PUBLIC COMMENTS 

AND RESPONSES 

SECTION 6 
Table 6-1 

Oral Comments on the Elba III Project Draft EIS 

The following table presents a summary of comments extracted from the transcripts for the DEIS public meetings 

Georgia (May 7, 2007), Thomson, Georgia (May 8, 2007), Sylvania, Georgia (May 9, 2007), and Pooler, Georgia 

text of the transcripts is available in the public file on the FERC Internet website (http://www.ferc.gov) using the e

ID #(1) 

Location / 

Transcript 

Page(s) 

Comment Summary – Commenter Response 

WT-01 Washington/p. 6 

The commenter is concerned that the pipeline route is through green space and believes that there is an alternative route using existing ROWs (Cindy Russell-Bounds-Landowner)

Section 3.3.2.2 of the EIS discusses the Full Cthat primarily follow existing ROW corridors. Aalternatives would affect substantially more acracres, respectively) as the proposed route (1,1would result in significantly greater impact to thalternatives do not provide an environmental aroute. Additionally, section 3.3.2.2 discusses the Partthat would partially collocate the proposed pipeand corridors located in the vicinity of the propoproposed route would traverse approximately 8West, Midwest, and East Route Alternatives alapproximately 55.6, 50.6, and 79.3 miles, resp3.3-2 and section 3.3.2.2, considering broader economic resources, we believe these alternatenvironmental advantage over the proposed ro

WT-02 Washington/p. 7-9 

The commenter states that the gas pipeline will just "pass through" rural Georgia for the benefit of industry far away, and not the local community, which has no industry and does not need any natural gas. Commenter states that the pipeline company will only pay a one-time payment for the ROW, but the landowner will have to continue paying property taxes on land they can no longer use for anything, which is particularly detrimental for local tree growers/harvesters. The 

In section 1.1 of the EIS, we discuss the objectnatural gas to the Georgia and South Carolina and other markets in the southeastern and eas2.2.2 and table 2.2-2, we identify that the Elba and deliver (through meter stations) natural gaelectric power plants (McIntosh and Effingham Georgia, and Rainey in Anderson County, Souproject area. Regarding property taxes, according to the StaRevenue, property taxes are based on the fair each county's Board of Assessors. Landowne

6-1 6.0 – Public Comments and Responses 
Table 6-1 (Continued) 

ID #(1) 

Location / 

Transcript 

Page(s) 

Comment Summary – Commenter Response 

commenter states that green space should be preserved. (Deborah Bennett-Landowner)

own assessment of the fair market value of theAssessors, or disputing a Board's assessment lead to a loss of their property value. See the G

Local Government Services Division website: http://www.dor.ga.gov/ptd/index.shtml and acc

Tax", "Appeals", and "Appraisal Procedure MaAccording to the Internal Revenue Service, trethe ROW before the trees reach maturity may taxes, to take as a loss the difference between less mature trees verses the price they would htrees. This is a one-time tax write-off. No lossthat is no longer available for tree growth. Confor further information. The 50-foot-wide permanent ROW through upllonger be available for tree growth for the life otemporarily disturbed by construction, howeverAdditionally, landowners may remove and sell trees before imminent construction, and still remarketable forested acreage disturbed by consThe total land disturbed by the proposed projecAs stated in section 4.5.1, the total acres of greforest and planted pine, permanently removed would be 528 acres. On a project-wide scale, total project. On a regional scale, out of a Geoforested acres (Georgia Forestry Commission, 

WT-03 Washington/p. 9-10 

The commenter is concerned that a ROW corridor will be established that may be used by other projects in the future, that trees will be removed unnecessarily affecting green space, and transit of farm equipment across the pipeline ROW. The commenter is also concerned that the removal of trees from the ROW will 

While there are no immediate plans by other pfacilities adjacent to EEC's proposed route, it is used for such purposes in the future. This, howbe located in one corridor, as opposed to impaminimizing cumulative land use impacts. See sdiscussion. In section 4.13 of the EIS we discuss potential 

6-2 6.0 – Public Comments and Responses 
Table 6-1 (Continued) 

ID #(1) 

Location / 

Transcript 

Page(s) 

Comment Summary – Commenter Response 

increase the effects of global warming as the trees will no longer be growing and sequestering carbon dioxide from the atmosphere. (Virginia Thomas-Landowner)

with development of the Elba III Project in the sof other known projects. Specifically, section 4impacts to vegetation and wildlife. The construction ROW, which is the minimum movement of construction equipment and persdiameter pipeline in this terrain, would be 110 fis necessary for safe maintenance of the pipelibe 50-feet-wide. Additionally, there will be tem

sizes necessary when the ROW encounters a utility, or other obstacles. After construction, 6construction ROW and all temporary workspacuses. Landowners can negotiate with EEC for requirements on these lands. Cross-section dareas are presented as figures 2.2-1 and 2.2-2response to comment WT-02. We have revised section 4.8.1.2 of the EIS to ilands, and state that use of farm equipment on permitted across the pipeline ROW. As detailed in Table 4.8-1, about 342 out of 94out of 562 acres of planted pine would be perm

Therefore, this acreage would no longer be avasequestering for the life of the proposed projecupland forest and 376 acres of planted pine wo

during construction and could revert to their prelandowners replant or request that EEC replannegotiations. These areas replanted with trees carbon sequestering. On a regional scale, the 528 forested acres out of a Georgia state total (Georgia Forestry Commission, 2007) would nsequestering of atmospheric carbon dioxide. 

WT-04 Washington/p. 10- 12 

The commenter is concerned about the impacts of the proposed pipeline on her land; specifically, her ability to farm crops, the loss of forested acres, impacts 

During construction, EEC would follow its Plan for protecting, repairing or replacing drain tiles, segregating topsoil from subsoil; and installing disturbance. (See appendix E.) Additionally, d

6-3 6.0 – Public Comments and Responses 
Table 6-1 (Continued) 

ID #(1) 

Location / 

Transcript 

Page(s) 

Comment Summary – Commenter Response 

on a small wetland, and the effects of construction on quail. Additionally, the commenter is concerned about the impact of pipeline construction on the Savannah and Little Rivers. (Carol Phillips-Landowner)

landowners may request that the pipe be burieso farm equipment does not impact the pipe in farm lands would be returned to their original scontinue as before. See section 4.2.3 for a disimpacts and mitigation. The 50-foot-wide permanent ROW through fore

available for tree growth for the life of the proje

disturbed by construction, however, could be re

a discussion on land use impacts and mitigatiopine. Regarding impacts on wetlands, see the discusregarding impacts and mitigation for forested, ewetlands. Given their mobility and the abundance of simiproposed ROW, quail are expected to vacate tduring construction activities. Following constrarea. Additionally, the edge habitat created by the project area. We have revised our discussion of EEC's propmitigation for crossing the Savannah and Little 

WT-05 Washington/p. 12- 13 

The commenter is concerned about the loss of marketable pine on her land as well as the loss of forested acres in deeper woods. Additionally, the commenter is concerned about the cutting of trees along a steep and rocky creek bank and the permanent loss of forest canopy over creeks crossed by the ROW. The commenter also expressed concern about the potential for blasting along the steep and rocky creek bank. (Kay Johnston-Landowner)

Regarding impact to forested areas, see respofragmentation are discussed in section 4.6.1 of Regarding the loss of forest canopy along the cnegotiate with EEC to plant shallow-rooted shrcreek. However, deep-rooted trees, which are the pipeline's coating and inhibit maintenance atherefore, would not be allowed within the permBlasting is a routine practice used during pipeliencountered at shallow depth (i.e., the diameteminimum depth of cover) and cannot be ripped trenching machine. Because rock is expected 

6-4 6.0 – Public Comments and Responses 
Table 6-1 (Continued) 

ID #(1)

Location / 

Transcript 

Page(s) 

Comment Summary – Commenter Response 

trenching machine. Because rock is expected proposed route, EEC prepared a Blasting Specthis plan and requested that EEC revise it to inblasting would be required prior to commencing 

WT-06 Washington/p. 13- 18

The commenter is concerned that two alternatives were not considered. The commenter also is concerned that the economic impacts on affected landowners are not being fully considered. (Ed Hallman-representing citizen landowners of the region)

Section 3.3.2.2 of the EIS discusses the commconcern, the East Route Alternative, which repbetween the Elba LNG Terminal and the Transalso discusses the commenter’s second alternaof Major Route Alternative A, which follows exiTransco pipeline system to the west of the propthe project objective of interconnecting with boRoute Alternative A requires both the western and eastern leg (Transco Zone 5 interconnect)Major Route Alternative A itself is not a viable, therefore we did not evaluate this alternative fuRegarding economic impacts and mitigation, se

TT-01 Thomson/p. 6-8 

The commenter is concerned that a 50-foot-wide ROW would destroy the integrity of a green space north of I-20 in McDuffie and Warren Counties, locally known as the "frontier", and open up the area to additional utility lines. The commenter questions whether there are any economic benefits to the local communities and landowners from the pipeline project. (Jim Allfriend-Landowner representing five other landowners)

The 50-foot-wide permanent pipeline ROW thrwould create an open corridor across those lanas pipelines, forest clearing is unavoidable for especially in a state like Georgia where about tHowever, the majority of the forested land in thowned by either private or commercial landownlarge parcels clear-cut as trees mature. Regarding the use of this line as a corridor for comment WT-03. Local communities along the pipeline route wolong-term economic benefits from construction facilities. During construction of the pipeline, aeach county, local communities would benefit flocal workers to construct the pipeline, the rentconstruction crews, and money spent by constservices. See section 4.9.2 (Economy and Em

6-1 6.0 – Public Comments and Responses 6-5 
Table 6-1 (Continued) 

ID #(1)

Location / 

Transcript 

Page(s) 

Comment Summary – Commenter Response 

revenues. During operation, EEC estimates th$206,876 in Warren County and $303,540 in Mtaxes for the life of the project. Section 4.9.3 hrevenues by county. 

TT-02 Thomson/p. 8-15 

The commenter is concerned about routing the project through the area when there is no economic benefit to the local population and to the size of the temporary construction easement proposed. (Deborah Bennett-Landowner representing 18 landowners)

Regarding route alternatives for the Elba Exprecomment WT-01. Regarding economic benefit to the local populaTT-01. In section 2.3.2.1 of the EIS, we identify temporequirements for the Elba Express Pipeline, No4.8.1.2 of the EIS, we discuss land use impacts Regarding private forest land use impacts and comments WT-03, WT-04, and WT-05. 

TT-03 Thomson/p. 15-20 

The commenter is concerned that his comments are not effective in changing the route of the project, that there are negative environmental impacts, and the effect of the permanent easement on his ability to grow trees. He is concerned and prefers the route be through existing ROWs. The commenter also states that he does not believe EEC would pay ad valorum taxes. The commenter asked whether the project is considered a public utility or a private industry. (Harold Eubank-Landowner representing family owning three tracts of affected land)

All comments received are reviewed by FERC review process and are part of the public recoralternatives that have been raised (by landowncompanies, and other stakeholders) regarding Express Pipeline, have been addressed during included in this final EIS. In addition see respoRegarding private forested land use impacts ancomments WT-03, WT-04, and WT-05. Regarding ad valorum taxes, see response to 4.9.3.EEC is a private company. If the Commission authorizing construction and operation of the Ebe a federally-regulated interstate transporter owould be regulated by the FERC. 

TT-04 Thomson/p. 20-21 

The commenter has a question as to the impact on the route if property has its mineral rights leased to others. (Murray Haddat-Landowner)

EEC would buy out the mineral rights lease.

6-6 6.0 – Public Comments and Responses 
Table 6-1 (Continued) 

ID #(1) 

Location / 

Transcript 

Page(s) 

Comment Summary – Commenter Response 

TT-05 

Thomson/p. 21-24 

The commenter is concerned about the size of the construction corridor being used for the project. The commenter is concerned that other potentially viable alternative routes were not evaluated for the project. (Cindy Russell-Bounds-Landowner)

The construction ROW, which is the minimum movement of construction equipment and persdiameter pipeline in this terrain, would be 110 fis necessary for safe maintenance of the pipelibe 50 feet wide. Additionally, there will be temsizes necessary when the ROW encounters a utility, or other obstacles. After construction, 6construction ROW and all temporary workspacuses. Landowners can negotiate with EEC for requirements on these lands. See responses tThe only trees that would be cut near streams ROW. Landowners can negotiate for tree saplareas not within the permanent ROW and for sreplanted in those areas within the permanent Regarding alternatives, see responses to comm

TT-06 Thomson/p. 24-27 

The commenter is concerned that her comments are not effective. She is seeking other avenues to express herself. (Ms. C. Shields)

Comment noted. 

ST-01 Sylvania/p. 6-9 

The commenter does not understand all the abbreviations used in Table 4.8.2. The commenter is concerned about the loss of mature trees, if and how EEC would remove the trees, and if only limbs would be cut from trees which could make trees unstable during storms. The commenter is concerned about additional work spaces. (Eugene Ansel-Landowner)

Land use abbreviations are defined at the bottoabbreviations have been corrected. Mature trees that are cut during construction wthe same age. EEC would remove all trees anthe ROW. Before construction, however, the laof aspects regarding the cutting and removal oreplantings on the temporary ROW. See respo04 and WT-05. Additional workspaces would be necessary whother obstacles in order to accommodate extra (e.g., a bell hole and boring machine at highwaDepending on site-specific conditions, the landworkspace location be adjusted to avoid trees 

6-7 6.0 – Public Comments and Responses 
Table 6-1 (Continued) 

ID #(1) 

Location / 

Transcript 

Page(s) 

Comment Summary – Commenter Response 

We note that on June 25, 2007, an EEC represon the property to identify possible adjustments minimize the project’s impacts on trees. EEC hfurther reduction of the construction workspace temporary workspace to limit tree impacts. 

PT-01 Pooler/p. 6-11 

The commenter is concerned that there were several subjects that were not completed in the DEIS and that she therefore could not comment on them. (Judy Jennings-Georgia Chapter of the Sierra Club) 

Comment noted. See response to this commeN-1. 

PT-02 Pooler/p. 11-13 

The commenter is concerned about the necessity of removing trees for the project that will affect the buffer between his property and the pipeline. (Charles E. Patterson-representing homeowners of Coldbrooke Plantation)

EEC has stated that it would consider making aconstruction procedures, and workspace requitrees where it is practicable and feasible. See Impacts and Mitigation. Regarding private foremitigation, see responses to comments WT-02 

PT-03 Pooler/p. 13-17 

The commenter is concerned about the possible impact of additional LNG storage capacity at the terminal on the potential worst-case fire emergency, the traffic analysis of the location of the LNG terminal within the Port of Savannah, and the LNG terminal site alternatives analysis. (Steve Willis-Blue Planet Projects Group)

The proposed LNG storage tanks would be site

applicable regulations in Section 49 of the CodPart 193. The impact of additional storage capcreated by the breach of an LNG ship has beeIn section 4.13 of the EIS, we discuss cumulatipotential future Savannah Harbor Expansion PAtlantic International Terminal (Jasper County EIS, we specifically discuss cumulative impacts In section 1.1 of the EIS, we discuss the purposection 3.2 of the EIS, we discuss LNG terminapotentially could fulfill the project’s purpose and section 3.2 of the EIS, we concluded that these significant environmental advantage over the pexpansion site. 

PT-04 Pooler/p. 17-20 The commenter requests that hard Hard copies of the DEIS were subsequently ma

6-8 6.0 – Public Comments and Responses 
Table 6-1 (Continued) 

ID #(1) 

Location / 

Transcript 

Page(s) 

Comment Summary – Commenter Response 

copies of the draft EIS be sent to persons requesting them and to Congressmen Jack Kingston and John Barrow. (Judy Jennings) 

of the FEIS will be sent to persons requesting t

Kingston and John Barrow. 

PT-05 Pooler/p. 20-24 

The commenter restated the recommendations for specific sections of the DEIS: appropriate measures to avoid vessel strikes with the Atlantic White Whale; avoid Eastern Indigo Snake burrows; survey for Flatland Salamander habitat; minimize impact on the bluebobbed pygmy sunfish; survey the Broad River for crayfish and lean crayfish; minimize impact on granite stone crop; granite whitlow grass, Indian olive Okamoki, Skull Cap, Parrot Pitcher plant, Pond Spice and Sweet Pitcher plants; assess need for additional surveys; survey for Camby’s Drop Wart Pond Berry or Pouse Sprit (sic) ; hydrostatic testing should be planned to minimize effects on the sandbar shiner and robust red horse in the Broad River; recommends that no construction or hydrostatic testing on Ugetie Creek from June 1-August 31; and that no construction begin until consultations are complete and written notification from OEP is received. (Gail Bowers-Sierra Club)

At the meeting, the commenter emphasized thathese measures instead of requiring the comparecommendations are to the Commission for inapplicant. Once these measures are adopted in its Order, the measures become requiremenwe have revised these sections (4.7.1 and 4.7.to comments received by individuals, agenciesEIS to further address these measures. 

(1) WT is Washington Transcript  TT is Thomson Transcript  ST is Sylvania Transcript  PT is Pooler Transcript

6-9 6.0 – Public Comments and Responses 
Table 6-2 

Written Public Comment Letters on Elba III Project Draft EIS

6-10 6.0 – Public Comments and Responses 

Federal Agencies 

F-1 United States Department of the Interior, Office of Environmental Policy and Compliance 

F-2 United States Department of Commerce, National Oceanic and Atmospheric 

Administration, National Marine Fisheries Service, Southeast Regional Office 

F-3 United States Environmental Protection Agency, Region 4 

State Agencies 

S-1 South Carolina Department of Archives & History 

Non-Government Organizations 

N-1 Georgia Chapter Sierra Club 

N-2 Savannah Riverkeeper 

Private Individuals 

P-1 Calvin C. Vaughn 

P-2 B. Hugh Hosch 

P-3 Gilbert Petition 

P-4 Angell Petition 

P-5 Decker, Hallman, Barber & Briggs (Landowner Intervenors) 

P-6 Decker, Hallman, Barber & Briggs (Landowner Intervenors), Supplement 

P-7 Decker, Hallman, Barber & Briggs (Landowner Intervenors), 2nd Supplement 

P-8 Laurie G. Dehil 

P-9 David and Karen Stubbs 

P-10 Thomas W. Wright 

Applicants 

A-1 Elba Express Company, L.L.C. 

A-2 Southern LNG Inc. 
Letter F-1 Responses to 

F1-1 DOI Grady Pond as Primary In section 4.3.3 we acknowledge that pipeline cothe containing layer of some ponds or wetland arequire EEC to maintain the hydrology of wetlan404 permit. EEC would also be required to mainlandowner agreements. Where waterbodies are ecosystem, EEC would implement measures to of the waterbody/wetland complex would be maicomments on the draft EIS, EEC indicates that sGDNR as a means to ensure proper restoration that it would obtain core samples near these wetconditions and evaluate the feasibility of this resrevised the text in section 4.3.3 to include this in

6-11 6.0 – Public Comments and Responses 
Letter F-1 Responses to 

6-12 6.0 – Public Comments and Responses 
Letter F-2 Responses to 

6-13 6.0 – Public Comments and Responses 
Letter F-2 Continued Responses to 

F2-1 NOAA EFH and Terminal ExpaComment noted. 

6-14 6.0 – Public Comments and Responses 
Letter F-2 Continued Responses to 

F2-2 NOAA Volume of ballComment noted.F2-3 NOAA Construction iComment noted. F2-4 NOAA EFH and pile dThank you for your comment. We have coordinadefine “soft start” and revised section 4.6.2.2 to ftechnique for pile driving. F2-5 NOAA EFH and ballasThe text in Section 4.6.2.3 has been revised to iinclude a condition that Southern LNG coordinatagencies to develop management practices to reand subsequent impacts on larval and juvenile fi

6-15 6.0 – Public Comments and Responses 
Letter F-2 Continued Responses to 

F2-6 NOAA EFH Comment noted. F2-7 NOAA EFH AssessmeThe text in section 4.6.2.3 and Appendix J has binformation. F2-8 NOAA EFH and hydroThe text in section 4.6.2.3 and Appendix J has binformation. F2-9 NOAA EFH and ballasSee response to comment F2-5. 

6-16 6.0 – Public Comments and Responses 
Letter F-2 Continued Responses to 

F2-10 NOAA NMFS CorrespWe responded to this request on June 4, 2007, irespond to NOAA’s essential fish habitat conserF2-11 NOAA ESA DeterminaIn section 4.7, we discuss federal- and state-listeother special status species (including their criticthe vicinity of the proposed Terminal Expansion Specifically, section 4.7.1 discusses potential imactivities associated with construction and opera4.7.1 also presents measures to avoid, minimize

sturgeon. No waterbodies containing shortnose EEC’s proposed pipeline route. Determinations involving listed species under thFisheries Service will be reported to the Protecte

F2-12 NOAA Construction ihabitats Comment noted. F2-13 NOAA Pipeline hydroWe disagree that diadromous fish species would water withdrawals. Test water would be withdraproposed HDD crossing location and from Ogeespecies would need to cross two dams downstrecrossing to be present where test water would bRiver, and the withdrawal location on Ogeechee location) is outside the known range for diadrom

6-17 6.0 – Public Comments and Responses 
Letter F-2 Continued Responses to 

F2-14 NOAA Affected WetlaComment noted. F2-15 NOAA Wetland ConstComment noted. F2-16 NOAA Impacts on dia

habitats

See response to comment F2-13.

6-18 6.0 – Public Comments and Responses 
Letter F-2 Continued Responses to 

F2-17 NOAA Atlantic right wThank you for your comment. Southern LNG haand has agreed to file with the Commission meawhale from ship strike once finalized. F2-18 NOAA Pile driving nomeasures Thank you for your comment. Southern LNG haCommission measures to reduce noise impact r

6-19 6.0 – Public Comments and Responses
Letter F-2 Continued Responses to 

6-20 6.0 – Public Comments and Responses 
Letter F-3 Letter F-3 Co

6-21 6.0 – Public Comments and Responses 
Letter F-3 Continued Responses to 

F3-1 USEPA Terminal expanIn section 4.3.3, we discuss surface water operaexpansion and state that surface water dischargcondensate from the vaporizers) would be piped existing firewater pond and would not be consideGDNR or the Georgia Environmental Protection discuss surface water and state that the existing would be modified to accommodate the additionTerminal expansion facilities. In addition, we updischarge process and wastewater treatment in F3-2 USEPA Air quality conThe length of the proposed pipeline in Anderson consist of less than one mile and construction embe minimal. Given this limited scope we do not would apply if the county is designated as non-acommences. We have revised the text in sectio

6-22 6.0 – Public Comments and Responses 
Letter F-3 Continued Responses to 

F3-3 USEPA Air emission imWe have revised the text in section 4.11.1.5 to inregarding a refined air dispersion analysis that pevaluation of the potential impacts on air quality Expansion conducted by Southern LNG. The aiused to predict the off-site concentrations in the and SO2 emissions associated with operation of appropriate federal air quality standards. The mcumulative impacts of NO2, CO, and SO2 for the below the corresponding NAAQS. Cumulative imexceed the NAAQS for the SO2 24-hour averagmeteorological data years analyzed, but the emicontributed substantially to the magnitude of the However, given the very conservative approach the Terminal Expansion alone would contribute tshown in the modeling analysis. Although the Tcontribute to the degradation of the regional air qsignificant impacts to the regional air quality. Finally, a comparative analysis of the yearly conestimated for the Terminal Expansion and Chathinventory was included in section 4.11.1.5. We emissions associated with the Terminal Expansiimpact on air quality. F3-4 USEPA Air impact ana

sources 

See response to comment F3-3. In section 4.1113 that provides a cumulative summary of seconthe future, fully-subscribed capacity of the TermiF3-5 USEPA Air emissions We have revised Section 5.2. See response to c

6-23 6.0 – Public Comments and Responses 
Letter F-3 Continued Responses to 

F3-6 USEPA Legal basis for 

agency permit 

Comment noted. We have added information to Commissions basis for this statement. F3-7 USEPA Noise sensitive Comment noted. F3-8 USEPA Northern Segm

and waterbody 

In section 3.3.2.2, we discuss alternatives to the Segment, Partial Collocation Route Alternatives Alternatives). Our evaluation of these alternativeprovided data, review of USGS topographic quaInventory maps, and aerial inspection. Based on quality of affected wetlands was generally similathe partial collocation routes, with the exception would require longer crossings of COE-managed tributaries. As presented in table 3.3-2 and our considering broader impacts to environmental anthese alternatives would not provide a significanthe proposed route. Because the results of our alternatives from further consideration, we believof potentially affected wetlands and waterbodies conclusions. Appendix I includes the quality of wetlands that wroute.

6-24 6.0 – Public Comments and Responses 
Letter F-3 Continued Responses to 

F3-9 USEPA Partial collocat

See response to comment F3-8. Based on a higdemonstrate a significant environmental advantatherefore eliminated the alternatives from further additional detailed analysis of potentially affectewarranted. F3-10 USEPA Major waterboWe have reviewed EEC’s HDD feasibility assessCreek, and Coldwater Creek dated May 18, 200these waterbodies, if geotechnially feasible, wousubstantively exceed waterbody widths and woucost by $11.5 million compared to conventional oproposes to construct these crossings using the documentation indicating concurrence from the Ccut method is acceptable for these crossings. Wto incorporate this information. Because these EEC’s Procedures, we believe impacts would be practicable. F3-11 USEPA Noise abatemeComment noted. F3-12 USEPA Wetland impac

See responses to comments F3-8 and F3-9. In as well as proposed impact avoidance, minimizameasures, for the proposed Elba Express Pipelithese measures in coordination with relevant fedaddition, EEC would comply with federal and staCOE under Section 404 of the Clean Water Act. 

F3-13 USEPA Single Transco In section 1.1 we discuss that part of the purposinterconnect with both Transco Zones 4 and 5. the proposed pipeline system and route that wouthe boundary between Transco Zones 4 and 5 bsingle Transco interconnect (on either side of the stated purpose and need. Therefore, we did not alternatives. We have clarified the discussion in section 3.3.2 are needed and why a single new interconnect iproject’s specific objectives. As presented in the Savannah River using an HDD, which is expecte

6-25 6.0 – Public Comments and Responses 
Letter F-3 Continued Responses to 

riparian corridor adjacent to the river itself. The development of this crossing location, and is satbe applied to the crossing. Further, the crossing adjacent to a major pipeline corridor. See also nRequirements for U.S. Army Corps of Engineers F3-14 USEPA Forested wetlaComment noted. In section 4.4.2, we discuss wemergent, and forested wetlands. EEC has statscrub-shrub and emergent wetlands by planting these wetlands to revegetate naturally. EEC hawith the conditions of applicable authorizations sSection 404 of the Clean Water Act. The COE crequirements for temporary impacts on forested reestablish the forest vegetation. Planting would of specific sizes planted at specified densities waddition, in accordance with its Procedures, EEC success for the first 3 years, and continue revegsuccessful. F3-15 USEPA Waters of the UIn section 4.4.2, we discuss on-site and off-site mThis section states that EEC would implement reshrub and emergent wetlands as described in its Delineation Report and Mitigation Plan and in acconditions. As indicated in section 4.4.2, EEC’s forested wetland impacts is currently under deveEEC will file the plan with the Commission once F3-16 USEPA Wetland MitigaWe have included a recommendation in the finacontinue to consult with the COE to evaluate the mitigation banks to maximize the “in kind” replacof this project.

6-26 6.0 – Public Comments and Responses
Letter F-3 Continued Responses to 

F3-17 USEPA Air emissions Station In EEC’s June 22, 2007, filing, EEC indicated thCompressor Station would not increase due to ththere would be no change in facility emissions aassociated with the project. F3-18 USEPA Reevaluate tabWe have revised tables 4.9-5 and 4.9-6. F3-19 USEPA Participation oThank you for your comment. In section 1.3, we participation process, including open houses and held in the vicinity of the proposed Terminal explocations along the proposed pipeline to solicit pWe will take the recommendations offered into cfuture scoping efforts. 

6-27 6.0 – Public Comments and Responses 
Letter F-3 Continued Responses to 

F3-20 USEPA Affect on MinoWe have revised section 4.9.7 with an additionaincome populations along the pipeline route throby census tract, which is a more limited geograpstatistics. We found that given the low populatiohowever, many of the census tracts statistics wedata. Therefore, we again conclude that all landpipeline would be subject to the same pipeline crace, ethnicity, or income status. We discuss popublic safety impacts in sections 4.8 and 4.12, reF3-21 USEPA Terminal ExpaWe have amended section 4.9.7, Environmental of minority and low income populations within Zocensus tract, which is a more limited geographic statistics. Given that the census tracks extend wwe could not determine with any accuracy the nuspecifically within the zones. However, because increase the number of offloading vessels and sand under the No-Action Alternative current openot be a significant change from an operational schange to the current effects on low-income and Regarding economic benefits to the local commuLocal Taxes and Government Revenue. Regarding temporary employment of the local pothat during the proposed 64-month construction expansion, Southern LNG would use local workenecessary skills. This section also describes the economic benefits to local workers and the commF3-22 USEPA Submerged coThe six submerged combustion vaporizers have 

6-28 6.0 – Public Comments and Responses 
Letter F-3 Continued Responses to 

F3-23 USEPA Compressor Srequirements The GEPD minor source construction/operating 1.5-1. F3-24 USEPA Remove emissThe referenced note has been removed from tabF3-25 USEPA Summary table Table 4.11.1-10 has been added to summarize tassociated with the future Elba LNG Terminal. 

6-29 6.0 – Public Comments and Responses 
Letter S-1 Responses to 

S1-1 South Carolina SHPO CulturThank you for your comment. 

6-30 6.0 – Public Comments and Responses 
Letter N-1 Responses to 

N1-1 Sierra Club Complete DEIS We disagree with the assertion that the draft EIS minimum requirements of” the National EnvironmThe draft EIS fully meets the requirements of NEno regulatory requirement that the discussions ointo discrete sections. In fact, the draft EIS followwere developed in conjunction with the CEQ (seEIS clearly meets the NEPA requirements of conenvironmental impacts. Discussions of potentiacommitment of resources are included in section that would be temporary, short-term, long-term, proposal are identified and evaluated in section Further, we have authority to issue conditional dCFR 380.7 and 18 CFR 380.7(e), which state thstaff conclusions section (see section 5.5 of the completed, or recommended studies that might data on the proposed action. The goal of the Coensure all potential adverse impacts to the humaminimized, or mitigated to a level that is not undNEPA process and through the public comment items identified in the draft EIS have been addrehas been revised to incorporate the resolution of conditional items (recommendations) identified irequire that Southern LNG and/or EEC file docuand approval prior to construction, initial site predesign, commissioning, commencement of servifollowing commencement of service, as approprspecific condition. In addition, if the Elba III ProjCommission, these conditional items (recommenCommission’s Order. Accordingly, Southern LNwith construction, commence facility operation, othe Commission is fully satisfied that all potentiaenvironment are avoided, minimized, or mitigatepracticable. Accordingly, we do not plan to reissue the draft Ecomment period. N1-2 Sierra Club Blasting plan The potential impacts of blasting are fully disclospresented therein, we believe that any impact on area would be minor and localized. While EEC Specification Plan, we have recommended that tadditional information to ensure that blasting locsupply wells/systems are protected during constrecommendation #15).

6-31 6.0 – Public Comments and Responses 
Letter N-1 Continued Responses to 

N1-3 Sierra Club Milepost locatiseeps As disclosed in section 4.3.1, 67 private water suwithin 150 feet of construction work areas assocPipeline. Appendix G of the draft EIS presents tmilepost. Because survey work is expected to ccommences, there is the potential that additionaidentified. Our recommendation (#16) for EEC tresources within 150 feet of its construction ROW be protected during construction.N1-4 Sierra Club Identify damagrepairs As previously disclosed, any impacts on groundwminor and localized. However, in the unlikely evdamaged by construction activities, we have recsuch damage and how damages were repaired the public file and available for inspection within facilities in service. N1-5 Sierra Club Turning basin We have reviewed EEC’s turning basin study anincorporate this additional information. The studGuard for its use. N1-6 Sierra Club Terminal expaNOAA Fisheries has recommended a time-of-yehydrostatic test water from the Savannah River athrough July 31) to minimize impacts to essentiawith this time of year restriction and have includeN1-7 Sierra Club HDD feasibility The potential impacts associated with the proposSavannah Rivers were fully disclosed in the drafrecommendation in section 5.5 of the final EIS thgeotechnical feasibility investigations for these wconstruction. We have revised the text in sectioinformation. 

6-32 6.0 – Public Comments and Responses 
Letter N-1 Continued Responses to 

N1-8 Sierra Club Preconstructio

endangered sp

We have retained this recommendation in sectioN1-9 Sierra Club 

poolsprite and 

We have retained this recommendation in sectio

N1-10 Sierra Club ESA consultat

We agree. We have retained this recommendat

N1-11 Sierra Club Agency consu

sunfish 

Thank you for your comment. Section 4.7.2 has information. We have retained this recommenda

N1-12 Sierra Club Approval of dr

hydrostatic tes

We have retained this recommendation in sectio

N1-13 Sierra Club Broad River bu

crayfish 

Thank you for your comment. Section 4.7.2 has information. We have retained this recommendaN1-14 Sierra Club Public availabi

information 

We disagree with the assertion that the informattechnical review of the front-end engineering des“should be made available to the public in the DThe draft EIS is completely adequate without incof fact, much of the information sought is designInfrastructure Information, and will not be availabour environmental review process or afterwards. the record are designated as Critical Energy Infrare restricted from public access. The Commissgaining access to CEII. Those procedures are a(http://www.ferc.gov). N1-15 Sierra Club HDD feasibility See response to comment N1-7. 

6-33 6.0 – Public Comments and Responses 
Responses to Letter N-1 

N1-16 Sierra Club Atlantic right whale impact avoidance plan Thank you for your comment. Southern LNG has been in consultation with NMFS and has agreed to file with the Commission measures to protect the Atlantic right whale from ship strikes once finalized. N1-17 Sierra Club Eastern indigo snake and gopher tortoise Thank you for your comment. Section 4.7.1 has been updated with new information. N1-18 Sierra Club Preconstruction surveys of flatwoods 

salamander 

We have reviewed EEC’s flatwoods salamander survey plan, filed with FWS and GDNR on May 1, 2007, and provided in its comment letter dated May 18, 2007. EEC states that biological surveys for protected species are required to be conducted within one year of construction. Therefore, EEC intends to survey areas identified as potential habitat for the flatwoods salamander in the spring of 2008. If flatwoods salamanders are found to inhabit these areas, measures would be developed to avoid or minimize impact to the flatwoods salamander. FWS and GDNR have verbally agreed with this approach. We have revised section 4.7.1 to incorporate this information. N1-19 Sierra Club GDNR consultation (sweet pitcher plant) As a result of our recommendation in the draft EIS, EEC developed mitigation in consultation with GDNR for this species that we found acceptable. We have revised section 4.7.2 to reflect this new information. N1-20 Sierra Club Vegetative maintenance plan We included recommendation #36 in the draft EIS to enable us to publish a completely accurate version of EEC’s Upland Erosion Control, Revegetation, and Maintenance Plan (Plan) in the final EIS. Between EEC’s initial Plan (presented as appendix E in the draft EIS) and the substance of our recommendation, there is simply no more information concerning EEC’s Plan for the public to review or comment on. We have revised the text in section 4.8.3 to incorporate EEC’s revised Plan and again presented the Plan as appendix E in the final EIS. N1-21 Sierra Club Site-specific residential crossing plans EEC submitted updated site-specific residential plans on May 18, 2007. We have reviewed these drawings and believe EEC’s implementation of the measures specified would lessen impact on the affected residences. However, for those residences within 25 feet of the construction ROW, we have recommended that EEC provide more detailed plans which outline the construction technique(s) to be used, minimize the time that the trench would 

Responses to 

remain open, and provide evidence of landowne

work areas would be within 10 feet of a residencdistances of the residences from the constructioassociated mitigation measures, has been upda

N1-22 Sierra Club Site-specific deWe included recommendation #38 in the draft Econsultations with land developers potentially affExpress Pipeline. While this information would bunlikely that it would reveal any previously undisimpact. And in fact, because neither the pipeline to commence construction in the immediate futureport regarding these consultations (see revisio

additional information regarding these consultatiplaced in the public record for these dockets and website at http://www.ferc.gov under the “e-LibraAdditionally, EEC met with the COE on May 7, 2acceptable mitigation plan for the crossings of Chas subsequently received concurrence from the revised the text in section 4.8.5, COE Mitigation information, and included a summary of the mitig

N1-23 Sierra Club HDD noise impThank you for your comment. EEC submitted a at the nearby NSAs for both the Broad River and the results of this analysis, the final EIS retains a impact at nearby NSAs. We have revised the tethis information.

6-34 6.0 – Public Comments and Responses 
Letter N-1 Continued Responses to 

N1-24 Sierra Club Terminal operaWe disagree. The draft EIS presents our assessnearby noise-sensitive areas for operation of botnew compressor station. In both cases, we concsignificant noise impacts resulting from operation have included recommendations in the final EIS EEC operate in compliance with our guidelines onoise controls if noise levels are found to exceed NSA. The one year period referenced in our conditions allows for mechanical modifications or other noisin order to reduce noise levels to the required 55 testing reveal an out-of-compliance condition. Padditional noise control applied is not warrantedN1-25 Sierra Club Native AmericaAs recommended in the draft EIS, EEC has furthCherokee Indians (ECBI). The ECBI have proviWe have revised the text in section 4.10.3 to incN1-26 Sierra Club Unanticipated As recommended in the draft EIS, EEC has revisand provided the revised plan to the FERC and tin section 4.10.2 to incorporate this information. N1-27 Sierra Club Historic StructAs recommended in the draft EIS, EEC has provPreservation Office with the requested additionaWe have revised the text in section 4.10.1 to incN1-28 Sierra Club Alternatives anComment noted. As stated in section 1.2.1, the compliance with the requirements of NEPA, the NEPA (40 CFR 1500-1508), and the FERC reguCFR 380). As required, section 3.2 objectively terminal facility alternatives that would potentially environmental impact than the proposed action, import terminal systems, LNG terminal (onshoreterminal alternatives (offshore unloading and offReasonable alternative gas pipeline delivery sysWe are not aware of what “new methodology avgas delivery systems” were not included in these 

6-35 6.0 – Public Comments and Responses 
Responses to 

N1-29 Sierra Club Economic AnaIn section 4.9, we provide a socioeconomic analand costs. Relationship to other ongoing constrconsidered in section 4.9 and section 4.13.9. Thbeyond the scope of this document. N1-30 Sierra Club Concerns with We disagree with the assertion that the draft EIS that the document is at a stage of completeness and reasoned public comment. 

6-36 6.0 – Public Comments and Responses 
Letter N-2 Responses to 

N2-1 Riverkeeper No action alterSee responses to comments N1-1 and N1-28. Sstates that the alternatives analysis shall: “includAdditionally, 40 CFR 1502.14(a) states that the a“Rigorously explore and objectively evaluate all alternatives which were eliminated from detailed for their having been eliminated”. In section 3.1 or Postponed-Action Alternative and the reasons from detailed study. Specifically, section 3.1 staconsequences associated with the proposed actbe avoided or delayed. Section 3.1 further stateAlternative would result in jeopardizing the objecimported LNG supplies for the southeastern and result in these supplies going to other destinatiowould be purely speculative to predict the resultithe end users if the natural gas supplied by the passociated direct or indirect environmental impaspeculative nature of these environmental conseis not further discussed in section 4.0. N2-2 Riverkeeper Conditional infWhile not all of the information about the proposEIS, we believe that adequate information was pcomments by respective agencies, landowners, the various impacts that would result from projecmade numerous changes to the draft EIS includclarifying discussions presented in the draft docuEIS, including responses to all comments receivCommission to be fully informed regarding the pramifications of any decision it makes regarding N2-3 Riverkeeper System alternaSection 3.2.1 presents an evaluation of existing alternatives, including expansion of the Trunkline terminal in Calcasieu Parish, Louisiana. As discalternative was eliminated from further considerathe Lake Charles terminal is limited by site const

6-37 6.0 – Public Comments and Responses
Responses to Letter N-2 

Any alternative which delivered the LNG to some point on the Gulf Coast (e.g., Louisiana) would still require: a. a transmission link (either an entirely new greenfield pipeline or a largediameter loop and compression) to deliver the gas between an import 

terminal and Transco’s pipeline system; and 

b. significant additional facilities (large-diameter loop and compression) to 

transport the gas to Transco Zones 4 and 5. 

As discussed in the material added to section 3.3.2.2, transporting the gas across additional Transco zones would result in a project too expensive to be economically attractive to either the shippers (Shell and BG) or customers in Transco Zones 4 and 5. The facilities needed to accept the LNG, regasify it, and then transport it between the Gulf Coast and Transco’s system would further exacerbate the cost consequences. From a purely environmental impact standpoint, while such an alternative would

avoid the 82 miles of greenfield pipeline (Northern Segment) associated with the proposed action, it most certainly wouldn’t avoid crossing numerous waterbodies and wetlands (including the Savannah River) between a Gulf Coast import point and Transco’s Zone 5 (South Carolina). Construction disturbance of a largediameter loop along Transco’s system between a point along the Gulf Coast and South Carolina would be several times that associated with the proposed action. As a result, we don’t consider delivery of the gas to Transco’s system in Louisiana (or Texas, Mississippi, or Alabama) a reasonable alternative to expansion of the existing import terminal and construction of the proposed pipeline facilities. 

N2-4 Riverkeeper Major route alternative This alternative was considered as the “east leg portion” of Major Route Alternative A (see figure 3.3-1 in the final EIS). However, in order to satisfy the project‘s objectives, two interconnections (one in each of Transco’s Zone 4 and Zone 5) are necessary. For the east leg of Alternative A to satisfy this requirement, an additional pipeline loop along Transco’s system between where the east leg interconnects with Transco (near Spartanburg, South Carolina) and the west side of the Savannah River (Hart County, Georgia) would be needed. See our discussion of Major Route Alternative B in section 3.3.2.2 and the revised discussion in section 1.1 which clarifies the Project Purpose and Need. 

Responses to 

N2-5 Riverkeeper Single Transco See revised discussion in section 1.1 which clarwith Transco’s system at the end of its Zone 4 awest and east sides of the Savannah River, respspecific objectives. 

6-38 6.0 – Public Comments and Responses 
Letter P-1 Responses to 

P1-1 Vaughn Landowner-pWe have evaluated a route variation based on thsuggested variation would provide no environmeroute. Specifically, the suggested variation woulandowners, approach more densely populated alandfill. We have revised the text in section 3.3

6-39 6.0 – Public Comments and Responses 
Letter P-2 Responses to 

P2-1 Hosch CompensatWe discuss the temporary (for construction) aneasement acquisition process and compensateconomic loss of value in section 4.8.2. Across this parcel (mileposts 87-89), EEC wouwide temporary ROW during construction but operation of the proposed pipeline. The area as near as practicable to its current condition fP2-2 Hosch EEC tax paymAccording to the State of Georgia Department based on the fair market value as assessed by Assessors. Landowners have the option of mfair market value of their land for their county's Board's assessment based on a factual event property value. See the Georgia Department Services Division website: http://www.dor.ga.g

links to "About Property Tax", "Appeals", and "EEC would pay taxes on the pipeline during boperiods. During construction, EEC would pay in the ground and during operation, EEC woullife of the project. Section 4.9.3 has been updby EEC to each county through which the pipe

P2-3 Hosch ROW maintIn section 2.7.2, appendix E, and appendix F, and ROW maintenance requirements and procinclude, but are not limited to, monitoring of re

6-40 6.0 – Public Comments and Responses 
Letter P-2 Continued Responses to 

revegetation efforts until revegetation is succedrainage or irrigation system problems, routine control unauthorized off-road vehicle use, and vehicle trails as necessary. We also require threcords, and file a quarterly activity report docidentified by the landowner, and corrective actfollowing construction. We believe that this apthese procedures would result in an appropriaP2-4 Hosch Request to EEC has stated that it would work with individunegotiations to minimize impact on trees. See and Mitigation - Upland Forest and Planted Pinsection 4.8.2, Landowner and Easement RequOnly the permanent ROW through upland foreavailable for tree growth for the life of the projedisturbed by construction, however, could be rnegotiate to have EEC plant saplings in those permanent ROW. 

6-41 6.0 – Public Comments and Responses 
Letter P-3 Responses to 

P3-1 Gilbert Petition Availability of The draft EIS contained 12 recommendatioprovide further information prior to the end information would be useful in the final EIS being able to publish EEC’s Plan accuratel#36), obtaining further detail on stream croour information on consultations with land dthe timely completion of consultations with and Wildlife Service, National Marine Fisheof Engineers). While we believe this informnot identify any previously undisclosed potedid it materially harm the integrity or the copresented in the draft EIS. Further, withholding the draft EIS from pubbasis of this information would not have beapplicant. For instance, there is very little nregarding consultations between EEC and neither party proposes to commence actuafuture. As a result, we have retained this reEIS. The information sought by 8 of the 12 incorporated, as appropriate, into the final subsequent to issuance of the final EIS will for these dockets, accessible via the FERC http://www.ferc.gov under the “e-Library” lin

6-42 6.0 – Public Comments and Responses
Letter P-4 Responses to 

P4-1 Angell Petition Availability of See response to comment P3-1. 

6-43 6.0 – Public Comments and Responses
Letter P-4 Continued Responses to 

6-44 6.0 – Public Comments and Responses
Letter P-5 Letter P-5 Co

6-45 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-1 Landowner Intervenors Northealternatives Section 3.3.2.2 discusses two alternatives to the existing ROWs entirely. As demonstrated in this greater environmental impact than the proposed P5-2 Landowner Intervenors Purpoalternatives We disagree. The EIS identifies the proposed athings) transportation of natural gas between Poof delivery with Transcontinental Gas Pipe Line County, Georgia and Anderson County, South CAlternatives to the proposed Northern Segment entirely are evaluated in section 3.3.2.2. 

6-46 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-3 Landowner Intervenors EmineComment noted. The proposed project is intenpublic in general (by delivering natural gas tfacilities in both Georgian and South Carolinacrossed (by providing ad valorem taxes for thinformation regarding estimated annual ad included in section 4.9.3. See also response to 

6-47 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-4 Landowner Intervenors ConfliWe have responded to all comments received o

the assistance of other agencies with jurisdiction Army Corps of Engineers, U.S. Coast Guard, NaGeorgia Department of Natural Resources) throucomments have been ignored.

P5-5 Landowner Intervenors ProjecWe have revised the discussion presented in seNeed) to clarify that two new interconnections wof its Zone 4 and (2) the beginning of its Zone 5 Savannah River, respectively) are one of the pro

therefore part of the proposed action, as was cledraft EIS. Connection to Transco’s system on both sides oof Transco Zone 4 and the beginning of Transco providing “competitively priced natural gas to the interstate natural gas markets”. See response to 

6-48 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-6 Landowner Intervenors ProjecThe existing Transco pipeline system does not pthe markets described in the goals of the project interconnection with a new larger pipeline from tTransco’s pipeline system has a west-to-east cavicinity of the interconnect of the western leg porGeorgia), this capacity is under contract to other therefore not available for transporting an incremJonesboro east to Anderson, South Carolina. See response to comments P5-5 and P5-8. The Commission is presented by EEC in its applicativerification of the system design requirements bstaff. There is no “presumption”, and a supplem

6-49 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-7 Landowner Intervenors ProjecSee response to comment P5-6. As stated in seorder to transport an incremental 1 Bcfd of naturStation to Transco’s system in both Georgia (Tra(Transco Zone 5), the Northern Segment alternarequire construction of more transmission and loadditional compression, than does the proposed includes discussion of a new Northern Segment comment P5-16.) P5-8 Landowner Intervenors ProjecOur discussion of Route Alternatives to the Norttwice references “incremental transportation chadiscussion. In short, natural gas transportation rone zone to another. By providing interconnecti5, customers in each zone receive natural gas apossible rather than paying an additional transpoadjacent zone and transported across zone bouOur analysis of the proposed crossing of the Savcommenter’s assertion of “inevitable and irreversto comment P5-6. 

6-50 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-9 Landowner Intervenors AlternWe disagree. Because EEC would transport nacommerce, it would be an “interstate” natural gathan deliver gas to Southern Natural Gas Compainterconnection near the end of Southern’s SoutCompressor Station in Jefferson County, GeorgiSee response to comment P5-3. As a point of fact, there are presently five naturaSavannah River in the immediate vicinity of EEC

6-51 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-10 Landowner Intervenors AlternAs discussed in section 3.3.2.2, Alternatives A asubstantially more environmental disturbance thproposed route between the Wrens Compressor interconnections with Transco’s Zones 4 and 5. environmental benefit when compared to the profrom further consideration. The respective acreaproposed and alternative routes are presented in This description of the draft EIS findings on the eaccurate. As a point of fact, the draft EIS states Alternative A between Wrens and Thomaston, Gof “little or no new pipeline” (emphasis added), n

additional volumes of gas. This statement was banalysis. A complete hydraulic simulation has nindicates that over 50 miles of 30- and 36-inch-dadditional compression at two existing compressneeded to provide firm transportation between Wrevised this discussion to more accurately reflecbe needed to move the Elba Expansion volumes Thomaston via Southern’s existing system for thAlternative A. The east leg portion of Alternative A was designZone 5 interconnection while following existing RTransco’s Zone 5. See response to comments P

6-52 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-11 Landowner Intervenors AlternWe disagree. As described in section 3.3.1, the 

not include an interconnection with Transco Zonaction (see draft EIS, page 1-1), and therefore wspecific objectives. See response to comment Phave sufficient capacity to achieve the project goAlternative A and new discussion of Route Alternthis topic). See response to comment P5-6. The Wrens-to-Thomaston portion of Alternative Asignificant looping. See response to comment P

6-53 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-12 Landowner Intervenors AlternWe disagree with commenter’s assertion. The edesigned to satisfy the project objective of an intwhile following existing ROWs between Wrens aAlternative A would not meet the project objectivP5-13 Landowner Intervenors ProjecWe disagree with commenter’s assertion. See rsentence cited by commenter was included in ouwith further insight into the rationale behind the pobjectives of providing new interconnections with Significant economic impacts associated with the considered when comparing alternatives. Any aproject shippers to pay transportation rates on mzones would not meet the project objective becaassociated with these activities would not “providgas transportation infrastructure that would attrasupplies”, as stated in draft EIS section 1.1 (Proj

6-54 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-14 Landowner Intervenors BalancAs cited by the commenter, the Commission’s P(not the Commission staff) will balance the econof proposals when it makes a Preliminary DetermIssues (PD). The Commission issued a PD for EPipeline on April 4, 2007, in which it found, subjeenvironmental review and the fulfillment of condbenefit of EEC’s proposed pipeline will outweigh is required and permitted by the public convenieP5-15 Landowner Intervenors Altern

We disagree. See response to comments P5-7 

6-55 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-16 Landowner Intervenors Route Please see figure 3.3-2, which clearly delineates Alternatives A and B. Also note the first sentencsection 3.3.2.2:  Alternative B uses the east leg portion 

east leg along Transco’s system to the Zone 4 (the Georgia side of the Savan

We have also added a discussion of a new Routto build upon the western leg of Alternative A, foproject objective for a Zone 5 interconnection. As explained in response to comment P5-11, the capable of satisfying the project objectives. See P5-17 Landowner Intervenors Route We have explained that the proposed action incl

of establishing new interconnections with Transccomments P5-2 and P5-5). See response to comments P5-8 and P5-13 for “incremental transportation charges” have shapeAlso, see response to comment P5-9, which addproject would not benefit the public in both GeorWe disagree that our conclusions, or the analysiare based on “arbitrary and capricious factors.” statement, either implied or explicit, which suppo“FERC has admitted that it cares not about the pstate of Georgia” or its ecosystems. 

6-56 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-18 Landowner Intervenors WesteSee response to comment P5-16. P5-19 Landowner Intervenors No actWe have carefully reviewed the discussion of the in draft EIS and disagree with commenter. If the action on the proposal to expand importation of facility and construct additional pipeline transmiseither be delayed or withdrawn. If the proposal wsignificant period of time), the LNG supplies propfacility would simply be marketed elsewhere. Wrequires the support of studies or reports. We disagree that the discussion implies “postporesult in natural gas suppliers cutting off supplies 3.2.1 of the draft EIS discusses two existing LNG presently undergoing expansion to receive additclarified the No Action Alternative discussion to b

like the Elba III Project, natural gas customers in “may have fewer and potentially more expensive in the near future” (draft EIS, page 3-2). We belsupported in the EIS. 

6-57 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-20 Landowner Intervenors Written responses to all comments received on tappendix to the final EIS. A supplemental EIS is comments P5-6, P5-11, and P5-16. Information in the “Background Data” referenced reprint in this document. Further, portions of comthe Commission’s filing requirements and had to the public file. 

6-58 6.0 – Public Comments and Responses 
Letter P-5 Continued Letter P-5 Co

6-59 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-21 Landowner Intervenors Wetlan

EnviroResou

As stated in sections 4.3.3, 4.4.2, 4.6.1, and 4.7the measures and procedures contained in EECPlan, agency-required permit conditions and mitwould avoid, minimize, or mitigate potential impawetlands, wildlife, and threatened and endanger

6-60 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-22 Landowner Intervenors SurfacIn section 4.3.3, we assess potential impacts to crossed by the proposed Elba Express Pipeline measures to minimize impacts on surface waters have also stated that EEC would need to obtain its COE Section 404 permit and Section 401 staP5-23 Landowner Intervenors PipelinWe note that commenter’s residence is about 97proposed construction work area and about 1,00centerline. Pipeline safety standards are discussed in detai4.12.10. Specifically, the available data show thabe a safe, reliable means of energy transportatio301,000 miles in service, the rate of public fatalittransmission and gathering line in service is 0.01 pipeline. Using this rate, EEC’s pipeline might replus years. This would represent only a slight inWe have revised the text in section 4.12.10.

6-61 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-24 Landowner Intervenors Wetlan

EnviroResou

See response to comment P5-21. 

6-62 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-25 Landowner Intervenors SurfacSee response to comment P5-22. P5-26 Landowner Intervenors Archa

resour

The archaeological survey was conducted using and approved by the GA SHPO and FERC. P5-27 Landowner Intervenors PipelinWe note that the pipeline route would be located residence. See response to comment P5-23. 

6-63 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

6-64 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-28 Landowner Intervenors Wetlan

EnviroResou

See response to comment P5-21. Based on a srepresentatives and this landowner on June 11, stream or wetland crossings on this property.

6-65 6.0 – Public Comments and Responses
Letter P-5 Continued Responses to 

P5-29 Landowner Intervenors CulturAll archaelolgical resources identified by the cultsurvey corridor were assessed for National Regiand the recommendations presented in section 4P5-30 Landowner Intervenors PipelinSee response to comment P5-23. We note that 220 feet from the edge of the proposed construcfrom the proposed pipeline centerline. 

6-66 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

6-67 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-31 Landowner Intervenors WildlifIn section 4.6.1, we discuss wildlife and wildlife hExpress Pipeline project area. We assess potenimpacts to wildlife and their habitat from construpipeline. We believe that the Elba Express Pipealter local wildlife populations, and that the impawildlife would be minimal. In section 4.7.2, we discuss the state-listed Atlanshiner. We reported that in the state of GeorgiaJenkins and Jefferson counties, and that sandbaWilkes, Elbert, and Hart counties. In section 4.7species and their habitat from the proposed Elba P5-32 Landowner Intervenors PipelinSee response to comment P5-23. We note that 100 feet from the edge of the proposed construcfrom the proposed pipeline centerline. Based on an on-site meeting between EEC reprJune 11, 2007, EEC identified that adjustments tproperty could be implemented to move the piperesidence.

6-68 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

6-69 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-33 Landowner Intervenors PropeIf the Elba III Project is approved by the Commison any remaining properties where access permunavailable thus far. Environmental surveys wolimited to, wetlands, waterbodies, wildlife, threatehabitat, and cultural resources. The results of ththe Commission and any appropriate Federal or a Notice to Proceed with construction. 

6-70 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-34 Landowner Intervenors Wetlan

EnviroResou

See response to comment P5-21. Based on an representatives and this landowner on June 12, adjustments to the proposed route on this propethe pond (near milepost 157.2) and planned recrP5-35 Landowner Intervenors CulturSee response to comment P5-29. P5-36 Landowner Intervenors WildlifSee response to comment P5-31. P5-37 Landowner Intervenors Land USee response to comment P5-34. As discuagreement discussions between the landowner uses for the land within the ROW and fair compof value to each affected parcel of land as discu

6-71 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-38 Landowner Intervenors CulturCultural resources surveys were not completed oconducted, any identified cultural resources, inclavoided or evaluated for National Register of HisP5-39 Landowner Intervenors PipelinSee response to comment P5-23. We note that than 1,000 feet from the proposed pipeline cente

6-72 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-40 Landowner Intervenors Wetlan

EnviroResou

See response to comment P5-21. 

6-73 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

P5-41 Landowner Intervenors CulturNone of the archaeological sites identified within County, where this property is located, were recoNational Register of Historic Places (i.e, significawas conducted using methods and standards reSHPO and FERC. P5-42 Landowner Intervenors WildlifSee response to comment P5-31. P5-43 Landowner Intervenors PipelinWe note that the pipeline route would be located residence. See response to comment P5-23. 

6-74 6.0 – Public Comments and Responses 
Letter P-5 Continued Responses to 

6-75 6.0 – Public Comments and Responses 
Letter P-6 Letter P-6 Con

6-76 6.0 – Public Comments and Responses 
Letter P-6 Continued Responses to L

6-77 6.0 – Public Comments and Responses 
Letter P-6 Continued Responses to L

P6-1 Landowner Intervenors Wetlands Sensitive See response to comment P5-21. P6-2 Landowner Intervenors WSee response to comment P5-31. 

6-78 6.0 – Public Comments and Responses 
Letter P-6 Continued Responses to L

P6-3 Landowner Intervenors PSee response to comment P5-23. We note that comfeet from the edge of the proposed construction worproposed pipeline centerline. Based on an on-site meeting between EEC and this June 12, 2007, EEC identified that adjustments to thcould be implemented to move the pipeline further apossibly reduce the amount of wetland area disturbe

6-79 6.0 – Public Comments and Responses 
Letter P-7 

The following Letter P-7 presents a summary of comments extracted from the Second Supplemental Comments to Draft Environmental Impact Statement (Exhibit A) filed by Decker, Hallman, Barber & Briggs, Attorneys for Intervenors, on May 30, 2007. The full text of the exhibit is available in the public file on the FERC Internet website (http://www.ferc.gov) using 

the eLibrary link. 

Letter P-7 Con

6-80 6.0 – Public Comments and Responses 
Letter P-7 Continued Responses to L

6-81 6.0 – Public Comments and Responses 
Letter P-7 Continued

The Elba Express Pipeline Project will result in the destruction of 440,000 mature trees. The Elba Express Pipeline Project will impact an area twice the size of Central Park. Assuming 300 trees per acre (12 x 12 foot spacing) for forest land and 12 trees per acre for agricultural land, this will result in the destruction of 440,000 mature trees. However, the total number of trees lost including mature and new growth could be in excess of 1,000,000, with a total leaf area loss of approximately 557 million square feet. This loss of tree cover is not acceptable and will exacerbate environmental conditions locally and throughout the region. These conditions will cause degraded water supplies through increased erosion, expansion of summer heating and worsening of regional air pollution. The Elba Express Pipeline Project bisects two increasingly rare contiguous forest ecosystems, causing irreparable habitat fragmentation and destroying the rural character of the area. 

Responses to L

P7-1 Landowner Intervenors Comment noted. Survey results do not indicate the nimpacted. Therefore, we can neither confirm nor densection 4.5.1, we do discuss potential impacts on foreacreage) from construction and operation of the proposection 4.2.2, we discuss EEC’s Upland Erosion ContMaintenance Plan (Plan) that would be implemented and potential air emissions from construction and opepresented in section 4.11.1.5. We disagree with the assertion of “irreparable habitat of the areas rural character. We address habitat fragFurther, sections 4.8.1 and 4.8.6 discuss potential imresources from construction and operation of the pipe

P7-1 

6-82 6.0 – Public Comments and Responses 
Letter P-7 Continued

The increased impermeability of the land caused by the construction of the Elba Express Pipeline Project will alter miles of natural streams and waterways. Construction of the Elba Express Pipeline will result in a wide swath of significant deforestation and permanent land impact, which will decrease the stormwater infiltration capacity on approximately 1,452 acres. The increased impermeability due to tree loss and soil compaction resulting from construction will harm miles of natural streams and waterways and produce the following continuing permanent significant economic and environmental impacts: • Increased water treatment costs from pollutant loads. • Increased water treatment costs from sedimentation. • Decreased land availability from increases in downstream floodplain 

extents. 

• Decreased water availability during critical summer months. • Decreased biodiversity in streams with greater than 10% impacted 

area within watershed. 

After construction of the pipeline, the highly compacted soils will prevent water from infiltrating to the groundwater table, prevent percolation, increase sheet flow, and diminish the storage of rainwater in the soils. This decline in storage causes a cascade of effects that will alter irreparably the natural ecosystems of the downstream water bodies. Temperature alterations from the lack of groundwater discharge will alter the biochemistry of the natural biotic environment and result in dramatic reductions in the number of different species (including fish) which such water bodies support. In addition, the biochemistry of a waterway is altered from increased run-off by reducing the ability to absorb excess nutrients (ammonia and phosphate), increased oil/grease and metals concentrations, and increased fecal coliform levels. 

The Greenfield Pipeline Project for the Elba Express Pipeline will impact surface water runoff (sheet flow) and groundwater resources by the physical disturbance of runoff patterns and the installation of the pipeline, particularly along slopes. The DEIS is inadequate in that it does not address the following issues: 

Responses to L

P7-2 Landowner Intervenors Comment noted. Section 4.3.3 presents our discussiwater (including streams and waterways) from constrproposed Elba Express Pipeline. The discussion of thpossibility of impervious soils and mitigation measurereduce those impacts. 

P7-2 

6-83 6.0 – Public Comments and Responses
Letter P-7 Continued

• Disturbance of sheet flow runoff from rain events due to highly 

compacted surface soils as a result of pipeline construction; 

• Groundwater or surface drainage flow interception by the pipeline 

trench; 

• Flooding at low topographical points caused by groundwater 

mounding as a result of preferential flow along the pipeline; and, 

• Disruption of surface water resources (streams and ponds). 

The construction of the Elba Express Pipeline will require the excavation of a trench from 5 to 7 feet deep, shallower if rock is encountered and deeper if not. The pipeline trench may be backfilled with excavated soil, or backfill brought in including sand, gravel or other materials. The physical presence of the pipeline surrounded by granular backfill materials such as sand and gravel will create a preferential pathway for interception of surface water runoff or shallow groundwater. This will be exacerbated on side slopes and at low points along the pipeline. The concern is that sheet flow will be diverted from entering the surface stream and ponds, flowing instead along the buried pipeline trench. The water will then gather at the low points along the pipeline route creating flooding conditions. The DEIS states on page 2-20 that sand bags or foam-type trench breakers would be placed across the trench to minimize subsurface water flow. However, the use of these measures will only protect the pipeline from washout and will not address the larger problem of permanent impacts to surface water flow and groundwater flow along the pipeline.The increased erosion caused by the construction of the Elba Express Pipeline Greenfield Pipeline Project will result in tons of additional sediment in area lakes and streams. 

Responses to L

Comment noted. In Section 4.3.1, we discuss potentresources from construction and operation of the propbags or foam-type trench breakers act to force any wtrench to the surface where it can be directed away frwell-vegetated areas. Comment noted. In section 4.2.2, we discuss EEC’s protect surface water quality during construction and This Plan, properly implemented, would effectively limthe prediction envisioned by the comment. 

6-84 6.0 – Public Comments and Responses 

P7-2 Cont 
Letter P-7 Continued

The Elba Express Greenfield Pipeline Project will encroach within 50 feet of 8 residences as noted in the DEIS. Mitigation measures proposed in the DEIS are inadequate to address the construction and operation of the Elba Express Pipeline within 50 feet of 8 residences as noted in Table ES1 of the DEIS. The factors of particular concern include the following: • Blasting is planned for construction in rock zones; • Noise, dust, impacted runoff and other nuisance issues during 

construction; 

• Impacts to property views due to loss of trees; • Impacts to property views due to presence of ROW; 

• Permanent loss of property value; • Soil compaction during construction limits restoration of vegetation; 

and, 

• Nuisance vegetation becomes established along restored areas. 

Responses to L

P7-3 Landowner Intervenors Comment noted. EEC has prepared a Blasting Specrecommended be modified prior to any blasting to incassessment of structures, wells, and utilities within 15ROW. If blasting is conducted in the immediate vicinowners identify any damage or change to the propertvelocities have been recorded during the blasting opefollow-up surveys of the potentially impacted propertyrepairs) would depend on the nature of the damage idNuisance impacts (dust, noise, etc.) would be limited would be considered short-term. Mitigation strategies already proposed and others will likely be a topic of dnegotiations. We discuss visual impact in section 4.8.6, and proper(see also response to comment P2-2). EEC would mareas following construction and continue revegetatiosuccessful. Revegetation is considered successful wnuisance vegetation on the ROW is similar to that fouImplementation of EEC’s Plan makes the establishmeSoil compaction has been addressed in response to c

P7-3 

6-85 6.0 – Public Comments and Responses 
Letter P-7 Continued

The Pipeline Project for the Elba Express Pipeline will eliminate or bisect approximately 236 acres of wetlands during construction and 119 acres permanently during operation. The DEIS recognizes that the wetlands will be impacted temporarily during construction, but states that the wetlands will not be permanently affected because they will self-restore. Elba does not plan to restore destroyed wetlands other than to restore the pre-construction topographical and hydrological patterns and allow the wetlands to re-vegetate from existing seeds and roots. Contrary to Elba’s assertions, there is no evidence that the wetlands destroyed by the Pipeline Project will actually self-restore as proposed in the DEIS. Given the importance of wetlands in improving water quality and providing unique wildlife habitat, this self restore plan is inadequate for the following reasons: • Disturbance of unique hydric soils will not allow vegetation to grow; • Rain events will erode top soils and seeds impeding restoration; and, 

• Significant erosion and degradation of hydric soils will occur during 

the 3 year timeframe allotted for self restoration of wetlands. 

Responses to L

P7-4 Landowner Intervenors Comment noted. In Section 4.4.1 we discuss potentiaconstruction and operation of the proposed Elba ExprIn Section 4.4.2 we discuss measures to mitigate poteconstruction of the proposed Elba Express Pipeline. measures to mitigate potential wetland impacts from cExpress Pipeline. The COE has indicated that plantinemergent wetlands because topsoil restoration would However, where forested wetlands would be convertethe necessary emergent seed bank may not be preseAdditionally, the COE indicated that it may require plawould be allowed to return to preconstruction conditiorequire post-construction monitoring to ensure the suhave stated that EEC would comply with federal and regarding wetland restoration and mitigation. EEC woconditions in the COE and state permits regarding corevegetation, and maintenance of the proposed pipel

P7-4 

6-86 6.0 – Public Comments and Responses 
Letter P-7 Continued

The risk of fire and explosion due to the construction of the Elba Express through the Pipeline Project is significant as a result of the following: • Lack of maintenance; • Unseen pipe damage during construction; 

• Incorrect location mapping in the as-built drawings; • The inability of local volunteer fire departments to respond to fire or 

explosion of the 36 inch high pressure LNG pipeline; and, 

• Creation of additional areas which will be subject to explosion from 

terrorist attack. 

Natural gas pipelines are far from foolproof, and represent a significant risk of fire and explosion. Accidents involving pipelines occur and result in huge fires and explosions, often with deadly results. Most of the areas crossed by Pipeline Project are protected only by volunteer fire departments, which are under staffed and under equipped to address a pipeline fire that would result from a 36 inch high pressure LNG pipeline fire. 

Responses to L

P7-5 Landowner Intervenors Comment noted. In sections 4.12.8, 4.12.9, and 4.12safety standards, pipeline accident data, and impact oavailable data show that natural gas pipelines continuenergy transportation. Based on approximately 301,0public fatalities for the nationwide mix of transmission 0.01 per year per 1,000 miles of pipeline. Using this a public fatality every 532 plus years. This would repto the nearby public. We have revised the text in sec

P7-5 

6-87 6.0 – Public Comments and Responses 
Letter P-7 Continued

The Elba Express Pipeline Greenfield Condemnation Corridor will impact 295 cultural resource sites. An example of one of these 295 sites that will be an impacted cultural resource area is property owned by Mr. Almond Standard. Mr. Standard’s property has produced multiple artifacts, including Indian pottery, shards, arrowheads, tools and games. The Pipeline Project will cross directly through the hay field and surrounding wooded areas which contain these artifacts. 

Responses to L

P7-6 Landowner Intervenors CThough 295 cultural resources were identified, 281 wNational Register of Historic Places. Impacts to non-consideration under the National Historic Preservation would be avoided or further evaluated, and for any reNational Register of Historic Places that could not be mitigated through data recovery. None of the archaeological sites identified within the swhere Mr. Standard’s property is located, were recomHistoric Places-eligible. Impacts to non-eligible sites runder the NHPA. 

P7-6 

6-88 6.0 – Public Comments and Responses 
Letter P-7 Continued

There is no justification in the Project Purpose and Need for FERC’s and Elba’s assumption that the proposed pipeline must interconnect with the existing Transco Pipeline on both sides of the Savannah River to "provide an incremental source of, and the transportation infrastructure required to deliver, firm, long-term, and competitively priced natural gas to the Georgia and South Carolina interstate natural gas markets, and other markets in the southeastern and eastern United States." Therefore this assumption is unfounded and is an arbitrary and capricious basis for pipeline route selection that will admittedly destroy a large area of pristine historically significant Greenfield property. The alternative routes mentioned have been grossly manipulated and misrepresented to justify FERC's flawed presumptions that the Pipeline Project should be chosen. The DEIS identifies two alternate routes for the Northern Segment as discussed in Section 3.3.2.2. that use existing ROW for the Northern Segment in order to reach the Transco pipeline. 

Responses to L

P7-7 Landowner Intervenors Project puWe have revised the discussion presented in section clarify that two new interconnections with Transco’s sand (2) the beginning of its Zone 5 (the west and easrespectively) are one of the projects specific objectiveproposed action, as was clearly indicated on page 1-1 Connection to Transco’s system on both sides of the Transco Zone 4 and the beginning of Transco Zone 5“competitively priced natural gas to the Georgia and Sgas markets”. P7-8 Landowner Intervenors AlSee response to comment P7-7. As discussed in secAlternatives A and B were found to require substantiathan that associated with the proposed route between and the proposed interconnections with Transco’s Zoprovided no environmental benefit when compared to eliminated from further consideration. The respective proposed and alternative routes are presented in tabl

P7-7 P7-8 

6-89 6.0 – Public Comments and Responses 
Letter P-7 Continued

The Pipeline Project will bisect two increasingly rare contiguous forest ecosystems, causing irreparable habitat fragmentation and destroying the rural character of the area. The impacted contiguous forest land in this contiguous tract will total approximately 8,700 acres. From an environmental resource standpoint, bisection of these ecosystems will cause irreparable habitat fragmentation, having a disproportional (relative to the actual land directly altered) impact on bird, animal, and fish habitats that are currently rapidly diminishing across north Georgia To assess the disruption to the ecosystem, the 2002 and 2003 aerial photographs were utilized to identify contiguous forest ecosystems located along the Elba Express Pipeline. A contiguous forest ecosystem provides greater benefits to the human population within and around the system than would be provided by equivalent areas broken into small, disconnected segments. These benefits derive from the greatly improved buffering of noise, air pollution, stormwater flooding and water quality. These ecosystems, in addition to the direct benefits of buffering environmental impacts, provide a significant aesthetic value. The residents of Wilkes County, for example, reside in the County due to its rural characteristics and forested lands. Large tracts of contiguous forest land provide immeasurable value to the residents, by preserving a rural character and various habitats of the area. 

Responses to L

P7-9 Landowner Intervenors HaComment noted. See response to comment P7-1. 

P7-9 

6-90 6.0 – Public Comments and Responses 
Letter P-7 Continued

The Elba Express Pipeline Pipeline Project will disturb approximately 843 acres of soil with significant inherent limitations for restoration according to the DEIS. During construction, up to 1,067 acres of land will be irreparably disturbed and damaged. Applying Natural Resource Conservation Service (NRCS) formulas, approximately 587,000 tons of soil will be lost within one year due to erosion from soils with significant inherent limitations for restoration. Erosion controls may reduce the amount of sediment deposited into area streams by 65% to approximately 200,000 tons per year. For comparison purposes, 10,000 dump trucks would be required to move 200,000 tons of sediment. Given the close proximity of the Pipeline Project to the sensitive water resources of the Savannah River basin, this is an unacceptable volume of additional sediment deposition.The DEIS states that 843 acres of soils with low revegetation potential or significant inherent limitations for restoration will be disturbed during construction. Since the late 1940’s, the NRCS has used the Musgrave Equation to compute the amount of erosion occurring in a watershed. Additional research on erosion has resulted in the development of the Universal SoilLoss Equation (USLE) by the Agricultural Research Service (ARS) in cooperation with the NRCS and certain state experiment stations. Based on the information compiled from the referenced material, the approximate soil loss per year of construction was calculated to be 587,000 tons. 

Responses to L

P7-10 Landowner Intervenors SoWe disagree with the characterization that any land dproposed project would be “irreparably” damaged. W4.2.3, Revegetation. As a point of clarification, of the with low revegetation potential affected by the Elba Eacres are located between mileposts 114.8 and 187.9 distribution of these soils listed in table 4.2.1-1. We bfertilizer/lime applications described in EEC’s Plan in planting for Georgia and South Carolina would result preconstruction conditions, and minimize potential ero

potential affected by pipeline construction. 

P7-10 

6-91 6.0 – Public Comments and Responses
Letter P-7 Continued

Elbert County, Georgia contains one of the richest natural deposits of granite in the world. Elberton’s more than 45 quarries produce more granite monuments than any other area of Georgia. It is unquestioned that extensive blasting will be required to construct the pipeline in Elbert County. Blasting during construction will damage buildings close to the ROW and will impact the natural habitats of livestock and wildlife. 

Responses to L

P7-11 Landowner Intervenors It is unlikely that blasting will damage buildings in proavoid or mitigate any impacts from blasting, EEC has Plan. This plan includes the measurement of peak pafrom the blasting), which would be used by the licensvibrations are limited to levels that would not damage slopes. Pre- and post-blast surveys of structures, wethe ROW provide property owners and ECC the neceand repair damage to any impacted property. Wildlife both blasting and non-blasting areas. 

P7-11 

6-92 6.0 – Public Comments and Responses
Letter P-7 Continued

Section 4.12.7 of the DEIS states that existing and proposed security measures discussed in this section make significant impacts to human life and property from a terrorist attack unlikely. There is no cited reference, report or data to support this unfounded conclusion. 

Responses to L

P7-12 Landowner Intervenors The statement cited refers to the Elba Island Import TThe security measures to be implemented are generaDetails regarding these measures are not made availsensitive nature. The Coast Guard, with input from various port stakehPilots Association, the Savannah Maritime Associatioemergency service agencies, waterfront facilities, and Maritime Security Committee, completed a review of Suitability Assessment, submitted in January 2006, in promulgated in Coast Guard Navigation and Vessel Inreview focused on the security risks posed by LNG mthe port community to implement the risk managemenresponsibly manage the risks of LNG marine traffic in of this review, the Coast Guard has made a preliminaRiver, based on existing measures and additional conLNG carriers and the increase in LNG marine traffic aexpansion. The Coast Guard letter also stated that, bsuitability, the Port of Savannah’s experience with LNrelationship between government agencies and port ssufficient capability within the port community to resposecurity risks introduced by this expansion project. Section 4.12.4.5 includes information resulting from thassessment. In addition, the security measures outlinincorporated into the detailed Savannah Area LNG VePlan, which would be become the basis for appropriaMaritime Security threat level. This plan would clearly specific procedures for an LNG carrier transiting the SLNG terminal, as well as for all agencies involved in iduring the operation. In addition, Southern LNG provides security for the Tefederal, state, and local agencies, according to the Faprepared under 33 CFR 105. This plan and any modthe proposed expansion would need to be approved bPort. 

P7-12 

6-93 6.0 – Public Comments and Responses