Appendix L 

COAST GUARD LETTER OF INTENT 

AND WATERWAY SUITABILITY REPORT 
January 12, 2006 

Commander David W. Murk 

United States Coast Guard 

100 W. Oglethorpe Avenue, Suite 1017 

Savannah, Georgia 31401 

Re: Letter of Intent Pursuant to 33 C.F.R. § 127.007 

Southern LNG Inc. – Elba III Expansion Project 

Dear Commander Murk: 

Southern LNG Inc. respectfully notifies you of its intent to construct new 

facilities at the liquefied natural gas terminal on Elba Island (“Elba Island 

Terminal”). The project will expand the terminal to supply growing demand for 

clean energy with new LNG imports, in addition to the expansion currently 

underway and scheduled to commence service on February 1, 2006. This 

additional expansion (“Elba III Project”), will commence service in phases 

starting in mid-2010, after a construction period of approximately three years. 

I. 

INTRODUCTION 

A description of the project and a map locating Elba Island appear in Attachment 

1 hereto. SLNG also submits, under separate cover, a preliminary waterway 

suitability assessment for the Elba III Project as specified in the United States 

Coast Guard’s Navigational and Vessel Inspection Circular No. 05-05 (“NVIC 

05-05”). 

Attachment 2 to this letter shows a draft schedule with dates imposed on the joint 

FERC-U.S. Coast Guard timeline from the Navigational and Vessel Inspection 

Circular No. 05-05 (“NVIC 05-05”). Although the draft schedule shows 8 months 

of prefiling, SLNG intends to commit resources in an effort to complete the 

prefiling process within the minimum of 6 months prescribed in the Energy Policy 

Act of 2005. SLNG welcomes any input your office may have in order to 

facilitate this effort. 

 
Letter of Intent 

Page 2 of 5 

The Elba III Project will improve marine and transfer facilities in the new marine 

slip to accommodate liquefied natural gas carriers (“LNG/C”) with a wider range 

of dimensions and with greater scheduling flexibility. These improvements in the 

slip will enable SLNG to decommission the LNG unloading facilities on the 

existing riverside dock. The riverside dock will remain available as a lay berth for 

use in non-LNG/C service. The combination of improving the new marine slip 

and converting the riverside dock to a lay berth will enhance marine safety and 

eliminate the need for maintenance dredging those portions of the turning basin 

previously used only for LNG/C service at the riverside dock. 

SLNG submits the enclosed information to comply with section 127.007 of your 

regulations and respectfully requests an LOR under section 127.009 on the 

suitability of your waterway for the Elba III Project. Shell NA LNG, LLC 

(“Shell”) and BG LNG Services, LLC (“BG”) have entered into agreements, 

subject to certain conditions precedent, with SLNG for capacity to import 

additional LNG through the Elba III Project, as described in the press releases in 

Attachment 3 hereto. In support of its request for a favorable LOR, SLNG states 

as follows: 

II. 

OWNER AND OPERATOR 

(33 CFR § 127.007(d)(1), (2)) 

The exact legal name of SLNG is Southern LNG Inc., a wholly owned subsidiary 

of Southern Natural Gas Company organized and existing under the laws of 

Delaware and having its principal place of business in the AmSouth Center, 1900 

5th Avenue North, Birmingham, Alabama 35203. SLNG has owned and operated 

the Elba Island Terminal under the Captain of the Port’s jurisdiction for almost 

thirty years. 

III. 

PHYSICAL LOCATION OF THE FACILITY 

(33 CFR § 127.007(d)(3)) 

The terminal lies entirely on Elba Island, which SLNG owns and uses exclusively 

for this purpose. 
Letter of Intent 

Page 3 of 5 

IV. 

DESCRIPTION OF THE FACILITY 

(33 CFR § 127.007(d)(4)) 

The Elba Island Terminal is designed, and the Elba III Project has been designed, 

for marine receipt of LNG for storage, regasification, and delivery into the 

interstate natural gas pipeline system regulated by the FERC. The existing 

facilities were constructed in 1973-1978, recommissioned in 2000-2001, and 

expanded in 2003-2006. 

Design and construction of the expansion facilities will adhere to regulatory and 

industry standards including the design and specifications of the existing facilities 

at the Elba Island Terminal, those adopted by the U.S. Department of 

Transportation’s Research and Special Programs Administration and Coast 

Guard, the National Fire Protection Association, the Oil Companies International 

Marine Forum, and the Society of International Gas Tanker and Terminal 

Operators. 

SLNG has demonstrated a commitment to operating safely. Consistent with Coast 

Guard regulations, SLNG has written operating, security and emergency 

procedures approved on several occasions by your office and has undergone 

numerous inspections by federal and state agencies in conjunction with past 

construction projects and actual operating experience. The expansion facilities 

will become integrated with the existing facilities and operating procedures and 

subject to the effective regulations and latest procedures approved by the Captain 

of the Port when operations commence following construction. 

V. 

LNG VESSEL CHARACTERISTICS AND FREQUENCY 

(33 CFR § 127.007(d)(5)) 

SLNG operates the terminal on an open-access basis according to FERC 

regulations that govern service to LNG suppliers. SLNG does not import LNG. 

Suppliers, primarily Shell and BG, using the terminal’s capacity will import the 

LNG and arrange for transportation to the Elba Island Terminal and for 

authorizations to import to, and use the waterways of, the U.S. SLNG’s tariff 

conditions service on suppliers’ complying with all safety requirements before 

SLNG will accept a shipment. As your office is intimately aware, SLNG unloaded 

55 shipments between 1978 and 1980 and, since recommissioning in 2001, has 

unloaded over 120 shipments. SLNG expects the annual number and frequency of 

shipments to increase with the expansion going in service on February 1, 2006 

and again when the Elba III Project commences in 2010. 
Letter of Intent 

Page 4 of 5 

The Elba III Project will enable SLNG to accommodate a greater range of LNG 

ships with the following modifications: 

 SLNG will upgrade the existing LNG transfer facilities at the Elba Island 

Terminal to provide for the ability for simultaneously unloading two 

LNG carriers each at a rate of approximately 50,000 gallons per minute. 

 SLNG will adjust the berthing configuration in the marine slip to receive 

LNG carriers having dimensions as large as the following 

approximations: 345 meters length overall, 55 meters breadth, 12 meters 

design laden draft, and 177,000 metric tons displacement. 

In addition, SLNG proposes to remove the following facilities from the riverside 

dock for the purpose of decommissioning its LNG transfer capability and 

reducing maintenance dredging requirements: 

 LNG transfer header; 

 Vapor return line; 

 Ship bunker line; 

 Fire protection equipment; 

 LNG unloading arms, vapor return arm, pedestals, and ancillary 

equipment. 

VI. 

WATERWAY AND AREA CHARTS 

(33 CFR § 127.007(d)(6)) 

If necessary, SLNG will supplement this letter with any navigational information 

your office requests. 

VII. 

SUITABILITY OF SAVANNAH RIVER 

(33 CFR § 127.009) 

Since the Elba Island Terminal was recommissioned, your office has issued two 

favorable LORs to SLNG for the same kind of operations as proposed herein for 

the Elba III Project. For your convenience, I have included those LORs in 

Attachment 4. 
Letter of Intent 

Page 5 of 5 

VIII. 

CONCLUSION 

For the reasons discussed above, SLNG asks that you initiate the Coast Guard’s 

process for reviewing the Elba III Project, participate in the FERC’s prefiling 

process, and work with SLNG’s staff at Elba Island to obtain any additional 

information needed to issue an LOR supporting the suitability of the Savannah 

River for the planned expansion. To expedite our efforts, please work directly 

with Chris Humes (912/944-3833) and DaWayne Penberthy (912/944-3815) at 

Elba Island. 

 Very respectfully yours, 

 SOUTHERN LNG INC. 

James D. Johnston 

Senior Counsel 

Southern LNG Inc. 

1900 Fifth Ave. N., Office 2938 

Birmingham, Alabama 35203 

(205) 326-2019 

james.johnston@elpaso.com 
THIS PAGE INTENTIONALLY LEFT BLANK 
Attachment 1 

PROJECT INFORMATION 
Non-Internet Public 

FINAL ENVIRONMENTAL IMPACT STATEMENT FOR THE 

PROPOSED ELBA III PROJECT 

Docket Nos. CP06-470-000, CP06-471-000, CP06-472-000, 

CP06-473-000, and CP06-474-000 

APPENDIX L 

COAST GUARD LETTER OF INTENT AND 

WATERWAY SUITABILITY REPORT 

Page 8 

Attachment I - Project Information 

Public access for the above information is available only 

through the Public Reference Room, or by e-mail at 

public.referenceroom@ferc.gov. 
THIS PAGE INTENTIONALLY LEFT BLANK 
Attachment 2 

“Pre-Filing” Timeline 
TIMELINE FOR PROCESS

"Pre-Filing" Option

Elba III Expansion / Elba Express Pipeline

EIII/EEC FERC's timeline USCG's timeline

Applicant: FERC: Applicant: COTP/FMSC:

-9

1/13/2006 > -8

-7

-6

-5

-4

-3

-2

-1

9/21/2006 > Filing 0 Submit Followon WSA

1

2

3

Issue Waterway

Suitability Report 

to FERC

1/19/2007 > Issue Draft-EIS 4

5

6

7

5/23/2007 > Issue Final-EIS 8

9

7/26/2007 > 10

11

12

* EEC and SLNG intend to commit resources to reduce the prefiling process to the statutory minimum of 6 months.

Review/Validation 

of Follow-on WSA

Month

Issue Final Order 

(10-12 months 

after Filing)

Issue LOR 

(anytime after 

Final EIS issued)

Pre-Filing 

(7-9 months 

before filing)

Start EIS process

Submit LOI & 

Preliminary 

WSA 

(at same time 

as Pre-Filing)

Start LOR process 

& review of 

Preliminary WSA

8* 

mos

4

mos

4

2

Enclosure (1) to NVIC 05-05
THIS PAGE INTENTIONALLY LEFT BLANK 
Attachment 3 

Press Releases 
El Paso Corporation Announces Elba Island Expansion and Related Pipeline Project

HOUSTON, Dec. 21 /PRNewswire-FirstCall/ -- El Paso Corporation (NYSE: EP) announced today that wholly owned subsidiaries will 

proceed with two projects -- the next expansion at the Elba Island LNG Receiving Terminal near Savannah, Georgia, and the 

construction of a related Elba Express Pipeline in Georgia -- to significantly expand the company's natural gas delivery capabilities in 

the Southeastern United States. The initial in-service date is expected to be mid-2010 and total expected capital cost of the two projects 

is approximately $850 million. 

First, El Paso plans to further expand its Elba Island liquefied natural gas (LNG) receiving terminal near Savannah, Georgia. The Phase 

III expansion will add 8.4 billion cubic feet (Bcf) of LNG storage, which will more than double Elba's storage capacity to 15.7 Bcf. The 

expansion will also add .9 Bcf per day (Bcf/d) of send-out capacity, raising Elba's capacity to 2.1 Bcf/d. In addition, the unloading docks 

at the terminal will be modified to accommodate new, larger LNG ships. The Phase III expansion is in addition to the Phase II 

expansion of Elba Island that is expected to be in service February 2006. 

Second, an El Paso subsidiary will also construct, own and operate a new 191-mile interstate natural gas pipeline with a total capacity 

of 1.1 Bcf/d. The new pipeline, Elba Express, will increase natural gas transportation capacity from Elba Island to markets in Georgia 

and through interconnections with other pipelines to the Southeastern and Eastern United States. Elba Express will run northwest, 

interconnecting with pipelines and customers along its route. The pipeline will consist of about 105 miles of 42-inch pipeline and 86 

miles of 36-inch pipeline. 

Shell NA LNG LLC (Shell), a subsidiary of Royal Dutch Shell (NYSE: RDS.A & RDS.B), and BG LNG Services, LLC, a wholly owned 

subsidiary of BG Group plc (NYSE: BRG.N), have entered into long-term agreements for the incremental storage and send-out capacity 

of the Elba Island Phase III expansion and for the transportation capacity on the new Elba Express pipeline. These agreements are 

subject to qualifying conditions including regulatory approval, and El Paso will submit applications to the FERC for the two projects in 

the third quarter of 2006. Shell intends to use its capacity to primarily import LNG from Qatar through its Qatargas IV project, also 

announced today. BG, the sole importer of LNG at Elba Island now, will continue to source LNG from its portfolio of existing and future 

supply sources in the Atlantic Basin, including Trinidad, Egypt and Equatorial Guinea. 

In announcing the expansions, Doug Foshee, president and chief executive officer of El Paso, said, "The Elba Island expansion and 

Elba Express pipeline show El Paso's commitment to expand our premier natural gas infrastructure franchise to meet the country's 

growing energy needs. By doubling the size of our Elba Island terminal and expanding our delivery capability from the terminal, we are 

significantly improving the natural gas supply picture in the Southeastern United States, and doing so together with Shell and BG 

Group, two of the largest players in the worldwide LNG business. These expansions will increase both the market's access to diverse 

and non-traditional supplies and the suppliers' access to the fast-growing Southeast markets and beyond." 

El Paso Corporation provides natural gas and related energy products in a safe, efficient, and dependable manner. The company owns 

North America's largest natural gas pipeline system and one of North America's largest independent natural gas producers. For more 

information, visit http://www.elpaso.com/elba/mediakit.shtm. 

Cautionary Statement Regarding Forward-Looking Statements 

This release includes forward-looking statements and projections, made in reliance on the safe harbor provisions of the Private

Securities Litigation Reform Act of 1995. The company has made every reasonable effort to ensure that the information and 

assumptions on which these statements and projections are based are current, reasonable, and complete. However, a variety of factors 

could cause actual results to differ materially from the projections, anticipated results or other expectations expressed in this release, 

including, without limitation, our ability to obtain all necessary regulatory approvals and to successfully construct and operate the 

proposed facilities described in this release; general economic conditions in geographic regions or markets served by El Paso 

Corporation and its affiliates, or where operations of the company and its affiliates are located, and other factors described in the 

company's (and its affiliates') Securities and Exchange Commission filings. While the company makes these statements and projections 

in good faith, neither the company nor its management can guarantee that anticipated future results will be achieved. Reference must 

be made to those filings for additional important factors that may affect actual results. The company assumes no obligation to publicly 

El Paso | News Release Page 1 of 2

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update or revise any forward-looking statements made herein or any other forward-looking statements made by the company, whether 

as a result of new information, future events, or otherwise. 

Contacts 

Investor and Public Relations 

Bruce L. Connery, Vice President 

Office: (713) 420-5855 

Media Relations 

Bill Baerg, Manager 

Office: (713) 420-2906 

SOURCE El Paso Corporation 

12/21/2005 

0916 12/21/2005 09:07 EST http://www.prnewswire.com 

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News & Media releases close

Shell adds major liquefied natural gas supply and regasification projects to its global 

portfolio 

21 Dec 2005

Royal Dutch Shell plc (Shell) today announced two major additions to its global Liquefied Natural 

Gas (LNG) portfolio. In Qatar, the company has joined forces with Qatar Petroleum (QP) in the 

development of the large scale Qatargas 4 LNG project, while in the United States Shell has agreed 

to acquire additional capacity at the Elba Island LNG import terminal in Georgia. 

 

Speaking from Doha in Qatar at the award of the Engineering, Procurement and Construction (EPC) contract for 

the Qatargas 4 project, Linda Cook, Shell Executive Director of Gas and Power said, "We are honoured to join 

Qatar Petroleum in partnership for the Qatargas 4 LNG venture. The project will contribute to Shell's goal of 

growing our natural gas production and reserves position, as well as to increased security and diversity of 

natural gas supply to North America." 

 

Qatargas 4 is Shell's seventh global LNG supply project and reaffirms the company's leadership position 

amongst international oil companies in the global LNG business. 

 

An integrated upstream and LNG project, Qatargas 4 will produce 1.4 billion cubic feet per day of natural gas, 

including an average of approximately 70 thousand barrels per day of associated natural gas liquids from 

Qatar's North Field over the 25 year life of the project. The project also includes a 7.8 million tonnes-per-annum 

(mtpa) liquefaction plant and related LNG shipping capability. Qatargas 4 is a joint venture between Qatar 

Petroleum (70 percent) and Shell (30 percent). The majority of the LNG will be delivered to the growing natural

gas market in North America. LNG deliveries are expected to commence around the end of the decade. 

 

Shell's LNG equity sales in 2004 were 10.15 million tonnes from projects in Nigeria, Malaysia, Brunei, Oman and

Australia. Three new LNG trains are currently nearing start-up, within budget and schedule expectations, in 

Oman and Nigeria. Good construction progress is being made on additional new trains in Australia, Russia and 

Nigeria for start up in the coming years. Now, with the addition of Qatargas 4, Shell's equity LNG production 

capacity is expected to approximately double by the end of the decade. 

 

Shell also announced today that it has reached agreement with Southern LNG Inc., a wholly owned subsidiary of

El Paso Corporation's Southern Natural Gas Company (SNG), to acquire additional capacity at the Elba Island 

LNG import terminal in Georgia in the United States. In addition Shell has reached agreement with Elba Express

Pipeline Company LLC, a wholly owned subsidiary of SNG, to acquire capacity in a new natural gas pipeline. 

Both projects will be filed with the U.S. Federal Energy Regulatory Commission (FERC) for approval in the third 

quarter of 2006. The intention is that this capacity will be utilised to import Qatargas 4 volumes into natural gas

markets in the eastern United States. 

 

The deal with El Paso will further strengthen Shell's LNG import position in North America. In addition to Elba 

Island, Shell has capacity rights at the existing Cove Point LNG terminal in Maryland and in the Altamira LNG 

terminal under construction on Mexico's east coast. Shell also has capacity rights at the Energia Costa Azul 

terminal currently under construction on the Pacific coast of Mexico. 

 

LNG supplies for these projects are planned from Shell's portfolio of existing and future LNG projects. 

 

Linda Cook added, "With global demand for LNG expected to double this decade, the addition of Qatargas 4 and 

additional Elba Island capacity to Shell's global portfolio of LNG assets will further strengthen our leading 

industry position in this exciting sector." 

 

 

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BG Group and Southern Natural Gas Company Enter Agreement to 

Further Expand the Elba Island LNG Import Terminal

Wednesday December 21, 9:00 am ET 

HOUSTON--(BUSINESS WIRE)--Dec. 21, 2005--BG LNG Services, LLC (BG) a wholly owned subsidiary of BG 

Group PLC (NYSE:BRG - News), today announced that it has entered into agreements with two wholly owned 

subsidiaries of El Paso Corporation to further expand the storage and throughput capacity at the Elba Island liquefied 

natural gas (LNG) terminal and to participate in a new interstate pipeline -- Elba Express. The expansion and new 

pipeline will benefit the southeastern U.S. by adding more LNG import capacity directly into the market area. Both 

projects will be filed with the U.S. Federal Energy Regulatory Commission (FERC) for approval in the third quarter of 

2006. 

The expansion of Elba Island will increase BG's storage capacity from 4.0 billion cubic feet (bcf) to 8.2 bcf and will 

increase BG's vaporization capacity from 675 million cubic feet per day (mmcfd) to 1.17 billion cubic feet per day. 

The expansion is expected to be completed before the end of 2012. 

As part of the expansion project, BG also entered into an agreement with SNG for transportation capacity on the 

recently announced Elba Express Pipeline. This new 191-mile interstate natural gas pipeline will allow BG to deliver 

natural gas from Elba Island to additional markets in Georgia and, through interconnections with other pipelines, to 

the southeastern and eastern United States. 

Martin Houston, BG executive vice president and managing director, North America, Caribbean and Global LNG, 

said, "The United States is one of our core markets and this agreement once again demonstrates BG's commitment 

to increasing LNG supply to the U.S. We have a clear market strategy which will continue to drive growth in our North 

American business." 

There are matters discussed in this media information that are forward-looking statements. Such statements are only 

predictions and actual events or results may differ materially. For a discussion of important factors which could cause 

actual results to differ from the forward-looking statements, refer to the Company's annual report and accounts for 

the year ended 31 December 2004. 

Notes to Editors: 

BG Group PLC is a global natural gas business. Active on five continents in over 20 countries, it operates four 

business segments -- Exploration and Production, LNG, Transmission and Distribution and Power. 

In the USA, BG LNG Services, LLC, holds, through 2023, 100% of the capacity rights at North America's largest 

operating LNG importation terminal, Lake Charles in Louisiana. This has the capability to receive, store, vaporise and 

deliver an average daily send out of 1.2 billion cubic feet per day (bcfd). Expansion work is scheduled to increase the 

average send-out rate to 1.8 bcfd by mid-2006. Additionally, BGLS currently holds supply and regasification rights of 

675 mmcfd for 22 years at the Elba Island LNG terminal near Savannah, Georgia. BG's website: www.bg-group.com

Contact:

Press Release Source: BG Group PLC

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archiving in a public web site or database, or redistribution in a computer network is strictly forbidden. 

BG Group PLC 

Communications, 713-599-4009 

or 

After-hours media, 832-213-9082 (cell) 

or 

Investor Relations 

Chris Lloyd or Helen Parris 

or Kate Bingham, +44 (0) 118 929 3025 

Source: BG Group PLC

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Attachment 4 

Letters of Recommendation 




Commanding Officer 

United States Coast Guard 

Marine Safety Unit 

Juliette G. Low Federal Bldg. 

100 W. Oglethorpe Ave., Ste. 1017 

Savannah, GA 31401 

Phone: (912) 652-4353 

Fax: (912) 652-4180 

16611 

June 18, 2007 

Director of Gas – Environmental & Engineering, PJ-11 

Attn: Larry Sauter 

Federal Energy Regulatory Commission 

888 First Street, NW 

Washington, DC 20426 

Dear Mr. Sauter: 

I have completed a review of the Waterway Suitability Assessment (WSA) for the Elba III Terminal 

Expansion Project submitted by Southern LNG on 20 Sept 06. This review is based on consultation 

with various port stakeholders including the Savannah Pilots Association, the Savannah Maritime 

Association, towing industry representatives, emergency service agencies, waterfront facilities, and 

select members of the Area Maritime Security Committee. Based upon this review, it appears that to 

make the Savannah River suitable for the type and frequency of LNG marine traffic associated with 

this project, additional measures will be necessary to responsibly manage the navigation, safety and 

security risks. The specific measures, and resources needed to implement them where applicable, are 

described in the enclosed Waterway Suitability Report (WSR). 

This determination is merely a preliminary assessment and does not constitute final agency action 

because analysis required by the National Environmental Policy Act (NEPA) has not been completed. 

The final determination of suitability as well as any requirements or conditions related thereto will be 

disclosed in my Letter of Recommendation. In the absence of the measures described in the WSR and 

the resources necessary to implement them or changes in Coast Guard policy upon which the necessary 

resources are based, the Savannah River would be considered unsuitable for the LNG marine traffic 

associated with the Elba III Terminal Expansion project. 

For further information, please contact Mr. Charlie Johnson at (912) 652-4353. 

 Sincerely, 

 D. W. Murk 

 Commander, U. S. Coast Guard 

 Captain of the Port 

Encl: (1) Waterway Suitability Report 

Copy: CCGD7(p) 

 LANTAREA(p) 

 CEU Miami 
Waterway Suitability Report: 

Proposed Expansion of the Southern 

LNG facility on Elba Island, Georgia 

Prepared by: 

U. S. Coast Guard, Captain of the Port 

Savannah 

Date: 18 Jun 07
1

1. INTRODUCTION 

This document constitutes the United States Coast Guard Captain of the Port Savannah’s (COTP 

Savannah) Waterways Suitability Report (WSR) for the proposed Phase III expansion to 

Southern LNG’s Liquefied Natural Gas (LNG) Facility on Elba Island. This Waterways 

Suitability Report meets the intent of paragraph 6.b. of U.S. Coast Guard Navigation and Vessel 

Inspection Circular (NVIC) 05-05. NVIC 05-05 establishes Coast Guard policy for assessing the 

suitability of a waterway to support LNG carrier traffic.

1.1 Background 

COTP Savannah and Southern LNG have a history of working cooperatively on LNG regulatory 

issues for operating and expanding LNG facilities in accordance with 33 CFR Part 127. The 

following timeline provides a general overview of historical filings from Southern LNG and 

COTP Savannah’s response. 

• 2 July 2001 – Southern LNG submitted a Letter of Intent notifying COTP Savannah of 

plans to recommission the LNG transfer terminal on Elba Island. The recommissioning 

included installing new LNG pumps and piping; upgrading the fire protection, hazard 

detection, and intrusion prevention systems; modernizing the control systems; and reestablishing the vessel berth along the Savannah River. 

• 25 July 2001 – COTP Savannah issued a letter of recommendation stating that the 

Savannah River, as far upriver as the westernmost extent of the LNG facility, is suitable 

for LNG marine traffic. This letter of recommendation was contingent upon the 

completion of dredging at the Southern LNG’s berth to comply with under-keel clearance 

guidelines and that a new turning basin be established adjacent to the berth to 

accommodate safe turning of LNG vessels and increase safe water for passing vessels. 

• 7 May 2002 – Southern LNG submitted a Letter of Intent to expand their existing facility 

to include the relocation of LNG unloading operations to a new marine slip with the 

capability to accommodate two vessels, a fourth LNG storage tank, and additional piping 

and send-out facilities. 

• 30 May 2002 – COTP Savannah issued a letter of recommendation stating that the 

Savannah River, as far upriver as the westernmost extent of the LNG facility, is suitable 

for expanded LNG marine traffic. In accordance with Southern LNG’s Letter of Intent, 

this recommendation was contingent upon relocating the primary LNG mooring facilities 

to reduce the risk of passing vessels alliding with a moored LNG tankship and designing 

this new berth to eliminate all but emergency use of the existing riverside mooring. 
2

• 12 January 2006 – Southern LNG submitted a Letter of Intent to conduct a facility 

expansion that would more than double storage tank capacity, increase the facility’s 

vaporization capability, and modify the terminal’s LNG tanker berthing and unloading 

facilities to accommodate larger tankers and provide faster and simultaneous unloading 

of two LNG tankers. 

Upon receipt of Southern LNG’s Letter of Intent, COTP Savannah initiated action in accordance 

with NVIC 05-05 to assess the Savannah River’s suitability for another increase in LNG marine 

traffic. 

1.2 COTP Role 

The Federal Energy Regulatory Commission (FERC) conducts environmental, safety, and 

security review of LNG plants and related pipeline facilities, and as the lead federal agency for 

the process of authorizing the siting, construction, and operation of such facilities, prepares the 

overall National Environmental Policy Act (NEPA) documentation. In accordance with an 

Interagency Agreement between FERC and the Coast Guard, the Coast Guard is a cooperating 

agency with FERC under the NEPA process, and will be providing input to FERC throughout the 

licensing process. The Coast Guard exercises regulatory authority over LNG facilities which 

affect the safety and security of port areas and navigable waters under Executive Order 10173, 

the Magnuson Act, the Ports and Waterways Safety Act of 1972, as amended, and the Maritime 

Transportation Security Act of 2002. The Coast Guard is responsible for matters related to 

navigation safety, vessel engineering and safety standards, and all matters pertaining to the 

security of facilities or equipment located in or adjacent to navigable waters. The Coast Guard 

also has authority for LNG facility security plan review, approval and compliance verification as 

provided in 33 CFR Part 105.

1.3 Public Comment 

On April 10, 2006, COTP Savannah and FERC hosted an open meeting to allow for public 

comment on Southern LNG’s proposed terminal expansion. The meeting announcement was 

disseminated to all port stakeholders on April 3, 2006 through a Marine Safety Information 

Bulletin and was discussed in a variety of port outreach forums leading up to the event. COTP 

Savannah also issued a press release informing the public of the meeting and outlining the 

process to submit comments on the project. The public meeting was covered by the Savannah 

Morning News (area newspaper) and the local NBC and CBS news affiliates. 

The public meeting was attended by approximately 30 people, with a majority of the public 

comment focusing on Right-of-Way issues surrounding the over 188 miles of additional pipeline. 

COTP Savannah did receive several comments from maritime stakeholders on the economic 

impacts associated with an increase in LNG vessel traffic due to delays associated with schedule 

changes for LNG arrivals and the Regulated Navigation Area (RNA) requirements. Because the 

Waterway Suitability Assessment focuses on the safety and security aspects of LNG deliveries, 

FERC required that Southern LNG conduct a more detailed economic impact study as part of 
3

Resource Report Number 5 of the Environmental Impact Statement (EIS). However, as part of 

the regulatory process for the revised RNA, the Coast Guard completed an economic review and 

determined the regulation did not pose a “significant impact”. 

1.4 Waterway Suitability Assessment (WSA) Group 

The WSA participants included members of the port community from maritime industry and 

government agencies including the Coast Guard, U.S. Customs and Border Protection, local fire 

and police departments, the Georgia Ports Authority, the Savannah River Pilots Association, 

local towing companies, the Savannah Maritime Association, and a handful of other 

stakeholders. Southern LNG contracted AcuTech Consulting Group to facilitate the WSA 

process. A full listing of participants can be found in Section 1.4 of the WSA. 

2. PORT AND LNG ROUTE CHARACTERIZATION 

2.1 The Port of Savannah 

The Port of Savannah, Georgia (Port ID # 16923, UN Locator Code USSAV) includes all waters 

and adjacent waterfront from the entrance of the Savannah River upstream to the US Route 17 

(Houlihan) Highway Bridge located at river mile 21.3 including the cities of Savannah, Garden 

City, and Port Wentworth. The Savannah River is navigable for deep-draft vessels to the upper 

end of Savannah Harbor, 19 miles above the outer ends of the entrance jetties, and for barges to 

the city of Augusta, 172 miles above the entrance. 

The Port of Savannah is one of the nation’s fastest growing ports and a major contributor to the 

economy of the state of Georgia and the southeastern United States. With the recently completed 

expansion of Garden City Terminal’s Container Berth 8, the continued expansion of the 

Liquefied Natural Gas facility on Elba Island, the deepening projects for the Savannah River, and 

the general growth of many other waterfront facilities, the Port of Savannah will continue to 

expand well into the foreseeable future. The Port of Savannah is currently the nation’s fourth 

largest container port and second largest on the east coast, with import and export numbers 

increasing annually. Other major products and industries of the port include petroleum products, 

kaolin clay, wood pulp, and various chemicals. The port is also 1 of 13 strategic ports in the 

United States and is regularly used to assist in the mobilization of the Army’s 3rd Infantry 

Division. The Savannah Riverfront is a downtown historic area with considerable tourist and 

entertainment activity, especially during St. Patrick’s Day where over 200,000 visit Savannah for 

celebration festivities. 

The Port of Savannah is serviced by rail (CSX and Norfolk Southern) with a short line (Rail 

Link) connecting them. An Inter-modal Container Transfer Facility (ICTF) allows containers to 

be offloaded from vessels and taken directly to train cars at Garden City Terminal, either by a 

top-lift or on a chassis or flatbed trailer. These containers can be in Atlanta within 12 hours of 

their arrival in the port. The Port of Savannah also has immediate access to the I-95 corridor 

allowing for rapid distribution of goods along the eastern seaboard. 
4

The Port of Savannah averages approximately 10 deep draft vessel arrivals per day. 

2.2 LNG Tanker Route on the Savannah River 

For LNG tankships, the transit from the Savannah River Sea Buoy (Tybee Lighted Buoy T) to 

the Southern LNG facility is 18 miles, with Southern LNG being the first facility a deep draft 

vessel encounters during inbound transit. The entrance to the Savannah River (Gated Buoys 1 

and 2) is 600 feet wide and dredged and maintained to a depth of 44 feet at mean low water. 

These waterway dimensions remain in place until Tybee Knoll Range (Buoys 17 and 18), where 

the width of the channel decreases to 500 feet and the depth is dredged and maintained to 42 feet 

at mean low water. These dimensions remain in place from Tybee Knoll Range to the LNG 

facility on Elba Island. 

Other than Tybee Island, both sides of the river from its mouth to Elba Island are generally 

undeveloped and consist of marsh, dredged material disposal sites, and other uninhabited 

waterfront areas. There is typically either a sand or hard sand bottom on both the north and 

south banks of the river, with an average 7.5 foot tidal range and regular ebb currents upwards of 

3 knots. The transit for any vessel entering the Savannah River requires passage by the Tybee 

National Wildlife Refuge and Fort Pulaski National Monument. 

3. SAFETY AND SECURITY ASSESSMENT 

 

3.1 Det Norske Veritas (DNV) Consulting Report on Larger Tankships 

The Sandia Laboratory Report on risks associated with LNG spills over water serves as the Coast 

Guard’s foundation for LNG safety and establishes zones of concern for consequence 

management following accidental or intentional LNG releases. However, the Sandia Report is 

based on LNG tankships with a capacity of 125,000 m3

 and does not sufficiently address 

potential risks associated with the future generation of LNG carriers. As part of this expansion 

project, Southern LNG will have the capability to offload Q-Max LNG carriers with a capacity 

of 266,000 m3

. 

Because of the discrepancy between the Sandia Report and Southern LNG’s proposal for future 

operations, COTP Savannah required that Southern LNG conduct a site-specific analysis as part 

of the WSA to account for these future generation tankships. Based on this requirement, 

Southern LNG contracted DNV Consulting to perform a vulnerability evaluation and 

consequence analysis for Q-Max LNG tankships with cargo capacities up to 266,000 m3

. 

Before beginning the analysis, members of Southern LNG met with the Coast Guard 

Headquarters Office of Operating and Environmental Standards to discuss the overview of the 

modeling and analysis requirements to address in the study to receive Coast Guard acceptance. 

The vulnerability evaluation was divided into two components: 

1. Qualitative comparison of particulars for different size LNG carriers. 
5

2. Collision vulnerability analysis to determine side impact energies that can be 

absorbed for different sized LNG carriers before deformation of the tank shell is 

initiated. 

The consequence analysis was divided into four components: 

1. A comparison of the potential spill volumes and initial liquid height of LNG for a QMax tankship versus those assumed in the Sandia Report. 

2. A summary of historic atmospheric and meteorological data for Elba Island, Georgia. 

3. Model vapor cloud and pool fire scenarios for a Q-Max LNG carrier under site 

specific conditions for both accidental and intentional breach sizes as outlined with a 

results comparison to the Sandia Report. 

4. Model vapor cloud and pool fire scenarios under site specific weather conditions 

based on Coast Guard recommendations. 

To model the relevant dispersion and flammable scenarios, DNV utilized PHAST (Process 

Hazard Analysis Tool Software), a commercial-use software package designed to comply with 

Dutch Yellow Book, US EPA, and UK HSE regulations. DNV ran multiple pool fire and vapor 

cloud scenarios with variable hole sizes (intentional and accidental), number of tanks breached, 

LNG discharge rates, atmospheric conditions, and the distances to Lower Flammable Limits. 

Based on these inputs, PHAST calculated updated Zones of Concern in alignment with the 

Sandia Report and Southern LNG incorporated them into the WSA. 

Prior to submission, DNV satisfactorily validated their results through comparison with 

scientifically accepted experimental LNG trials. On September 6, 2006, Southern LNG 

submitted the DNV report entitled Elba Island: Approach to LNG Consequence Modeling to the 

Coast Guard Headquarters Office of Vessel and Facility Operating Standards for evaluation and 

official acceptance. On September 25, 2006, Coast Guard Headquarters responded via letter that 

the DNV report is “acceptable for addressing the modeling gaps that exist between the quantities 

of LNG carried on vessels included in the Sandia Report of December 2004 and those of future 

LNG carriers currently being designed and considered for use in conjunction with the expansion 

project at Elba Island.” 

3.2 WSA Process Overview 

The WSA group divided the LNG tanker route into six segments to evaluate safety and security 

risks offshore and along the Savannah River: 

Segment 1 - Pilot Boarding Area to Gated Buoys 1 and 2 

Segment 2 - Gated Buoys 1 and 2 to Gated Buoys 17 and 18 

Segment 3 - Gated Buoys 17 and 18 to Gated Buoys 24 and 25 

Segment 4 - Gated Buoys 24 and 25 to Elba Island Facility Slip 

Segment 5 - LNG Carrier moored within the slip at Elba Island 

Segment 6 - Outbound from Elba Island to Gated Buoys 1 and 2 following offload (less than 5% 

heel remains) 
6

The Zones of Concern from the DNV Report were overlaid along each segment of the transit 

route to evaluate risk factors and vulnerabilities, as well as potential impacts to population 

centers, critical infrastructure, and the environment. 

3.3 Population Centers 

The WSA group used 2000 census data to identify population areas potentially affected by the 

Zones of Concern along each transit route segment as outlined on page 11 of the WSA. Two of 

the affected census tracts (Tracts 111.04 and 111.05) have a Medium average population density 

as per NVIC 05-05; however, the population centers for both of these tracts are located outside 

the Zones of Concern. The portions of each tract within the Zones of Concern have minimal to 

no residential areas and were considered low population density areas by the WSA group. 

The census data also indicated that Tract 111.03 (Tybee Island) was a low population density 

area. Although this may be true for year-round residents, the WSA group considered Tract 

110.03 a Medium population density area based on the high recreational use of Tybee Island 

during the summer months. Tract 111.03 is located in Segment 3 of the LNG tanker route and 

impacted by both Zones 2 and 3. 

3.4 Critical Infrastructure 

The Zones of Concern were overlaid along the Savannah River to determine possible impacts to 

critical infrastructure identified in the Area Maritime Security (AMS) Plan for the Savannah 

COTP Zone. The results of this evaluation are outlined in the Sensitive Security Information 

supplement to this report. 

3.5 Security 

Once the potentially affected areas along the transit route were established, the WSA group 

evaluated both intentional and accidental LNG releases using the threat and attack scenarios 

recommended in enclosure (3) to NVIC 05-05. 

These scenarios were evaluated against five risk variables - Consequences, Likelihood, Threat, 

Vulnerability, and Target Attractiveness – to identify the areas of highest risk and develop 

possible risk management strategies. The WSA group evaluated each segment of the transit 

route individually, using the risk variables to reach a conclusion of high, medium, or low risk for 

each scenario. The results of this assessment are outlined in the Sensitive Security Information 

supplement to this report. 

4. RISK MANAGEMENT STRATEGIES 

There are a number of proven safeguards in place for today’s LNG marine traffic on the 

Savannah River that will remain in place following the proposed expansion. As port-wide 
7

experience with LNG deliveries has increased, these safeguards have been evaluated through 

discussions with port stakeholders and updated to maintain safety and security risk mitigation 

while minimizing impact to port mobility. 

4.1 Risk Management Strategies In Place 

4.1.1 Regulated Navigation Area (RNA) 

When Southern LNG was recommissioned in 2001, COTP Savannah instituted a Regulated 

Navigation Area (33 CFR Part 165.756) outlining the requirements for all vessels transiting the 

Savannah River when an LNG tankship is within the geographic limits of the RNA (the 

Savannah River between Fort Jackson and the Savannah River Channel Entrance Sea Buoy). 

When originally enacted, COTP Savannah did not allow any vessels over 1,600 gross tons within 

the boundaries of the RNA when an LNG tankship was transiting. As the Coast Guard, Southern 

LNG, the Savannah River Pilots, and the local tug operators gained experience in the safety and 

security aspects of LNG tankship arrivals, the RNA was revised multiple times to improve port 

mobility during LNG operations while not increasing associated safety and security risks. 

When the new facility slip was placed into service, the RNA was again revised to account for the 

different possible mooring configurations and to remove several requirements based on the 

additional level of safety the slip provides. A Notice of Proposed Rulemaking was published for 

public comment and additional changes were made after considering this feedback. Although the 

Final Rule has not yet been published, COTP Savannah expects the RNA provisions to include a 

number of port-agreed upon requirements. 

There are several requirements below for FiFi Class 1 equipped towing vessels. The National 

Fire Protection Academy outlines the criteria for towing vessels to be certified as Class 1 

equipped in NFPA 1915 – Standard on Marine Fire-Fighting Vessels. This publication addresses 

the construction of marine fire-fighting vessels and contains criteria on a wide-range of specific 

standards that include outfitting, stability, propulsion, auxiliary machinery, electrical systems, 

fire pumps and fire-fighting equipment. 

Requirements for vessel operations while an LNG tankship, carrying LNG in excess of 

heel, is underway within the RNA 

• No vessel 1,600 gross tons or greater may approach within two nautical miles of a 

transiting LNG tankship. 

• All vessels less than 1,600 gross tons shall keep clear of transiting tankships. 

• The vessel master must obtain permission from COTP Savannah before transiting into the 

RNA and can not enter or get underway within the RNA if visibility is not sufficient to 

safely navigate, and/or wind speed is, or is expected to be, greater than 25 knots. 

• While transiting, the LNG tankship shall have a minimum of two escort towing vessels 

with a minimum of 100,000 pounds of bollard pull, 4,000 horsepower, and capable of 
8

safely operating in indirect mode. At least one of the towing vessels shall be at least FiFi 

Class 1 equipped. 

Requirements while LNG tankships are moored inside the facility slip 

• An LNG tankship moored inside the facility slip shall have two standby towing vessels 

with a minimum of 100,000 pounds of bollard pull, 4,000 horsepower, and capable of 

safely operating in indirect mode. At least one of the towing vessels shall be at least FiFi 

Class 1 equipped. 

• The standby towing vessels shall be available to provide a ready means of assistance to 

maintain a safe zone around the moored LNG tankship; to provide emergency firefighting 

assistance; to aid the LNG tankship in the event of an emergency departure; or to take 

other appropriate actions in an emergency as directed by the LNG vessel bridge watch. 

• If two LNG tankships are moored inside the facility slip, each vessel shall provide a 

standby towing vessel that is FiFi Class 1 equipped with a minimum of 100,000 pounds 

of bollard pull, 4,000 horsepower, and capable of safely operating in indirect mode that is 

available to assist either vessel as described above. 

Requirements while an LNG tankship is moored outside of the facility slip 

• An LNG tankship moored outside of the LNG facility slip shall have on-scene a 

minimum of two escort towing vessels, with a minimum of 100,000 pounds of bollard 

pull, 4,000 horsepower and capable of safely operating in the indirect mode, to escort 

transiting vessels 1,600 gross tons or greater past the moored LNG tankship. At least one 

of these towing vessels shall be FiFi Class 1 equipped.

• In addition to the two towing vessels described above, the LNG tankship moored outside 

of the slip shall have at least one standby towing vessel with a minimum of 90,000 

pounds of bollard pull to take appropriate actions in an emergency as directed by the 

LNG vessel bridge watch. 

• If LNG tankships are moored both inside and outside of the slip, the LNG tankship 

moored outside the slip shall provide the two escort towing vessels and the LNG tankship 

moored inside the slip shall provide the standby towing vessel.

Requirements while LNG tankships are moored both inside and outside the LNG 

facility slip 

• When one LNG tankship is moored inside and one LNG tankship is moored outside the 

LNG facility slip, the LNG tankship moored outside of the slip shall have on-scene a 

minimum of two escort towing vessels, with a minimum of 100,000 pounds of bollard 

pull, 4,000 horsepower and capable of safely operating in the indirect mode, to escort 

transiting vessels 1,600 gross tons or greater past the LNG tankship. At least one of these 

escort towing vessels shall be FiFi Class 1 equipped. In addition, the LNG tankship 

inside of the slip shall have at least one standby towing vessel with a minimum of 
9

100,000 pounds of bollard pull, 4,000 horsepower, and FiFi Class 1 quipped to take 

appropriate action in an emergency. 

• When one LNG tankship is moored outside and two LNG tankships are moored inside 

the LNG facility slip, the LNG tankship moored outside of the slip shall have on-scene a 

minimum of two escort towing vessels, with a minimum of 100,000 pounds of bollard 

pull, 4,000 horsepower and capable of safely operating in the indirect mode, to escort 

transiting vessels 1,600 gross tons or greater past the moored LNG tankship. At least one 

of these towing vessels shall be FiFi Class 1 equipped. In addition, the LNG tankships 

moored inside of the slip shall have at lease one standby towing vessel between the two 

ships with a minimum of 100,000 pounds of bollard pull, 4,000 horsepower, and FiFi 

Class 1 quipped to take appropriate action in an emergency. 

• In the event of an actual emergency, escort towing vessels can be utilized as stand-by 

towing vessels to take appropriate action by the LNG vessel bridge watch. 

Requirements for LNG tankships moored within the RNA 

• While moored within the RNA, LNG tankships shall maintain a bridge watch consisting 

of a docking pilot or licensed deck officer who shall monitor all vessels transiting passed 

the LNG facility. In addition, the LNG Bridge Watch shall communicate with the pilots 

of vessels 1,600 gross tons or greater at pre-designated locations prior to passing the 

LNG facility in order to take actions of the towing vessel(s) in the event of emergency. 

• LNG tankships shall also have emergency towing wires (fire wires) positioned one meter 

above the waterline, both on the off-shore bow and quarter of the ship. LNG vessels 

equipped with waterline bollards are exempt from this requirement. 

Requirements for other vessels while within the RNA 

• When one or more LNG tankships are moored only inside the facility slip, escort towing 

vessel for vessels greater than 1,600 gross tons are not required. 

• When an LNG tankship is moored outside of the facility slip, vessels 1,600 gross tons or 

greater shall have a minimum of two towing vessels with a minimum capacity of 100,000 

pounds of bollard pull, 4,000 horsepower, and the ability to operate safely in the indirect 

mode, made-up in such a way as to be immediately available to arrest and control the 

motion of a transiting vessel in the event of steering, propulsion or other casualty. At 

least one of the towing vessels shall be at least FiFi Class 1 equipped. These escort 

towing vessels are the same required by LNG tankships when moored outside of the 

facility slip or while LNG tankships are moored both inside and outside the LNG facility 

slip sections. 

• Vessels 1,600 gross tons or greater shall make a broadcast on VHF Channel 13 at predesignated locations on the Savannah River. 

• Vessels 1,600 gross tons or greater shall at a minimum transit at bare steerageway when 

within an area 1,000 yards on either side of the LNG facility slip to minimize potential 

wake or surge damage to the LNG facility and vessel(s) within the slip. 
10

• Vessels 1,600 gross tons or greater shall not meet or overtake within an area 1,000 yards 

on either side of the LNG facility slip when an LNG tankship is present in the slip. 

• Vessels less than 1,600 gross tons shall not approach within 70 yards of an LNG tankship 

without COTP permission. 

• No vessel shall enter the LNG facility slip at any time without COTP permission. 

4.1.2 Savannah Area LNG Vessel Management and Emergency Plan 

In addition to the requirements of the RNA, the entire process for LNG tankship arrivals is 

outlined in the Savannah Area LNG Vessel Management and Emergency Plan. This document 

contains detailed information on pre-arrival requirements for the facility, vessel, and COTP; 

vessel transit procedures; mooring procedures; cargo transfer operations and vessel departure 

procedures. This plan is periodically reviewed and updated to incorporate any new 

developments in the LNG vessel transit, transfer and departure procedures. 

4.1.3 Coast Guard Presence and Intelligence 

Because of the pre-arrival reporting requirements required by 33 CFR Part 160 and the Savannah 

Area LNG Vessel Management and Emergency Plan, Coast Guard security coordination takes 

place well in advance of LNG tankship arrivals. Upon receiving a Notice of Arrival from an 

LNG tankship, COTP Savannah conducts a vessel safety and security screening using 

standardized matrices prior to port entry. The results of these screening are a key component in 

determining COTP Savannah’s inspection and enforcement presence during the vessel’s transit 

and their time in port. Additionally, COTP Savannah receives several national-level intelligence 

feeds that can include general threat assessments to certain maritime infrastructure or specific 

intelligence relating to a vessel or person of interest. 

All Coast Guard security operations for LNG vessels and facilities, including harbor patrols of 

critical infrastructure, security zone enforcement, positive control boardings, vessel escorts, and 

aerial over-flights, are conducted in accordance with Coast Guard policy on Ports, Waterways, 

and Coastal Security. 

 

4.1.4 Facility Security and Safety 

As a facility regulated under the Maritime Transportation Security Act (MTSA), Southern LNG 

must meet all of the security requirements outlined in 33 CFR Parts 101 and 105. This includes 

defining the facility’s security organizational structure, designating a Facility Security Officer, 

and implementing a Coast Guard-approved Facility Security Plan. 

Southern LNG is subject to an annual MTSA compliance exam evaluating their entire security 

program including personnel training, recordkeeping and reporting, drills and exercises, external 

Facility Security Plan audits, equipment maintenance. Additionally, Coast Guard facility 

inspectors conduct random MTSA security spot checks of Southern LNG to verify proper 

implementation of the Facility Security Plan to include the performance of personnel with 
11

security duties, vehicle screening rates, access control and monitoring, and the facility-to-vessel 

security relationship. 

As a waterfront facility handling LNG, Southern LNG must also comply with the regulations of 

33 CFR Part 127, including a number of specific requirements concerning equipment, 

operations, maintenance, training, and firefighting. As part of these requirements, Southern 

LNG must maintain a Coast Guard-approved Operations Manual and Emergency that contains 

LNG release response procedures, emergency shutdown procedures, fire equipment operating 

procedures, emergency lighting systems, emergency contact information, and the emergency 

procedures for mooring and unmooring a vessel. 

Coast Guard facility inspectors also conduct an annual exam to ensure facility compliance with 

33 CFR Part 127 and random cargo transfer monitors to verify the facility is operating in 

accordance with their Operations Manual. 

 4.1.5 Chatham County Warning Siren Program 

The Chatham Emergency Management Agency (CEMA) uses warning sirens installed at 

recreation facilities and in areas of high population to notify the public of potential or actual 

emergencies such as hazardous material releases and fire. For public emergency notification, 

CEMA will activate the siren with a 3-minute fast high-low alarm. Upon hearing the alarm, 

residents are advised to seek shelter immediately and access local television and radio to gather 

additional information and guidance on the specific threat. 

4.2 Additional Risk Management Recommendations Resulting from WSA 

 

The WSA recommends four additional risk management strategies be implemented at all 

Maritime Security (MARSEC) Levels to reduce risk associated with LNG deliveries. These 

recommendations are not conditions on the suitability of the waterway, but could be used to 

further reduce the risk potential associated with LNG deliveries. The recommendations 

suggested further evaluation of; Coast Guard boarding programs, Coast Guard security zones, 

and operational measures to help enhance security. 

 

 

5. RESOURCE NEEDS FOR SECURITY AND SAFETY 

5.1 Security Resources 

Based on the number of proposed and expanding LNG terminals, Coast Guard Headquarters 

developed a model to evaluate resource requirements for each operating and proposed LNG 

facility. The model calculation takes into account a number of factors including the number of 

estimated transits per week, the number of different LNG tankships expected to call on 

Savannah, the average vessel transit time, the average cargo transfer time, and the Coast Guard 

policy for safety and security activities related to LNG. While an LNG vessel is navigating its 
12

loaded inbound transit, an armed escort may be required to enforce a safety zone around the 

moving LNG vessel. This escort may consist of USCG patrol boats, and/or patrol boats provided 

by state/local LE agencies. The escort will commence in a specified area beyond the entrance to 

the Savannah River and continue during the remainder of the inbound transit. The number of 

escort boats may range from 0 to 4 depending on the MARSEC level and other factors. 

5.2 Port Resources 

 5.2.1 Tug Availability 

Tug availability is the only potential limiting factor for port resources. The Port of Savannah 

currently has a complement of 10 tugs operated by either Moran or Crescent Towing including 

three tractor tugs, two of which are FiFi Class 1 equipped. The most recent proposed change to 

the RNA further alleviates the requirement for towing vessel presence, namely for outbound 

LNG tankships departing the port in heel (less than 5% of the LNG tankship’s carrying capacity). 

The WSA group did not feel additional tugs were necessary to maintain current tug availability 

levels, but felt future traffic growth might require additional tugs to support port operations 

without costly delays. 

5.2.2 State Enforcement of Security Zones 

An increase in LNG shipments would further drain Coast Guard response resources because state 

and local law enforcement agencies are not authorized to enforce federal law in Georgia. COTP 

Savannah is actively pursuing several possible avenues to legally obtain state and local 

assistance, including having the state overlay Special Exclusionary Zones over Coast Guard 

safety and security zones to allow for state enforcement, or passing a new Georgia statute 

making the violation of federal access areas also a violation of state law. Both of these 

possibilities may take considerable time to enact. In the interim, although local and state 

resources are assisting, only Coast Guard assets will be used for LNG vessel escorts and security 

zone enforcement. 

5.2.3 Turning Basin Adjacent to Elba Island 

During Southern LNG’s recommisioning in 2001, COTP Savannah’s positive letter of 

recommendation was contingent upon the establishment of a new turning basin adjacent to the 

berth to accommodate the safe turning of LNG vessels and increase safe water for passing 

vessels. Based on the size of Q-Max LNG tankships, COTP Savannah is considering 

reinstituting this turning basing requirement as part of the letter of recommendation for the Elba 

III expansion project. 

6. CONCLUSION AND RECOMMENDATIONS 

In accordance with NVIC 05-05, the Coast Guard Captain of the Port has three basic decisionmaking options in a WSR: the waterway is unsuitable for LNG marine traffic, the waterway is 
13

suitable for LNG marine traffic, or the waterway is suitable with additional conditions to 

responsibly manage the safety and security risks. 

After evaluating Southern LNG’s proposal and reviewing their WSA, COTP Savannah has 

preliminarily determined from a safety and security standpoint that the Savannah River, based on 

existing measures and additional recommended conditions, is suitable for an increase in LNG 

marine traffic associated with this project. Contingent upon a full National Environmental 

Policy Act analysis, these additional conditions for suitability are as follows: 

• Appropriate resources must be available to implement the required security measures 

outlined in the WSR or the most current Coast Guard policy on Ports, Waterways, and 

Coastal Security; and 

• Throughout the period of construction and until such time when the LNG facility goes 

into operation, the applicant must conduct an annual review of the WSA to identify 

changes that have occurred to the project scope and/or port community since submission 

of the initial WSA. The applicant shall provide a written statement to the COTP annually 

coinciding with the date of this letter attesting as to whether or not any changes have 

occurred. If this annual review identifies changes to the project and/or port that may 

invalidate portions of the WSA, the applicant must describe the changes in detail and 

describe any actions necessary to update the WSA. If updating the WSA is required, the 

applicant shall include a timeline for actions to take place. Prior to the start of operations, 

the applicant shall conduct a final review of the WSA and submit documentation to the 

COTP attesting that the most recent WSA on file with the COTP is current and up to 

date. Documentation of the final review shall be submitted to the COTP between 30 and 

60 days prior to the start of operations. 

Based on these conditions, the Port of Savannah’s experience with LNG import and the 

cooperative relationship between government agencies and port stakeholders, there would be 

sufficient capability within the port community to responsibly manage the safety and security 

risks introduced by this expansion project. 

COTP Savannah will continue to collaborate with FERC in the development of the 

Environmental Impact Statement (EIS) for this project. After FERC issues the Final EIS and it 

meets Coast Guard NEPA requirements, COTP Savannah will issue a Letter of Recommendation 

to Southern LNG as required by 33 CFR Part 127.009, with copies to all government agencies 

having jurisdictional responsibilities.