3-1 3.0 – Alternatives

3.0 ALTERNATIVES 

We have evaluated a number of alternatives to the Elba III Project to determine whether any 

would be reasonable and environmentally preferable to the proposed action. Alternatives 

described in the following sections include the no-action or postponed-action alternatives, 

Terminal site and system alternatives, pipeline system and route alternatives, and compressor 

station site alternatives. 

Southern LNG and EEC state that the Project would help to meet the growing demand for 

importation and delivery of LNG to domestic markets, specifically Georgia and South Carolina 

interstate natural gas markets, and other markets in the southeastern and eastern U.S. Southern 

LNG and EEC also state that the proposed project has the following specific objectives: 

• to provide direct access to a very reliable source of LNG supply for the southeastern and 

eastern U.S. markets to supplement traditional domestic supplies; 

• to provide a competitively-priced natural gas transportation infrastructure which would 

attract incremental global LNG supplies into the southeastern and eastern U.S. natural gas 

market to help meet the growing demand for clean energy; 

• to provide new pipeline transportation services under long-term firm agreements with BG 

LNG Services LLC and Shell NA LNG LLC; and 

• to provide firm interstate natural gas pipeline capacity that can move gas from the Elba 

Island import terminal to major pipeline interconnects with (1) the existing Southern 

pipeline system in its Zone 3 near the end of its South Main Line, (2) the existing Transco 

pipeline system at the end of its Zone 4, and (3) the existing Transco pipeline system at 

the beginning of its Zone 5. 

Our evaluation of reasonable alternatives is based on whether these alternatives (1) meet the 

objectives identified by Southern LNG and EEC; (2) would be environmentally preferable; and 

(3) are technically and economically feasible. 

Overall, the FERC has three courses of action in processing an application. It may: 

• deny the proposal; 

• postpone action pending further study; or 

• authorize the proposal, either with or without conditions. 

The Coast Guard alternatives include: 

• issue a negative LOR (an LOR finding the waterway unsuitable for LNG marine traffic); 

• postpone issuance of an LOR; or 

• issue an LOR with conditions. 

3.1 NO ACTION OR POSTPONED ACTION 

If the Commission denies the proposal (the no-action alternative), the short- and long-term 

environmental impacts identified in section 4.0 of this EIS would not occur. If the Commission 
3-2 3.0 – Alternatives

postpones action on the application, the environmental impacts identified in section 4.0 of this 

draft EIS would be delayed, or if the Applicants decided not to pursue the Project, would not 

occur. 

If the Commission selects the No Action Alternative, the objectives of the proposed project 

would not be met, and Southern LNG and EEC would not be able to provide the proposed 

increased capacity of LNG import, storage, vaporization, and transportation services to its 

shippers. If action on the project is postponed, it could have the same result as the No Action 

Alternative, i.e., the objective of providing direct access to imported LNG supplies for the 

southeastern and eastern U.S. market would be jeopardized and could result in these supplies 

going to other destinations around the world. 

Public comments were received regarding utilization of existing facilities and/or non-natural gas 

technologies to meet this Project’s purpose and need in lieu of the proposed action, and all of 

these were evaluated. The demand for energy in the U.S. is predicted to increase and domestic 

natural gas supplies are declining. As a result, natural gas customers may have fewer and 

potentially more expensive options for obtaining natural gas supplies in the near future. It is 

possible that existing natural gas infrastructure supplying natural gas to the market area could be 

developed in other ways unforeseen at this point, including the further development of natural 

gas sources in North America and construction of associated pipeline projects. Alternatively, 

potential customers of natural gas could select other available energy alternatives to compensate 

for the reduced availability of natural gas. However, increased use of alternative fossil fuels, 

such as oil or coal, generally would result in higher emission rates of nitrogen oxide (NOx) and 

sulfur dioxide (SO2) than would be the case with natural gas. 

To comply with current air emission regulations, emission control technologies could be required 

that could limit the economic viability of projects using alternative fuels. Another option – the 

development of renewable sources of energy, such as wind and solar – would result in lower 

emission rates for NOx and SO2 than would be the case with alternative hydrocarbon-based fuels. 

However, while development of renewable energy sources as well as energy conservation can 

play a critical role in the future of the U.S. energy sector, growth projections continue to indicate 

that the demand for energy, and specifically natural gas, will far exceed energy provided through 

renewable sources or savings resulting from energy conservation. Ultimately, it is purely 

speculative to predict the resulting actions that would be taken by the end users if the natural gas 

supplied by the Project were not available or the associated direct and indirect environmental 

impacts of these actions. 

Coast Guard Alternatives 

For the Elba III Project, the range of reasonable alternatives for the Coast Guard includes the 

issuing a negative LOR, postponing issuance of an LOR, and issuing an LOR with certain 

conditions. 

The Coast Guard’s preferred alternative for the Project is the issuance of an LOR finding the 

Savannah River/territorial seas waterway is suitable for the increase in LNG marine traffic 

associated with the proposed expansion of the Elba Island import terminal facility, with 
3-3 3.0 – Alternatives

conditions. Conditions on the existing LOR (for current LNG vessel transit) would remain in 

effect/be reiterated in the LOR for the expansion and the Coast Guard is proposing to modify or 

add to those conditions. The conditions on the current LOR are as follows: 

• LNG operations in the port must follow the Coast Guard approved LNG Vessel Transit 

and Emergency Plan; 

• all LNG operations must be in accordance with the Regulated Navigation Area outlined 

in 33 CFR 165.756; and 

• the turning basing adjacent to the facility berth must be dredged. 

In the Coast Guard’s WSR, issued January 8, 2007, the COTP Savannah preliminarily 

determined (contingent on completed NEPA analyses) that the waterway is suitable for the 

increase in LNG marine traffic associated with the proposed project. Additional conditions 

proposed for the Elba III LOR include, but are not limited to: 

• the applicant shall conduct an annual review of its WSA to evaluate if any conditions in 

the waterway have changed that would require issuance of a new LOR and submit the 

annual review to the COTP Savannah; and 

• appropriate resources must be available to implement the required security measures. 

The Coast Guard alternative of issuing a negative LOR by finding the waterway unsuitable for 

the proposed increase in LNG marine traffic would be similar to the No Action Alternative 

described above and the discussion regarding the potential for customers selecting other energy 

sources. A negative LOR would prevent the increase in the number and size of LNG vessels 

from transiting the waterway and the applicants would not be able to meet the project objective 

of providing increased LNG import and storage services. This alternative would avoid the 

impacts identified in section 4.0 of this EIS for the proposed action but the impacts associated 

with the current LNG marine traffic would continue. 

If the Coast Guard postpones issuance of an LOR pending further analysis or study, the effect is 

expected to be similar to FERC postponing its action. That is, although it is speculative to 

predict the resulting effects, postponing issuance of an LOR for the expansion could have the 

same result as the No Action Alternative because it could result in the LNG supplies going to 

other destinations around the world and customers would be required to seek other energy 

sources. 

Coast Guard Alternatives Eliminated from Analysis 

In some cases, a reasonable alternative for the Coast Guard is the issuance of an LOR without 

conditions. On this project, this alternative is deemed not reasonable and was eliminated from 

analysis because it would preclude the Coast Guard from exercising its responsibilities to 

adequately ensure the safety and security of the Savannah port area and navigable waterways. 

See section 1.2.2 for a description of the Coast Guard’s regulatory authority. 

A possible additional alternative for the Coast Guard would be to find the waterway suitable for 

LNG marine traffic only if modifications were made to the applicant’s proposal, such as 
3-4 3.0 – Alternatives

evaluating different routes for the vessels to take to the facility or the imposition of seasonal 

restrictions on vessel traffic. Different waterway routes were eliminated as alternatives from 

further analysis because the Elba terminal is an existing LNG import facility and all LNG marine 

traffic must use the existing marine transit route to reach the site of the Terminal Expansion. 

(See section 3.2 for a discussion of LNG Terminal Facility Alternatives) The proposed action is 

to increase the frequency and size of LNG vessels. 

3.2 LNG TERMINAL FACILITY ALTERNATIVES 

3.2.1 Existing LNG Import Terminal Systems 

Our analysis of LNG facility alternatives includes the use of existing LNG import and storage 

facilities at other existing ports in the southeastern and eastern U.S. Although system 

alternatives could make it unnecessary to construct all or part of the Elba III Project, including 

the Terminal Expansion, significant modifications or additions to existing facilities may be 

required that would result in environmental impacts that are greater, equal to, or less than that of 

the proposed action. 

Public concern was expressed as to the location of the proposed Terminal expansion facilities 

and the relative location to the market that the Project would serve. The identified markets 

include three existing gas-fired electric power plants (Effingham, McIntosh, and Rainey) in 

Georgia, and the Georgia and South Carolina interstate natural gas markets. Currently, two LNG 

import terminals exist that provide unloading, storage, and delivery within the southeastern U.S. 

in addition to Elba Island. These facilities are Dominion’s terminal at Cove Point, Maryland, 

and Trunkline LNG’s terminal on the Louisiana gulf coast (see figure 3.2-1). As discussed 

below, both Dominion and Trunkline LNG have recently expanded the terminals to help meet 

the nation’s need for additional natural gas. 

Dominion Cove Point 

As a result of previous expansions, Cove Point presently has five LNG storage tanks totaling 

2.35 million barrels (4 tanks @ 375,000 bbl and 1 tank @ 850,000 bbl) and a marine pier which 

can accommodate two LNG vessels unloading simultaneously. Dominion is presently 

constructing facilities to increase the Cove Point import terminal’s daily output capacity by 0.8 

Bcfd, from 1.0 to 1.8 Bcfd. Construction of two new 1-million-barrel LNG storage tanks will 

increase storage capacity by approximately 6.8 Bcf. Dominion will also construct downstream 

pipeline looping to facilitate transmission of additional natural gas supplies from the expanded 

terminal. 

The Dominion Cove Point Project is not considered a viable alternative to the proposed 

expansion at Elba Island because: 

• its storage and send-out capacity (including the expansion currently under construction) 

is allocated to existing customers; and 

• when service associated with its current expansion commences, there will be no further 

room for additional tanks, infrastructure, or berthing facilities. 
Non-Internet Public 

DRAFT 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 

Page 3-5 

Figure 3.2-1 

Existing LNG System Terminal Alternatives 

Public access for the above information is available only 

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

public.referenceroom@ferc.gov. 
3-6 3.0 – Alternatives

Trunkline LNG Lake Charles

The Trunkline LNG import terminal is located on the Gulf Coast, on the northeast side of 

Calcasieu Lake in Calcasieu Parish, Louisiana. The facility is owned by Southern Union and 

operated by Trunkline LNG Company LLC. The Commission has approved several expansions 

of this import terminal. The terminal currently has two marine LNG vessel berths and total LNG 

storage capacity of 2.68 million barrels. 

With completion of its current expansion, the Trunkline LNG import terminal has almost tripled 

its send-out capacity and significantly increased its storage capability. The recent expansions 

have increased the sustained daily send-out capacity of the terminal from 630 MMcfd to 1.2 Bcfd 

and increased storage capacity to 9.3 Bcf. All the capacity at the Trunkline LNG import terminal 

is committed to firm contracts. 

After the expansion work is completed, the Lake Charles Terminal would not have adequate 

space within its 125-acre fenced site to accommodate the storage tanks and send-out facilities 

associated with the delivery volumes for the proposed Terminal Expansion. Because the terminal 

is 100 percent committed, further expansion outside the existing fence line would be needed. 

Expansion potential at this site is limited by existing or planned industrial facilities, so the Lake 

Charles Terminal cannot be considered a practical alternative. 

Existing Facility Alternative Conclusions 

Southern LNG is proposing a facility that would have the ability to unload, store, and deliver 

imported LNG directly to the southeastern and eastern U.S. markets. No other existing LNG 

facility is in reasonable proximity to the southeast and eastern coasts of the U.S. to perform this 

service. Because the capacity of each of the existing facilities discussed above is fully 

committed, use of one of the existing LNG terminal facilities to meet the proposed Project 

objectives would not be possible without significant expansion and/or modification to their 

unloading, storage, and delivery systems. Because of their physical site constraints, significant 

expansion or modifications to one or more of these existing LNG import facilities is not a 

reasonable alternative to the proposed Terminal Expansion Project, and we have eliminated them 

from further consideration. 

3.2.2 LNG Terminal Site Alternatives 

We examined three options for siting the proposed LNG import terminal at alternative locations. 

Our process considered environmental, engineering, economic, safety and regulatory factors, 

keeping in mind the stated objectives of the Project. Within the southeastern region of the U.S., 

alternative sites could be existing ship unloading sites suitable for conversion to an LNG 

terminal, new land sites, or new offshore sites. 

Offsite Storage Tank Locations

Public comments were received requesting the evaluation of locating the proposed storage tanks 

inland at an existing industrial site on Interstate 16 just northwest of Interstate 95 instead of at 
3-7 3.0 – Alternatives

the existing terminal. The Terminal is located on the south side of the shipping channel that 

leads to the Port of Savannah, and the alternative inland site is approximately 5 miles west of the 

Terminal. Siting the proposed LNG storage tanks off-site from the existing Terminal would 

require cryogenic pipeline(s) from the receiving facilities at the Terminal to the off-site location. 

Construction and operation of off-site cryogenic pipeline(s) and LNG storage tanks would result 

in additional impacts to the environment, urban centers, numerous additional landowners, and 

increased operational considerations for cryogenic pipelines in an urban setting. The technology 

required for a multi-mile cryogenic pipeline has not been demonstrated at this scale. As such, its 

routine operation would be speculative and extremely expensive. Additionally, the alternative 

site would require storage of large quantities of LNG at more than one location within/near the 

City of Savannah, resulting in additional concerns regarding operation and security. As a result, 

we believe that locating the proposed LNG storage tanks at a distant off-terminal site is not a 

reasonable or feasible alternative, and would result in greater potential environmental impacts. 

Port of Savannah 

Potential alternative sites within the Port of Savannah could include existing industrial sites 

suitable for conversion to an LNG terminal, such as an idle refinery, a liquids-handling terminal 

site, or a new land site. However, use of any such site would have to comply with the Coast 

Guard’s requirement to maintain a safe distance between unloading LNG ships and other ship 

traffic in the Savannah River channel. Currently there are no existing refinery- or liquidshandling terminal sites along the Savannah River that would be suitable for conversion to an 

LNG import and delivery terminal that would comply with the Coast Guard’s requirement. 

Even if an alternative site were available within the Port of Savannah, we anticipate it would 

have comparatively increased adverse environmental effects associated with development of a 

new terminal site and the construction and operation of a natural gas send-out pipeline than 

would the proposed Elba III Project. 

Southeastern Region of the U.S. 

Potential alternative sites within the southeastern region of the U.S. would require on-shore land 

suitable for construction and operation of a new LNG import facility and direct ocean access. 

Such sites would ideally be located in relative proximity to interstate natural gas pipeline 

transmission systems to support development of the new terminal. Depending on the location of 

the new terminal site, some amount of new pipeline would have to be constructed to meet the 

objectives of the Project. Both of these factors would have a direct bearing on the associated 

environmental impacts. 

The only potential alternative on-shore site that has been identified for an LNG import terminal 

on the southeastern coast of the U.S. is located on Radio Island, North Carolina. To meet the 

purpose of the Project, construction of a new LNG facility at this site would require about 200 

miles of new, large-diameter, greenfield natural gas pipeline in North Carolina to an interconnect 

with the Transco Pipeline System in Transco Zone 5. If the Project customers would accept gas 

deliveries at a point other than “the beginning of Zone 5” (where the Transco system crosses the 

Savannah River from Georgia into South Carolina), deliveries to Zone 4 could be made by a 
3-8 3.0 – Alternatives

backhaul arrangement. However, the tariff costs associated with such an arrangement are 

inconsistent with the Project objectives. Further, such an arrangement would not satisfy the 

Project objectives of providing deliveries to Southern near the end of its South Main Line in 

Zone 3 or to the Effingham and McIntosh Power Plants. 

Construction and operation of an entirely new LNG facility (even without the new pipeline and 

the tariff issue) would result in substantially more environmental impact than that associated 

with the proposed Terminal Expansion. As a result, and in view of the new pipeline and tariff 

issues, this alternative was eliminated from further consideration. 

Conclusions of LNG Site Alternatives 

The proper location of a terminal would be required to ensure flexibility in the delivery of the 

natural gas to a variety of markets. The Elba III Project would interconnect with existing 

pipeline facilities (Southern’s Zone 3) and require a relatively direct route for new greenfield 

facilities to interconnect with Transco’s Zones 4 and 5. Construction and operation of an 

alternative terminal site would require new disturbance of on-shore and marine resources and a 

substantial length of new, large-diameter pipeline, with associated environmental impacts. 

While other potential LNG terminal sites (both onshore and offshore) likely exist in the 

southeastern U.S. (including the Gulf Coast region of Florida), Southern LNG would not be able 

to acquire or develop such sites in time to meet its contractual obligations. Further, development 

of an entirely new import terminal when the Elba Island facility is already established, 

operational, and easily expandable, would be a questionable economic decision. We conclude 

that development of a new alternative site in close proximity to Elba Island or in the southeastern 

U.S. region, and associated pipeline facilities that would be required, is not an advantageous 

alternative to the proposed action, and therefore have eliminated alternative onshore terminal 

sites from further consideration. 

3.2.3 Offshore Terminal Alternatives 

Public comments were received that raised concern about the safety of LNG carriers navigating 

the Savannah River, and requested analysis of offshore LNG facility alternatives. In response to 

this comment, we examined the available offshore alternatives. 

There are four existing onshore and one existing offshore LNG import terminals in the U.S. The 

onshore terminals are located at shoreline marine transfer terminals with onshore LNG storage 

and vaporization facilities. Numerous companies are either proposing or evaluating methods of 

importing LNG into the U.S. through the use of deepwater ports that would, potentially, avoid 

many of the perceived environmental and safety issues associated with onshore LNG facilities. 

Terminals sited in federal waters fall under the Deepwater Port Act of 1974, and as amended by 

the Maritime Transportation Security Act of 2002 (which provided jurisdiction for natural gas). 

Deepwater ports with either a fixed or floating structure (other than a vessel) or a group of 

structures that are located off the coast of the U.S. and are used as a port or terminal for the 

transportation, storage, and further handling of oil or natural gas. This legislation requires that 

the DOT (Maritime Administration) and the Coast Guard regulate the licensing, siting, 
3-9 3.0 – Alternatives

construction, and operation of deepwater ports for natural gas. The FERC would cooperate with 

the Coast Guard on environmental review for any land-based pipelines associated with these 

offshore facilities. 

Only one offshore LNG import facility has been completed in the U.S. (the Energy Bridge 

Project). Currently, additional offshore LNG terminals have been proposed and are under review 

in the U.S., Australia, West Africa, Taiwan, and Italy. The four main offshore technologies 

under development include: 

• regasification vessels where vaporization equipment is installed on LNG ships and the 

LNG ships are offloaded to a pipeline via a floating buoy and riser system; 

• gravity based structures (GBS) where LNG storage tanks, offloading, and vaporization 

facilities are placed on platforms with foundations that are anchored directly to the 

seafloor; 

• reuse of existing platforms for storage and vaporization facilities; and 

• floating storage and regasification units (FSRU) where storage tanks, offloading, and 

vaporization facilities are placed on a floating structure (or ship) that is moored to the 

seafloor. 

Calypso LNG LLC has announced the development of a deepwater port project near Fort 

Lauderdale, Florida that would include both a floating buoy and riser system terminal and a 

semi-permanently moored FSRU-like vessel. This project would serve Florida markets and if 

approved and constructed would not serve the market proposed for the Project. 

Typical floating buoy and riser system terminals do not have the capacity to store LNG. The 

lack of storage severely limits this technology for providing base load natural gas supply to the 

region. To ensure that a continuous supply of gas would be provided to the region, use of a 

floating buoy and riser system LNG terminal would require two or three unloading buoys to 

allow for the departure/arrival of a regasification vessel while another regasification vessel is 

unloading. During severe weather, particularly in the Atlantic Ocean, the potential for periodic 

interruptions of service when the regasification vessels are unable to berth and unload natural gas 

into the riser significantly reduces the reliability of this alternative. Given these limitations, we 

have eliminated this alternative from further consideration. 

To accommodate LNG carriers, a GBS-based LNG terminal would need to be installed where 

water depth is at least 50 feet. Because the GBS must extend above the water, the maximum 

practicable water depth for a facility of this type would be approximately 100 feet. As water 

depth increases beyond 100 feet, factors such as structure size and geotechnical constraints 

generally limit the practicability of a GBS-based terminal. 

GBSs would be constructed at a specialized onshore construction facility called a graving dock. 

Graving docks generally are established adjacent to a channel of sufficient depth to float the 

GBS once the construction is complete. In most cases, sheet piling or a similar type of barrier is 

installed to block water from the channel, and an area is excavated to accommodate the concrete 

forms required to construct the structure. In some cases, more than one graving dock is 

constructed to allow concurrent construction of all structures associated with the terminal. After 
3-10 3.0 – Alternatives

the GBS is constructed in the graving dock, the barrier would be removed and the GBS floated 

and towed to the terminal location. Here, the GBS would be allowed to sink to the sea bottom. 

For most potential sites for graving docks in the region, the impacts associated with construction 

of a GBS would be substantially greater than those associated with the modest modifications 

proposed by the Terminal Expansion. Based on anticipated impacts, we eliminated the GBS 

technology from further consideration. 

This analysis addresses the two remaining offshore technologies for unloading LNG to meet the 

needs of the Project: 

• an offshore unloading terminal with connecting cryogenic pipeline; and 

• an offshore unloading and regasification terminal with connecting natural gas pipeline. 

We requested that Southern LNG provide input regarding the design of facilities that would be 

required to interconnect an offshore facility with the existing facilities at Elba Island, and 

associated cost estimates for construction of offshore alternatives. Such offshore terminal 

facilities would be required to be sited in areas away from shipping fairways and operating oil 

and gas platforms, and include a safety buffer zone to preclude commercial or recreational 

fishing. 

For both offshore alternatives, the analysis assumed that the offshore terminal would be located a 

sufficient distance at sea (about 20 miles from the existing terminal) such that the platform 

would be only minimally visible, if visible at all, from the shores of Hilton Head Island, South 

Carolina, and Tybee Island, Georgia. We further assumed that the associated interconnect 

pipeline(s) would extend westward from the offshore unloading terminal, through federal and 

state waters, across the onshore lands of South Carolina’s Jasper County, under the Savannah 

River channel, to the existing Elba Island Terminal. Both offshore alternatives would be located 

as depicted in figure 3.2-2.

Southern LNG provided estimated costs and mileage of offshore alternative facilities compared 

to the equivalent portion of the proposed Terminal Expansion facilities. Southern LNG provided 

an analysis of the modifications at the existing Elba Island onshore berthing facility that are 

summarized in table 3.2-1, as well as a comparison of the estimated environmental impacts of 

the offshore alternatives and the proposed modifications at the berthing facility provided in table 

3.2-2. 

Offshore Unloading Terminal Alternative

An alternative to the proposed modifications to existing berthing facilities is an offshore 

unloading platform with twin cryogenic pipelines connecting to the existing Elba Island facility 

where the proposed Elba III storage and vaporization facilities would be located. The unloading 

platform would be capable of offloading two LNG carriers simultaneously to consistently meet 

the need for 900 MMcfd of baseload deliverability. The estimated cost for an Offshore 

Offloading Terminal would be approximately $426,000,000. 
Non-Internet Public 

DRAFT 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 

Page 3-11 

Figure 3.2-2 

Offshore LNG Terminal Alternative Site 

Public access for the above information is available only 

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

public.referenceroom@ferc.gov. 
3-12 3.0 – Alternatives

TABLE 3.2-1

Engineering and Economic Comparison of the Proposed Terminal Expansion Project 

to Offshore Terminal Alternatives 

Offshore Unloading Terminal 

Alternative 

(Cryogenic Pipe and 

Unloading Platform)

Offshore Regasification 

Terminal Alternative 

(Natural Gas Pipe and 

Unloading Vessel)

Terminal Expansion Project

(Berth Modification)

Facilities Required 

Offshore Structure Type Fixed Platform Floating No offshore structure 

(Land-Based) 

Pipeline Type Two - Cryogenic (42-inch 

Outside Diameter) 

Natural Gas (42-inch Outside 

Diameter) 

No Pipeline 

Pipeline Length (miles) 20 20 0 

Terminal facilities Unloading terminal offshore, 

LNG storage tanks, 

regasification, and auxiliary 

facilities onshore at Elba Island. 

Floating LNG unloading, storage, 

and regasification unit offshore. 

Measuring and receiving facilities 

onshore at Elba Island. 

LNG unloading, storage tanks, 

regasification, measuring, and 

auxiliary facilities onshore at 

Elba Island Terminal. 

Pipeline Cost 

Pipeline cost/mile: $34,000,000 $4,000,000 $0.00 

 Material cost/mile $16,800,000 $1,200,000 $0.00 

Installation cost/mile $17,200,000 $2,800,000 $0.00 

 Total pipeline cost $680,000,000 $80,000,000 $0.00 

Terminal Facilities Cost 

Material $146,000,000 $315,000,000 $160,000,000 

Installation $280,000,000 $385,000,000 $270,000,000 

Total Terminal 

Facilities Cost 

$426,000,000 $700,000,000 $430,000,000 

Total Project Cost $1,106,000,000 $780,000,000 $430,000,000 

Comments Because the feasibility of the 

concept remains unproven, 

particularly with respect to 

cryogenic pipe insulation, and 

because the specifics of suitable 

materials are unknown, the 

above cost estimates should be 

interpreted as “at least” figures, 

with the actual costs increasing 

with time until commercial 

availability and more testing 

yields more stringent design 

specifications. 

The technology for offshore 

storage and regasification at this 

scale would require a significant 

amount of engineering, design, 

and permitting activities that 

would extend the schedule 

significantly and likely would not 

be accomplished to meet the 

proposed Project schedule.

These cost estimates remain 

in development but represent 

existing technology, materials, 

construction techniques and 

ROW. More definitive costs 

are included in Exhibit K to 

Southern LNG’s FERC 

application. 
3-13 3.0 – Alternatives

TABLE 3.2-2

Comparison Of Environmental Impacts Among The Terminal Expansion Project And 

The Two Berthing Alternatives 

Impacts Offshore Unloading 

Terminal Alternative 

Offshore Regasification 

Terminal Alternative Terminal Expansion Project 

Temporary Impacts by Facility (acres) 

Offshore Terminal Facilities 10.00 5.00 0.00 

Elba Island Facilities 124.08 2.50 178.82 

Pipeline 353.69 a/ 355.94 b/ 0.00 

Total 487.77 363.44 178.82 

Permanent Impacts by Facility (acres) 

Offshore Terminal Facilities 20.00 10.00 0.00 

Elba Island Facilities 34.26 5.00 34.26 

Pipeline 217.57 c/ 199.45 d/ 0.00 

Total 271.83 214.45 34.26 

Total Impacts by Facility (acres) 

Offshore Terminal Facilities 30.00 15.00 0.00 

Elba Island Facilities 158.34 7.50 213.08 

Pipeline 571.27 e/ 555.39 0.00 

Total 759.61 577.89 213.08 

Temporary Impacts by Resource (acres) 

Wetlands 28.67 28.67 0.00 

Uplands 3.33 3.33 0.00 

Developed Industrial Land f/ 124.08 4.75 145.51 

Open Water 327.09 g/ 322.09 g/ 33.31 

Government Lands h/ 4.60 4.60 0.00 

Total 487.77 363.44 178.82 

Permanent Impacts by Resource (acres) 

Wetlands 43.00 28.67 0.00 

Uplands 5.00 3.33 0.00 

Developed Industrial Land f/ 34.26 7.24 34.26 

Open Water 182.66 g/ 170.61 g/ 0.00 

Government Lands h/ 6.91 4.60 0.00 

Total 271.83 214.45 34.26 

Total Impacts by Resource (acres) 

Wetlands 71.67 57.33 0.00 

Uplands 8.33 6.67 0.00 

Developed Industrial Land f/ 158.34 11.99 179.77 

Open Water 509.75 g/ 492.70 g/ 33.31 

Government Lands h/ 11.51 9.20 0.00 

Total 759.60 562.89 213.08 

Other Impacts 

Channel/Stream Crossings 3 3 0 

Marine and Coastal 

Resources 

Potential for direct impacts 

(e.g., sea turtles, whales, hard 

bottom outcrops, oyster reefs) 

Potential for direct impacts 

(e.g., sea turtles, whales, hard 

bottom outcrops, oyster reefs) 

Potential for direct impacts low 

and limited to slip modification 

work 
3-14 3.0 – Alternatives

TABLE 3.2-2 (continued) 

Comparison of Environmental Impacts Among the Terminal Expansion Project and 

the Two Berthing Alternatives

Impacts Offshore Unloading 

Terminal Alternative 

Offshore Regasification 

Terminal Alternative Terminal Expansion Project 

Other Impacts (continued) 

Essential Fish Habitat 

(SAFMC 1998) 

Potential for impacts more 

likely during offshore and 

wetland/marsh construction 

Potential for impacts more 

likely during offshore and 

wetland/marsh construction 

Potential for impacts less 

likely; expect only minor 

indirect impacts, if any, from 

turbidity generated during slip 

modification work 

Additional Engineering and Constructability Factors 

Marine and Wetland 

Construction 

Approximately 92 percent 

marine and wetland 

construction, requiring floating 

equipment subject to weather, 

current and tidal effects; 

complicated material and 

supply logistics; relative safety 

concerns related to 

construction offshore and in 

unstable marsh substrates 

Approximately 92 percent 

marine and wetland 

construction, requiring floating 

equipment subject to weather, 

current and tidal effects; 

complicated material and 

supply logistics; relative safety 

concerns related to 

construction offshore and in 

unstable marsh substrates 

Minimal; only for modification 

of the slip 

Horizontal Directional Drilling 

Required 

At least 5 HDDs required At least 5 HDDs required None 

________________________________________________________________ 

a/ Assumes a cryogenic LNG pipeline and a return pipeline; value is calculated from an assumed 200-foot temporary construction 

impact zone offshore (in addition to, but excluding, the 100-foot permanent ROW) and 50 feet of extra workspace equivalent (in 

addition to, but excluding, the 75-foot permanent ROW) onshore; 2.24 acres for the pipeline are included with the Elba Island 

Facilities acres. 

b/ Assumes a single natural gas pipeline; value is calculated from an assumed 200-foot temporary construction impact zone 

offshore (in addition to, but excluding, the 100-foot permanent ROW) and 50 feet of extra workspace equivalent (in addition to,

but excluding, the 50-foot permanent ROW) onshore. 

c/ Assumes a 75-foot permanent ROW onshore and a 100-foot permanent ROW offshore (assumed easement from MMS); 3.36 

acres for the pipeline are included with the Elba Island Facilities acres. 

d/ Assumes a 50-foot permanent ROW onshore and a 100-foot permanent ROW offshore. 

e/ 5.61 acres are included in the Elba Island Facilities acres. 

f/ Elba Island. 

g/ Includes pipeline and offshore terminal facility acres. 

h/ COE Confined Disposal Facility 

The cost estimates in table 3.2-1 exclude expenses related to drilling, boring and/or tunneling the 

entire length of the approximately 20-mile cryogenic pipeline. Utilizing HDD techniques for 

some onshore segments would mitigate some of these impacts; however the extended length of 

onshore construction through Jasper County, South Carolina, would presumably involve earth 

disturbance through trenching and pipe laying construction techniques, which would impose 

other environmental impacts related to vegetation removal, turbidity, and sedimentation. The 

estimate installed cost of the twin 20-mile-long connecting pipelines would be $680,000,000. 

Also, the cryogenic pipeline would require a vacuum jacket or special insulted wrapping which 

is unproven for this application. 

Modifying the existing berths at Elba Island as proposed would confine construction and 

operation to a limited area already dedicated to LNG operations, while constructing an unloading 

platform and cryogenic pipeline for the Offshore Unloading Terminal Alternative would impact 

approximately 20 miles of navigable rivers, open water, coastal marshlands, and sea beds. Total 
3-15 3.0 – Alternatives

temporary and permanent impacts to resources for this alternative are nearly eight times and two 

and a half times that of the proposed action, respectively. Additionally, the total estimated cost 

for this alternative is more than two and a half times that of the proposed action. 

Offshore Regasification Terminal Alternative

An offshore regasification terminal including receiving, storage, and vaporization components 

with a standard 42-inch-diameter pipeline connecting to the existing Elba Island facility was 

evaluated as an alternative to the proposed berthing and onshore terminal facilities modifications. 

The estimated installed cost of the 20-mile-long pipeline would be $80,000,000. 

Estimated costs for the unloading facilities associated with the Offshore Regasification Terminal 

Alternative assume use of a FSRU. Using public information available for the Broadwater 

Energy project under review by the Commission in Docket No. CP05-64-000, the estimated cost 

for an Offshore Regasification Terminal Alternative based on the FSRU concept would be at 

least $700,000,000. 

Expanding terminal facilities at Elba Island as proposed would confine construction and 

operations to very limited areas that are previously disturbed, currently maintained, and already 

dedicated to LNG operation. Construction of the natural gas pipeline and unloading vessel for 

the Offshore Regasification Terminal Alternative would impact 20 miles of navigable rivers, 

coastal marshlands, sea beds, and open water. Total temporary and permanent impacts to 

resources for this alternative are greater than six times and two times that of the proposed action, 

respectively. Additionally, the total estimated cost for this alternative is $780,000,000, which is 

nearly twice that of the proposed action. 

3.2.4 Conclusions of Offshore Berth Alternatives 

The offshore terminal alternatives would require installation of offshore facilities and 

approximately 20 miles of pipeline (figure 3.2-2), most of which would traverse marine and 

wetland environments before making landfall at the Elba Island Terminal. Table 3.2-2 

summarizes the environmental impacts that would be associated with the proposed Terminal 

Expansion and each of the two offshore berthing alternatives. All construction and operation of 

the proposed Terminal Expansion would occur on an existing, previously disturbed industrial site 

situated on dredged material. Compared to the proposed Terminal Expansion, both offshore 

alternatives would disturb more wetlands, open water habitat, and government lands, as well as 

have a greater potential to adversely impact marine and estuarine resources, including EFH 

(SAFMC 1998; Van Dolah, et al. 1983; UGA 2006a). 

The two offshore terminal alternatives also would require significant additional engineering and 

design efforts to address and mitigate safety and environmental issues associated with 

construction and operation due to the variability of offshore weather and marine conditions and 

unstable wetland soils that would be traversed by the pipeline(s). The offshore unloading 

terminal would require 20 miles of cryogenic pipeline, which is not technically feasible. Finally, 

the offshore alternatives would be substantially more expensive to construct and operate than the 

proposed onshore Terminal Expansion facilities. Therefore, we concluded that an offshore LNG 
3-16 3.0 – Alternatives

terminal and pipeline facility would not provide an environmental advantage over the proposed 

action. In this instance, it would also be economically infeasible and therefore not a reasonable 

alternative to the proposed terminal expansion. 

3.3 ELBA EXPRESS PIPELINE ALTERNATIVES 

A number of public comments were received requesting analysis of pipeline system alternatives, 

route alternatives, and minor route variations to avoid specific localized resource impact 

concerns along each proposed segment. The results of these analyses are presented in this 

section. 

3.3.1 Pipeline System Alternatives 

Because there are no known pipeline systems proposed for construction in the project area (other 

than Elba Express), our analysis of pipeline system alternatives focused on the use of existing 

project-area pipeline systems to meet the objectives of the Elba III Project. 

There are only two existing pipeline systems in the project area that potentially could be used to 

transport the vaporized LNG from the proposed Terminal Expansion to the target locations and 

customers. These systems belong to Southern and to South Carolina Pipeline Company 

(SCPC).14 However, neither system (nor both systems combined) is currently capable of 

transporting the additional volume of natural gas without construction of major new looping and 

other facilities similar to those proposed by EEC. Further, because construction of similar 

facilities would result in a similar level of environmental impact, we conducted no further 

analysis of existing pipeline system alternatives. 

3.3.2 Pipeline Route Alternatives 

In evaluating pipeline route alternatives, we looked for alternatives that could reduce overall 

environmental impacts or reduce impact on environmentally sensitive resources such as 

population centers, extensive wetland areas, difficult terrain, and public lands. Route alternatives 

generally follow a different corridor for a portion of the proposed route, and may ultimately 

terminate at different locations. 

3.3.2.1 Southern Segment 

The proposed Southern Segment (MP 0.0 to MP 104.8) is entirely collocated with Southern’s 

existing pipeline system and provides a direct route from the Terminal to the southernmost 

intended interconnect zone at Wrens Compressor Station. Because alternative routes which 

would follow other existing corridors (utility, road, rail, etc.) between Port Wentworth and 

Wrens would be far less direct, they would significantly increase the pipeline length and 

associated environmental impacts. For instance, public comments were received requesting 

evaluation of a route alternative from Port Wentworth west along Interstate 16 to Laurens 

 

14 In order to access SCPC’s system, a major new pipeline would be required between MP 0.0 (the Port Wentworth 

Meter Station) on the Elba Express Pipeline route and central Beaufort County, South Carolina. 
3-17 3.0 – Alternatives

County where it would interconnect with other existing corridors (pipeline and roadway) to reach 

the Wrens Compressor Station. This route would require a minimum of 20 miles of additional 

pipeline along a less direct route. The proposed route yields the least amount of environmental 

impact by minimizing the length of the required pipeline and maximizing the use of previously 

disturbed areas for construction. Further, because the Southern Segment would be sited on 

Southern’s existing ROW, the need for new permanently maintained ROW is very limited. For 

these reasons, we did no further analysis of route alternatives for this segment. 

3.3.2.2 Northern Segment 

Because the proposed 83.1-mile Elba Express Pipeline-Northern Segment would primarily 

involve greenfield construction (i.e., follows no existing corridor), we considered two major 

route alternatives and three additional alternatives that would place the Northern Segment 

adjacent to existing corridors for all or a portion of its length. 

Full Collocation Alternatives

In response to public comments, we evaluated two major route alternatives that would meet the 

project objectives by entirely following existing pipeline corridors between the Wrens 

Compressor Station (MP 104.8) in Jefferson County, Georgia, and the Transco system in Hart 

County, Georgia (Transco Zone 4) and Anderson County, South Carolina (Transco Zone 5). 

These alternatives are identified as Major Route Alternatives A and B in figure 3.3-1. Table 

3.3-1 provides a summary of the significant environmental characteristics of these two 

alternatives. 

TABLE 3.3-1

Comparison of Major Route Alternatives for the Northern Segment of 

The Elba Express Pipeline 

Evaluation Factor Proposed 

Pipeline Alternative A Alternative B 

Total Length of New Pipeline (miles) 83.1 235 175 

New ROW, greenfield (miles) 81 0 0 

Adjacent to existing pipeline ROW (miles) 3 235 175 

Total ROW (acres) 1,098 2,012 2,121 

Temporary Construction ROW (acres) 604 1,782 1,273 

Incremental Permanent ROW (acres) 494 1,030 848 

Estimated Construction Cost ($millions) $194 $614 $446 
Non-Internet Public 

DRAFT 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 

Page 3-18 

Figure 3.3-1 

Major Route Alternatives A and B 

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3-19 3.0 – Alternatives

Major Route Alternative A

Alternative A has two components, an eastern leg and a western leg, to access the two Transco 

zones. The western leg would follow Southern’s pipeline system from Wrens to an area west of 

Macon near Thomaston, and then north to a new interconnection with Transco in its Zone 4 near 

Jonesboro, Georgia. The eastern leg would follow Southern’s system eastward from Wrens, 

across the Savannah River, to an interconnection with SCPL near Akin, South Carolina, and then 

follow SCPL’s system northward to a new interconnection with Transco in its Zone 5 near 

Spartanburg. 

Along the western leg, Southern’s existing pipeline system between Wrens and Thomaston has a 

west-to-east design capacity of a little less than 1 Bcfd; therefore, little or no new pipeline would 

be needed. However, the compressor stations along this segment would require reconfiguration, 

possible involving additional horsepower, to enable pumping natural gas bidirectionally. 

Between Thomaston and Jonesboro, Southern’s system does not have sufficient capacity and 

would require construction of about 60 miles of new 36-inch-diameter pipeline. This new 

pipeline would require a minimum of 70 feet of construction ROW in addition to a 

approximately 20-30 feet of incremental permanent ROW (a minimum of 20 feet for the first 30 

miles and a minimum of 30 feet for the remaining 30 miles). 

The east leg portion would require a new pipeline along the Southern and SCPC systems for the 

full distance between Wrens and the Transco Zone 5 interconnect near Spartanburg, South 

Carolina. This east leg route is approximately 175 miles long, of which 100 miles would be 42-

inch and 75 miles would be 36-inch pipe. Also, approximately 8,000 hp of new compression 

would be required at Wrens. An estimated minimum 60 feet of construction ROW plus a 

minimum of 40 feet of incremental permanent ROW would be required for the entire 175 miles. 

As seen in table 3.3-1, the length of pipeline (and therefore the environmental impacts) required 

by Alternative A is significantly greater than that associated with the proposed route. Alternative 

A would also conflict with the project’s objectives because it would incur additional incremental 

transportation charges associated with the use of Southern’s pipeline system between Wrens and 

Thomaston. Additionally, the cost to construct Alternative A is greater than three times that of 

the proposed action between Wrens and Transco’s Zones 4 and 5. 

Major Route Alternative B

Alternative B uses the eastleg portion of Alternative A but extends the east leg along Transco’s 

system to the southwest to enable deliveries in Zone 4 (the Georgia side of the Savannah River). 

The alternative would require about 175 miles of new collocated pipeline between Wrens, 

Georgia and a new Transco interconnection near Spartanburg, and additional compression (see 

Alternative A discussion above). Between the Transco interconnection and Transco Zone 4, 

little or no new pipeline construction would be required because this portion of Transco’s system 

has available capacity. 
3-20 3.0 – Alternatives

As with Alternative A, Alternative B would impact a greater number of acres than the proposed 

action because the length of new pipeline construction required for this alternative is more than 

twice that required by the proposed route. And again, because the alternative would use a 

portion of Transco’s system to transport gas between Spartanburg and Zone 4, it would incur 

additional incremental transportation charges. 

Conclusions of Full Collocation Route Alternatives 

The proposed action would provide a direct route and efficient means of delivering regasified 

LNG between Wrens and the Transco system in Hart County, Georgia (Transco Zone 4) and 

Anderson County, South Carolina (Transco Zone 5). As discussed above, there are no existing 

natural gas pipeline corridors in the vicinity of the Northern Segment route that are situated in 

such a manner as to allow reasonably direct access to the Transco system zones that are the 

objective of the proposed action. Full (100 percent) collocation with any other interstate pipeline 

would require the construction of substantial pipeline facilities, and associated environmental 

impacts, which would greatly exceed those proposed by the Project. As a result, we eliminated 

Major Route Alternatives A and B from further consideration. 

Partial Collocation Route Alternatives

In an effort to respond to public comments which sought the use of existing corridors for routing 

the Northern Segment of the Elba Express Pipeline, we investigated existing pipeline, railroad, 

and utility line corridors in the vicinity of the proposed route. This proved challenging because: 

• there are a limited number of existing corridors in the project vicinity; 

• those that exist tend to trend east-west (the Southern and Transco systems, and the 

Hartwell Railroad [HRT-RR]) rather than north-south (the Atlanta Gas and Light [AGL] 

system); and 

• railroad corridors frequently weave across the proposed route in an indirect manner 

(Norfolk Southern Railroad [NS-RR] and Georgia Woodlands Railroad [GWRC-RR]). 

Ultimately, we evaluated three route alternatives which began at the Wrens Compressor Station 

(MP 104.8) and would be partially collocated with other existing corridors. These alternatives 

are presented in figure 3.3-2. A comparison of environmental factors associated with each route 

alternative is provided in table 3.3-2. 

West Route Alternative 

As shown in figure 3.3-2, the West Route Alternative would follow Southern’s ROW west from 

the Wrens Compressor Station for about 8.9 miles to an intersection with the AGL system. The 

alternative would then follow AGL’s system north for a total of about 26.6 miles. Midway in 

this interval, the alternative would make a 7.1-mile-long deviation from the AGL ROW to route 

around the east side of Warrenton, Georgia. After following AGL, the alternative would 

continue cross-country in a northerly direction for about 29 miles before rejoining the proposed 

route near MP 166.8 Overall, the West Route Alternative would be collocated with existing 

pipeline ROWs for about 37.2 miles (40 percent) of its entire 92.8-mile length. 
Non-Internet Public 

DRAFT 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 

Page 3-21 

Figure 3.3-2 

West, Midwest, and East Route Alternatives 

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

public.referenceroom@ferc.gov. 
3-22 3.0 – Alternatives

TABLE 3.3-2 

Environmental Comparison of Partial Collocation Route Alternatives to the Proposed Route 

Environmental Factor Unit Proposed 

Route 

West Route 

Alternative 

Midwest Route 

Alternative 

East Route 

Alternative 

Total length Miles 83.1 92.8 90.3 81.0 

Percentage parallel to or 

within existing ROW 

Percent 1.6 40.0 44.0 2.1 

Construction disturbance a/ Acres 1,259.1 1,406.1 1,368.2 1,227.3 

Perennial waterbody 

crossings 

Number 101 121 94 119 

Major waterbody crossings Number 4 4 4 4 

Wetlands Acres 28.1 47.7 35.7 29.8 

Hardwood forest Acres 167.7 128.2 135.2 125.1 

Softwood forest Acres 235.0 254.0 237.6 299.4 

Urban areas b/ Acres 0.4 1.2 9.3 2.3 

Agricultural land c/ Acres 214.2 233.6 244.7 118.6 

Public lands crossed d/ Number 2 3 2 4 

Number of landowners Number 358 413 425 Unknown 

________________________________________________________________ 

a/ Based on a nominal ROW width of 125 feet. 

b/ Includes high- and low- intensity urban areas. 

c/ Includes pasture, hay, and row crops. 

d/ Includes wildlife management areas, ball fields, campgrounds, landfills, quarries, and other public lands. 

While the West Route Alternative would be parallel to or within existing ROWs for 40 percent 

of its length, it would be 9.7 miles longer than EEC’s proposed route. This additional mileage 

translates into almost 140 acres of additional impact on soils, waterbodies, and wetlands (see 

table 3.3-2). The alternative would also encounter some of the roughest terrain of any Northern 

Segment route along a 7.5-mile-long portion of the AGL ROW north of Warrenton (further 

increasing the overall disturbance acreage). Additionally, in order to meet delivery pressure 

requirements without construction of an additional compressor station, use of this alternative 

would also require about 17 miles of the proposed 36-inch-diameter pipeline to be replaced with 

42-inch-diameter pipeline. This would have both an environmental impact (need for a wider 

construction ROW and more disturbance acreage) and an economic impact (greater pipe costs). 

While the use of existing utility corridors is generally preferable, the trade-off in this case would 

be to substantially increase the length of the pipeline (and attendant environmental impact) 

without providing a significant environmental advantage over the proposed route. As a result, 

we eliminated the West Route Alternative from further consideration. 

Midwest Route Alternative 

The Midwest Route Alternative would follow Southern’s ROW for about 3 miles westward to an 

intersection with the NS-RR corridor. It would then follow the railroad corridor for about 13 

miles to an intersection with the AGL ROW. From here, it would follow an identical path as the 

West Route Alternative until intersecting with the GWRC-RR corridor in southern Wilkes 

County, Georgia. The alternative would follow this railroad corridor to just south of 

Washington, circle around the west and north sides of Washington, and then continue crosscountry on a northeast heading to intersect with the proposed route near MP 153. 
3-23 3.0 – Alternatives

The Midwest Route Alternative would be parallel to or within existing pipeline or railroad 

ROWs for about 44 percent of its 90.3-mile-long length. Although the increased length (about 

7.2 miles) would reduce the number of perennial stream crossings, it would again significantly 

increase the overall acreage disturbed by construction and involve more wetland acreage. As 

with the West Route Alternative, use of this alternative would trade difficult construction terrain 

along the AGL corridor and more than 100 acres of additional construction disturbance for 

following existing corridors. We also note that following a railroad ROW is different than 

following a pipeline or road ROW because the track area and subgrade cannot be used. For these 

reasons, the alternative would not provide a significant environmental advantage over the 

proposed route. As a result, we eliminated the Midwest Route Alternative from further 

consideration. 

East Route Alternative

The East Route Alternative was an attempt to minimize the length of pipeline needed by drawing 

an almost straight line between the Wrens Compressor Station and the proposed interconnection 

with Transco Zone 4 in Hart County. As shown in figure 3.3-2, the alternative runs east of the 

proposed route for about 76.7 miles to a point of intersection near MP 184. Overall, the 

alternative would be about 81 miles long or 2.6 miles shorter than the proposed route. 

The advantage of East Route Alternative is that, of the three Northern Segment alternatives 

analyzed, it would be the shortest route and therefore reduce construction impact by about 32 

acres. While it would reduce the amount of hardwood forest land disturbed, it would cross two 

additional public land areas (Elbert County WMA and Richard B. Russell State Park) and 

encounter an area of surface mining along the first 10 miles. Reroutes to avoid the WMA, State 

Park, and surface mining operations would ultimately increase the length of the alternative to the 

point where it would be longer than the proposed route. Because the East Route Alternative 

would offer no significant environmental advantage over the proposed route, we eliminated it 

from further consideration. 

Conclusion of Partial Collocation Route Alternatives 

We evaluated three alternatives to the Northern Segment which would partially collocate the 

proposed pipeline with other existing utilities. For the reasons discussed above and summarized 

in table 3.3-2, we believe that the proposed route (or the proposed route with minor variations to 

address site-specific issues) is the best selection of the routes considered for the following 

reasons: 

• it would avoid strip mines, and most urbanized areas; 

• it would disturb the least amount of wetland acreage; and 

• it would avoid the rough terrain and steep side slopes encountered along the AGL 

corridor. Side-slope construction would entail a wider construction ROW (more 

disturbance) and increased safety risks for construction workers. 
3-24 3.0 – Alternatives

As a general rule, we believe that new pipeline facilities should be placed adjacent to or 

overlapping with existing utility corridors. This belief is based on the premise that the use of 

existing corridors (the “common corridor” concept) will limit the proliferation of new utility 

ROWs and thereby reduce environmental impact. However, the use of existing corridors is not a 

rule; if corridors are overloaded, not reasonably available, or require a significantly longer 

construction path, other routing considerations become more important. Our analysis of partial 

collocation route alternatives indicated that the use of existing corridors in the project area would 

not provide a significant environmental advantage over the proposed route. 

3.3.3 Pipeline Route Variations 

Route variations differ from route alternatives in that they are identified to avoid or reduce 

construction impacts on specific, localized resources such as a residence, cultural resource site, 

or endangered species habitat. 

We have not identified any issues or concerns that would necessitate the evaluation of route 

variations along the Southern Segment pipeline because this portion of the route parallels and 

largely overlaps Southern’s existing pipeline corridor. However, EEC has considered and 

incorporated numerous reroutes and variations into its proposed Northern Segment route in an 

attempt to avoid or reduce impacts on specific local resources of agency or public concern raised 

during open houses, public scoping, and negotiations with individual landowners. These 

variations would avoid or minimize impacts on residences and private property concerns, a 

nursing home, a public water line, and a highway crossing. All route variations adopted to date 

are shown on EEC’s filed alignment sheets and have been reviewed as part of our analysis. 

COE-Managed Land Route Variations

The proposed route of the Elba Express Pipeline would cross COE-administered lands at five 

locations. See section 4.8.5 for additional discussion of COE Project Lands. 

On the Southern Segment, the route would cross the Di-Lane WMA in Burke County, Georgia, 

for about 2.7 miles (MPs 74.43-78.13). Here, the pipeline would parallel two existing SNG 

pipelines. Although construction would require clearing 70 feet of temporary workspace along 

the edge of the existing pipeline corridor, EEC would require no additional permanent ROW to 

cross the WMA. Because the proposed route follows an established corridor across the WMA 

and any additional mitigation beyond EEC’s Plan and Procedures (which constitute Best 

Management Practices) would be developed between EEC, the COE, and the GDNR before 

construction commenced, we believe that the proposed route would have less impact on 

environmental resources than development of a new pipeline route which circumvented the 

WMA. As a result, no alternatives to crossing the Di-Lane WMA were developed. 

On the Northern Segment, COE-administered lands would be crossed at four locations. At three 

locations, we evaluated routing variations to crossing COE parcels. At the fourth location (the 

Savannah River crossing), discussions between EEC and the COE resulted in a reroute that the 

COE believes would minimize impact on Project and Mitigation Lands associated with the 

Hartwell and Richard B. Russell Projects by keeping EEC’s ROW as close to contiguous as 
3-25 3.0 – Alternatives

possible to Transco’s existing ROW and limiting the sprawl of natural gas pipelines in the area. 

Our route variation assessments for the remaining three locations are presented below. We are 

recommending that none of the variations be adopted for the reasons presented. 

Little River Variation 

At MP 134.9, the proposed route would cross the Little River within a 0.5-mile parcel of COE 

Project Land associated with the J. Strom Thurmond Project. This parcel is locally known as the 

Clarks Hill WMA and straddles the line between McDuffie and Wilkes County, Georgia. As an 

alternative to crossing the WMA, we evaluated a route to the west of the proposed crossing 

location. The route evaluated is presented in figure 3.3-3. Table 3.3-3 compares the impacts of 

the Little River Variation to the corresponding segment of the proposed route. 

TABLE 3.3-3 

Little River Variation Comparison 

Environmental Factor Unit Little River 

Variation 

Corresponding Segment 

of Proposed Route 

Length Miles 5.0 2.5 

Construction disturbance a/ Acres 75.7 37.9 

Perennial waterbody crossings Number 2 3 

Major waterbody crossings Number 1 1 

Wetland crossing Feet 1,500 b/ 19 

Forest land crossing Miles 4.6 2.4 

Open land crossing Miles 0.4 0.1 

________________________________________________________________ 

a/ Based on a nominal ROW width of 125 feet 

b/ NWI Mapped Wetland 

As shown, the Little River Variation would cross one less perennial stream than the 

corresponding segment of the proposed route. However, it would essentially be double the 

length of the proposed route in this area and result in proportionally greater impacts on soil, 

wetland, and vegetation resources. For the proposed route, the COE has requested that EEC 

cross the Little River by HDD, and EEC has agreed to do so if geologic conditions are favorable. 

For these reasons, we believe that the Little River Variation does not offer an environmental 

advantage over EEC’s proposed route, and therefore eliminated this alternative from further 

consideration. 

Beaverdam Creek Variation 

Near MP 171 in Elbert County, Georgia, the proposed route would cross two parcels of COE 

Mitigation Lands associated with the Richard B. Russell Project. These parcels, totaling about 

4,115 feet overall, contain the primary stem of the Beverdam Creek and several tributaries. As 

an alternative to crossing these Mitigation Lands, we evaluated a route that would run west of the 

proposed crossing location. The route evaluated is presented in figure 3.3-4. Table 3.3-4 

compares the impacts of the Beaverdam Creek Variation to the corresponding segment of the 

proposed route. 
Non-Internet Public 

DRAFT 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 

Page 3-26 

Figure 3.3-3 

Little River Variation 

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

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Non-Internet Public 

DRAFT 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 

Page 3-27 

Figure 3.3-4 

Beaverdam Creek Variation 

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3-28 3.0 – Alternatives

TABLE 3.3-4

Beaverdam Creek Variation Comparison 

Environmental Factor Unit Beaverdam Creek 

Variation 

Corresponding Segment 

of Proposed Route 

Length Miles 9.2 5.0 

Construction disturbance a/ Acres 139.4 75.7 

Perennial waterbody crossings Number 0 9 

Major waterbody crossings Number 0 1 

Wetland crossing Feet 2,900 b/ 287 

Forest land crossing Miles 8.5 4.5 

Open land crossing Miles 0.7 0.5 

________________________________________________________________ 

a/ Based on a nominal ROW width of 125 feet 

b/ NWI Mapped Wetland 

The advantage of Beaverdam Creek Variation is that it would not cross any perennial streams 

(and avoid a major waterbody) compared with the corresponding segment of the proposed route. 

However, to circumvent a relatively short stretch of COE Mitigation Lands, this alternative 

would be 4.2 miles longer and affect proportionally greater acreages of soil, wetland, and 

vegetation resources. For the proposed route, the COE has requested that EEC cross Beaverdam 

Creek (the major waterbody) by HDD, and EEC has agreed to do so if geologic conditions are 

favorable. Further, EEC and the COE are presently in the process of developing mitigation 

specific to crossing these lands. As a result, we believe that the Beaverdam Creek Variation does 

not offer a significant environmental advantage over EEC’s proposed route and eliminated this 

alternative from further consideration. 

Coldwater Creek Variation 

The proposed route would cross Coldwater Creek at MP 178 within a 950-foot parcel of COE 

Mitigation Land associated with the Russell Project in Elbert County, Georgia. As an alternative 

to crossing this ribbon of Mitigation Land on the banks of Coldwater Creek, we developed a 

route that again headed west to an upstream crossing location. The route evaluated is presented 

in figure 3.3-5. Table 3.3-5 compares the impacts of the Coldwater Creek Variation to the 

corresponding segment of the proposed route. 

The primary advantages of the Coldwater Creek Variation versus the proposed route is that it 

would cross one less perennial stream and avoid a major waterbody. However, an additional 2.2 

miles of disturbance to soil, wetland, and vegetation resources would result from avoiding less 

than 1,000 feet of COE Mitigation Land. For the proposed route, the COE has requested that 

EEC cross Coldwater Creek (the major waterbody) by HDD, and EEC has agreed to do so if 

geologic conditions are favorable. Further, EEC and the COE are presently in the process of 

developing mitigation specific to crossing this land. As a result, we believe that the Coldwater 

Creek Variation does not offer an environmental advantage over EEC’s proposed route, and 

eliminated this alternative from further consideration. 
Non-Internet Public 

DRAFT 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 

Page 3-29 

Figure 3.3-5 

Coldwater Creek Variation 

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

public.referenceroom@ferc.gov. 
3-30 3.0 – Alternatives

TABLE 3.3-5 

 

Coldwater Creek Variation Comparison 

Environmental Factor Unit Coldwater Creek 

Variation 

Corresponding Segment 

of Proposed Route 

Length Miles 4.7 2.5 

Construction disturbance a/ Acres 71.2 37.9 

Perennial waterbody crossings Number 3 4 

Major waterbody crossings Number 0 1 

Wetland crossing Feet 500 b/ 0 

Forest land crossing Miles 3.9 1.6 

Open land crossing Miles 0.8 0.9 

________________________________________________________________ 

a/ Based on a nominal ROW width of 125 feet 

b/ NWI Mapped Wetland 

3.3.4 Other Pipeline Issues 

Southern Segment Design

A public comment was received requesting analysis of whether the proposed 42-inch-diameter 

pipeline could be reduced to a 36-inch-diameter pipeline along the Southern Segment (MPs 0.0 

to 104.8). Based on detailed hydraulic and engineering analysis, EEC has determined that a 

42-inch-diameter pipeline with a Maximum Allowable Operating Pressure (MAOP) of 1,250 

pounds per square inch (psi) would be required for the entire Southern Segment and first 10 

miles of the Northern Segment of the Elba Express Pipeline.15 A smaller-diameter pipeline 

would compromise EEC’s ability to ensure firm capacity and reliable delivery of required natural 

gas volumes to the target markets. Therefore, we conclude that a smaller-diameter pipeline 

design for the Southern Segment would not meet the Project purpose and need, and this 

alternative is eliminated from further consideration. 

Initial Ten Miles of Southern Segment

When EEC filed its application with the FERC, Southern already had a Commission Certificate16

to construct and operate the Cypress Expansion Project, which would involve construction of 

about 9.8 miles of 30-inch-diameter pipeline between the Port Wentworth Meter Station (Elba 

Express Pipeline, MP 0.0) and the Rincon Gate Meter Station (Elba Express Pipeline, MP 9.8) 

near Rincon, Georgia. This 9.8-mile-long segment of the Cypress Pipeline is planned for 

construction along Southern’s existing ROW in 2010 as Phase III of the Cypress Pipeline. 

 

15 It is also noteworthy to recall that between MPs 0.0-9.7, the 42-inch-diameter Elba Express Pipeline would be 

built in the place of the authorized 30-inch-diameter Cypress Pipeline. Elba would transport the natural gas 

originally proposed to be carried by the Cypress Pipeline, eliminating the need for a second pipeline. 16 See Order Issuing Certificates, issued on June 15, 2006, in Docket Nos. CP05-388-000 (Southern Natural Gas 

Company) and CP06-1-000 (Florida Gas Transmission Company). 
3-31 3.0 – Alternatives

Based on public comments collected during EEC’s Open Houses and scoping, EEC examined 

three possibilities for reducing construction impacts associated with two pipelines (Elba Express 

and Cypress) being constructed immediately adjacent to one another along the existing Southern 

ROW in the interval between Port Wentworth and Rincon. Alternatives considered included: 

• Replacement Pipeline Alternative – replacing one of Southern’s existing (smaller 

diameter) pipelines in the ROW with either the Cypress or Elba Express Pipeline; 

• Reduced Separation Alternative – constructing the Cypress and Elba Express Pipelines 

closer together in this area to avoid or minimize the need for additional ROW; and 

• One Pipeline Alternative – constructing one pipeline to carry the volumes of both the 

authorized Cypress Expansion Project and the proposed Elba Express Pipeline. 

During Pre-Filing, EEC studied these options, the existing Southern pipeline corridor, and the 

challenges that constructing two new large diameter pipelines along this 9.8-mile-long interval 

would pose. Taking a fully-operational pipeline used to fulfill firm transportation obligations out 

of service for replacement would create serious problems for Southern, as well as being a poor 

economic decision. On the other hand, reducing the separation distance between two largediameter pipelines would present problems during construction as well as long-term maintenance 

concerns. Further, construction through the saturated soils common in this interval of Southern’s 

system would result in a wider trench during construction, making reduced separation difficult to 

achieve and possibly threatening the stability of the existing adjacent pipelines. 

While the One Pipeline alternative may appear attractive, it would pose a number of unique 

difficulties. For instance, both projects are on different schedules. They have different tariffs 

and belong to different companies. Different agreements are in place with different obligations 

for different customers. Further, the Cypress Project received a FERC Certificate in June 2006 

while the Elba Express Pipeline is still in the permitting stage. And finally, if the second project 

is not constructed for some reason, then the first project would be unnecessarily burdened with 

the increased cost of the larger capacity pipeline. 

In the end, EEC and Southern (working with the shippers of the two projects) agreed to 

implement the One Pipeline Alternative and presented this option as EEC’s proposed action in its 

FERC application. This approach required the hydraulic design of the Elba Express Pipeline to 

be modified such that 10 more miles of 42-inch-diameter pipeline would be needed, as well as 

construction of an additional meter station at Rincon Gate to segregate the Elba Express and 

Cypress volumes. However, use of this alternative would reduce overall environmental impact 

associated with pipeline construction in the interval between Port Wentworth and Rincon Gate, 

and reduce congestion impact in an already and increasingly crowded area. 

3.3.5 Aboveground Facility Site Alternatives 

Elba Express Compressor Station 

Phase B of the proposed Elba Express Pipeline Project would involve construction of the Elba 

Express Compressor Station in the vicinity of northwest Screven County or southeast Jenkins 

County, Georgia. After reviewing several locations, EEC investigated two locations in detail: 
3-32 3.0 – Alternatives

the proposed site in Jenkins County (MP 58.5; see map 7 in appendix B) and an alternate site 

nearby in Screven County (at the same location of the proposed MLV #4, MP 53.3; see map 6). 

Based upon engineering, economic, and environmental impact considerations, EEC determined 

that the Jenkins County site would best satisfy the purpose and need of the Project. Figures 3.3-6 

and 3.3-7 are aerial photographs with land use overlays of the proposed site in Jenkins County 

and the alternate site in Screven County, respectively. 

EEC selected the proposed Jenkins County site over the alternate Screven County site for several 

reasons. First, the Screven County site is closer to noise sensitive areas (NSAs). The Jenkins 

County site has one NSA approximately 1,400 feet from the site (a church) and a second NSA 

approximately 3,500 feet from the site (a house used as a hunting lodge). The closest permanent 

residence is located approximately 1.1 miles from the Jenkins County site. The Screven County 

site has two NSAs approximately 1,500 feet from the site and several NSAs approximately 1,800 

feet from the site. Most of these NSAs are full time residences. Secondly, the area that 

surrounds the Jenkins County site generally is wooded, and the site is not visible from the nearby 

highway. The Screven County site is more visible from nearby roadways so the visual impacts 

of the Jenkins County site would be less than those of the Screven County site. Finally, the 

Jenkins County site is very close to a high voltage power line. In the event electric-driven 

compressors are selected for the Elba Express Compressor Station, a power source for the 

compressors would be readily available. In the case of the Screven County site, if electric-driven 

compressors were selected, a new high voltage power line would have to be constructed to the 

site, which would cause additional impacts. Based on these factors and our visit to both sites, we 

support EEC’s selection of the Jenkins County site. 

Miscellaneous Facilities

EEC proposes to construct eight meter stations, 11 MLVs, two pig launchers (42-inch and 36-

inch), and two pig receivers (42-inch and 36-inch) as part of the proposed Project. Our review of 

the proposed sites raised no issues (e.g., proximity to residences, impacts to wetlands) that 

warranted the identification and analysis of alternative sites for these proposed facilities. 
Non-Internet Public 

DRAFT 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 

Page 3-33 

Figure 3.3-6 

Proposed Compressor Station Site in Jenkins County, Georgia 

Public access for the above information is available only 

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

public.referenceroom@ferc.gov. 
Non-Internet Public 

DRAFT 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 

Page 3-34 

Figure 3.3-7 

Alternative Compressor Station Site in Screven County, Georgia 

Public access for the above information is available only 

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

public.referenceroom@ferc.gov.