

and loblolly pine-hardwood forest) and 578.8 acres of pine plantation. 

Cumulative impacts within a region, such as lost acreage of forestland, are additive. 

Furthermore, many wildlife species depend on mature contiguous tracts of forest to sustain their 

migratory and reproduction cycles. These species include dozens of migratory songbirds and terrestrial 

mammals that are not migratory but that require large tracts of forest to support their home ranges. The 

impacts of fragmentation can be immediate and significant because population levels for many such 

species are currently low and on the decline. 

The extent and duration of cumulative wildlife habitat impacts associated with construction of 

the proposed Project and other future projects would be minimized by using existing, maintained rightsof-way and other disturbed areas as much as possible. Gulf South's proposed route would be collocated 

with or parallel to existing utility rights-of-way such as Crosstex and Transco rights-of-way where 

possible, thereby minimizing impacts to previously undisturbed vegetation. The proposed pipeline route 

would parallel existing utility rights-of-way for approximately 73 miles, or about 66 percent of the 

proposed route. Additionally, approximately 33 percent of the proposed pipeline route would traverse 

agricultural, industrial, open lands, pastures, and other areas that would typically experience rapid 

revegetation. Furthermore, Gulf South would implement the mitigation measures outlined in its plans and 

Procedures to encourage the regrowth of native vegetation and discourage the spread of exotic or noxious 

plant species. 

Forty-six federally-listed endangered or threatened, state-listed endangered or threatened, 

and/or special-status species would be potentially impacted by construction activities associated with the 

proposed Project. As described in Section 3.7, with implementation of our recommendations for 

mitigation to avoid and minimize impacts, we believe that the proposed Project would not significantly 

affect federally listed species. However, if other reasonably foreseeable future projects were to impact 

the same habitats as the proposed Project route, cumulative impacts to these listed species would occur. 

Impacts to such species would likely be reduced or eliminated through conservation and mitigation 

measures identified during the permitting processes because protection of threatened, endangered and 

other special-status species is part of the federal and state permitting processes. Consequently, we believe 

that cumulative impacts to vegetation and wildlife resources would be relatively minor. 

3.13.3.3 Land Use 

Construction of the proposed Project and other reasonably foreseeable future projects would 

result in temporary and permanent changes in land use within the Project area. The proposed Project 

would encumber a total of approximately 1,727 acres of land during construction. Approximately 

71.0 percent of that land would be upland forest or pine plantation, 4.6 percent would be agricultural, 

10.0 percent would be open land, 3.3 percent would be pasture, and 4.4 percent would be wetland. 

Residential land, other/roads, commercial/industrial land, and open water land use types would also be 

affected, accounting for the remaining 6.7 percent. While most of these impacts would be temporary in 

nature, construction of the proposed Project would result in some permanent land use changes, including 
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conversion of approximately 283.4 acres of pine plantation, 336.1 acres of forested uplands, and 

17.9 acres of forested wetlands to maintained utility right-of-way. 

Land use impacts associated with the proposed ETM Expansion Project include approximately 

4,034 acres. Land use impacts associated with the existing Denbury, Crosstex, and Transco pipelines 

have already been accounted for during the permitting of the respective lines. Land use impacts 

associated with the pipeline projects would likely cause a cumulative effect when considered in 

conjunction with the proposed Project. Because some or parts of these projects were constructed or are 

proposed to be constructed largely within or adjacent to existing maintained rights-of-way, the impact of 

land use changes would be reduced. Unlike transportation projects which would permanently convert 

thousands of acres of land to paved impervious surface, much of the land affected during construction of 

the proposed Project and the other pipeline projects would be restored and allowed to revert to 

preconstruction uses and conditions once pipeline installation was complete. Because non-woody 

vegetation would be expected to return to preconstruction conditions over the short term, impacts to 

acreage classified as agriculture, pastures, or open land would be short term and minor. Long-term 

impacts to cleared forestland located outside of permanently maintained rights-of-way would take many 

years to return to preconstruction conditions, with recovery time dependent on the types and ages of the 

trees removed. However, given the prevalence of these land uses and cover types within the affected 

counties and parishes, we believe that cumulative impacts to land use would be relatively minor. 

3.13.3.4 Air Quality 

Air quality would be affected by construction and operation of the proposed Project and other 

reasonably foreseeable future projects. Construction of these projects would temporarily impact air 

quality by generating emissions from operation of fossil-fueled construction equipment and fugitive dust 

from land clearing, grading, excavation, concrete work, and vehicle traffic on paved and unpaved roads. 

However, the majority of impacts to air quality would occur during operation of these projects. The 

currently constructed CTP Project, the proposed Project, and the proposed ETM and SESH Projects, all 

would contribute to ongoing air emissions associated with operation of compressor stations. In the Delhi, 

Louisiana area, the proposed Delhi Compressor Station would produce cumulative impacts in association 

with the CEGT's existing Delhi Compressor Station and the proposed SESH Delhi Compressor Station. 

Any proposed or planned roadway improvements in the area of the proposed Project might also contribute 

increased levels of air emissions as a result of increased vehicular traffic. 

Because construction-related air emissions would be temporary and localized in nature, they 

would be unlikely to contribute significantly to cumulative air quality impacts. Air emissions from 

operations of portions the proposed Project and the portions of other projects listed in Table 3.13-2 with 

compressor stations located in the same air quality control region could present a cumulative impact since 

they would be discharged into a shared air basin. The Delhi Compressor Station is the only station that 

would be constructed in the same region as other compressor stations listed in Table 3.13-2. Initial 

screening modeling has been recommended to be performed for the Delhi Compressor Station to identify 

potential impacts and determine whether further cumulative analysis is warranted. The counties and 

parish in which the proposed Project would be constructed are in attainment for all NAAQS criteria 

pollutants. Also, each of the projects listed in Table 3.13-2 would be required to meet all applicable 

federal and state air quality standards. 

3.13.3.5 Noise 

Potential noise impacts associated with the proposed Project and those projects listed in 

Table 3.13-2 would occur during construction and operation. Because of the linear nature of these 

projects, construction-related noise impacts would tend to be of short duration in a given area. 
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Furthermore, because most construction activities would be limited to daylight hours, construction-related 

noise impacts would not occur at night for the most part. The proposed Project would cause minor 

temporary impacts at NSAs near HDD sites. Potential noise-related impacts during operation of the 

proposed Project and the other pipeline projects listed in Table 3.13-2 would primarily be limited to the 

vicinity of the associated compressor stations. As described in Section 3.11, the estimated noise that 

would be generated by the proposed Delhi, Destin, and Harrisville Compressor Stations would meet 

acceptable levels at the nearest NSA, but we are recommending monitoring to ensure no impacts occur. 

Noise emissions from compressor station operations may be additive with noise-generating 

elements of other reasonably foreseeable future projects if they are located near a common NSA, for 

example, in the Delhi, Louisiana, area where two new compressor stations are being proposed. However, 

both compressor stations would be required to comply with the FERC standards for noise levels. A 

cumulative noise analysis is currently being performed at the NSAs in common for both compressor 

stations which should identify any potential noise impacts at this location. 

The proposed project would include 18,940 Hp at the Harrisville Compressor Station. The 

Gulf Crossing Project would add an additional 30,000 Hp at this compressor station. At a minimum, both 

projects would be required to comply with the FERC standards for noise levels. With both projects 

complying with the FERC noise level requirements, noise impacts would not be considered significant. 

3.13.4 Conclusions 

If the proposed Project and the SESH Project are certificated, along with the recently 

certificated CTP and ETM Expansion Projects, all construction would be within the same general area, 

and the effects would overlap in time from the years 2006 through 2009. Additionally, the type of 

project, construction methods, and impacts would be similar. Although each of these unrelated projects 

would result in temporary and minor effects during construction, each project would be designed to avoid 

or minimize impacts to wetlands, waterbodies, protected and special-status species, and other sensitive 

resources. Additionally, significant unavoidable impacts to sensitive resources resulting from these 

projects would be mitigated. Mitigation generally leads to avoidance or minimization of cumulative 

impacts. We therefore consider that the potential cumulative impacts of the three proposed pipeline 

projects under our review, the recently certificated CTP Project, Gulf South's proposed project routed 

along the existing Crosstex and Transco pipeline corridors, have been or would be minimized. 

We are recommending additional measures to further reduce the environmental impacts 

associated with the proposed Project, including requiring Gulf South to evaluate whether it can use about 

10 feet of other existing utility rights-of-way to further reduce impacts. The environmental impacts 

associated with the proposed Project would be minimized by careful project routing, utilization of HDD 

techniques to avoid and minimize impacts to some sensitive resources, and implementation of appropriate 

mitigation measures. Consequently, only a small cumulative effect is anticipated when the impacts of the 

proposed Project are added to past, present, or reasonably foreseeable future projects in the area. For any 

project that still requires a FERC certificate, we would evaluate the impact during our NEPA review 

process.