A-1

APPENDIX A – DISTRIBUTION LIST 

Federally Elected 

Federal Courthouse, Ron Wyden, U.S. Senator, DC 

Secretary of Housing and Urban Development, OK 

U.S. House of Representatives, Jamie Herrera Beutler, The 

Honorable, DC 

U.S. House, Dave Reichert, Representative, WA 

U.S. House, Jaime Herrera Beutler, Representative, WA 

U.S. House, Rick Larsen, Representative, WA 

U.S. Senate, Jeff Merkley, Senator, OR 

U.S. Senate, Maria Cantwell, Senator, DC 

U.S. Senate, Maria Cantwell, Senator, DC 

U.S. Senate, Patty Murray, Senator, DC 

U.S. Senator Patty Murray, Mindi Linquist, Southwest 

Washington Director, WA 

Federal Agencies 

Acquisition Technology & Logistics, Peter Potochne, Acting 

Director, DC 

Bureau of Land Management-OR State Office, John 

Styduhar, OR 

Dept. of Commerce, Director, Ecology & Conservation, 

NOAA, DC 

Dept. of Transportation - Office of Pipeline Safety, Harold 

Winnie, MO 

Energy Facility Site Evaluation Council, Jim Luce, Chair, WA 

Fed. Aviation Administration, Matthew McMillen, Office of 

Environment and Energy, DC 

Fed. Communications Commission, Aliza Katz, NEPA 

contact, DC 

Fed. Highway Administration, Gerald Solomon, Director, DC 

Fed. Maritime Commission, Karen Gregory, Asst. Secretary, 

DC 

Federal Energy Reguatory Commission, Medha Kochhar, 

Project Manager, MD 

Federal Trade Commission, Asst. General Counsel, DC 

General Services Administration, Environmental Program 

Manager, DC 

HUD - Housing and Urban Dev, CA 

Minerals Management Service, James Bennett, Chief, 

Environmental Assessment Branch, VA 

National Marine Fisheries Service, Ben Meyer, OR 

National Marine Fisheries Service, Dr. Tom Sibley, Branch 

Chief-Northwest Region, WA 

National Marine Fisheries Service, Matt Longenbaugh, 

Branch Chief-Central Puget Sound, WA 

National Marine Fisheries Service, Scott Anderson, WA 

National Marine Fisheries Service, Tom Hausmann, WA 

National Marine Fisheries Service-Habitat Conserv Div, 

Michael Crouse, Asst. Regional Admin., OR 

National Marine Fisheries Service-NW Region, Robert D. 

Lohn, Regional Administrator, WA 

National Marine Fisheries Service-Office of Habitat 

Protection-SSMC 3, Marine Resource Habitat 

Specialist, MD 

National Marine Fisheries Service-Oregon State Habitat 

Branch, Michael Tehan, Director, OR 

National Marine Fisheries Service-Protected Resources 

Division, Donna Darm, Assist. Regional Admin, WA 

National Park Service, Lewis and Clark National Historic Trail, 

NE 

National Park Service-Pacific West Region, Susan 

Rosebrough, WA 

National Science Foundation, Charisse Carney-Nunes, VA 

Nuclear Reg. Commission, Osiris Siurano, Intergovernment 

Programs, DC 

Office of Environment/Health, Department of State, DC 

Office of Federal Activities - EPA, Ariel Rios, Acting Director, 

DC 

Office of Pipeline Safety, Karen Butler, MO 

Office of the Deputy Under Secretary of Defense, Robert 

Uhrich, Installations and Environment, DC 

Office of the Judge Advocate General, U.S.Coast Guard 

Headquarters, DC 

Office of the Under Secretary of Defense, IRM, DC 

Securities & Exchange Commission, David LaRoche, Special 

Counsel, DC 

Small Business Administration, Gary Fox, Asst. General 

Counsel, DC 

U.S. Army Corps of Engineers, Office of the Chief of Army 

Engineers, DC 

U.S. Army Corps of Engineers, Dominic Yballe, CENWP-ODG, OR 

U.S. Army Corps of Engineers, Jim Goudzwaard, Portland 

District, OR 

U.S. Army Corps of Engineers, Judy Linton, Portland District, 

OR 

U.S. Army Corps of Engineers, Olivia Romano, Project 

Manager, WA 

U.S. Army Corps of Engineers, Richard Chong, OR 

U.S. Army Corps of Engineers-Portland District, Marci 

Johnson, Planning and Outreach Specialist, OR 

U.S. Army Corps of Engineers-Seattle Dist., Peter Olmstead, 

SW WA Field Office, WA 

U.S. Bureau of Indian Affairs, Northwest Regional Office, OR 

U.S. Coast Guard Sector Portland, Russell Berg, OR 

U.S. Coast Guard, WA 

U.S. Coast Guard, Daniel LeBlanc, OR 

U.S. Coast Guard, Jack Hug, Chief, Environmental Law 

Branch, CA 

U.S. Coast Guard, Pacific Region, Dave Sox, Sr. 

Environmental Protection Specialist, CA 

U.S. Coast Guard, Patrick Gerrity, Commander, Sector 

Portland, OR 
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Federal Agencies (cont’d) 

U.S. Coast Guard-Office of Operating & Environmental 

Standards, Capt. Mike Blair, (CG-3PSO), DC 

U.S. Dept. of Agriculture, Natural Resources Conservation 

Service, WA 

U.S. Dept. of Agriculture, Office of Finance & Management, 

DC 

U.S. Dept. of Agriculture, Linda Goodman, Forest Service - 

Pacific NW Region, Regional Forester, OR 

U.S. Dept. of Commerce, NOAA, Director of Ecology & 

Conservation, DC 

U.S. Dept. of Commerce, Office of the Secretary, Senior 

Policy Advisor, DC 

U.S. Dept. of Energy, Office of Intergov Affairs--DOE, DC 

U.S. Dept. of Homeland Security, David Reese, 

Environmental Protection Specialist, DC 

U.S. Dept. of Homeland Security-U.S. Coast Guard, Chief, 

Port Security Branch, DC 

U.S. Dept. of Housing & Urban Development, Office of 

Environment and Energy, Director, DC 

U.S. Dept. of Labor, Mike O'Malley, Employment & Training, 

DC 

U.S. Dept. of State, Office of Environment/Health, DC 

U.S. Dept. of the Air Force, Environment & Safety, DC 

U.S. Dept. of the Interior MIB 2340, Dir. Ofc. of Environmental 

Policy & Compliance, DC 

U.S. Dept. of the Interior, Chip Jenkins, Deputy Regional 

Director, Pacific West Region, WA 

U.S. Dept. of the Interior, Donald Sutherland, Bureau of 

Indian Affairs, NEPA Coordinator, DC 

U.S. Dept. of the Interior, Elaine Brong, Bureau of Land 

Management, Oregon State Office, State Director, OR 

U.S. Dept. of Transportation - Marine Safety Office, Daniel 

Pippenger, Commander, OR 

U.S. Dept. of Transportation, Director - Environment and 

Policy, DC 

U.S. Dept. of Transportation, Environmental Policies, DC 

U.S. Dept. of Transportation, Pipeline & Hazardous Materials 

Safety Administration, DC 

U.S. Dept. of Transportation, Pipeline & HazMat Safety 

Admin, DC 

U.S. Dept. of Transportation, Office of Pipeline Safety, 

Administrator, Research & Special Programs, DC 

U.S. Dept. of Transportation, Chris Hoidal, Western Office 

OPS/RSPA, Director, CO 

U.S. Dept. of Transportation, Ellen Crum, Air Traffic Control 

Specialist, DC 

U.S. Dept. of Transportation, Kenneth Lee, Director of 

Engineering and Research Division Office of Pipeline 

Safety, DC 

U.S. Dept. of Transportation, Thomas Finch, CATS Manager, 

Western Region, PHMSA, CO 

U.S. Dept. of Transportaton - Office of Pipeline Safety, 

Research and Research Programs Admin., GA 

U.S. Environmental Protection Agency, Anthony Barber, 

Oregon Operations Office, Director, OR 

U.S. Environmental Protection Agency, Christine Reichgott, 

Manager, NEPA Review, WA 

U.S. Environmental Protection Agency, Teresa Kubo, OR 

U.S. Environmental Protection Agency, Yvonne Vallette, 

Oregon Operations Office, Aquatic Ecologist, OR 

U.S. Fish and Wildlife Service, Doug Young, Energy Program 

Coordinator, OR 

U.S. Fish and Wildlife Service, Greg Smith, Oregon Fish & 

Wildlife Office, OR 

U.S. Fish and Wildlife Service, Karen Myers, Biologist, WA 

U.S. Fish and Wildlife Service, Kemper McMaster, Oregon 

Fish & Wildlife Office, State Supervisor, OR 

U.S. Fish and Wildlife Service, Lisa Wood, WA 

U.S. Fish and Wildlife Service, Martha Jensen, Branch 

Manager-Division of Consultation and Technical 

Assistance, WA 

U.S. Fish and Wildlife Service, Rebecca Toland, Oregon Fish 

& Wildlife Office, OR 

U.S. Forest Service, Ecosystem Mgmt. Coordination, DC 

U.S. National Parks, Columbia Cascades Land Resources 

Program, WA 

USDA Natural Resource Conservation Service, OR 

USDA Forest Service, Jim Sauser, OR 

State Representatives – Oregon 

District 8 - OR, Paul Holvey, State Representative, OR 

OR Governor, Kate Brown, OR 

OR House of Representatives (Clatsop and Columbia 

Counties), Bradley Witt, OR 

OR House of Representatives, Arnie Roblan, Co-Speaker of 

the House, OR 

OR House of Representatives, Betty Komp, Representative, 

OR 

OR House of Representatives, Bruce Hanna, Co-Speaker of 

the House, OR 

OR House of Representatives, Deborah Boone, 

Representative, OR 

OR House of Representatives, Kim Thatcher, Representative, 

OR 

OR House of Representatives, Vic Gilliam, Representative, 

OR 

OR State Senate, Betsy Johnson, Senator, OR 

OR State Senate, Bruce Starr, Senator, OR 

OR State Senate, Larry George, Senator, OR 

OR State Senate, Lee Beyer, Senator, OR 

OR State Senate, Peter Courtney, Senator, OR 

State Representatives – Washington 

State of Washington Senate (Wahkiakum Cty), Brian Hatfield, 

The Honorable, WA 

State Representative - District 49, Nancy DeLeo, WA 

WA House of Representatives, Brian Blake, State 

Representative, WA 

WA House of Representatives, Dean Takko, State 

Representative, WA 

WA House of Representatives, Jim Moeller, Representative, 

WA 
 A-3

State Representatives – Washington (cont’d) 

Washington State Legislature, Andy Hill, Senator, WA 

Washington State Legislature, Ann Rivers, Representative, 

WA 

Washington State Legislature, Barbara Bailey, 

Representative, WA 

Washington State Legislature, Bruce Dammeier, 

Representative, WA 

Washington State Legislature, Cathy Dahlquist, 

Representative, WA 

Washington State Legislature, Charles Ross, Representative, 

WA 

Washington State Legislature, Christopher Hurst, 

Representative, WA 

Washington State Legislature, Curtis King, Senator, WA 

Washington State Legislature, Dan Kristiansen, 

Representative, WA 

Washington State Legislature, Derek Stanford, 

Representative, WA 

Washington State Legislature, Don Benton, Senator, WA 

Washington State Legislature, Doug Ericksen, Senator, WA 

Washington State Legislature, Ed Orcutt, Representative, WA 

Washington State Legislature, Graham Hunt, Representative, 

WA 

Washington State Legislature, Hans Dunshee, 

Representative, WA 

Washington State Legislature, Hans Zeiger, Representative, 

WA 

Washington State Legislature, J.T. Wilcox, Representative, 

WA 

Washington State Legislature, Jason Overstreet, 

Representative, WA 

Washington State Legislature, Jay Rodne, Representative, 

WA 

Washington State Legislature, Joe Fain, Senator, WA 

Washington State Legislature, Judy Clibborn, Representative, 

WA 

Washington State Legislature, Kirk Pearson, Representative, 

WA 

Washington State Legislature, Larry Springer, 

Representative, WA 

Washington State Legislature, Luis Moscoso, Representative, 

WA 

Washington State Legislature, Mark Hargrove, 

Representative, WA 

Washington State Legislature, Mark Harmsworth, 

Representative, WA 

Washington State Legislature, Maureen Walsh, 

Representative, WA 

Washington State Legislature, Mike Hewitt, Senator, WA 

Washington State Legislature, Norm Johnson, 

Representative, WA 

Washington State Legislature, Norma Smith, Representative, 

WA 

Washington State Legislature, Pam Roach, Senator, WA 

Washington State Legislature, Pat Sullivan, Representative, 

WA 

Washington State Legislature, Paul Harris, Representative, 

WA 

Washington State Legislature, Randi Becker, Senator, WA 

Washington State Legislature, Richard DeBolt, 

Representative, WA 

Washington State Legislature, Rodne Jay, Representative, 

WA 

Washington State Legislature, Roger Goodman, 

Representative, WA 

Washington State Legislature, Rosemary McAuliffe, Senator, 

WA 

Washington State Legislature, Steve Conway, Senator, WA 

Washington State Legislature, Steve Hobbs, Senator, WA 

Washington State Legislature, Steve Kirby, Representative, 

WA 

Washington State Legislature, Steve Litzow, Senator, WA 

Washington State Legislature, Steve O'Ban, Senator, WA 

Washington State Legislature, Tami Green, Representative, 

WA 

Washington State Legislature, Tana Senn, Representative, 

WA 

Washington State Legislature, Terry Nealey, Representative, 

WA 

Washington State Legislature, Vincent Buys, Representative, 

WA 

State Government Agencies – Oregon 

Columbia SWCD, OR 

Governor's Office, Margi Hoggmann, Energy Policy Advisor, 

OR 

Legislative Commission on Indian Services, Jeana 

Harrington, Commission Assistant, OR 

Legislative Commission on Indian Services, Karen Quigley, 

Executive Director, OR 

Northwest Clean Air Agency, Erica Shuler, WA 

ODFW North Coast Watershed District, Chris Knutsen, 

District Fish Biologist, OR 

Office of the State Fire Marshall, Stacy Warner, OR 

OR Building Codes Agency, Dana Roberts, OR 

OR Dept. of Agriculture, Bob Meinke, OR 

OR Dept. of Agriculture, Deb Cannon, Food Division, OR 

OR Dept. of Agriculture, Debbie Gorham, Administrator, OR 

OR Dept. of Agriculture, Jim Johnson, Land Use & Water 

Planning Coord., OR 

OR Dept. of Aviation, Jeff Caines, Aviation Planner, OR 

OR Dept. of Energy, Adam Bless, OR 

OR Dept. of Energy, Deanna Henry, Emergency 

Preparedness Manager, OR 

OR Dept. of Energy, Diana Enright, Assistant Director 

Renewable Energy Public Information, OR 

OR Dept. of Energy, Ken Niles, Nuclear Safety & Energy 

Siting, OR 

OR Dept. of Energy, Michael Grainey, Director, OR 
 A-4 

State Government Agencies – Oregon (cont’d) 

OR Dept. of Energy, Tom Stoops, Siting Manager, OR 

OR Dept. of Environmental Quality, Warrenton NWR Office, 

OR 

OR Dept. of Environmental Quality, Christine Svetkovich, OR 

OR Dept. of Environmental Quality, Jennifer Purcell, DEQ 

NW Region, OR 

OR Dept. of Environmental Quality, L. Alexandra Cyril, 401 

Water Quality Certification Specalist, OR 

OR Dept. of Environmental Quality, Neil Mullane, OR 

OR Dept. of Environmental Quality, NWR Storm Water, 

Dennis Jurries, OR 

OR Dept. of Fish & Wildlife, Art Martin, OR 

OR Dept. of Fish & Wildlife, Devin Simmons, OR 

OR Dept. of Fish & Wildlife, Herman Biederbeck, OR 

OR Dept. of Fish & Wildlife, Jon Germond, OR 

OR Dept. of Fish & Wildlife, Keith Braun, Biologist, OR 

OR Dept. of Fish & Wildlife, Rose Owens, Habitat Special 

Projects Coordinator, OR 

OR Dept. of Fish & Wildlife, Tom Murtaugh, District Fish 

Biologist, OR 

OR Dept. of Fish & Wildlife, Tom Rein, OR 

OR Dept. of Fish & Wildlife, Wayne van der Naald, OR 

OR Dept. of Forestry, OR 

OR Dept. of Forestry, Dan Goody, Tillamook District Forester, 

OR 

OR Dept. of Forestry, Forest Grove District, Mike Caferrata, 

District Forester, OR 

OR Dept. of Forestry, George Pointe, OR 

OR Dept. of Forestry, Joe Misek, OR 

OR Dept. of Forestry, John Tokarczyk, OR 

OR Dept. of Forestry, Ted Lorensen, Assistant State 

Forester, OR 

OR Dept. of Forestry, Todd Reinwald, State Forest Planning 

Coordinator, OR 

OR Dept. of Forestry, Tom Savage, District Forester, OR 

OR Dept. of Forestry: Astoria Dist., Cullen Bangs, OR 

OR Dept. of Geology & Mineral Industries, OR 

OR Dept. of Geology & Mineral Industries, Bill Burns, 

Engineering Geologist, OR 

OR Dept. of Geology & Mineral Industries, Dr. Vicki 

McConnell, OR 

OR Dept. of Highways, OR 

OR Dept. of Justice, Anika Marriott, OR 

OR Dept. of Justice, Lore Bensel, OR 

OR Dept. of Justice, Paul Garrahan, OR 

OR Dept. of Justice, Stephen Sanders, OR 

OR Dept. of Justice, Steve Shipsey, OR 

OR Dept. of State Lands, Ann Hanus, Director, OR 

OR Dept. of State Lands, Clara Taylor, Waterway Lease 

Agent, OR 

OR Dept. of State Lands, Janet Morlan, OR 

OR Dept. of State Lands, Jim Grimes, OR 

OR Dept. of State Lands, Kevin Moynahan, OR 

OR Dept. of State Lands, Lori Warner-Dickason, OR 

OR Dept. of State Lands, Louise Bos, OR 

OR Dept. of State Lands, Louise Solliday, Director, OR 

OR Dept. of Transportation Dist. 2A, Ron Kroop, OR 

OR Dept. of Transportation, OR 

OR Dept. of Transportation, OR 

OR Dept. of Transportation, District Manager - District 1 

Maintenance, OR 

OR Dept. of Transportation, David J. Neys, District Manager - 

District 1 Maintenance, OR 

OR Dept. of Transportation, Donald L. Jordan, OR 

OR Dept. of Transportation, Edward Miller, OR 

OR Dept. of Transportation, Ingrid Weisenbach, OR 

OR Dept. of Transportation, Kelvin Kohanes, OR 

OR Dept. of Transportation, Matt Caswell, OR 

OR Dept. of Veteran Affairs, OR 

OR Economic & Community Development Commission, Carl 

Talton, Commissioner, OR 

OR Economic & Community Development Commission, 

Marty Brantely, Director, OR 

OR Economic & Community Development Commission, Ron 

Fox, OR 

OR Economic & Community Development Commission, Tony 

Hyde, Commissioner, OR 

OR Governor's Office, Mike Carrier, Natural Resources Policy 

Director, OR 

OR Historical Society, George L Vogt, Executive Director, OR 

OR Invasive Species Council, Plant Division C/O Oregon 

Dept. of Agriculture, OR 

OR Natural Resources Council, Regna Merritt, Executive 

Director, OR 

OR Parks & Rec Dept., State Historic Preservation Office, Dr. 

Dennis Griffin, OR 

OR Parks & Rec Dept., State Historic Preservation Office, 

Jason Allen, OR 

OR Parks & Rec Dept., State Historic Preservation Office, 

Matthew Diederich, OR 

OR Parks & Rec Dept., Steve Brutscher, OR 

OR Public Utility Commission, Kenneth R. Zimmerman, 

Senior Analyst - Electric and Natural Gas Division, OR 

OR Public Utility Commission, Lee Beyer, OR 

OR State Board of Forestry, OR 

OR State Fire Marshall, OR 

OR State Marine Board, Randy Henry, OR 

OR Water Resources Dept., Dwight French, OR 

OR Water Resources Dept., Jerry Sauter, OR 

Oregon State Habitat Office, Kim W. Kratz, Director, WA 

Dept. of Community, Trade & Economic Dev, Allen Fiksdal, 

Manager, Energy, Facility, WA 

Dept. of Community, Trade & Economic Dev, Stephen 

Posner, EFSEC Specialist, Energy Facility, WA 
 A-5

State Government Agencies – Washington 

Dept. of Community, Trade & Economic Dev, Tony Usibelli, 

Assistant Director Energy Policy Division, WA 

Energy Facility Site Evaluation Council, Al Wright, Manager, 

Energy Facility, WA 

Governor’s Office of Regulatory Assistance, Alan Bogner, SW 

Region Lead, WA 

Governor's Office of Regulatory Assistance, Jane Dewell, 

Regional Lead, WA 

Northwest Clean Air Agency, Christoforou Christos, Air 

Quality Engineer, WA 

Northwest Clean Air Agency, Christos Christoforou, Air 

Quality Engineer, WA 

Northwest Clean Air Agency, Erica Shuhler, Air Quality 

Engineer, WA 

Office of Regulatory Assistance, Karen Pemerl, Director, WA 

Office of the Governor, Joby Shimomura, Chief of Staff, WA 

Puget Sound Clear Air Agency, Gerry Pade, Air Quality 

Engineer, WA 

Southwest Clean Air Agency, Vannessa McClelland, Air 

Quality Engineer, WA 

State Historic Preservation Office, Dr. Robert Whitlam, State 

Archaeologist, WA 

State of Washington, WA 

State of Washington, Paul L & Karen J Johansen, WA 

State School Land, WA 

WA Dept. of Commerce, Brian Bonlender, Director, WA 

WA Dept. of Ecology, Brenden McFarland, Manager, 

Shorelands and Environmental Assistance (HQ), WA 

WA Dept. of Ecology, Helen Pressley, Shorelands & 

Environmental Assistance, WA 

WA Dept. of Ecology, Jeanie Summerhays, Shorelands & 

Environmental Assistance, WA 

WA Dept. of Ecology, Lori Ochoa, Federal Permit 

Coordinator, SW Region, WA 

WA Dept. of Ecology, Marc Crooks, WA 

WA Dept. of Ecology, Paula Ehlers, WA 

WA Dept. of Ecology, Perry Lund, WA 

WA Dept. of Ecology, Rebecca Schroeder, WA 

WA Dept. of Ecology, Rebekah Padgett, Federal Permit 

Coordinator, NW Region, WA 

WA Dept. of Ecology, Ryan Paulsen, WA 

WA Dept. of Ecology, Sally Toteff, Director SW Regional 

Office, WA 

WA Dept. of Ecology, Terry Swanson, WA 

WA Dept. of Fish and Wildlife - Southwest Region 5, Tim 

Rymer, Regional Habitat Program Manager, WA 

WA Dept. of Fish and Wildlife, Anne Friesz, Assistant 

Regional Habitat Program Manager, WA 

WA Dept. of Fish and Wildlife, Brock Applegate, Major 

Projects Mitigation Biologist, WA 

WA Dept. of Fish and Wildlife, Dave Howe, Program 

Manager, Region 5, WA 

WA Dept. of Fish and Wildlife, Joel Ingram, WA 

WA Dept. of Fish and Wildlife, Leonard Machut, WA 

WA Dept. of Fish and Wildlife, Region 5, Steve West, Area 

Habitat Biologist, WA 

WA Dept. of Fish and Wildlife, Stephan Kalinowski, Program 

Manager, WA 

WA Dept. of Fish and Wildlife, Wendy Cole, WA 

WA Dept. of Natural Resources - Aquatic Region Rivers 

District, Scott Robinson, WA 

WA Dept. of Natural Resources - Aquatic Resources Division, 

Courtney Wasson, DMMP Manager, WA 

WA Dept. of Natural Resources, Art Tasker, Region Manager, 

WA 

WA Dept. of Natural Resources, Ben Cleveland, Region 

Manager, WA 

WA Dept. of Natural Resources, Curt Pavola, WA 

WA Dept. of Natural Resources, Darin Cramer, Division 

Manager, WA 

WA Dept. of Natural Resources, Dennis Clark, WA 

WA Dept. of Natural Resources, Eric Wilsch, Region 

Manager, WA 

WA Dept. of Natural Resources, Kristin Swenddal, WA 

WA Dept. of Natural Resources, WA 

WA Dept. of Transportation, WA 

WA Dept. of Transportation, Jeff Barsness, Southwest Region 

Development Services Manager, WA 

Washington Governor, Jay Inslee, Governor, WA 

Washington Governor's Office, Office of the Governor, WA 

Washington State Conservation Commission, WA 

Washington State Department of Agriculture, Dan Newhouse, 

Director, WA 

Washington State Department of Game, WA 

Washington State Forest Board, WA 

Washington State Noxious Weed Control Board, WA 

Washington Utilities Transportation Commission, David 

Lykken, Pipeline Safety Director, WA 

Washington Utilities Transportation Commission, Jeffrey 

Goltz, Chair, WA 

Washington Utilities Transportation Commission, Joe Subsits, 

Pipeline Safety Program, WA 

Washington Utilities Transportation Commission, Patrick 

Oshie, Commissioner, WA 

Washington Utilities Transportation Commission, Phil Jones, 

Commissioner, WA 

Washington, State of, Pierce College, WA 

Local Government Agenies – Oregon 

City of Astoria, Arline LaMear, Councilor, OR 

City of Astoria, John Compere, Community Liaison, OR 

City of Astoria, Karen Mellin, Councilor, OR 

City of Astoria, Peter Roscoe, Councilor, OR 

City of Astoria, Russ Warr, Councilor, OR 

City of Astoria, Willis VanDusen, Mayor, OR 

City of Banks, Brian Biehl, Councilor, OR 

City of Banks, Craig Stewart, Councilor, OR 

City of Banks, Jason Short, Councilor, OR 
 A-6 

Local Government Agenies – Oregon (cont’d) 

City of Banks, Pete Edison, Councilor, OR 

City of Banks, Ron Kemper, Councilor, OR 

City of Banks, Teri Branstitre, Mayor, OR 

City of Carlton, Carey Rhoads, Councilor, OR 

City of Carlton, David Vandewalle, Councilor, OR 

City of Carlton, Ginger Williams, Councilor, OR 

City of Carlton, Jesse Berry, Councilor, OR 

City of Carlton, Kathie Oriet, Mayor, OR 

City of Carlton, Scott Carl, Councilor, OR 

City of Carlton, Steven Weaver, City Manager, OR 

City of Cornelius, Brad Coffey, Councilor, OR 

City of Cornelius, David Waffle, City Manager, OR 

City of Cornelius, Jeffrey Dalin, Councilor, OR 

City of Cornelius, Neal Knight, Mayor, OR 

City of Cornelius, Robert Ferrie, Councilor, OR 

City of Cornelius, Steve Heinrich, Councilor, OR 

City of Dayton, Jolie White, Mayor, OR 

City of Dayton, Monte Blackburn, Councilor, OR 

City of Dayton, Sue Hollis, City Manager, OR 

City of Forest Grove, Camille Miller, Councilor, OR 

City of Forest Grove, Elena Uhing, Councilor, OR 

City of Forest Grove, Michael Sykes, City Manager, OR 

City of Forest Grove, Pete Truax, Councilor, OR 

City of Forest Grove, Richard Kidd, Mayor, OR 

City of Forest Grove, Ron Thompson, Councilor, OR 

City of Forest Grove, Tom Johnston, Councilor, OR 

City of Forest Grove, Victoria Lowe, Councilor, OR 

City of Gaston, Dwain McKenzie, Councilor, OR 

City of Gaston, Ed Schult, Councilor, OR 

City of Gaston, Grace Haines-Kloock, Councilor, OR 

City of Gaston, Jon Georg, Councilor, OR 

City of Gaston, Richard Sager, Councilor, OR 

City of Gaston, Rick Lorenz, Mayor, OR 

City of Gearhart, Carole Connell, City Planner, OR 

City of Gearhart, Chuck Schluter, Councilor, OR 

City of Gearhart, Dennis McNally, Councilor, OR 

City of Gearhart, Dianne Widdop, Councilor, OR 

City of Gearhart, Dorothy Well, Councilor, OR 

City of Gearhart, Ed Tice, Councilor, OR 

City of Gearhart, Kent Smith, Mayor, OR 

City of Gearhart, Lauren Schibye, Student Representative, 

OR 

City of Gervais, John Harvey, Council President, OR 

City of Gervais, Michael Gregory, Councilor, OR 

City of Gervais, Pamela Milam, Councilor, OR 

City of Gervais, Sam Sasaki, City Manager, OR 

City of Gervais, Sandra Foote, Councilor, OR 

City of Gervais, Shanti Platt, City Mayor, OR 

City of Gervais, Tony Miller, Councilor, OR 

City of Hubbard, Angie Wheatcroft, Councilor, OR 

City of Hubbard, Bruce Warner, Councilor, OR 

City of Hubbard, Chip Enbody, Councilor, OR 

City of Hubbard, Matt Kennedy, Councilor, OR 

City of Hubbard, Mike Hill, Planning Commission Chair, OR 

City of Hubbard, Tom McCain, Mayor, OR 

City of Lafayette, Art Bixman, Councilor, OR 

City of Lafayette, Bob Cullen, Councilor, OR 

City of Lafayette, Diane Rinks, City Administrator, OR 

City of Lafayette, Don Leard, Mayor, OR 

City of Lafayette, James Rue, Councilor, OR 

City of Lafayette, Lisa Heatherly, Councilor, OR 

City of Lafayette, Matt Smith, Councilor, OR 

City of Lafayette, Michael Roberts, Councilor, OR 

City of McMinnville, Dave Hansen, Councilor, OR 

City of McMinnville, Ed Gormley, Mayor, OR 

City of McMinnville, Kellie Menke, Councilor, OR 

City of McMinnville, Kent Taylor, City Manager, OR 

City of McMinnville, Larry Yoder, Councilor, OR 

City of McMinnville, Paul May, Councilor, OR 

City of McMinnville, Rick Olson, Councilor, OR 

City of McMinnville, Scott Hill, Councilor, OR 

City of Molalla, Donna Jacober, City Council, OR 

City of Molalla, Glen Boreth, City Council, OR 

City of Molalla, James Needham, City Council, OR 

City of Molalla, Mary Jo Mackie, City Council, OR 

City of Molalla, Shane Potter, Planning Director, OR 

City of Molalla, Tom Foster, Mayor, OR 

City of Saint Paul, Charlie Bernards, Councilor, OR 

City of Saint Paul, Jay Phillips, Councilor, OR 

City of Saint Paul, Kathy Connor, Mayor, OR 

City of Saint Paul, Kelly Fowler, Councilor, OR 

City of Saint Paul, Mike Bernard, Councilor, OR 

City of Saint Paul, Walt Wendolowski, City Planner, OR 

City of Seaside, Dave Moore, Councilor, OR 

City of Seaside, Don Johnson, Councilor, OR 

City of Seaside, Don Larson, Mayor, OR 

City of Seaside, Gary Diebold, Councilor, OR 

City of Seaside, Kevin Cupples, City Planner, OR 

City of Seaside, Larry Haller, Councilor, OR 

City of Seaside, Mark Winstanley, City Manager, OR 

City of Seaside, Stubby Lyons, Councilor, OR 

City of Seaside, Tim Tolan, Councilor, OR 

City of St. Helens, Randy Peterson, Mayor and Interim City 

Administrator, OR 

City of Warrenton, OR 

City of Warrenton, Bob Maxfield, City Manager, OR 
 A-7

Local Government Agenies – Oregon (cont’d) 

City of Warrenton, Carol Parker, City Planner, OR 

City of Warrenton, Dick Hellberg, OR 

City of Warrenton, Don Snyder, Public Works Director, OR 

City of Warrenton, Edward Madere, City Manager, OR 

City of Warrenton, Frank Orrell, City Council, OR 

City of Warrenton, James (Lessee) Scarborough, OR 

City of Warrenton, Mark Kujala, Mayor, OR 

City of Warrenton, Russ Farmer, OR 

City of Warrenton, Skip Urling, Community Development 

Director, OR 

City of Warrenton, Ted Ames, Fire Chief, OR 

City of Warrenton, Terry Ferguson, City Council, OR 

City of Woodburn, City Council, OR 

City of Woodburn, City Planner, OR 

City of Woodburn, John Brown, City Administrator, OR 

City of Woodburn, Kathy Figley, Mayor, OR 

City of Yamhill, Kay Echauri, Councilor, OR 

City of Yamhill, Melvin Jordan, Council President, OR 

City of Yamhill, Paula Terp, Councilor, OR 

City of Yamhill, Randy Murphy, Mayor, OR 

City of Yamhill, Senz Chris, Councilor, OR 

Clackamas County, Martha Schrader, Commissioner, OR 

Clatsop County Board of Commissioners, Peter Huhtala, 

Chairperson, OR 

Clatsop County Farm Bureau, Mike Seppa, OR 

Clatsop County Planning Dept., Kathleen Sellman, CDD 

Director, OR 

Clatsop County, Ann Samuelson, Commissioner, OR 

Clatsop County, Helen Westbrook, Commissioner, OR 

Clatsop County, Hiller West, Director, Land Use Planning, OR 

Clatsop County, Jeff Hazen, Commissioner, OR 

Clatsop County, Jennifer Bunch, OR 

Clatsop County, Lyla Gaebel, Commissioner, OR 

Clatsop County, Patricia Roberts, Commissioner, OR 

Clatsop County, Richard Lee, Commissioner, OR 

Clatsop County, Samuel Patrick, Commissioner, OR 

Clatsop Soil & Water Conservation District, Misty Ogier, OR 

Columbia County, Joe Corsiglia, Commissioner, OR 

Columbia County, Rita Bernhard, Commissioner, OR 

Columbia County, Todd Dugdale, Land Development 

Services Director, OR 

Columbia County, Tony Hyde, Commissioner, OR 

Columbia River Estuary Study Taskforce, Denise Lofman, 

Director, OR 

Columbia River PUD, OR 

Marion County Farm Bureau, Dan Goffin, President, OR 

Marion County, Janet Carlson, Commissioner, OR 

Marion County, Patti Milne, Commissioner, OR 

Marion County, Sam Brentano, Commissioner, OR 

Tillamook County, Brad Sheets, Associate Planner, OR 

Tillamook County, Mark Labhart, Commissioner, OR 

Tillamook County, Tim Josi, Commissioner, OR 

Tualatin Soil & Water Conservation District Board, Jerry 

Ward, Chair, OR 

Washington County, Andy Duyck, Commissioner, OR 

Washington County, Dick Schouten, Commissioner, OR 

Washington County, Roy Rogers, Commissioner, OR 

Washington County, Terry Lawler, OR 

Washington County, Tom Brian, Commissioner, OR 

Yamhill County, Kathy George, Commissioner, OR 

Yamhill County, Leslie Lewis, Commissioner, OR 

Yamhill County, Mary Stern, Commissioner, OR 

Local Government Agenies – Washington 

City of Auburn, Bill Peloza, Councilor, WA 

City of Auburn, Bob Lee, Police Chief, WA 

City of Auburn, Chris Andersen, WA 

City of Auburn, Claude DaCorsi, Councilor, WA 

City of Auburn, Daniel B. Heid, City Attorney, WA 

City of Auburn, Daryl Faber, Parks & Recreation, WA 

City of Auburn, Jeff Tate, Assistant Director, Community 

Development, WA 

City of Auburn, John Holman, Councilor, WA 

City of Auburn, Kevin Snyder, Public Works Director, WA 

City of Auburn, Largo Wales, Councilor, WA 

City of Auburn, Nancy Backus, Mayor, WA 

City of Auburn, Nancy Welch, Director of Planning, WA 

City of Auburn, Richard Wagner, Deputy Mayor, WA 

City of Auburn, Wayne Osborne, Councilor, WA 

City of Auburn, Yolanda Trout, Councilor, WA 

City of Bellingham, Cathy Lehman, Councilor, WA 

City of Bellingham, Gene Knutson, Councilor, WA 

City of Bellingham, Jack Weiss, Councilor, WA 

City of Bellingham, James King, Parks & Recreation Director, 

WA 

City of Bellingham, Jeff Thomas, Planning Director, WA 

City of Bellingham, Kelli Linville, Mayor, WA 

City of Bellingham, Mark Gill, Interim Police Chief, WA 

City of Bellingham, Michael Lilliquist, Councilor, WA 

City of Bellingham, Peter Raffato, City Attorney, WA 

City of Bellingham, Pinky Vargas, Councilor, WA 

City of Bellingham, Roger Christensen, Fire Chief, WA 

City of Bellingham, Roxanne Murphy, Councilor, WA 

City of Bellingham, Ted Carlson, Public Works Director, WA 

City of Bellingham, Terry Bornemann, Councilor, WA 

City of Bonney Lake, Dan Grisby, Public Works Director, WA 

City of Bonney Lake, Dan Morrison, City Administrator, WA 

City of Bonney Lake, Dan Swatman, Councilor, WA 

City of Bonney Lake, Dana Powers, Police Chief, WA 
 A-8 

Local Government Agenies – Washington (cont’d) 

City of Bonney Lake, Donn Lewis, Councilor, WA 

City of Bonney Lake, James Rackley, Councilor, WA 

City of Bonney Lake, Jason Sullivan, Senior Planner, WA 

City of Bonney Lake, John Vodopich, Community 

Development Dir., WA 

City of Bonney Lake, Katrina Minton-Davis, Councilor, WA 

City of Bonney Lake, Mark Hamilton, Councilor, WA 

City of Bonney Lake, Neil Johnson, Mayor, WA 

City of Bonney Lake, Randy McKibbin, Councilor, WA 

City of Bonney Lake, Tom Watson, Councilor, WA 

City of Burlingon, Bill Van Wieringen, Police Chief, WA 

City of Burlington, Bill Aslett, Councilor, WA 

City of Burlington, Chris Loving, Councilor, WA 

City of Burlington, Dave Nielson, Fire Chief, WA 

City of Burlington, Edie Edmundson, Councilor, WA 

City of Burlington, Garnor Bensen, Councilor, WA 

City of Burlington, Margaret Fleek, Planning Director, WA 

City of Burlington, Mary Pulst P.E.,, Public Works Director, 

WA 

City of Burlington, Rick DeGloria, Councilor, WA 

City of Burlington, Steve Sexton, Mayor, WA 

City of Burlington, Ted Montgomery, Councilor, WA 

City of Burlington, Tonya Bieche, Councilor, WA 

City of Castle Rock, Bob Heuer, Police Chief, WA 

City of Castle Rock, David Vorse, Public Works Director, WA 

City of Castle Rock, Earl Queen, Councilor, WA 

City of Castle Rock, Ellen Rose, Councilor, WA 

City of Castle Rock, Glenn Pingree, Councilor, WA 

City of Castle Rock, Mike Davis, Councilor, WA 

City of Castle Rock, Paul Helenberg, Mayor, WA 

City of Castle Rock, Ray Teter, Councilor, WA 

City of Castle Rock, T.J. Keiran, City Planner, WA 

City of Centralia, Bart Ricks, Councilor, WA 

City of Centralia, Bonnie Canaday, Councilor, WA 

City of Centralia, Emil Pierson, Community Development 

Director, WA 

City of Centralia, Gabe Anzelini, Councilor, WA 

City of Centralia, Harlan Thompson, Mayor, WA 

City of Centralia, Jim Walkowski, Fire Chief, WA 

City of Centralia, John Elmore, Councilor, WA 

City of Centralia, Kahle Jennings, Public Works Director, WA 

City of Centralia, Lee Coumbs, Councilor, WA 

City of Centralia, Patrick Gallgher, Councilor, WA 

City of Centralia, Rob Hill, City Manager, WA 

City of Centralia, Robert Berg, Police Chief, WA 

City of Centralia, Ron Greenwood, Councilor, WA 

City of Centralia, Shannon Murphy, City Attorney, WA 

City of Centralia, Tammy Baraconi, Planning Director, WA 

City of Chehalis, Anthony Ketchum, Mayor, WA 

City of Chehalis, Chad Taylor, Councilor, WA 

City of Chehalis, Daryl Lund, Councilor, WA 

City of Chehalis, Dennis Dawes, Councilor, WA 

City of Chehalis, Dennis Osborne, Community Development 

Dir., WA 

City of Chehalis, Glenn Schaffer, Police Chief, WA 

City of Chehalis, Issac Pope, Councilor, WA 

City of Chehalis, Jim Walkowski, Fire Chief, WA 

City of Chehalis, Merlin MacReynold, City Manager, WA 

City of Chehalis, Rick Sahlin, Public Works Director, WA 

City of Chehalis, Robert Spahr, Councilor, WA 

City of Chehalis, Terry Harris, Mayor Pro-Tem, WA 

City of Chehalis, William Hillier, City Attorney, WA 

City of Covington, Derek M. Matheson, City Manager, WA 

City of Covington, Don Vondran, Public Works Director, WA 

City of Covington, James Scott, Councilor, WA 

City of Covington, Jeff Wagner, Mayor Pro-Tem.Councilor, 

WA 

City of Covington, Joseph Cimaomo Jr., Councilor, WA 

City of Covington, Kevin Klason, Police Chief, WA 

City of Covington, Margaret Harto, Mayor, WA 

City of Covington, Mark Lanza, Councilor, WA 

City of Covington, Marlla Mhoon, Councilor, WA 

City of Covington, Nelson Ogren, WA 

City of Covington, Richard Hart, Community Development 

Dir., WA 

City of Covington, Salina Lyons, Principal Planner, WA 

City of Covington, Scott Thomas, Parks & Recreation 

Director, WA 

City of Covington, Wayne Snoey, Councilor, WA 

City of Everett, WA 

City of Everett, Allan Giffen, Planning Director, WA 

City of Everett, Dave Davis, Public Works Director, WA 

City of Everett, Kathy Atwood, Police Chief, WA 

City of Everett, Murray Gordon, Fire Chief, WA 

City of Everett, Paul Kaftanski, Parks Director, WA 

City of Everett, Richard Anderson, Councilor, WA 

City of Everson, Andy Jewell, Councilor, WA 

City of Everson, Andy Rowlson, Councilor, WA 

City of Everson, Dan MacPhee, Police Chief, WA 

City of Everson, Eric Oettel, Councilor, WA 

City of Everson, Jennifer Lautenbach, Councilor, WA 

City of Everson, John Sitkin, City Attorney, WA 

City of Everson, Rick Holt, Public Works Director, WA 

City of Everson, Rollin Harper, Planning Director, WA 

City of Granite Falls, Brent Kirk, Public Works Supervisor, WA 

City of Granite Falls, Don Lauer, Acting Police Chief, WA 

City of Granite Falls, Joshua Golston, Mayor, WA 

City of Granite Falls, Matt Hartman, Councilor, WA 

City of Granite Falls, Ray Sturtz, Planning Director, WA 
 A-9

Local Government Agenies – Washington (cont’d) 

City of Granite Falls, Suzie Ashworth, Councilor, WA 

City of Granite Falls, Tess Greene, Councilor, WA 

City of Granite Falls, Thomas Fitzgerald, Councilor, WA 

City of Granite Falls, Tom Collins, Councilor, WA 

City of Ilawco, Flint Wright, Police Chief, WA 

City of Ilawco, Tom Williams, Fire Chief, WA 

City of Issaquah, WA 

City of Issaquah, Anne McGill, Parks & Recreation Director, 

WA 

City of Issaquah, Brenda Bramwell, Emergency Mgmt. 

Coordinator, WA 

City of Issaquah, Charlie Bush, Deputy City Administrator, 

WA 

City of Issaquah, Eileen Barber, Councilor, WA 

City of Issaquah, Fred Butler, Mayor, WA 

City of Issaquah, Jason Rogers, Developmental Services, WA 

City of Issaquah, Joshua Schaer, Councilor, WA 

City of Issaquah, Keith Niven, Economic Development 

Director, WA 

City of Issaquah, Lee A. Soptich, Fire Chief, WA 

City of Issaquah, Lynne Sheldon, Public Works Director, WA 

City of Issaquah, Mark Hinthorne, Planning Director, WA 

City of Issaquah, Mary Lou Pauly, Councilor, WA 

City of Issaquah, Matt Mechler, Open Space Steward, WA 

City of Issaquah, Nina Milligan, Councilor, WA 

City of Issaquah, Paul Ayers, Chief of Police, WA 

City of Issaquah, Paul Winterstein, Councilor, WA 

City of Issaquah, Stacy Goodman, Councilor, WA 

City of Issaquah, Tola Marts, Councilor, WA 

City of Kalama, Adam Smee, City Administrator, WA 

City of Kalama, Dominic Ciancibelli, Councilor, WA 

City of Kalama, Donald Purvis, Mayor Pro-Tem, WA 

City of Kalama, Mary Putka, Councilor, WA 

City of Kalama, Matt Hermen, Planning Director, WA 

City of Kalama, Mike Langham, Councilor, WA 

City of Kalama, Mike Truesdell, Councilor, WA 

City of Kalama, Paul Brachvogel, City Attorney, WA 

City of Kalama, Pete Poulsen, Mayor, WA 

City of Kalama, Randy Gibson, Police Chief, WA 

City of Kelso, Andrew O. Hamilton, Police Chief, WA 

City of Kelso, Dan Myers, Councilor, WA 

City of Kelso, David Futcher, Mayor, WA 

City of Kelso, Frank Randolph, City Attorney, WA 

City of Kelso, Gary Archer, Councilor, WA 

City of Kelso, Gary Schimmel, Councilor, WA 

City of Kelso, Kim Lefebvre, Councilor, WA 

City of Kelso, Michael Kardas, Community Development Dir., 

WA 

City of Kelso, Rick Roberson, Councilor, WA 

City of Kelso, Steve Taylor, City Manager, WA 

City of Kelso, Todd McDaniel, Deputy Mayor, WA 

City of Kent, Bill Boyce, Councilor, WA 

City of Kent, Dana Ralph, Councilor, WA 

City of Kent, Deborah Ranniger, Councilor, WA 

City of Kent, Dennis Higgins, Councilor, WA 

City of Kent, Fred Satterstrom, Planning Director, WA 

City of Kent, Jim Berrios, Councilor, WA 

City of Kent, Jim Schneider, Fire Chief, WA 

City of Kent, John Hodgson, Chief Adminstrative Officer, WA 

City of Kent, Kelly Peterson, AICP, Environmental 

Conservation Supervisor, WA 

City of Kent, Ken Thomas, Police Chief, WA 

City of Kent, Kurt Hanson, AICP, Economic Development 

Manager, WA 

City of Kent, Les Thomas, Councilor, WA 

City of Kent, Suzette Cooke, Mayor, WA 

City of Kent, Tim LaPorte, Public Works Director, WA 

City of Kent, Tom Brubaker, City Attorney, WA 

City of Lake Stevens, Becky Ableman, Planning Director, WA 

City of Lake Stevens, John Spencer, Councilor, WA 

City of Lake Stevens, Kathy Holder, Councilor, WA 

City of Lake Stevens, Kim Daughtry, Councilor, WA 

City of Lake Stevens, Marcus Tageant, Councilor, WA 

City of Lake Stevens, Mark Somers, Councilor, WA 

City of Lake Stevens, Mike Monken, Public Works Director, 

WA 

City of Lake Stevens, Randy Celori, Police Chief, WA 

City of Lake Stevens, Sam Low, Councilor, WA 

City of Lake Stevens, Suzanne Quigley, Councilor, WA 

City of Lake Stevens, Vern Little, Mayor, WA 

City of Longview, Bob Gregory, City Manager, WA 

City of Maple Valley, Bill Allison, Mayor, WA 

City of Maple Valley, Christy Todd, City Attorney, WA 

City of Maple Valley, David Johnston, City Manager, WA 

City of Maple Valley, Erin Weaver, Councilor, WA 

City of Maple Valley, Greg Brown, Parks & Recreation 

Director, WA 

City of Maple Valley, Layne Barnes, Councilor, WA 

City of Maple Valley, Linda Johnson, Councilor, WA 

City of Maple Valley, Matt Torpey, Senior Planner, WA 

City of Maple Valley, Noel Gerken, Councilor, WA 

City of Maple Valley, Sean Kelly, Deputy Mayor, WA 

City of Maple Valley, Steve Clark, Public Works Director, WA 

City of Maple Valley, Victoria Laise Jonas, Councilor, WA 

City of Marysville, Donna Wright, Councilor, WA 

City of Marysville, Gloria Hirashima, Community Development 

Dir., WA 

City of Marysville, Jeff Seibert, Councilor, WA 

City of Marysville, Jeffrey Vaughan, Mayor Pro Tem, WA 
 A-10 

Local Government Agenies – Washington (cont’d) 

City of Marysville, Jim Ballew, Parks & Recreation Director, 

WA 

City of Marysville, Jon Nehring, Mayor, WA 

City of Marysville, Kamille Norton, Councilor, WA 

City of Marysville, Kevin Nielsen, Public Works Director, WA 

City of Marysville, Michael Stevens, Councilor, WA 

City of Marysville, Rick Smith, Police Chief, WA 

City of Marysville, Roy Toyer, Councilor, WA 

City of Marysville, Steven C. Muller, Councilor, WA 

City of Monroe, Brad Feilberg, P.E., Public Works Director, 

WA 

City of Monroe, Ed Davis, Councilor, WA 

City of Monroe, Geoffrey Thomas, Mayor, WA 

City of Monroe, Jamie Silva, Fire Chief, WA 

City of Monroe, Jason Gamble, Councilor, WA 

City of Monroe, Jeff Rasmussen, Councilor, WA 

City of Monroe, Jim Kamp, Councilor, WA 

City of Monroe, Kevin Hanford, Councilor, WA 

City of Monroe, Kurt Goering, Councilor, WA 

City of Monroe, Mike Farrell, Parks & Recreation Director, WA 

City of Monroe, Patsy Cudaback, Councilor, WA 

City of Monroe, Paul Popelka, RLA/AICP, Planning & 

Permitting Manager, WA 

City of Monroe, T. Quenzer, Police Chief, WA 

City of Mount Vernon, Bob Fiedler, Councilor, WA 

City of Mount Vernon, Dale Ragan, Councilor, WA 

City of Mount Vernon, Esco Bell P.E.,, Public Works Director, 

WA 

City of Mount Vernon, Gary Molenaar, Councilor, WA 

City of Mount Vernon, Jill Boudreau, Mayor, WA 

City of Mount Vernon, Joe Lindquist, Councilor, WA 

City of Mount Vernon, Ken Quam, Councilor, WA 

City of Mount Vernon, Larry Otos, Parks & Recreation 

Director, WA 

City of Mount Vernon, Mark Hulst, Councilor, WA 

City of Mount Vernon, Mike Urban, Councilor, WA 

City of Napavine, Jennifer Slemp, Councilor, WA 

City of Napavine, John Sayers, Mayor, WA 

City of Napavine, Kenneth Twining, Superintendent, WA 

City of Napavine, LaVerne Haslett, Councilor, WA 

City of Napavine, Lionel Pinn, Councilor, WA 

City of Napavine, Robert A. Wheeler, Councilor, WA 

City of Napavine, S. Elwood, Officer in Charge, WA 

City of Napavine, Scott Hamilton, Councilor, WA 

City of Napavine, Steve Ashley, Community Development 

Director, WA 

City of Nooksack, Bruce Likkel, Public Works Director, WA 

City of Nooksack, Daniel Bennett, Councilor, WA 

City of Nooksack, Fritz Zemler, Councilor, WA 

City of Nooksack, Jim Ackerman, Mayor, WA 

City of Nooksack, Marshall Judy, Councilor, WA 

City of Nooksack, Mel Blankers, Fire Chief, WA 

City of Nooksack, Scott Bodven, Councilor, WA 

City of Nooksack, Tom Fryer, City Attorney, WA 

City of Nooksack, Tom Jones, Councilor, WA 

City of Puyallup, Brian Jeter, Police Chief, WA 

City of Puyallup, Dan Handa, Public Park, WA 

City of Puyallup, Heather Shadko, Councilor, WA 

City of Puyallup, John D. Knutsen, Deputy Mayor, WA 

City of Puyallup, John Hopkins, Councilor, WA 

City of Puyallup, John Palmer, Councilor, WA 

City of Puyallup, Julie Door, Councilor, WA 

City of Puyallup, Kevin Yamato, City Attorney, WA 

City of Puyallup, Rick Hansen, Councilor, WA 

City of Puyallup, Rob Andreotti, Public Works Director, WA 

City of Puyallup, Sarah Harris, Parks Administrator, WA 

City of Puyallup, Steve Vermillion, Councilor, WA 

City of Puyallup, Tom Swanson, Councilor, WA 

City of Puyallup, Tom Utterback, Planning Director, WA 

City of Puyallup, William McDonald, City Manager, WA 

City of Rainier, Fire Chief, WA 

City of Rainier, Bob Shaw, Councilor, WA 

City of Rainier, Christine Winslow, Councilor, WA 

City of Rainier, Dennis McVey, Councilor, WA 

City of Rainier, Fred Evander, Planning Director, WA 

City of Rainier, Kristin Guizzetti, Councilor, WA 

City of Rainier, Randy Schleis, Mayor, WA 

City of Rainier, Ronald Gibson, Public Works Director, WA 

City of Rainier, Tom Ambrister, Councilor, WA 

City of Rainier, William Cameron, City Attorney, WA 

City of Sammamish Finance Dept, Jeff Brauns, City Engineer, 

WA 

City of Sammamish, Ben Yazici, City Manager, WA 

City of Sammamish, Bob Keller, Councilor, WA 

City of Sammamish, Darci Donovan, Permit Manager, WA 

City of Sammamish, Don Gerend, Councilor, WA 

City of Sammamish, Jessi Bon, Parks & Recreation Director, 

WA 

City of Sammamish, Kamuron Gurol, Planning Director, WA 

City of Sammamish, Kathy Huckabay, Councilor, WA 

City of Sammamish, Laura Philpot, Public Works Director, 

WA 

City of Sammamish, Linda Frkuska, Parks & Recreation 

Deputy Director, WA 

City of Sammamish, Nancy Whitten, Councilor, WA 

City of Sammamish, Nate Elledge, Police Chief, WA 

City of Sammamish, Ramiro Valderrama- Aramayo, 

Councilor, WA 

City of Sammamish, Tom Odell, Mayor, WA 
 A-11

Local Government Agenies – Washington (cont’d) 

City of Sammamish, Tom Vance, Councilor, WA 

City of Sedro-Woolley, Brenda Kinzer, Councilor, WA 

City of Sedro-Woolley, Bret Sandstrom, Councilor, WA 

City of Sedro-Woolley, Dean Klinger, Fire Chief, WA 

City of Sedro-Woolley, Doug Wood, Police Chief, WA 

City of Sedro-Woolley, Eron Berg, City Attorney, WA 

City of Sedro-Woolley, Germaine Kornegay, Councilor, WA 

City of Sedro-Woolley, Hugh Galbraith, Councilor, WA 

City of Sedro-Woolley, Jack Moore, Planning Director, WA 

City of Sedro-Woolley, Keith Wagoner, Councilor, WA 

City of Sedro-Woolley, Kevin Loy, Councilor, WA 

City of Sedro-Woolley, Mike Anderson, Mayor, WA 

City of Sedro-Woolley, Nathan Salseina, Parks & Recreation 

Supervisor, WA 

City of Sedro-Woolley, Rick Lemley, Councilor, WA 

City of Snohomish, Corbitt Loch, Planning Director, WA 

City of Snohomish, Dave Bender, Parks & Facilities Division 

Lead, WA 

City of Snohomish, Dean Randall, Councilor, WA 

City of Snohomish, Debbie Emge, Economic Development 

Manager, WA 

City of Snohomish, Derrick Burke, Councilor, WA 

City of Snohomish, Grant Weed, City Attorney, WA 

City of Snohomish, John Turner, Police Chief, WA 

City of Snohomish, Karen Guzak, Mayor, WA 

City of Snohomish, Lynn Schilaty, Councilor, WA 

City of Snohomish, Michael Rohrscheib, Councilor, WA 

City of Snohomish, Paul Kaftanski, Councilor, WA 

City of Snohomish, Tim Cross, Public Works Inspector, WA 

City of Snohomish, Tim Heydon, Public Works Director, WA 

City of Snohomish, Tom Hamilton, Councilor, WA 

City of Sumas, Bob Bromley, Mayor, WA 

City of Sumas, Bruce Bosch, Councilor, WA 

City of Sumas, Chris Haugen, Police Chief, WA 

City of Sumas, Gary Debont, Councilor, WA 

City of Sumas, Jerry DeBruin, Fire Chief, WA 

City of Sumas, Jim Wright, City Attorney, WA 

City of Sumas, Leige Clare, Councilor, WA 

City of Sumas, Mike Quinn, Councilor, WA 

City of Sumas, Rod Fadden, Public Works Director, WA 

City of Sumas, Todd Daniels, Councilor, WA 

City of Sumner, Bill Pugh, Public Works Director, WA 

City of Sumner, Brad Moericke, Police Chief, WA 

City of Sumner, Brett Vinson, City Attorney, WA 

City of Sumner, Cindi Hochstatter, Councilor, WA 

City of Sumner, Curt Brown, Councilor, WA 

City of Sumner, David Enslow, Mayor, WA 

City of Sumner, Earle Stuard, Councilor, WA 

City of Sumner, Greg Schwayer, WA 

City of Sumner, Joe Fessler, WA 

City of Sumner, Kathy Hayden, Councilor, WA 

City of Sumner, Mike LeMaster, Deputy Mayor, WA 

City of Sumner, Nancy Dumas, Councilor, WA 

City of Sumner, Paul Rogerson, Planning Director, WA 

City of Sumner, Rebecca Coleman, Permit Specialist, WA 

City of Sumner, Steve Allsop, Councilor, WA 

City of Tacoma Water, Real Estate Management, WA 

City of Toledo, Bill Boehm, City Attorney, WA 

City of Toledo, Carol Hill, Councilor, WA 

City of Toledo, Craig McCown, Public Works Director, WA 

City of Toledo, Guy Spratt, Councilor, WA 

City of Toledo, Jerry Pratt, Mayor, WA 

City of Toledo, John Brockmueller, Police Chief, WA 

City of Toledo, Michelle Whitten, WA 

City of Toledo, Mike Thomas, Councilor, WA 

City of Toledo, Nathan Cook, Councilor, WA 

City of Toledo, Steve Dobosh, Councilor, WA 

City of Vader, Andy Wilson, Councilor, WA 

City of Vader, Dana Williams, City Attorney, WA 

City of Vader, Janet Charlton, Councilor, WA 

City of Vader, Ken Smith, Mayor, WA 

City of Vader, Kevin Flynn, Councilor, WA 

City of Vader, Rodney Allison, Councilor, WA 

City of Vader, Sean Uhlich, Police Chief, WA 

City of Vader, Sharron Ross, Councilor, WA 

City of Vader, Wanda Barzda, Public Works Director, WA 

City of Winlock, Amanda C. Vey, City Attorney, WA 

City of Winlock, Barbara Pedersen, Councilor, WA 

City of Winlock, Denise Green, Councilor, WA 

City of Winlock, Dennis Korpi, Councilor, WA 

City of Winlock, Glen Cook, Mayor, WA 

City of Winlock, Gregg Robinson, Public Works Director, WA 

City of Winlock, Jerry Rader, Councilor, WA 

City of Winlock, Pat Anderson, Councilor, WA 

City of Winlock, Tammy Hamilton, Planning Director, WA 

City of Winlock, Terry Williams, Police Chief, WA 

City of Woodland, WA 

City of Woodland, Al Swindell, Councilor, WA 

City of Woodland, Amanda Smeller, Community Development 

Planner, WA 

City of Woodland, Bart Stepp P.E., Public Works Director, WA 

City of Woodland, Benjamin Fredricks, Councilor, WA 

City of Woodland, Grover Laseke, Mayor, WA 

City of Woodland, Jennifer Heffernan, Councilor, WA 

City of Woodland, Marilee McCall, Councilor, WA 

City of Woodland, Marshall Allen, Councilor, WA 

City of Woodland, Rob Stephenson, Police Chief, WA 

City of Woodland, Scott Perry, Councilor, WA 
 A-12 

Local Government Agenies – Washington (cont’d) 

City of Woodland, Susan Humbyrd, Councilor, WA 

City of Yelm, Bob Isom, Councilor, WA 

City of Yelm, Grant Beck, Communicty Development Dir., WA 

City of Yelm, Joe Baker, Councilor, WA 

City of Yelm, JW Foster, Councilor, WA 

City of Yelm, Ken Garmann, Councilor, WA 

City of Yelm, Mark King, Fire Chief, WA 

City of Yelm, Mike McGowan, Councilor, WA 

City of Yelm, Ron Harding, Mayor, WA 

City of Yelm, Russ Hendrickson, Councilor, WA 

City of Yelm, Ryan Johnstone, Public Works Director, WA 

City of Yelm, Todd Stancil, Police Chief, WA 

City of Yelm, Tracey Wood, Councilor, WA 

Clark County, Anna Pendergrass, Emergency Management, 

WA 

Clark County, David Madore, County Commissioner, WA 

Clark County, Dennis Mason, County Fire Chief, WA 

Clark County, Garry E. Lucas, County Sheriff, WA 

Clark County, Mark McCauley, County Administrator, WA 

Clark County, Oliver Orjiako, County Planning Director, WA 

Clark County, Peter Capell, County Public Works Director, 

WA 

Clark County, Sonja Wiser, Community Development, WA 

Clark County, Steve Stuart, County Commissioner, WA 

Clark County, Tom Mielke, County Commissioner, WA 

Clark County, WA, Matt Hall, Project Manager-Dept of Public 

Works, WA 

Clark Public Utilities, Sharon Crouch, Loss Control Manager, 

WA 

Cowlitz Conservation District, WA 

Cowlitz County Board of Commissioners, George Raiter, 

Chair, WA 

Cowlitz County CDID #2, WA 

Cowlitz County CDID #2, WA 

Cowlitz County Fire District 5, Victor Leatzow, Fire Chief, WA 

Cowlitz County PUD, WA 

Cowlitz County Weed Control Board, WA 

Cowlitz County, WA 

Cowlitz County, Dennis Weber, County Commissioner, WA 

Cowlitz County, E. Elaine Placido, Dir. Building & Planning, 

WA 

Cowlitz County, Ernie Schnabler, County Emergency 

Management, WA 

Cowlitz County, James Misner, County Commissioner, WA 

Cowlitz County, Kent Cash, County Public Works Director, 

WA 

Cowlitz County, Mark S. Nelson, County Sheriff, WA 

Cowlitz County, Michael A. Karnofski, County Commissioner, 

WA 

Cowlitz County, Phillip Rupp, Planning Manager, WA 

Cowlitz County, Ron Junker, WA 

Cowlitz Economic Development Council, Rotary Club of 

Longview, Ted Sprague, President, WA 

Dept. of Public Works Environmental Permitting, Karen 

Streeter, Environmental Permitting Manager, WA 

Dept. of Public Works-Operations Division, Dean Shadix, Sr. 

Engineering Technician Utility Inspection, WA 

King Conservation District, WA 

King County Noxious Weed Board, WA 

King County Noxious Weed Control Program, Steven Burke, 

Manager, WA 

King County, Dow Constantine, County Executive, WA 

King County, Jane Hague, County Councilor, WA 

King County, Joe McDermott, County Councilor, WA 

King County, John Urquhart, County Sheriff, WA 

King County, Kathy Lambert, County Councilor, WA 

King County, Larry Gossett, County Councilor, WA 

King County, Larry Phillips, County Councilor, WA 

King County, Laura Casey, Environmental Scientist, WA 

King County, Pete von Reichbauer, County Councilor, WA 

King County, Reagan Dunn, County Councilor, WA 

King County, Rod Dembowski, County Councilor, WA 

King County, Ron Ainslie, Site Development Specialist, WA 

King County, Walt Hubbard, Emergency Management, WA 

King County-Parks, WA 

Lewis County Conservation District, WA 

Lewis County Weed Control, WA 

Lewis County, Bill Schulte, County Commissioner, WA 

Lewis County, Bob Johnson, County Planning Director, WA 

Lewis County, Edna Fund, County Commissioner, WA 

Lewis County, Lee Grose, County Commissioner, WA 

Lewis County, Lee Napier, Community Development Dir., WA 

Lewis County, Ross McDowell, Emergency Management, WA 

Lewis County, Steve Mansfield, County Sheriff, WA 

Noxious Weed Board, William Rogers, Coordinator, WA 

Pacific County, Bryan Harrison, Pacific County Courthouse 

Annex, WA 

Pacific County, Clay Hardwood, Commissioner, WA 

Pacific County, John Kaino, Commissioner, WA 

Pacific County, Mike DeSimone, Pacific County Courthouse 

Annex, WA 

Pacific County, Norman "Bud" Cuffel, Commissioner, WA 

Pierce Conservation District, WA 

Pierce County Fire Protection 22, WA 

Pierce County Noxious Weed Control Board, WA 

Pierce County Parks, Parks & Recreation, WA 

Pierce County Public Works & Utilities, Kyle Dworchak, 

Transportation Services, WA 

Pierce County, WA 

Pierce County, Transportation Services, WA 

Pierce County, Brian D. Stacy, P.E., County Engineer, WA 
 A-13

Local Government Agenies – Washington (cont’d) 

Pierce County, Brian J. Ziegler, County Public Works 

Director, WA 

Pierce County, Brynn Brady, Government Relations 

Coordinator, WA 

Pierce County, Connie Ladenburg, County Council, WA 

Pierce County, Dan Roach, County Council, WA 

Pierce County, Denise Dyer, Manager, Economic Devel, WA 

Pierce County, Dennis Hanberg, County Planning Director, 

WA 

Pierce County, Diane Ryba, Environmental Biologist, WA 

Pierce County, Douglas Richardson, County Council, WA 

Pierce County, Jennifer Joly, Government Relations Director, 

WA 

Pierce County, Jennifer Walker, SR/WA, ROW Section 

Supervisor, WA 

Pierce County, Joyce McDonald, County Council, WA 

Pierce County, Kathryn Kravit-Smith, Director, Parks & 

Recreati, WA 

Pierce County, Mark Maenhout, Director, Risk Management, 

WA 

Pierce County, Pat McCarthy, County Executive, WA 

Pierce County, Paul A. Pastor, County Sheriff, WA 

Pierce County, Rick Talbert, County Council, WA 

Pierce County, Roger Bush, County Council, WA 

Pierce County, Stan Flemming, County Council, WA 

Pierce County, Steven Bailey, Emergency Management, WA 

Pierce County, Toby Rickman, P.E., Deputy Director, Public 

Wo, WA 

Pierce County, William Sleeth, PLS, Survey Supervisor, WA 

Public Utility District, Larry Saunders, WA 

Skagit Co Public Utility District, Al Littlefield, WA 

Skagit Conservation District, WA 

Skagit County, Brian Adams, Parks & Recreation Director, 

WA 

Skagit County, Dale Pernula, Planning Director, WA 

Skagit County, Dan Berentson, Public Works Interim Director, 

WA 

Skagit County, Gary Christensen, County Planning Director, 

WA 

Skagit County, Kelly Blaine, County Fire Chief, WA 

Skagit County, Ken Dahlstedt, County Commissioner, WA 

Skagit County, Mark Watkinson, Emergency Management, 

WA 

Skagit County, Ron Wesen, County Commissioner, WA 

Skagit County, Sharon Dillon, County Commissioner, WA 

Skagit County, Will Reichardt, County Sheriff, WA 

Skagit Public Utility Distric, Lora Elsom, Environmental 

Services Coordinator, WA 

Snohomish Conservation District, Monte Marti, Distric 

Manager, WA 

Snohomish County Department of Public Works, David 

Evans, WA 

Snohomish County Noxious Weed Control Board, WA 

Snohomish County Parks & Recreation, Dianne Bailey, Park 

Property Administrator, WA 

Snohomish County Parks & Recreation, James Yap, Principal 

Park Planner, WA 

Snohomish County, Brian Sullivan, Councilor, WA 

Snohomish County, Clay White, County Planning Director, 

WA 

Snohomish County, Dave Somers, Councilor, WA 

Snohomish County, Frank Scherf, Senior Planner, WA 

Snohomish County, John Lovick, County Executive, WA 

Snohomish County, John Lovick, County Sheriff, WA 

Snohomish County, John Pennington, Emergency 

Management, WA 

Snohomish County, Ken Klein, Councilor, WA 

Snohomish County, Stephanie Wright, Councilor, WA 

Snohomish County, Steve Thomsen, Public Works Director, 

WA 

Snohomish County, Terry Ryan, Councilor, WA 

Snohomish County, Ty Trenary, County Sheriff, WA 

Thurston Conservation District, WA 

Thurston County Noxious Weed Control Agency, WA 

Thurston County Parks, WA 

Thurston County, Cathy Wolfe, County Commissioner, WA 

Thurston County, Cliff Moore, County Manager, WA 

Thurston County, Cythia Wilson, Senior Planner, WA 

Thurston County, Donavan Willcutt, Public Works Director, 

WA 

Thurston County, John Snaza, County Sheriff, WA 

Thurston County, Mark Swartout, Natural Resource Program 

Manager, WA 

Thurston County, Sandra Romero, County Commissioner, 

WA 

Thurston County, Sandra Romero, County Commissioner, 

WA 

Thurston County, Scott Clark, Planning Director, WA 

Whatcom Conservation District, WA 

Whatcom County, Barbara Brenner, County Council, WA 

Whatcom County, Barry Buchanan, County Council, WA 

Whatcom County, Bill Elfo, County Sheriff, WA 

Whatcom County, Carl Weimer, County Council, WA 

Whatcom County, Frank M. Abart, County Public Works 

Director, WA 

Whatcom County, J.E. Ryan, County Fire Chief, WA 

Whatcom County, Ken Mann, County Council, WA 

Whatcom County, Lyn Morgan-Hill, Senior Planner, WA 

Whatcom County, Michael McFarlane, Director of Parks & 

Recreation, WA 

Whatcom County, Pete Kremen, County Executive, WA 

Whatcom County, Rodney Lamb, Design & Development 

Supervisor, WA 

Whatcom County, Rud Browne, County Council, WA 
 A-14 

Local Government Agenies – Washington (cont’d) 

Whatcom County, Sam Crawford, County Council, WA 

Whatcom County, Suzanne Bosman, Senior Planner, WA 

Native American Groups 

Chehalis Confederated Tribes, David Burnett, Chair, WA 

Chinook Indian Tribe, Tony Johnson, Cultural Resources, WA 

Chinook Nation, Ray Gardner, Council Chairman, WA 

Clatsop-Nehalem Confederated Tribes, Joseph Scovell, OR 

Columbia River Inter-Tribal Fish Commission, FERC 

Coordinator, OR 

Columbia River Inter-Tribal Fish Commission, Jaime 

Pinkham, OR 

Columbia River Inter-Tribal Fish Commission, Lumley Paul, 

Executive Director, OR 

Columbia River Inter-Tribal Fish Commission, Patti Howard, 

Water Quality Coordinator, OR 

Colville Confederated Tribes, Michael Finley, WA 

Confederated Tribes & Bands of Yakama Nation, Kate 

Valdez, Cultural Resources, WA 

Confederated Tribes & Bands of Yakama Nation, Philip 

Rigdon, DNR Deputy Director, WA 

Confederated Tribes of Grand Ronde, Brandy Humphreys, 

OR 

Confederated Tribes of Grand Ronde, Cheryle Kennedy, 

Chair, OR 

Confederated Tribes of Grand Ronde, David Lewis, Cultural 

Resources Manager, OR 

Confederated Tribes of Grand Ronde, Eirik Thorsgard, 

Cultural Resources, OR 

Confederated Tribes of Grand Ronde, Erik Thorsgard, Tribal 

Historic Preservation Officer, OR 

Confederated Tribes of Grand Ronde, Michael Karnosh, OR 

Confederated Tribes of Grand Ronde, Reynold Leno, OR 

Confederated Tribes of Grand Ronde, Schultz Khani, Cultural 

Resources Specialist, OR 

Confederated Tribes of Siletz, Robert Kennta, OR 

Confederated Tribes of the Chehalis, Mark White, Natural 

Resources, WA 

Confederated Tribes of the Chehalis, Richard Bellon, Cultural 

Resources, WA 

Confederated Tribes of the Umatilla, Board of Trustees - 

Chair, OR 

Confederated Tribes of the Umatilla, Bruce Zimmerman, OR 

Confederated Tribes of the Umatilla, Carey Miller, THPO, 

Cultural Resources Protection Program, OR 

Confederated Tribes of the Umatilla, Catherine Dickson, 

Cultural Resources, OR 

Confederated Tribes of the Umatilla, Les Minthorn, Chair, OR 

Confederated Tribes of the Warm Springs Reserv, Sally Bird, 

Cultural Resources Manager, OR 

Confederated Tribes of the Warm Springs Reservation of 

Oregon, Eugene Greene Jr., Chairman, OR 

Cowlitz Indian Tribe, Bill Iyall, Chair, WA 

Cowlitz Indian Tribe, Dave Burlingame, Cultural Resources, 

WA 

Cowlitz Indian Tribe, Ed Arthur, Assistant Director, WA 

Cowlitz Indian Tribe, Mike Iyall, Natural Resources Director, 

WA 

Cowlitz Indian Tribe, Taylor Aalvik, Natural Resource 

Director, WA 

Hoh Tribe, Maria Lopez, WA 

Jamestown S'Klallam Tribe, Ron Allen, WA 

Kalispel Tribe, Glen Nenema, WA 

Kikiallus Indian Tribe, Kurt Weinreich, Cultural Resources, 

WA 

Lower Elwha Klallam Tribe, Frances Charles, WA 

Lummi Nation, Lena Tso, Cultural Resources, WA 

Lummi Nation, Merle Jefferson, Natural Resources, WA 

Lummi Nation, Timothy Ballew II, WA 

Lumni Nation, Cliff Cultee, Chair, WA 

Makah Tribe, Timothy Greene, Sr., WA 

Muckleshoot Indian Tribe, Cultural/Preservation, WA 

Muckleshoot Indian Tribe, Fisheries, WA 

Muckleshoot Indian Tribe, Planning, WA 

Muckleshoot Tribe, Karen Walter, Natural Resources, WA 

Muckleshoot Tribe, Laura Murphy, Cultural Resources, WA 

Muckleshoot Tribe, Virginia Cross, Chair, WA 

Nez Perce Tribal Executive Committee, Brooklyn Baptiste, 

Chairman, ID 

Nez Perce Tribe, Ryan Sudbury, Office of Legal Council, ID 

Nisqually Tribe, Cynthia Iyall, Chair, WA 

Nisqually Tribe, David Troutt, Natural Resources, WA 

Nisqually Tribe, Dorian Sanchez, Chair, WA 

Nisqually Tribe, Fabio Apolito, Cultural Resources, WA 

Nisqually Tribe, Joe Kalama, Cultural Resources, WA 

Nisqually Tribe, Thor Hoyte, WA 

Nooksack Tribe, Gary MacWilliams, Natural Resources, WA 

Nooksack Tribe, George Swanaset Jr., Cultural Resources, 

WA 

Nooksack Tribe, Jeffrey Thomas, Natural Resources, WA 

Nooksack Tribe, Kelly, Jr Robert, Chair, WA 

Port Gamble S'Klallam Tribe, Jeromy Sullivan, WA 

Puyallup Tribe, Bill Sullivan, Natural Resources, WA 

Puyallup Tribe, Brandon Reynon, Cultural Resources, WA 

Puyallup Tribe, Dillon, Sr. Herman, Chair, WA 

Quileute Nation, Tony Foster, WA 

Quinault Nation, Fawn Sharp, WA 

Samish Nation, Christine Woodward, Natural Resources, WA 

Samish Nation, Jacquelyn Ferry, Cultural Resources, WA 

Samish Nation, Thomas Wooten, Chair, WA 

Sauk-Suiattle Tribe, Michael Hoffman, Chair, WA 

Sauk-Suiattle Tribe, Norma Joseph, WA 

Sauk-Suiattle Tribe, Norma Joseph, Cultural Resources, WA 

Sauk-Suiattle Tribe, Richard Wolten, Natural Resources, WA 

Shoalwater Bay Tribe, Charlene Nelson, Chair, WA 
 A-15

Native American Groups (cont’d) 

Shoalwater Bay Tribe, Earl Davis, Cultural Resources, WA 

Shoalwater Bay Tribe, Gary Burns, Natural Resources, WA 

Shoalwater Bay Tribe, Tony Johnson, Cultural Resources, 

WA 

Siletz Confederated Tribes, Delores Pigsley, Chair, OR 

Skagit River System Cooperative, Stan Walsh, Environmental 

Services Manager, WA 

Skokomish Tribe, Charles "Guy" Miller, WA 

Spokane Tribe, Rudy Peone, WA 

Squaxin Island Tribe, Dave Lopeman, WA 

Steilacoom Indian Tribe, Danny Marshall, Chair, WA 

Stillaguamish Tribe, Jay Harvey, Cultural Resources, WA 

Stillaguamish Tribe, Pat Stevenson, Natural Resources, WA 

Stillaguamish Tribe, Shawn Yanity, Chair, WA 

Suquamish Tribe, Dennis Lewarch, Cultural Resources, WA 

Swinomish Indian Tribal Community, Larry Campbell, Tribal 

Historic Preservation Officer, WA 

Swinomish Tribe, Brian Cladoosby, WA 

Tulalip Tribe, Melvin Sheldon, Jr., WA 

Tulalip Tribe, Richard Young, Cultural Resources, WA 

Upper Skagit Tribe, Jennifer Washington, WA 

Upper Skagit Tribe, Scott Shuyler, Cultural Resources, WA 

Yakama Nation, Harry Smiskin, Chair, WA 

Yakama Nation, Jerry Meninick, Chair, WA 

Intervenors 

Allen Neuringer, OR 

Astoria Fire & Rescue, Michael Jackson, Asst. Chief/Fire 

Marshal, OR 

Astoria Police Dept., Robert Deu Pree, Chief of Police, OR 

Atmos Energy Corporation, Kevin Frank, TX 

CC Meisel Co Inc., OR 

Center for Biological Diversity, Sarah Uhlemann, Senior 

Attorney, WA 

City of Astoria, Brett Estes, City Manager, OR 

City of Molalla, Mike Clark, City Manager, OR 

City of St. Helens, John Walsh, City Administrator, OR 

City of Warrenton, Kurt Fritsch, City Manager, OR 

Clatsop County, Scott Derickson, County Manager, OR 

Columbia County, Sarah Hanson, Columbia County, OR 

Columbia River Inter-Tribal Fish Commission, Rob Lothrop, 

Policy Development/Litigation Support Manager, OR 

Columbia Riverkeeper, Daniel R. Serres, OR 

Confederated Tribes of Grand Ronde, Senior Staff Attorney, 

OR 

D. Richard & Louise E. Fischer, OR 

Daniel J & Matiele Law, WA 

Davidson Family LLC, Jerry Mullen, OR 

Flood & Water Watch, Julia DeGraw, OR 

Joint Water Commission, OR 

Jordan Ramis PC, Ronald Guerra, City Attorney for St. 

Helens, OR 

Laurie Caplan, OR 

Lolita and Menton A. Carl LLC, OR 

Lori Durheim, OR 

Morris and Victoria Baxter, AZ 

National Marine Fisheries Service, Dr. Jeff Fisher, Branch 

Chief-Southwest Region, WA 

National Marine Fisheries Service, Jane Hannuksela, WA 

National Marine Fisheries Service, Mischa Connine, OR 

Northwest Environmental Defense Center, Marla S. Nelson, 

OR 

Northwest Industrial Gas Users, Edward A. Finklea, 

Exuecutive Director, OR 

Northwest Natural Gas Co, OR 

Old Standard Life Ins Co., WA 

OR Dept. of Energy, Shanda Shribbs, OR 

OR Dept. of Environmental Quality, Nina DeConcini, 

Northwest Region Administrator, OR 

OR Dept. of Fish & Wildlife, OR 

OR Dept. of Land Conservation and Development, Patty 

Snow, OR 

OR Dept. of State Lands, Steve Purchase, OR 

OR Parks & Recreation Dept., OR 

OR Water Resources Dept., OR 

Oregon Coast Alliance, Cameron La Follete, Land Use 

Director, OR 

Oregon Shores Conservation Coalition, Courtney Johnson, 

OR 

Pinnacle Long, LLC, Kell, Alternman, & Runstein, LLP, 

Attorneys (Pinnacle), OR 

Post & Schell, P.C., Douglas Canter, DC 

Saddleback Neighborhood Road Maintenance Association, 

Lee Geil, President, WA 

Southwest Gas Corporation, Keith Layton, Associate General 

Counsel, NV 

Southwest Gas Corporation, Pamela Ruckel, Senior Analyst 

Federal Regulatory Affairs, NV 

Southwest Gas Corporation, Sam Brown, Manager/Federal 

Regulatory Affairs, NV 

Teresa Charboneau, WA 

WA Dept. of Ecology Shorelands & Environmental 

Assistance, Loree Randall, WA 

WA Dept. of Fish and Wildlife, David Brock, Program 

Manager, WA 

WA Dept. of Natural Resources, Rochelle Knust, External 

Affairs Program Lead, WA 

WA Dept. of Natural Resources, Terence Pruit, Assistant 

Attorney General, WA 

Waterkeeper Alliance, Lesley Adams, Western Regional 

Coordinator, OR 

Willamette Riverkeeper, OR 
 A-16 

Libraries 

Astoria Public Library, OR 

Auburn Library, WA 

Black Diamond Library, WA 

Centralia Timberland Library, WA 

Covington Library, WA 

Forest Grove City Library, OR 

Ilwaco Timberland Library, WA 

Issaquah Public Library, WA 

Kalama Library, WA 

Kelso Public Library, WA 

McMinnville Public Library, OR 

Monroe Library, WA 

Sammamish Library, WA 

Sedro-Woolley Public Library, WA 

Snohomish Library, WA 

South Hill Library, WA 

Sumner Library, WA 

Warrenton Community Library, OR 

Winlock Public Library, WA 

Woodburn Public Library, OR 

Woodland Public Library, WA 

Media 

Bellingham Herald, Managing Editor, WA 

Chinook Observer, WA 

Chronicle, Managing Editor, WA 

Forest Grove Times-News, Christian Gaston, OR 

Issaquah Press, Kathleen Merrill, Managing Editor, WA 

KMUN Radio, Joanne Rideout, OR 

Longview Daily News, Managing Editor, WA 

Longview Daily News, Eric Olson, Reporter, WA 

News-Register, Steve Bagwell, OR 

Nisqually Valley News, Kevin Graves, Editor and Publisher, 

WA 

Puyallup Herald, Andrew Fickes, Reporter, WA 

Puyallup Herald, Tyler Hemstreet, Managing Editor, WA 

Skagit Valley Herald, Managing Editor, WA 

Skagit Valley Herald, Gina Cole, Reporter, WA 

The Chronicle, Kyle Spurr, WA 

The Daily Astorian, OR 

The Hillsboro Argus, Nick Christensen, OR 

The Oregonian, OR 

The Oregonian, Lori Tobias, OR 

Vernonia's Voice Newspaper, Scott Laird, OR 

Willamette Week, Nick Budnick, OR 

Woodburn Independent, John Gervais, OR 

Entities and Organizations 

1000 Friends of OR, OR 

2014-1 IH Borrower LP, TX 

410 Associates LLC, Ronald Goodchild, WA 

64th Street Apartments, LLC, WA 

94Th Avenue LLC, WA 

AFBM II LLC, OR 

Alco, WA 

Allito Properties LLC, WA 

American Concrete Inc, Bob Beeson, WA 

American Eagle Mtg Mexico #200 LLC, WA 

American Equities Inc., Ross Miles, WA 

American Gas Association, President, DC 

American Savings Bank, NC 

APA Development LLC, Kurt Brunner, WA 

Appleton Development LLC, WA 

Arch Wood Protection Inc, GA 

Ariniello Properties, LLC, WA 

Ashton D Group LLC, WA 

Association of Washington Business, Kris Johnson, 

President, WA 

Astoria Ford, Dane Gouge, OR 

Astoria-Warrenton Area Chamber of Commerce, OR 

Auburn Lions Club, WA 

Auburn School Dist 408, Randy Thomas, Dir. Of O & M, WA 

BAC Home Loans Servicing LP, CA 

Bahr Tree Farm LLC, Steve Pedersen, WA 

Bank of New York Mellon, UT 

Bauder Family Limited Partnership, OR 

BBC LLC, Brie Garland, WA 

BCC Puyallup LLC, WA 

Benham Property LLC, WA 

Berean Baptist Church, WA 

Blue Breeze, LLC, WA 

BNSF Railway Company, TX 

Bordeaux / Cameray HOA, WA 

BR Valley Townhomes Sub Dst II Flanagan-Orion, Jennifer 

Spears, IL 

Brandley Investments Inc, Jim Brandley, WA 

BRC Family LLC, WA 

Brewer's Sports Complex, LLC, Jeff Backmeier, WA 

Brick House Wine Company, M. Mills, OR 

Brookshire Estates HOA - Issaquah, WA 

Brookshire Ridge HOA, WA 

Buchan Homes LLC, WA 

Building and Planning Dept., Carolyn Johnson, WA 

Buy2Fix, LLC, Scott Emry, WA 

Cameray HOA, WA 

Canyon Road Property LLC, WA 

Caporn Skies, LLC, WA 

Car Wash Enterprises Inc., WA 

Carpenter's Local 156, Kevin Weller, OR 
 A-17

Entities and Organizations (cont’d) 

Casa Associates, Claire Petersen, KAMG Mgmnt, WA 

Cascade Natural Gas Corp, ND 

Cascade Natural Gas Corp, WA 

Cascade Water Alliance, WA 

Cascade West Development Inc, WA 

Castle Rock Fuel Stop Inc, Manjit Singh Chahil, WA 

Cava Materials LLC, WA 

CCJ Inc, OR 

Cedar Springs at I LLC, WA 

Celebration Center, WA 

Cemetery Dist #1, WA 

CH2MHill, Jay Lorenz, OR 

CH2MHill, Mark Bricker, WA 

Chilton, Inc., WA 

Chrystal Farm, LLC, Lindley Morton, Manager, OR 

Church of Jesus Christ LDS, UT 

Clackamas County Farm Bureau, Jon Iverson, OR 

Cleaning Services, Richard Lee, WA 

Clover Creek Highlands LLC, Schilt M Seabrook, WA 

Coastal Condo LLC, OR 

Cohiba, Cripple Crk, French Crk Hunt Club LLC, Scott 

Gunning, WA 

Coleman Ranch, OR 

Columbia Bank, Jim Duncan, WA 

Columbia Colstor Inc., WA 

Columbia River Bar Pilot, Robert Johnson, OR 

Columbia River Bar Pilots, Gary Lewin, OR 

Columbia River Business Alliance, Don West, OR 

Columbia River Estuary Study Taskforce, Jay Flint, OR 

Columbia River Estuary Study Taskforce, Robert Warren, OR 

Columbia River Maritime Museum, Jerry Ostermiller, OR 

Columbia River Maritime Museum, Sam Johnson, Executive 

Director, OR 

Columbia River Pilots Association, David Halmagyi, OR 

Columbia Riverkeeper, Cheryl Johnson, OR 

Columbia Riverkeeper, Debi Donnelly, OR 

Columbia Riverkeeper, Ted Messing, OR 

Consolidated Products Int Inc, OR 

Cowlitz Community Foundation, William Iyall, Chairman, 

Cowlitz Indian Tribe, WA 

Cowlitz Dairy, WA 

Creator Lutheran Church At Lake Tapps, WA 

Crest Builders, WA 

Crystal Creek Holdings LLC, WA 

Darzolf Holdings LLC, WA 

Davidson Family LLC, OR 

DD&V Company LLC, Dennis Derr, WA 

DE & ME Enterprises LLC, WA 

Deer Island Stock Ranch Trust, OR 

Deutsche Bank Trust Co, TX 

Dewitt Investments LLC, WA 

Dieringer School Dist 343, WA 

Doneen Inc, Anne Hanschu, OR 

Dorel Properties LLC, Eric Pries, WA 

Down To Earth Enterprises LLC, Starr Tavenner, WA 

DRK, LLC, WA 

Drllevich Const Inc, WA 

Dubuque Crest HOA III, WA 

Duenhoelter LLC, WA 

Dyno Nobel Inc, UT 

E & E Gradline LLC, Mark Ekman, WA 

E/B Work LLC, WA 

East Echo Lake LLC, WA 

East West Real Estate Inv, WA 

Eastridge Christian Assembly, Pete Blum, WA 

Echo Lake Community Church, WA 

Echo Lake Estates HOA, Brian Kovacevish, WA 

Eight Is Enough LLC, WA 

Endeavor Properties, LLC, WA 

Englund LLC, OR 

Estates Homeowners Assn, Morris Management, WA 

exp Energy Services Inc., Mike Aubele, TX 

Federal National Mortgage A, CA 

Field Services, Inc., Leslie Benckendorf, OR 

Fir Lane Valley LLC, WA 

Fire District 44, Mike Barlow, WA 

Fire Mtn Farms, Robert J Thode, WA 

First Svgs Bk NW, WA 

Forest Canyon Park LLC, WA 

Forestree GM LLC, WA 

Four Crowes, WA 

Four Seasons Farms, Inc, Bernie James Stratton, WA 

Fox Hill HOA, Eric Seislove, WA 

Fraternity Snoqualmie Inc, WA 

FREO Washington, LLC, AZ 

Friends of Living OR Waters, Daniel Serres, OR 

Fruithill, Inc, Lee Schrepel, OR 

Fulbright & Jaworski, LLP, Lisa Tonery, NY 

General Steel Corp., CA 

Glenbrooke Apartments, WA 

Goodyear Nelson Lumber Co, Rod Remington, WA 

Gradawn LLC, Paul N Best, WA 

Grand Ridge Country Estates, Frederick Detore, II, WA 

Grandma Jane's LLC, WA 

Green Diamond Resource Co, David Backstrom, WA 

Grigg Properties LLC, WA 

Gusman & Magnuson Trust, WA 

Gwin & Sons Logging Co., OR 
 A-18 

Entities and Organizations (cont’d) 

Hampton Lumber Mills Inc., OR 

HDR, Patricia Terhaar, MN 

Helgaland LLC, Tom Burke, WA 

Herbrand Company, Dan Miller, WA 

Hidden Glen MHC LLC, CA 

Highland Ridge LLC, Kent Landerholm, WA 

Highlands At South Hill LLC, WA 

High-Level, LLC, WA 

Hill Family LLC, Shelly Smith, WA 

Holt Distressed Property Fund 2010, Scott Miller, WA 

HRRUS LLC, OR 

HSH Beauty, WA 

Hubbard Seed & Supply Co., Gordon Jones, OR 

IH4 Property Washington LP, AZ 

Illahee Homeowners Assoc, WA 

Ilwaco Fisherman, John Grocott, WA 

Invitation Homes Property Management, WA 

Issaquah Highlands Comm, Sarah Phillips, Executive 

Director, WA 

Issaquah Montessori Property, WA 

Issaquah Rotary Club, WA 

Issaquah School Dist, Nancy Wilson, WA 

Jacoby-Bigelow Trust, WA 

Jansma Construction Inc., WA 

Jeff Akins Inc, WA 

Jenny Creek Properties, LLC, Craig Pfeifer, WA 

John Hancock Mutual Life Ins. Co., WA 

Jordan Ramis PC, E. Andrew Jordan, OR 

Jorgensen Timber LLC, WA 

JRS Lost Lake LLC, WA 

KCT Investments, Robert E. Kimball, WA 

Kinder Cemetery, OR 

Klahanie HOA Association, WA 

Knife River Corporation - Northwest, OR 

Knutson Farms Inc, Roger, WA 

L&D Race Tech, Don Hall, OR 

Lake Tapps Community Church, WA 

Lamon LLC, WA 

LDS Church Real Estate, Scott Williams, UT 

Lemay Investments LLC, WA 

Level 3 Communications, Bruce A Kolancy, CO 

Lincoln Trust Company FBO, WA 

LJF Properties, WA 

Llama Landing HOA, WA 

Longview Pioneer Lions, Doug Harvey, WA 

Lopez Farm LLC, WA 

Lower Columbia Alliance for Sustainable Fishing, Bernie 

Bjork, OR 

Lower Columbia River Estuary Partnership, Deborah Marriott, 

OR 

LPORT 2 (WA) QRS 16-147 Inc., WA 

Mallard Marsh LLC/Smartweed LLC, Richard Bus, WA 

Manorwood North Division III Association, WA 

Marine Mammal Commission, Michael Gosliner, MD 

Max J Kuney Co, WA 

Meridian Greens HOA, WA 

Meridian Greens LLC, WA 

Meridian Place LLC, OR 

Meridian Square LLC, JSH Properties, WA 

Milestone Homes Inc., WA 

Molalla Community Planning Organization, Jim Gilbert 

(Chair), OR 

Molalla Community Planning Organization, Susan Hansen, 

OR 

Morris & Morris & McNeil, Marcia McNall, LA 

Moskee Investment Company, OR 

Mount Vernon Lions Club, WA 

MP Properties LLC, WA 

N Pacific Dist Of The Bible, WA 

Nehls 2011 Trust, CA 

Nelson Condominiums, WA 

Nevil Financial Lmtd. Partnership Etal, WA 

North Coast Watershed Association, OR 

Northwest Commercial Investments LLC, WA 

Northwest D/D Inc., WA 

Northwest Environmenal Defense Council, Corey Moffet, OR 

Northwest Environmental Defense Center, OR 

Northwest Gas Association, Dan Kirschner, Executive 

Director, OR 

Northwest Industrial Gas Users, Paula Pyron, OR 

Northwest OR Regional Partnership, Shirley Kalkhoven, OR 

NW Real Properties LLC, WA 

OLNG, Peter Hansen, WA 

Olympia Timber Holdings, LLC, WA 

Olympic Acupuncture, WA 

Olympic Pipeline Co, James Prince, CA 

Olympic Pipeline Co., IL 

Oneill Storage LLC, WA 

OR Fishermen's Cable Committee, Jeff Kroft, OR 

OR Shores Conservation Coalition, Frank Fromherz, OR 

OR Wild, Doug Heiken, OR 

Orusic2 LLC, OR 

Overlook Crest LLC, Rob Janicki, WA 

P & C Land Co LLC, OR 

Pacific Coast Seafoods Co, OR 

Pacific Lifestyle Homes, Inc., WA 

Pacific Natural Gas Co, C T Corporation System, WA 

Pacific Park LLC, WA 
 A-19

Entities and Organizations (cont’d) 

Pacifica Poplar Inc, John Fitzpatrick, BC 

Palmer Creek Water District Improvement Company, Robert 

May, OR 

Penny Lane Company LLC, WA 

Pente Winlock LLC, Harry Hanna, OR 

Pierce College Puyallup, WA 

Pipe Line Contractors Assoc., TX 

Port of Astoria, OR 

Port of Astoria, Herb Florer, Deputy Director/Interim Executive 

Director, OR 

Port of Ilwaco, Cindy Wigard, WA 

Port of Kalama, Mark Wilson, Development Director, WA 

Port of Tacoma, WA 

Port of Woodland, Nelson Holmberg, Executive Director, WA 

Port Warren Moorage Assoc., OR 

Port Warren Sea Lion LLC, OR 

Puget Sound Energy & Elec, WA 

Puget Sound Energy & Gas, WA 

R D Farms Inc., Steve Davidson, OR 

Racca Rentals LLC, WA 

Radars Marsh LLC, WA 

RB40 LLC, Coy Anglin, WA 

Redmond Lions Club, WA 

Reeve Resources LLC, NV 

Renaissance Ridge HOA, Don Corbett, WA 

RESOLVE, Paul DeMorgan, OR 

Ridge At Woodbrook HOA, VIS Group INS, WA 

Ridgecrest Development III LLC, Ross Miles, OR 

Ridgeview Estates Assoc, S. Roscoe, WA 

River Grove Apartments LLC, WA 

Riverwalk Condominium Association, WA 

RJE Real Estate LLC, WA 

Robin Hill LLC, WA 

Rocky Mountain P/L Constr Assoc., J.D. Lormand, LA 

Rotary Club of Sammamish, WA 

Rotary Club of Snohomish, WA 

Salmon for All, Inc, Oliver Waldman, OR 

Samuel & Antoinette Lapore Trust, WA 

Sandy Glen HOA, Lindsey Nagle, WA 

Sarbanand Farms LLC, CA 

Saxony-Pacific LLC, OR 

Schmoe Forest Land LLC, WA 

SE 111th St Water & Rd Association, David Shallow, WA 

Sea Spray Prop., OR 

Seaside Signal, John Yoakum, OR 

Seppa Dairy Co, OR 

Seurity State Bank, WA 

Shaw Road Development LLC, Kurt Brunner, WA 

Sierra Club - OR Chapter, Ted Gleichman, OR 

Sister Keeper Homes LLC, WA 

Skookumchuck Dam LLC, Tom Emrich, AB 

Smartweed LLC, Robert E Manger, WA 

Snohomish Lions Club, WA 

Sound Development Corp., WA 

South Hill Christian Center, Dennis Cummins, WA 

South Valley Estates, WA 

Stag Hallow Wines, LLC, Jill Zarnowitz, OR 

Star Feets, LLC, WA 

Steadfast LLC, OR 

Steve Burnstead Construction L, Leo, WA 

Summa Real Estate Group, Diane Jette, Principal Broker, OR 

Summit Bank, WA 

Sunset Empire Transportation District, OR 

Suzuki & Used Cars, Vincent Williams, OR 

Tacoma Pierce Co YMCA, WA 

Tafa Properties LLC, WA 

Tanca Ioan, WA 

Tapps 3205 LLC, WA 

Teevin Brothers Land & Timber co., Shawn Teevin, OR 

Teitzel Selchert LLC, WA 

The Boeing Company, M/C 20-00, WA 

The Brookshire East HOA, WA 

The Crest on the Plateau, HOA, WA 

The Longview Rotary Club, Allan Erickson, President, WA 

The Wilderness Society, Resource Economist, CO 

THR Washington II LP, AZ 

Three Ps Development LLC, OR 

Timberland Bank, WA 

Timberland Homes Assoc., Inc., WA 

Toutle River View HOA, WA 

Trailwood Farms, WA 

Transalta Centralia Mining LLC, Tim LeDuc, WA 

Tree Farm Association of lot Owners, WA 

Trestine LLC, Lorie Spogen, WA 

Tualatin River Watershed Council, April Olbrich, OR 

Twin Gables LLC, WA 

Union Pacific Railroad Co., Renay Robison, NE 

US Partner Co Ltd, WA 

Verizon Northwest, Inc, TX 

Village At Rivergrove HOA, Robin Shea, WA 

WA Assn Mgt Svcs LLC, WA 

WA Development Co Inc, MT 

Warrenton Lumber Mill, Dale C. Williams, Unit Manager, OR 

Washington Water Power Co - El, Nick Floros, WA 

Wasser & Winters, WA 

Water Rights Services Division, Jerry K. Sauter, Water Rights 

Program Analyst, OR 
 A-20 

Entities and Organizations (cont’d) 

Waterlands LLC, WA 

Wellman Woodland LLC, OR 

Wells Fargo Bank Minnesota Na, UT 

Wells Fargo Bank NA, SC 

Wesley Homes, Kevin Anderson, WA 

Westside Community Bank, Peter Lofgren, WA 

Wetland & Waterways Conservation, Michael McCabe, 

Senior Resource Coordinator, OR 

Weyerhaeuser Columbia Timberlands LLC, WA 

Weyerhaeuser Columbia Timberlands LLC, Chris Lipton, WA 

Weyerhaeuser Columbia Timberlands, LLC, Wesley 

Schlenker, WA 

Weyerhaeuser Company, Dale Williams, Unit Manager 

Warrenton Lumber Mill, OR 

Weyerhaeuser Company, Tax Dept. CH1C28, WA 

Weyerhaeuser NR Company/Lewis & Clark Oregon Buyer 

LLC, OR 

WGW Inc, John Ottis, WA 

Whatcom Land Trust, Eric Carobba, WA 

Wildernest, WA 

Willams Northwest Pipeline GP, Pam Barnes, UT 

Williams Communications, Pete Johnson, CO 

Williams Pipeline, Albert Michini, UT 

Williams Pipeline, George Angerbauer, UT 

Williams Puyallup Office, Rex Johnson, Land Supervisor, WA 

Williams, Dallas Scholes, Sr. State Gov't. Affairs Rep., UT 

Williams, Emily Kushlan, UT 

Williams, Matt Kautzman, WA 

Windsor Park Estates Puyallup LLC, WA 

Winkelman Farm LLC, WA 

Woodland America LLC, WA 

Yamhill County Farm Bureau, Zach Christensen, OR 

Yamhill District Improvement Company No. 1, Ron Schindler, 

OR 

Yinkay Heritage Inc, Philip L Thom, WA 

Yoder Sparling LLC, WA 

Zimlar Tree Farms, Leah Larson-Saroni, CA 

Zimlar Tree Farms, Lynden Larson-Magnoli, CT 

Individuals 

Aaron & Rachel Lamb, WA 

Aaron C & Victoria A Watt, WA 

Aaron Colvin, WA 

Aaron D & Melody A Molen, WA 

Aaron J & Kimberly A Blindheim, WA 

Aaron N & Leah M Dunsdon, WA 

Aaron Puckett, WA 

Abbie Sullivan & Christopher Taylor, WA 

Abbilene Overton, WA 

Abigail Ziltener, WA 

Abraham M S & Shin Quon Goo, WA 

Adam & Autumn Link, WA 

Adam & Kiekenapp, Katie Schukantz, WA 

Adam & Lori Hoffman, WA 

Adam Hillard, WA 

Adam J & Erin J Bluett, WA 

Adam Levine, WA 

Adolph H & Linda L Krantz, WA 

Adrian P & Kirsten A B Happel, WA 

Adrian Santangelo, WA 

Ahna Lich, OR 

Ahren & Shannon Minsch, WA 

Aileen Taylor, WA 

Alan D & Ethyl L Schumacher, WA 

Alan H Homestead, WA 

Alan K. & Joyce Asher Nicholson, WA 

Alan Lee Buswell, WA 

Alan Makayev, WA 

Alana Dittrich, WA 

Albert E & Patricia A Szymusiak, WA 

Aleksandr & Ludmila Bugaychuk, WA 

Aleksey A & Yelena V Petrov, WA 

Alex & Cassandra Buchanan, WA 

Alex & Daryna Bozhko, WA 

Alex & Lotti Finke, OR 

Alexander Baldwin & Inkyung J. Lee, WA 

Alice Dewell, WA 

Alice F Furgeson, CA 

Alice Smith, OR 

Allan & Diane Mount, WA 

Allan R Guenther, WA 

Allan W & Karen Oudean, WA 

Allen & Kim Ward, WA 

Allen A Turner, WA 

Allen E Berg, WA 

Allen K & Terry L Loftis, WA 

Allen L & Mary A Chick, WA 

Allen Muramoto, WA 

Allen S & Bobby J McElhaney, WA 

Allison Ciancibelli, WA 

Alvin & Agnes Jensen, WA 

Amber Allison, WA 

Amber Clayton, WA 

Amelia D. Acosta, WA 

Amityikram & Dora Rajkhowa, WA 

Ammon Jay & Nicole M Harris, WA 

Amos R Ipock, WA 

Amy D Larson, WA 

Amy K Hausrath, WA 
 A-21

Individuals (cont’d) 

Amy Smith, WA 

Amy Wicklund, WA 

Andrea & Ryan M. Sangrey, WA 

Andres Rosas, WA 

Andrew & Ann Mackenzie, WA 

Andrew & Diana Druschba, WA 

Andrew C & Frida R P Richwine, WA 

Andrew Cier, OR 

Andrew Douvier, WA 

Andrew Drummond, OR 

Andrew E & Chona Z Kubiak, WA 

Andrew E & Janice Harlin, WA 

Andrew E Haynie, WA 

Andrew J & Linda D Poplawski, WA 

Andrew K & Lacey J Heinz, WA 

Andrew L & Deborah L O'Brien, WA 

Andrew M Soethe, WA 

Andrew Nygaard, OR 

Andrew Rosenberger, OR 

Andrew Ulven, OR 

Angela & Mustafa Ameen, VA 

Angela M Broome, WA 

Angus Carmichael, WA 

Anita Tavernier, WA 

Ann K Slonecker, WA 

Ann M. Hutchinson, WA 

Ann Marie Willson, WA 

Ann Pappas, WA 

Ann Ukockis, OR 

Anna Folejewski, WA 

Anna L Simsich, WA 

Anna M. Fleming & John Sweet, WA 

Anna Parsons, WA 

Anna Rogers, WA 

Anne E & Gabriel W Spencer, WA 

Anne Horner, OR 

Anne Marie Shultz, WA 

Annie Oliver, OR 

Ann-Marie Becker, WA 

Anthony & Adina Zerwig, WA 

Anthony & Hui-Pun, Ching Pun, WA 

Anthony & Pamela Diana, WA 

Anthony & Park, Christie Chrestler, WA 

Anthony Harbison, WA 

Anthony Lee Rask, OR 

Anthony M & Diane C Mayta, AZ 

Anthony Ray, WA 

Antonio E., Jr & Miriam Ramirez, WA 

Antoune Family Trust, WA 

April S Collett, WA 

Arbutus Grendahl, WA 

Arjun Mitra, WA 

Arlene M & Patrick F Gallagher, WA 

Arnold & Barbara Odegaard, WA 

Arnold D Horath, WA 

Arnold Gomez, WA 

Arnold Haberstroh, WA 

Arnold Olson, WA 

Aron Lee & Barbara M Larsen, WA 

Art & Wilma Yenter, WA 

Art Pearl, OR 

Artem & Yelena Palich, WA 

Arthur B Sandford, WA 

Arthur Bein, MN 

Arthur E & Nancy J Francis, WA 

Arthur H Schwerzel, WA 

Arthur L Bobb, WA 

Arthur W Erickson, OR 

Ashely Burns & John M. Eisenbacher, WA 

Ashley & Nina Henderson, WA 

Ashley G Skeen, WA 

Ashok Bavanla, TX 

Ashok K Singh, WA 

Aunnit White & David A. King, WA 

Aurelia Sanders, Wa 

Austin Guss, WA 

Auston H Mathis, WA 

B Bernard, OR 

B Warren & Melissa G Myers, WA 

Barbara Cervantes-Gautsch, OR 

Barbara J Justice, WA 

Barbara J Mckay, WA 

Barbara J Roberts, WA 

Barbara Jackson, WA 

Barbara Kalinoski, WA 

Barbara L Wollman, WA 

Barbara Morton, WA 

Barbara Perelra, OR 

Barbara Roller, WA 

Barbara Wright, WA 

Barbara, H Herbold, OR 

Barney & Rhonda Melnrick, WA 

Barrie M & Starr L MacDonald, WA 

Barry & Susanna Foster, WA 

Barry Hinkson, OR 

Barry Ulman, WA 

Beatrice Jankins, WA 
 A-22 

Individuals (cont’d) 

Beatrice Kister, WA 

Becky Beasley, WA 

Becky Moody, WA 

Behzad & Lindsay D Pakzad, WA 

Ben R & Tammy S Wilcox, WA 

Ben W Twight, WA 

Benjamin & Kathryn Stuart, WA 

Benjamin & Monica Meyette, WA 

Benjamin J. & An Culver, WA 

Benjamin L Norwood, WA 

Benjamin T Humphreys, WA 

Benjamin Warren & Lys Mercier, WA 

Berkley R Keith, WA 

Bernadette Butterworth, WA 

Bernard E. & Michael H. Dykshoorn, BC 

Bernard R Brunson, WA 

Bernard Vogt, WA 

Bernice Meyer, WA 

Bernie West, WA 

Bertha Koplitz, WA 

Beth Call, WA 

Betha Gutsche, WA 

Bethany Lynn, WA 

Bette Pierson, WA 

Bettina Bradley, WA 

Beverley Collins, OR 

Beverly Ann Crocker, WA 

Beverly Berkholtz, OR 

Beverly Huu, WA 

Beverly Smith, WA 

Bill Booth, OR 

Bill Dickas, OR 

Bill Hanson, OR 

Bill Sauber, OR 

Bill T Wold, WA 

Bill W & Janet M Barnes, WA 

Billie & James Garber, WA 

Billie J. Swalla, WA 

Billie Schmidt, WA 

Billy D. & Brenda J. Click, WA 

Billy G Johnson, OR 

Billy Gene Johnson, OR 

Binda Douglas, WA 

Blair S & Beth C Tuck, WA 

Bo & Kellie Manary, WA 

Bob D & Michele Eaves, WA 

Bob Finnigan, OR 

Bob Goldberg, OR 

Bobby C Krigbaum, WA 

Bobby J & Kristine K Nichols, WA 

Bogdan & Brygida Bednarek, WA 

Bohnda O'Donnell, WA 

Bonnie Mager, WA 

Brad Deaver, WA 

Brad J & Wright, Deletha Little, WA 

Brad M & Carol L Weber, WA 

Brad McBride, WA 

Brad S & Carolyn I Barber, WA 

Bradford & Bridget Cochrane, WA 

Bradford Kropp, WA 

Bradley Buchanan, WA 

Bradley Cowan, OR 

Bradley D Baker, WA 

Bradley Heil, OR 

Bradly R & Parsons Temple Zlotoff, WA 

Brady C & Linda L Jacobs, WA 

Brady L & Christie I Stevens, WA 

Brady Preheim, OR 

Brandee L Warren, WA 

Brandon & Leah Richner, WA 

Brandon & Shaffer, Sunny Smith, WA 

Brandon A Clayton, WA 

Brean Hobbs & Corey Smith, WA 

Brenda Gazabat, WA 

Brenda MacRoberts, OR 

Brenda Recor, WA 

Brendan S & Heather Brosnan, WA 

Brent B & Cindy B Gow, WA 

Brent K & Kari B Hoke, WA 

Brett & Bethany Wise, WA 

Brian & Cara Wright, WA 

Brian & Erin Lorence, WA 

Brian & Joanie Ganske, WA 

Brian & Mary Jane Purvis, WA 

Brian & Shannon Griffith, WA 

Brian A & Cindy E Welk, WA 

Brian C & Susan Barrett, WA 

Brian Craig Freeland, OR 

Brian D & Andrea L Garvey, WA 

Brian G & Rebecca L Leonard, WA 

Brian K Carter, WA 

Brian K. & Deborah M. Miedema, WA 

Brian L Kenkman, WA 

Brian L. & Susannah L. Conrad, WA 

Brian M McGuiness, WA 

Brian Osche, WA 

Brian R McClain, WA 
 A-23

Individuals (cont’d) 

Brian S & Suzanne J Lange, WA 

Brian S. & Kristin M. Isakson, WA 

Brian Wilson, WA 

Brock M Lenhart, WA 

Bruce & Joni McKenzie, WA 

Bruce & Shawnan M Becker, WA 

Bruce & Valerie Thompson, WA 

Bruce A Kincy, WA 

Bruce C & Melissa J Groenewegen, WA 

Bruce E & Kristen Nichols, WA 

Bruce G Blackstone, WA 

Bruce Stock, OR 

Bryan & Linda Stowe, WA 

Bryan & Rebecca Biggs, WA 

Bryan Gilbert, OR 

Bryan M & Monica L Besteman, WA 

Bryan R Plog, WA 

Bryan Rowlands, WA 

Bryan W. Sample & Jennifer L. Gorton, WA 

Bryce Eckhart, WA 

Bryn E & Marie J Volkman, NC 

Bryon K & Connie A Fauchald, WA 

Buford E & Judith O Welsh, WA 

Burl & Kang Yang Sullivan, WA 

Byung Jin Yang, WA 

C Murray Twelves, WA 

Calvin J & Elissa D Bruno, WA 

Calvin Patterson, WA 

Calvin R & Marilyn M Dickerson, WA 

Cameron & Amy L Birk, Wa 

Cameron Brister, OR 

Candace M France, WA 

Candis L Taylor, WA 

Cara Story, WA 

Cardyn Vena, OR 

Careen Stoll, WA 

Carey Mcquesten, OR 

Carl & Lynnette Law, WA 

Carl A. & Betty Lou Romtvedt & Curtis & Rosemary Goche, 

WA 

Carl Burns, WA 

Carl Dominey, OR 

Carl Harold Carlson, CA 

Carl Kisaberth, OR 

Carl L & Juanita M Carlson, WA 

Carl L Roth, WA 

Carl Ronzheimer, OR 

Carla C & Michael D Reynolds, WA 

Carla Kelley, WA 

Carlos A & Oku, Ayumi Melendez, WA 

Carlos Martinez, OR 

Carmen E Preciado, WA 

Carmen J & Olvera Sara Olvera, WA 

Carmen Rawlings, WA 

Carol Crawford, WA 

Carol Davis, OR 

Carol Graham, WA 

Carol Hewitt, WA 

Carol J. Borgaard, WA 

Carol L Markewitz, OR 

Carol Mcnair, OR 

Carol Newman, OR 

Carol Pellett, WA 

Carol Terry, OR 

Carole Bernhardt, WA 

Carole Hildebrandt, OR 

Carole J.C. Campbell, WA 

Caroline Kimler, OR 

Carolyn Eady, OR 

Carolyn H Clapp, OR 

Carolyn Lindau-Gill, WA 

Carolyn M Verner, OR 

Carolyn M. Geertsma & Robert A. Geertsma, WA 

Catherine Matthias, OR 

Catherine McKenzie, WA 

Catherine Siskron, OR 

Catherine Walters & Charles K. Jones, WA 

Cathy Hendrickson, WA 

Cathy Lindsay, WA 

Cathy Tombow, WA 

Cem H & Laura J Ullman-Onener, WA 

Chad Rankin, WA 

Chaeil & Kyong Bok Pak, WA 

 Chan, WA 

Chanthou & Sounn Tepsovanmony Lach, WA 

Charlene A Doran, WA 

Charles & Colleen Beauregard, WA 

Charles & Darcy Ross, WA 

Charles & Gretchen Grant, WA 

Charles A & Aura L Schreiner, WA 

Charles A & Chriseth L Hass, WA 

Charles A Petschke, WA 

Charles B Kimmel, OR 

Charles B., Jr & Donna L Pearman, WA 

Charles C & Janet K Duncan, WA 

Charles D & Julianne McEwen, WA 

Charles D Carman, WA 
 A-24 

Individuals (cont’d) 

Charles Dralle, WA 

Charles E & Erin M Eaton, WA 

Charles E & Martha C Schaffer, WA 

Charles F., Jr Osborn, WA 

Charles Garner, WA 

Charles Hughes, WA 

Charles J Clark, WA 

Charles J., Jr & Linda G Sandor, WA 

Charles L Dean, WA 

Charles L Royse, WA 

Charles M Patton, OR 

Charles N Wilson, WA 

Charles R & Kelley Smith, WA 

Charles R. Jones, WA 

Charles S Washer, WA 

Charles Schweigert, OR 

Charles Straughan, OR 

Charles V Helming, WA 

Charlotte Buck, WA 

Charlotte Winslett, OR 

Chen Suh Chyn & Larry L. Broad, WA 

Cheng-Taou & Lin, Chia-Ling Chou, WA 

Cheol-Min & Lee, Hyn Young Park, WA 

Cheree' Turner, WA 

Cheri Howe, WA 

Cheryl J. McDowell, OR 

Cheryl S Hannon, WA 

Chester E Wells, WA 

Chester R & Tana L Britton, WA 

Chloe Davenport, WA 

Chol Soon Shin, WA 

Chris & Autumn Bock, WA 

Chris & Jensen, Georgi Shoemaker, WA 

Chris & Julie Mardis, WA 

Chris & Katie Edwards, WA 

Chris Bridgens, OR 

Chris C. Ness, WA 

Christi Packard, WA 

Christian Bernard & Cary Wade, WA 

Christian M Johnson, WA 

Christina & David L. Heim, WA 

Christina Alexander, OR 

Christine A. Straight, OR 

Christine Henkel, WA 

Christine L Mahaffey, WA 

Christine Landry, WA 

Christine M & Melvin R Greiser, WA 

Christine M & Melvin R. Greiser, WA 

Christine North, OR 

Christine Su, WA 

Christine Underwood, WA 

Christine Whitehall, WA 

Christofer Joe Beacock, WA 

Christopher & Ann E Wenrick, WA 

Christopher & Lisa Kirby, WA 

Christopher & Melinda Brown, VA 

Christopher & Susan Bruder, WA 

Christopher A Johnson, WA 

Christopher and David Koh, CO Trustees, WA 

Christopher D Dideon, WA 

Christopher D Prochazka, WA 

Christopher Farrar, OR 

Christopher J & Wendy H Hagle, WA 

Christopher L Rask, OR 

Christopher Lamb, OR 

Christopher P & Rebecca H Pierce, WA 

Christopher P Tuohy, WA 

Christopher S & Bobbie J Roth, WA 

Christy Ann Peschl, OR 

Cindy Carder, OR 

Cindy Daly, OR 

Cindy L Littlejohn, WA 

Cindy Price, OR 

CJ Abbott, OR 

Claire A & Joshua W Douglas, WA 

Claire Keeble, WA 

Clarence L. Westhoff, WA 

Clarica Parsons, WA 

Clark C., Sr. & Barbara S. Gould, WA 

Clark C., Sr. Gould, WA 

Claudia DeLoff, OR 

Clay A & Claire R Keith, WA 

Clay S & Patricia L Benner, WA 

Clinton & Rachelle Nowels, WA 

Clinton A & Stefanie J Kilborn, WA 

Clinton Abbott, WA 

Clivonne Corbett, OR 

Clyde A & Sally Shetler, WA 

Clyde J & Patricia A Hall, WA 

Cody & Heather A Leckner, WA 

Colin Donnelly, WA 

Colin Donoghue, OR 

Colin Elder, WA 

Colin Riley, WA 

Colleen Burnett, WA 

Colleen Porter, WA 

Connie Paulsen, OR 
 A-25

Individuals (cont’d) 

Connie R Beyers, WA 

Connie Y & Oppenheimer Nakano, WA 

Connor N. Smith, WA 

Cordell N Stone, WA 

Cornelius-Eileen K Vreugdenhil, WA 

Craig A & Catherine C Hawkins, WA 

Craig A Seader, WA 

Cruz Elpidio, OR 

Curtis & Carolyn Lacy, WA 

Curtis Clifford, WA 

Curtis L & Joyce Robinson, WA 

Curtis L & Laura D Counley, WA 

Curtis R & Debra L Baxstrom, WA 

Curtis Vanselus, WA 

Cynthia Kaul, WA 

Cynthia Robinson, WA 

D Adair Drynan, OR 

D. Anderson, WA 

D. E. & T. R. Otterstrom, WA 

D. Mcclelland, OR 

D. Salochana & Lalesh Chand, WA 

Da Ouk, WA 

Daisy E Cissna, WA 

Dale & Darline Pruett, WA 

Dale A Clarke, OR 

Dale Albert & Shari K Roth, WA 

Dale Allen Guidi, OR 

Dale Barrett, OR 

Dale Boon, WA 

Dale D Klein, WA 

Dale E & Myra A Clark, WA 

Dale E Holtzworth, WA 

Dale E. & Amy K. Boultinghouse, WA 

Dale F Slanger, WA 

Dale L & Cheril A Erickson, WA 

Dallas J., Jr Dyer, WA 

Dan & Alicia L Wislocker, WA 

Dan & Ranum, Jennifer Murray, WA 

Dan Berentson, WA 

Dan Coyne, WA 

Dan Cronenwett, WA 

Dan K & Cathy J Loholt, WA 

Dan L & Eunice Defreece, WA 

Dan Lyon, MT 

Dan Miller, WA 

Dan Serres, OR 

Dan W & Gracie Jansen, WA 

Dan William Heiner, OR 

Dan Williams, WA 

Dana L Mattson, WA 

Dana M. Klatt, WA 

Dana W Holton, WA 

Dana Zia, OR 

Danay S & Teresa R McIntryre, WA 

Dane & Anne Egenes, WA 

Danial Kennedy, WA 

Danieil Green, OR 

Daniel & Amy Duefrane, WA 

Daniel & Arliss Benz, WA 

Daniel & Christin Raymond, WA 

Daniel & Davis, Kristin Ferguson, WA 

Daniel & Elizabeth Detloff, WA 

Daniel & Elizabeth Hanlon, WA 

Daniel & Ellen Cain, WA 

Daniel & Jo Eva Parker, WA 

Daniel & Ligia Iorga, WA 

Daniel & Mary Ann Hogue, WA 

Daniel A & Silvia L Peterson, WA 

Daniel Anthony Giluck, WA 

Daniel Armstrong, OR 

Daniel B Breen, WA 

Daniel B Rosenthal, WA 

Daniel Bergeron, OR 

Daniel D & Jenni Sillito, WA 

Daniel Dinh, WA 

Daniel E & Alisa D Lahaie, WA 

Daniel E & Bonnie R Ritola, WA 

Daniel F & Lori J Cockerham, WA 

Daniel G Sanders, WA 

Daniel Green, OR 

Daniel J & Ashley A Kristofzski, WA 

Daniel J & Cynthia R Winston, WA 

Daniel J & Karen M Hauser, WA 

Daniel J & Melissa A Rogers, WA 

Daniel J & Valerie Bryant, WA 

Daniel J. & Nathan B. Spencer, WA 

Daniel L & Sherrie L Baily, WA 

Daniel L & Sylvia M Hertlein, WA 

Daniel L Diiullo, WA 

Daniel M & Rebecca L McManus, WA 

Daniel Maguire, WA 

Daniel Ogren, OR 

Daniel P & Katrina M Scott, WA 

Daniel Q & Carolina C Rouse, WA 

Daniel R & Barbara M Presseisen, WA 

Daniel R. Serres, OR 

Daniel Rouslin, OR 
 A-26 

Individuals (cont’d) 

Daniel V Vasquez, WA 

Daniel Weishaar, WA 

Danny L & Shirley R Price, WA 

Dante Jesus & Liezl Arranza, WA 

Darcey B & Regina Teets, WA 

Darcie Babcock, OR 

Darcie C & Rafael Lessante, WA 

Darcy Walker, WA 

Daren S & Lesley Rogers, WA 

Darlene Turner, WA 

Darlene V Bellman, WA 

Darrel Claymore, WA 

Darren & Danielle Sterling, WA 

Darren Godbey, WA 

Darron L Whitehead, WA 

Daryl E & Tracy A Tanner, WA 

Daryl W. & De Etta Connite, WA 

David & Audrey Antkowiak, WA 

David & Catherin Anderson, WA 

David & Chong S Cutarelli, WA 

David & Cindy Rudisill, WA 

David & Cydney Lewis Nixon, WA 

David & Darlene Thompson, WA 

David & Linda Dorough, WA 

David & Lynn Thornton, WA 

David & Megan Edwards, WA 

David & Perish, Anthony McDowell, WA 

David & Sandra Egge, WA 

David & Terrie Espinoza, WA 

David & Terry Taylor, WA 

David & Victoria Levinson, WA 

David & Wendy Knoeppel, WA 

David (Trustee) McKeel, OR 

David A & Susan M Smith, WA 

David A Belden, OR 

David A Pierot, WA 

David A. Thompson Sr., OR 

David Ambrose, OR 

David B & Tricia A Bagley, WA 

David Black, WA 

David C & Mutita P Honsberger, WA 

David Carter, WA 

David Cruickshank, OR 

David D & Ajia A Davies, WA 

David D & Joan D Dawson, WA 

David D Borden, WA 

David Danielson, OR 

David Drury, OR 

David E & Hanna Dalia Sabath, WA 

David E. & Carey L. Allison, WA 

David Eugene Power, WA 

David G & Kathy A Elkins, WA 

David G & Kay J Chevalier, WA 

David G & Shirley R Krause, OR 

David Gill, WA 

David Glass, OR 

David Goldman, OR 

David H & Irma E Gross, WA 

David Hall Stewart, WA 

David J & Heather A Vitzthum, WA 

David J Fraser, WA 

David J. & Michelle R. & Christine L. Prestin, WA 

David Jones, OR 

David Jones, OR 

David K & Toni L Smith, WA 

David L & Jean M Rule, WA 

David L & Kathryn J Morgan, WA 

David L Webb, OR 

David L Wells, WA 

David L. & Leslie Hughes, WA 

David M McLaughlin, WA 

David McMahon, WA 

David N & Jennifer Allen, WA 

David N & Sherry L Heiserman, WA 

David P & Phuong T Hebert, WA 

David Paul & Amy Elizabeth Tallbut, WA 

David Plate, OR 

David R & Cheryl S Wheeler, WA 

David R & Jean H Seeley, WA 

David R & Tammy L McCabe, WA 

David R & Tresa Nelson, WA 

David R Eatwell, WA 

David R Swords, WA 

David S & Deborah S Masters, WA 

David S. & C. Carpenter; & Darryl & D. Brown, WA 

David Schmitz, WA 

David T & Valerie L Patterson, WA 

David T Walworth, WA 

David T. & Barbara E. Moore, WA 

David W & Harris-Riley, Sarah L Riley, WA 

David W & Judith A Foskette, WA 

David W & Kendra Richard, WA 

David W Raines, WA 

David Yager, OR 

David Zanghi, WA 

Dawn Clark, OR 

Dawn Zuger, WA 
 A-27

Individuals (cont’d) 

Dean & Betty Gross, WA 

Dean & Jodie Anderson, WA 

Dean A Kaufman, WA 

Dean Allen Owens, OR 

Dean D Lee, WA 

Dean Flaig, WA 

Dean Johnson, WA 

Dean N Sorensen, WA 

Dean Phelps, OR 

Dean Su, WA 

Deane R & Rachel E Wood, WA 

Deann Ketchum, WA 

Deanna Devereaux, WA 

Deanna L Hungerland, WA 

Debbra K. Edwards & James C. Pointere, WA 

Deborah Cain, WA 

Deborah M Marvil, WA 

Deborah McBeath, WA 

Debra A Bachmeier, WA 

Debra Hines, OR 

Debra L. Joh & Charlie, Jr West, WA 

Delbert & Colleen Ferree, WA 

Delene M Brayer, WA 

Dell Goldsmith, OR 

Della Johnson, WA 

Della M. Walker, WA 

Delores S Lumberg, WA 

Deloris F Jones, WA 

Delta Ockert, OR 

Dena Frances Baker-Davis, WA 

Dena Paffenroth, WA 

Denis Douglas Meunier, OR 

Denise Cornwell, WA 

Dennis & Adam Biwit, WA 

Dennis & Amy Gronholdt, WA 

Dennis & Shirley & Michael Roberts, WA 

Dennis Callegari, OR 

Dennis D & Judy A Walter, WA 

Dennis D & Maureen L Fehrenbach, WA 

Dennis E Holzer, WA 

Dennis F Koher, WA 

Dennis G Smith, WA 

Dennis Hanes, OR 

Dennis Heller, WA 

Dennis Higgins, OR 

Dennis J Mazelin, WA 

Dennis L & Karen J Karnes, WA 

Dennis M., Sr Dodge, WA 

Dennis P. & Kathle Bibko, WA 

Dennis R & Evelyn J Erceg, WA 

Dennis W. Sennert, WA 

Dennis Warren, OR 

Denyse Lockard, WA 

Derek & Bozlee, Breann Spence, WA 

Derek & Kristin Rand, WA 

Derick & Ames, Linda Allen, WA 

Devender Daniel & Debra Van, WA 

DeWayne & Dannella Jensen, WA 

Diana Boom, OR 

Diana Keller, OR 

Diana L & Bryce R Reynolds, WA 

Diana L & Mark A Haley, WA 

Diana M Loback, WA 

Diana McCarty, WA 

Diana S Bright, OR 

Diane Amarotico, OR 

Diane Dick, WA 

Diane E Gould, WA 

Diane Greenberg, WA 

Diane Heath, OR 

Diane Stearns, OR 

Diane Zink, OR 

Dianna P Spence, OR 

Dianne Frothingham, WA 

Dianne McChesney-Davis & Thomas Davis, WA 

Dick & Leona McArthur, WA 

Diedre M Clarke, WA 

Diljit & Dang Sethi & Kanwaldeep, WA 

Dion Kiene-Wheeler, WA 

Dirk E & Kristen Volcke, WA 

Dmitriy & Iryna Aleksandruk, WA 

Dodie Needham, WA 

Doe M. & Scott H. Hartz, WA 

Dolores L. Sannicolas & Chris D. Comstock, WA 

Dolores Zella E Nugent Nugent, WA 

Domonick Sanchez, OR 

Don & Charlotte Larison, WA 

Don Carson, OR 

Don E Sims, WA 

Don Hennig, OR 

Don Mills, OR 

Dona D Palmer, WA 

Donald & Betty Ansel, WA 

Donald A. & Nancy J. Sundvick, WA 

Donald E & Kathleen K Mundy, WA 

Donald E & Kathy J Fourre, WA 

Donald E & Marian L Ely, WA 
 A-28 

Individuals (cont’d) 

Donald F Beatty, WA 

Donald Falleur, OR 

Donald G & Jacqueline J West, WA 

Donald G Winter, WA 

Donald H & Emma J Hemminger Rev Living Trust, Donald H. 

& Emma J. Hemminger, WA 

Donald J & G Nadeane Jensen, WA 

Donald J & Minnie E Trentman, WA 

Donald Johnson, OR 

Donald L Berg, WA 

Donald L Pugh, WA 

Donald M Sykes, WA 

Donald Mangini, WA 

Donald McDaniel, WA 

Donald Morden, OR 

Donald R & Jane M Carbaugh, WA 

Donald R & Kathryn A Rushton, WA 

Donald R & Kathy R Dibblee, WA 

Donald R Kennedy, WA 

Donald R Staley, WA 

Donald R Swanson, WA 

Donald R Wallace, WA 

Donald S. Lieurance, WA 

Donald T Sanders, WA 

Donald V. Bergerson, OR 

Donna & Ricardo Casanova, WA 

Donna Baker, WA 

Donna Loomans, WA 

Donna Osborne, OR 

Donnie Lee & Sheryl Ann Herring, WA 

Donnie R. & Rudine V. Mayfield, WA 

Doris Corrado, OR 

Dorothy A Harju, NV 

Dorothy Carpenter, WA 

Dorothy I Park, WA 

Dorothy L & Daniel I Buell, WA 

Dorothy Leu, WA 

Dorothy R. Mooney, OR 

Doug Huigen, WA 

Doug Lofting, OR 

Doug N & Nicole M Kiger, WA 

Douglas & Shaune Godfrey, WA 

Douglas A Meyer, WA 

Douglas D Burns, WA 

Douglas Faron, WA 

Douglas J Almond, WA 

Douglas J Perry, WA 

Douglas J Weber, WA 

Douglas Morrison, WA 

Douglas P & Joy E Miller, WA 

Douglas R Crim, WA 

Douglas S Roth, WA 

Douglas Speers, OR 

Douglas Werner, WA 

Douwe & Leona Van Ess, WA 

Doyle & Arlene Johnson, WA 

Drew & Ashlee Evans, WA 

Drew Herzig, OR 

Duaine A. Hiler Etux, WA 

Duane & Connie Bryant, WA 

Duane & Jeanette Tevelde, WA 

Duane Clausen, OR 

Duane Clausen, OR 

Duane E & Diane C Hahn, WA 

Duane T. & Vivian T. Cordray, WA 

Duc Do, WA 

Dustin Y & Alison Greer, WA 

Dysa Kafoury, WA 

Eahou R & Nicole D Davis, WA 

Earl & Carmen Henderson, WA 

Earl C Lauth, WA 

Earl Lee Hyatt, WA 

Earl Powers, OR 

Earl Wright, OR 

Earlene Rothauge, WA 

Ed Frodel, WA 

Ed J & Kelly A Depaoli, WA 

Eddie Fusaro, WA 

Eddie J Leach, WA 

Edith A & Judi A Lovelace, WA 

Edith S. Orner, OR 

Edmund W., Jr Roller, WA 

Edward & Jacqueline Peterson, WA 

Edward & Pamela Klopfer, WA 

Edward & Penny Zenker, WA 

Edward & Terry Holtgraves, WA 

Edward A & Carol B Dayoob, WA 

Edward A & Christina G Martinez, WA 

Edward A & Helen K Solem, WA 

Edward A & Susan Klatkiewicz, WA 

Edward A Fletcher, WA 

Edward A Tilzer, WA 

Edward Archie Dass, OR 

Edward B Angus, OR 

Edward D. & Tamera Malakoff Barrows, WA 

Edward Durham, OR 

Edward E & Molly E Evans, WA 
 A-29

Individuals (cont’d) 

Edward G & Christine G Coleman, WA 

Edward J & Helen G Schlotfeldt, WA 

Edward L & Bethel K Johnson, WA 

Edward M & Krista M Olson, WA 

Edward Panowicz, OR 

Edward R & Jennifer C Herda, WA 

Edward Stratton, OR 

Edward, L Bayly, Or 

Edwin & Linda Massey, WA 

Edwin C. & Kathleen D. Sharpe, WA 

Edwin J & Myrna L Hume, WA 

Edwin Q & Jennifer W Tam, WA 

Efrain & Laurie Sanchez, WA 

Eileen and Victor Chieco, OR 

Eileen R Boman, WA 

Eino Johnson, OR 

Ekta Mittal, WA 

Eldon D & Rebecca S Baumgardner, WA 

Elfriede H Kristwald, WA 

Eli & Kaela Holm, WA 

Elinore Darland, OR 

Elisabeth Bondy, WA 

Elisha S & Judy E Harris, WA 

Elizabeth A Roberts, WA 

Elizabeth C Haba, WA 

Elizabeth H Coker, OR 

Elizabeth Keyser, OR 

Elizabeth R Larson, WA 

Elizabeth R. Carnay, WA 

Elizabeth Rankine, WA 

Elizabeth S Noorwood, WA 

Elizabeth Vreugdenhil, WA 

Elizabeth W Rogers, WA 

Ellen Bondurant, OR 

Ellen Carpentier, WA 

Ellen Odmark, WA 

Ellen R. O'Hern, WA 

Ellen Saunders, OR 

Elma E Monts, WA 

Elmer M & Marjory Hoover, WA 

Elpidio Cruz, OR 

Elton & Fritzi M Edwards, WA 

Emil L & Kristin M Williams Liedtke, WA 

Emily J. Montreuil & Richard T. McCartney, WA 

Emory J Gerhart, WA 

Erc Mendenhale, WA 

Eric & Barbara Lopez, WA 

Eric & Lisa Brunner, WA 

Eric B & Cheryl A Smith, WA 

Eric B McLeroy, WA 

Eric Burr, WA 

Eric C & Courtney J Grimstad, WA 

Eric C. Stroud, OR 

Eric Chase, WA 

Eric D & Daniel Webster Wilkerson, WA 

Eric D & Kristina K Swanson, WA 

Eric Devereaux, WA 

Eric Grechko, WA 

Eric J & Andrea G Haley, WA 

Eric Johnson, WA 

Eric K & Melinda D Ness, WA 

Eric L T Johnson, WA 

Eric M & Tracy A Haines, WA 

Eric W & Julia A Sims, WA 

Erich Freitas, WA 

Erick P. Bennett, OR 

Erik Halvorson, WA 

Erin G & Robert W Stevens, WA 

Ernest O'Byrne, OR 

Ernest W & Elsie M Moffet, WA 

Ernie Laulainen, WA 

Ernie Loreen, WA 

Escott L Gardiner, WA 

Estelle Voeller, OR 

Eugene & Ida Vangrinsven, WA 

Eugene M Bleth, WA 

Evelyn J Wilson, WA 

Evelyn M & Owens, Leah Tte Miller, WA 

Everett G & Eileen M Meyer, WA 

Ezra D. Baldwin, WA 

Farhad & Lida Mottaghian-Milani, WA 

Farrell Orton Farms LLC, WA 

Fay Payton, WA 

Felicia Cohen, OR 

Ferdinand Mark P & Girlie A Flores, WA 

Finn R Christiansen, WA 

Flick D Broughton, WA 

Florin Baias, WA 

Floyd L., Sr Voie, WA 

Floyd Prozanski, OR 

Francis C & Adanne J Jeffries, WA 

Francis E. Quinn, OR 

Francis G & Pamela K Humiston, WA 

Francis J & Larene K Durning, WA 

Francisco Santiago, WA 

Frank & Joan Wagner, WA 

Frank Falco, OR 
 A-30 

Individuals (cont’d) 

Franklin & Margarita Molina, WA 

Franklyn Henry, WA 

Frans Eykel, WA 

Franz Puhl, OR 

Fred & Darlene Furukawa, WA 

Fred White, OR 

Fred, Jr Hamm, WA 

Frederick A & Carol A Mathers, WA 

Frederick Graves, WA 

Frederick K Go, CA 

Frederick M & Dorothy F Lowell, WA 

Frederick R Revocable Trust ET AL Bernet, OR 

Fredrick L & Cristi Casebolt, WA 

Fritz E. & Louise M. Abhold, WA 

G. Dianne & Gilmore I., Jr Peterson, WA 

Gabe C Fields, OR 

Gabriel V Cruceanu, WA 

Gabriele Bartholomew, WA 

Gail J Poole, WA 

Gail Lovelady, WA 

Gail M. Zmok, OR 

Gail Sorensen, WA 

Gale A & Penny S Massey, WA 

Gale M. Fitterer & Gregory Jon Wagner, WA 

Galen Davis, WA 

Gansler Trust, WA 

Gary & Pamela Hendrickson, WA 

Gary & Sandra Chittenden, WA 

Gary & Sherylynn Dettwiller, WA 

Gary & Susan Rogers, Wa 

Gary & Wiggins, Whitney Lagerstrom, WA 

Gary A Alexander, WA 

Gary Barnett, OR 

Gary Cannell, WA 

Gary Cotton, WA 

Gary Dyer, WA 

Gary E & Debroah R Nicklett, WA 

Gary F & Debbie R Daniels, WA 

Gary K Johnson, WA 

Gary L & Chrysler Dana L Chrysler, WA 

Gary L & Debra D Hatfield, WA 

Gary L & Edith A Thomas, WA 

Gary L & Jacquelyn K Knaus, WA 

Gary L Sylte, WA 

Gary M. & Rebecca & David Ferderer Cline, WA 

Gary Massoni, OR 

Gary N Robertson, WA 

Gary Norman, WA 

Gary R. Howard, WA 

Gary T & Becky Ribelin, WA 

Gary W & Brigid K Totten, WA 

Gary W & Kari L Carlin, WA 

Gary Witteman, OR 

Gary Ziak, OR 

Gayle & Jerome Kroke, WA 

Gayle Kiser, WA 

Gayle RogersBullington, WA 

Gene & Kim, Eun Jung Oh, WA 

Gene & Magdalena Ross, AZ 

GENIE L LIVING TRUST & DAVID L FOLSOM, WA 

Geoffrey A & Lorna D Mueller, WA 

George & Dona Loflin, WA 

George & Judy Keith, WA 

George & Julia Hemminger, WA 

George & Maricel Abenojar, WA 

George A Biggerstaff, WA 

George and Caroline Trice, WA 

George E & Heather H Holcomb, WA 

George E & Portia Wilcock, WA 

George Exum, WA 

George Georgitsis & Scott Overby, WA 

George Hague, OR 

George L & Bernice E Brunelle, WA 

George N. Ying Lin Lawrence, WA 

George Paradis, WA 

George R & Sandra L Roscoe, WA 

George S & Patricia A Krencik, WA 

George W. & Sharon R. Kinkade, WA 

George Warren, OR 

George William Wiemerslage, WA 

Georgina Boyson, WA 

Gerald & Jody R Bentler, WA 

Gerald & Vicki Mylan, WA 

Gerald A & Janet L Welch, WA 

Gerald Copeland, OR 

Gerald G Clark, WA 

Gerald Holubiczko, AZ 

Gerald L & Cherie M Kiger, WA 

Gerald L & Judith L Lange, WA 

Gerald Lindquist, WA 

Gerald Peterson, WA 

Gerald R & Marie A Johnson, WA 

Gerald R Lemmons, OR 

Gerald T & Shirley L TTEE Hodgins, WA 

Gerald W Walstad, WA 

Geri Roubidoux, WA 

Gerold D & Lori A Parsons, WA 
 A-31

Individuals (cont’d) 

Gerry & Myldred Cunnington, WA 

Gerry R & S K Anderson Curtis, WA 

Ghose Sayata & Marcus Belcher, WA 

Gilbert & Leta R Goethals, WA 

Gilbert D Snyder, WA 

Gilbert Rodriguez, WA 

Gina L Andrews, WA 

Gladys T Ramsdell, WA 

Glen Harter, WA 

Glenn E Bagley, WA 

Glenn Gilbert, WA 

Gloria Miniszewski, OR 

Gordon E Howe, WA 

Gordon J & Kathy M Francis, WA 

Gordon W & Nadeene Wiebe, WA 

Govindaswamy Bacthavachalu, WA 

Grace Moore, WA 

Gray Mckee, OR 

Greg & Christiane Carder, WA 

Greg Blomstrom, CA 

Greg Hanon, WA 

Greg Mecklem, OR 

Gregg K & Cynthia K Cunningham, WA 

Gregory & Amanda Nelson, WA 

Gregory & Smith, Evon Andal, WA 

Gregory & Vanhout, Gretch Johnson, WA 

Gregory B & Charlotte R Proulx, WA 

Gregory Cecil, WA 

Gregory E & Angela M Hovde, WA 

Gregory N & Brandi L Marvin, WA 

Gregory S & Danielle L Watson, WA 

Gregory S & Patricia E McVey, WA 

Gretchen E Vanbrunt, WA 

Guadalupe Reifers, WA 

Guerdon C Ellis, WA 

Gust A & Tricia M Jahner, WA 

Gwen L. McMahon, OR 

H. Bernard, IV & Kristen L. Hansen, WA 

Hank & Ruth Leenstra, WA 

Hank Mrazkowski, OR 

Hans G & Ann K Lindstrom, WA 

Hans J & Hazel A Siebert, WA 

Harley Pfaff, WA 

Harnek & Sohi Ananteeep Kaur Dhudwal, WA 

Harold A Matz, WA 

Harold D & Elizabeth A Disharoon, WA 

Harold E & Gertrude L Britton, WA 

Harold Gaskin, OR 

Harold Grass, OR 

Harold J & Kathleen I Rupe, WA 

Harold Palmer, WA 

Harriet Berman, OR 

Harriett Mckim-Smith, OR 

Harris E & Elaine M Cox, WA 

Harry B. & Doris A. Anderson, WA 

Harry G Cumming, OR 

Harry K D O'Neill, WA 

Harry L & Darlene R Woolery, WA 

Harry L Bond, WA 

Harry O Clements, WA 

Hassan & Shahla Ghassemieh, WA 

Hazel Caldwell, WA 

HDR, Matt Hutchinson, OR 

He & Fan, Yi Tiangi, WA 

Heather & Moerch, Tony D Shaw, WA 

Heather Greene-Beloit, WA 

Heather Marx & Corey Ray, WA 

Hector A P & Siragusa Mariscol C Matos, WA 

Hector L & Zina M Rodriguez, WA 

Heidi Buchwald, WA 

Heidi Matheney, OR 

Heidi Newsome, WA 

Helen & Perry E. Johnson Living Trust, Helen Johnson, NJ 

Helen Jean Tillotson, WA 

Helen Moore, OR 

Helen, Trust Dtd 11-23-09, Et Al Johnson, NJ 

Helena M Wester, OR 

Helon Howard, OR 

Henry & Carol Hayes, WA 

Henry & Kathleen Vandermeulen, WA 

Henry E Whittlesey, WA 

Henry Meeker, OR 

Henry N. & Tanis Miller, WA 

Henry O'Brien, OR 

Herbert A Wilke, WA 

Herbert H & Grace Killam, WA 

Herbert Lloyd G & Rudge, Barbara Knowles, WA 

Herbert M. & Nancy Jean Wiseman, WA 

Herman Barnett, WA 

Herman Gotfrid Conrad Nix, WA 

Higgins Living Trust & Robert W. Higgins, WA 

Hikojiro & Sharon E Katsuhisa, WA 

Hoi Man Sun, WA 

Hollis Paul, WA 

Holly A. Grenz & Allen J. Grenz, WA 

Holly Ann Rogers, WA 

Holly L & Jonathan H James, WA 
 A-32 

Individuals (cont’d) 

Holly Rickles, WA 

Hong Wan, WA 

Hongzeng & Liu Fengfen Guo, WA 

Howard B & Lisa C Nelson, WA 

Howard Clark, WA 

Howard E III & Janet G Bowers, WA 

Howard L., Jr & Jana Herrold, WA 

Hugh A & Janet L Grimoldby, WA 

Hugh A Hillis, WA 

Huiqin Jiang, OR 

Hye Kyung Kim, WA 

Ian Jezorek, WA 

Ian Quinones, WA 

Ik Jung & Eun Hee Seo Chun, OR 

Ila E Hawkes, OR 

Innes McLaren, OR 

Ioan & Raveca Muntean, WA 

Irene & Arnold Coon, WA 

Irene & Howard G. Judd, WA 

Irene Bensinger, WA 

Irene Embrey, WA 

Irene M. Suver, WA 

Ivan E & Terry Jensen, WA 

Ivan O. Anderson, WA 

Iwona Marciniak-Glabek & Arkady Glabek, WA 

J Richard & Tami Baalman, WA 

Jack & Jackie Bruner, WA 

Jack & Janice Bothwell, WA 

Jack A. Goodson, WA 

Jack Dalton, OR 

Jack E Hughes, WA 

Jack K & Danelle L Sanders, WA 

Jack L Wray, WA 

Jack M & Kathryn C Frost, WA 

Jack M Turk, WA 

Jack Oates, WA 

Jack P & Suzanne C Edwards, WA 

Jack R & Kathy I Green, WA 

Jack Radey, OR 

Jackie Melvin, OR 

Jackie Orton, WA 

Jackie Sorensen, OR 

Jacob A Rummel, OR 

Jacob W & Jennifer L Miller, WA 

Jacqueline Lorenzen, WA 

Jagdish & Sibylle Singh, WA 

Jai Hari S Khalsa, OR 

Jaime & Priscilla Cerna, WA 

Jaime & Spengler, John & Link, WA 

Jamee J Tate, WA 

James & Carol Fare, WA 

James & Carole Gay, WA 

James & Carole Lowman, WA 

James & Connie Jo Dykstra, WA 

James & Doris Lott, WA 

James & Gumhan Kim, WA 

James & Krishanthi Nelson, WA 

James & Marsha Wilson, WA 

James & Melinda Riley, WA 

James & Vernalee Lindemann, WA 

James A & Cristi A Acuna, WA 

James A & Norma Douvier, WA 

James A West, WA 

James A. & Laura J. S. Laudolff, WA 

James A. Douglas, WA 

James B & Cynthia L Badham, WA 

James B & Rebecca A Potter, WA 

James B & Shea A Craver, WA 

James B & Sheryl M Schmidt, WA 

James C & Crystalina D Hyatt, WA 

James C Ralph, WA 

James E & Camela M Sutton, WA 

James E & Carrie J Olesen, WA 

James E & Cynthia L Elder, WA 

James E & Jillene K Holter, WA 

James E & Lisa Thomas, WA 

James E. Lee, OR 

James E. Spiess, WA 

James E., Jr & Evelyn Brooks, WA 

James F Koch, WA 

James F. O'Hearn & Todd L. Kody, WA 

James G. Moore, WA 

James H & Leanne R Miller, WA 

James H & Shirley W Echols, WA 

James Holman, OR 

James K Lee, WA 

James Kalberer, WA 

James Kellett, WA 

James L & Lucille S Langland, WA 

James L & Vonnie E Milden, WA 

James L McFall, WA 

James L. Martini, OR 

James Lee Lancaster, WA 

James Leonard, WA 

James Leroy Dillinger, WA 

James Lyle & Alic Hardenburgh, WA 

James M & Jane C Bond, WA 
 A-33

Individuals (cont’d) 

James M & Marcie R Fricke, WA 

James M & Vicki L Wagner, WA 

James M., Jr Johnson, WA 

James McClasky, WA 

James Neikes, OR 

James Nichols, OR 

James O & Shirley J Boldt, WA 

James O & Tammy L Ludlow, WA 

James O Kimball, WA 

James P & Kelly M Bramell, WA 

James P & Marylan L Kelly, WA 

James P Dailey, WA 

James P Kennedy, WA 

James R Gallaugher, WA 

James R. & Shannon R. Silvernail, WA 

James R., Jr & Janet L. Carson, WA 

James Reith, OR 

James S., Jr & Heide A. Hudson, WA 

James Schuler; & E. W. & Therese Gordon, WA 

James T Kreofsky, WA 

James Taylor, WA 

James W & Eugenia K Fenton, WA 

James W Richard, WA 

James W Tootell, WA 

James Wallace, WA 

James Y Kim, WA 

Jamie & Joshua A Taylor, WA 

Jamie & Peter Quinlan, WA 

Jamie Lee Stewart & Jacqueline Miller, WA 

Jan Petree, OR 

Jan Rinehart, OR 

Jan Walker, WA 

Jane & Shimoda, Terryll Ronngren, WA 

Janet Allen, WA 

Janet and Daniel A. Dommasch, OR 

Janet Ross, WA 

Janet Vaillancourt, OR 

Jani J Kelly, WA 

Janice Baker, WA 

Janice E Jonas, WA 

Janice Eller, OR 

Janice L George, WA 

Janice Levi, OR 

Janis A Leikam, WA 

Jared C & Janelle N Mike, WA 

Jared L Hamrick, WA 

Jason & Elaine Noack, WA 

Jason & Kristalyn March, WA 

Jason & Megan Turner, WA 

Jason & Stephanie Lucier, WA 

Jason & Toni Brown, WA 

Jason & Wentz, Stepheney Eley, WA 

Jason Brim, OR 

Jason D & Gabriel A Omat, WA 

Jason Ford, WA 

Jason G & Krystal L Strand, WA 

Jason Howell, WA 

Jason L & Sommer S Lindell, WA 

Jason R & Donna M Holland, WA 

Jason Sweeney, OR 

Jay & Megan M Marchand, WA 

Jay & Vallone Ben Vallone, WA 

Jay B & Pamela J Penick, WA 

Jay K & Nicole C Gusler, WA 

Jay M Weil, OR 

Jay R. & Bernadette M. Lind, WA 

Jay W Garthwaite, WA 

Jayn Foy, WA 

Jean C Boyd-Wylie, WA 

Jean M & Susan C Kattar, WA 

Jeanette L Mishler, WA 

Jeanne A Lohmann, WA 

Jeanne Brooks, OR 

Jeanne Hochstein, WA 

Jed M & Michelle L Woodward, WA 

Jeff & Lynda Schwindt, WA 

Jeff & Michele Friesel, WA 

Jeff C. Variel, OR 

Jeff R & Gail L Hemstead, WA 

Jeffery A & Candy D McVey, WA 

Jeffery K & Tahlia M Butler, WA 

Jeffery K. & Karen R. Jansma, WA 

Jeffrey & Marta Smith, WA 

Jeffrey & Mildred De Marre, WA 

Jeffrey & Rebbecca Krone, WA 

Jeffrey & Reichlin, Danise Robinson, WA 

Jeffrey & Shannon Von Forell, WA 

Jeffrey & Tina Ko, WA 

Jeffrey A & Cheri S Jacobsen, WA 

Jeffrey A Davis, WA 

Jeffrey Campbell, WA 

Jeffrey Ellwood, WA 

Jeffrey H Chivers, FL 

Jeffrey J Conwell, WA 

Jeffrey L & Cynthia E Akins, WA 

Jeffrey M & Lora Patterson, WA 

Jeffrey M & Naoni E Elliott, WA 
 A-34 

Individuals (cont’d) 

Jeffrey P Poirrier, WA 

Jeffrey Quinney, WA 

Jeffrey S & Turner, Katherine R Lawrence, WA 

Jeffrey S Pantley, WA 

Jeffry & Theodore Dunnington, WA 

Jemma Crae, OR 

Jenelyn M Wessler, OR 

Jenness Mann, OR 

Jennifer & Scott Hamblen, WA 

Jennifer Anne Sakchalathorn, CA 

Jennifer Risner, WA 

Jennifer Short, WA 

Jennifer Tice, WA 

Jennifer Torgison, WA 

Jennimae Hillyard, WA 

Jenny YoungSeidemann, OR 

Jerald L & Yumi T Roth, WA 

Jeramie J & Angela M Ausmus, WA 

Jeremiah D Pierucci, WA 

Jeremy & Renee Evje, WA 

Jeremy & Rivera, Ruben & Rivera, WA 

Jeremy & Shanna Visser, WA 

Jeremy A & Joanne D Ehrmantrout, WA 

Jeremy J & James R Herbel, WA 

Jeremy Kallerman, WA 

Jeri K Sargent, OR 

Jerri Eilert, WA 

Jerrol Smerek, WA 

Jerry & Brandy Huang, WA 

Jerry & Brenda Ng, WA 

Jerry & Pamela Gomes, WA 

Jerry D Mooberry, WA 

Jerry N Sturglaugson, WA 

Jerry Osness, WA 

Jeryce Russell, OR 

Jess & Carol Workman, WA 

Jesse A & Maren L Kreun, WA 

Jessica Schwabe, WA 

Jessie G & Andrea N Napenias, WA 

Jessie Thomas, OR 

Jesus Martinez Diaz, WA 

Jian Zhong & Yuehua, Lin Tang, WA 

Jill Hartman, WA 

Jill J. Walter & Deann Goodspeed, WA 

Jill Rouse, WA 

Jill Seidenstein, WA 

Jim Burnett, OR 

Jim Capellen, OR 

Jim Hawk, WA 

Jim K & Lani L Lok, WA 

Jim Santee, OR 

Jim Scheller, OR 

Jim Stoffer, OR 

Jim VonStein, OR 

Jim Zaleski, OR 

Jimmie L & Patricia H Richardson, WA 

Jimmie Y & Lynne Inouye, WA 

Jimmy Beckwith, OR 

Jimmy D & Debbie Francis, WA 

Jisook Ri Chun & Young K. Chon, WA 

Jo Hannan, OR 

Joan R. Buckmaster, WA 

Joann Muller, OR 

Joanna Connolly, OR 

Joanne Gregory, CA 

Joanne Shih, WA 

Joao Karlos Vilca Soto, WA 

Jody McCaffree, OR 

Jody Rodgers, WA 

Joe A & Lora M Riley, WA 

Joe E Wishcamper, WA 

Joe Hengel, OR 

Joe Kane, WA 

Joe Nelson, WA 

Joe R Hutchings, WA 

Joel A & Michelle M Zehe, WA 

Joel Lucia, OR 

Joel Myers, OR 

Joelle Mauthe, WA 

John & Asako Voorhees, WA 

John & Catherine Lenac, WA 

John & Christine Rosenquist, WA 

John & Cynthia Fuller, WA 

John & Elizabeth Davidson, WA 

John & Gretchen Corbin, WA 

John & Heidi Ellis, WA 

John & Joanne Parmley, WA 

John & Linda Larsen, WA 

John & Lynne Norton, WA 

John & Marta Tankersley, WA 

John & Mary Faure, WA 

John & Michelle Dunn, WA 

John & Michelle Scoggins, WA 

John & Sheila Barlow, WA 

John & Teri Parks, WA 

John A & Donna P Hunter, WA 

John A & Joan A Dragavon, WA 
 A-35

Individuals (cont’d) 

John A & Joyce A Burns, WA 

John A Rodrigue, WA 

John A Surbert, WA 

John A. Williams; & J. M. Fulton & L. Edward Strobel, WA 

John Angell, AK 

John C Taber, OR 

John D Bargen, WA 

John D Feldman, WA 

John D Ferris, WA 

John D. & Crystal R. Hagel, OR 

John Demaria, OR 

John Dervin, WA 

John DuBois, WA 

John E & Chun Mien Christian, WA 

John E & Lynn E Kilgus, WA 

John E & Sheri L Lawson, WA 

John E Mitnik, WA 

John E Scofield, WA 

John Edwards, WA 

John H & Allene L Rodenberg, WA 

John H & Nancy E Dahlen, WA 

John H Pitman, OR 

John H. Korpi, AK 

John Hahn-Francini, OR 

John I & Gloria Kountz, WA 

John J & Brigett T I Hall, WA 

John J Christiansen, WA 

John J. & Lisa K. Bluff, WA 

John Jordan, OR 

John Jr. (Heir) Taggart, OR 

John K Tolonen, WA 

John K. Hoxeng & Sonja L. Prince, WA 

John Kaakinen, OR 

John Kalander, OR 

John Linzee, WA 

John Little, OR 

John M & Carol A Hamlot, WA 

John M & Nancy Graff, WA 

John M Corwell, WA 

John M., III Myles, WA 

John Magnuson, WA 

John O'Neil, WA 

John Oscar, Jr & Kirsten Marie Morton, WA 

John P & Kathleen A Corrigan, WA 

John P Jeroue, WA 

John P Wimberley, OK 

John Paul, OR 

John R & Delores Pettitt, WA 

John R Urback, WA 

John Rogantine, OR 

John Rogantine, OR 

John S & Lynn G Burch, WA 

John S & Toni Brender, WA 

John Stelfox, WA 

John W & Judith A Bogsch, WA 

John W & Rosemary B Allen, WA 

John Washington, OR 

John William Kaakinen, OR 

John, Jr Soltis, WA 

Johnny E & M Sharon Swartz, WA 

Johnson Revocable Trust, WA 

Jon B. Thomas, OR 

Jon C & Cynthia J Flinchbaugh, WA 

Jon C & Joyce C Evans, WA 

Jon D & Evanne B Aarstad, WA 

Jon Hornback, WA 

Jon Koriagin, OR 

Jon Madian, WA 

Jon Shelley, OR 

Jonathan & Angela Teano, WA 

Jonathan A & Maegen A Blue, WA 

Jonathan Floyd, WA 

Jonathan G & Mary J Dinsmore, WA 

Jonathan H & Elizabeth Clark, WA 

Jonathon A & Kimberly Shipman, WA 

Joni M Bragg, WA 

Jon-Michael & Caroline Terlaje, WA 

Jorge G & Barbara J Tirado, WA 

Jose A Trujillo, WA 

Jose Acosta-Jaquez, MI 

Jose Garcia, WA 

Jose Mendoza, WA 

Jose R & Armida Mayorquin, WA 

Josef Gault, OR 

Joseph & Karen Hurzeler, WA 

Joseph & Kathleen Spadaro, WA 

Joseph & Suzette Yoshitake, WA 

Joseph B & Theresa Indovina, WA 

Joseph Bodmer, WA 

Joseph C. & P. F. Patterson, WA 

Joseph Christen, OR 

Joseph Deutsch, WA 

Joseph Gymkowski, OR 

Joseph L & Kelley L Bremgartner, WA 

Joseph L & Margie R Parker, WA 

Joseph Lee Rex & Bern Hoover, WA 

Joseph M & Janet E Macher, WA 
 A-36 

Individuals (cont’d) 

Joseph M & Janice M Emery, WA 

Joseph Michael Haggren, OR 

Joseph P & Roberta L Schlosser, WA 

Joseph Riddell, WA 

Joseph S & Susan P Powell, WA 

Joseph T. & Annette T. Leclair, WA 

Joseph, Jr Santilli, WA 

Josephine Luke, WA 

Josh Cole, OR 

Joshua & Walker, Adrienne Mark, WA 

Joshua Alan & Beth Alison Smith, WA 

Joshua C Searle, WA 

Joshua D & Nicolette E Marzolf, WA 

Joshua Lomen, WA 

Joshua Montero, WA 

Josie Peper, OR 

Joy Arianashira, WA 

Joyce C Beahan, WA 

Joyce Law & David Faires, WA 

Joyce M Driscoll, WA 

Joyce W Teng, WA 

Joyce Weir, WA 

Jr & Tressa Greene Trust Clarence, WA 

Juan J & Vazquez, Deyana M Hernandez, WA 

Juan, Jr & Georgette M. Bandin, WA 

Juanita Rosene, OR 

Judith A Hart, WA 

Judith A Rivera, WA 

Judith B. Kocer, WA 

Judith Grote, WA 

Judith Hart, WA 

Judson & Karil J Branch, WA 

Juel M. Smith & Ronald L. Norton, WA 

Jugraj & Randhawa Singh, WA 

Julia Bondi, OR 

Julia C Partlow, OR 

Julia Herrin Reed, WA 

Julia Hurd, WA 

Julianne Hall, OR 

Julie E Hillend-Jones, WA 

Julie K Larson, WA 

Julie Whitacre, WA 

Juliet Ching, OR 

Juliette C Smith, WA 

Julio & Phoebe Mendez, WA 

Julio Torres, WA 

June Buma, WA 

June C Stinson, WA 

Jurgen Exner, WA 

Justin & Erin Gillenwater, WA 

Justin & Michelle A Harries, WA 

Justin & Mindy Byran, WA 

Justin & Raquel Onedera, WA 

Justin T Kenney, WA 

K C Heckenberg, OR 

K Jane Mccassey, OR 

K Sweeney-Easter, WA 

Kae Moe, WA 

Kalyanaraman & Sangeet Prasad, WA 

Kanishk & Neha Panwar, WA 

Kannan Choodamani & Aruna Kannan Iyer, WA 

Karen Calvin & Robert E., Jr Woodard, WA 

Karen L Rodewald, WA 

Karen Levine, OR 

Karen M & Michael A Thomas, WA 

Karen M Haverkate, WA 

Karen Moody, WA 

Karen Pehoushek, WA 

Karen Shawcross, OR 

Karen Whalen, WA 

Karen Wickham, OR 

Kari & Ruth Ann Hakso, WA 

Kari Kay Boyle, WA 

Karl H & Beth M Deissler, WA 

Karl M Ludwig, WA 

Karl Piller, OR 

Karl R Sieger, WA 

Karla C Pineda, WA 

Kate Joyce Cooper, OR 

Katherine & Eric and Brown, Randall Gudgel, WA 

Katherine & Salvador Santos, WA 

Katherine A & Nygaard K & R E Selsor, WA 

Katherine Batts, WA 

Katherine Foldes, OR 

Katherine Kauzlarich, WA 

Katherine Mast, OR 

Katherine Mayben, WA 

Katherine Riddle, WA 

Kathi Merrit, OR 

Kathleen A Erholm, WA 

Kathleen A Seehorn, WA 

Kathleen C Carrera, WA 

Kathleen Forcier, WA 

Kathleen Hall, WA 

Kathleen Ing, WA 

Kathleen Kelly, WA 

Kathleen Meagher, OR 
 A-37

Individuals (cont’d) 

Kathleen Mitchell, WA 

Kathleen Richardson, WA 

Kathleen Robson, WA 

Kathleen Sullivan, OR 

Kathryn Levine, OR 

Kathryn M Barnard, WA 

Kathryn R Wayne, WA 

Kathy Bowen, OR 

Kathy Greysmith, OR 

Kathy Johnson, WA 

Kathy L Saka, WA 

Kathy M Boyll, OR 

Kathy Su-Tsow, WA 

Kathy Swingle, WA 

Kathy Wilson, WA 

Katie Whittier, WA 

Kay Kendall, OR 

Kay Kinsley, OR 

Kay L Hoffman, WA 

Kay M Lyon, WA 

Kay Peterson, OR 

Kayla & Alex Hill, WA 

Kees Kolff, WA 

Keith & Charlyn Anderson, WA 

Keith A Terry, WA 

Keith D Zaichkin, WA 

Keith Hay, CA 

Keith J & Karen J Boon, WA 

Keith Mason, WA 

Keith Morey, OR 

Keith Neal, OR 

Keith Strader, WA 

Keith W Lofstrom, WA 

Kelly Glenn & Thaddeus Singer, WA 

Kelly Paige, OR 

Kelvin G & Tracie T Lung, WA 

Kelvin Lindren, WA 

Kemper Family Living Trust, Matthew & Delores Schouten, 

OR 

Ken & Gena Unser, WA 

Ken & Joomi Shou, WA 

Ken & Rise A Crowl, WA 

Ken Garman, WA 

Ken R & Linda C Solberg, WA 

Ken Whipple, WA 

Kendrick Simila, OR 

Kenneth & Linda Carlson Schroeder, WA 

Kenneth B. & Sandra L. Ness, WA 

Kenneth Breckwoldt, WA 

Kenneth Brown, OR 

Kenneth Cambley, WA 

Kenneth D. Smith, WA 

Kenneth G & Lisa A Haynes, WA 

Kenneth J. Hicks, OR 

Kenneth L & Gloria Crocker, WA 

Kenneth L & Janna L Stevens, WA 

Kenneth L & Kimberly L Courser, WA 

Kenneth M & Carlaine E Downs, WA 

Kenneth R & Susan F Geschwint, WA 

Kenneth R. Ampel, OR 

Kenneth Rask, OR 

Kennie Lee Jr & Adrienne L Cotton, WA 

Kent & Maureen Callen, WA 

Kent A & Heidi L Kamphouse, WA 

Kent J Preston, WA 

Kent S & Gretchen M Stepaniuk, WA 

Kenton C. Barker & Megan P. Condon, WA 

Keri Callahan, WA 

Kerie M & Aaron A Swepston, WA 

Kerry K. Harper & T. C. Goff, MO 

Kerry Phibbs, WA 

Kerry W & Debrah J Cruze, WA 

Kerry Warren, WA 

Keshuang & Zhang, Caifeng Shen, WA 

Kevin & Cherisse Chapman, WA 

Kevin & Gallo, Patti Murphy, WA 

Kevin A & Pamela Wessel, WA 

Kevin A & Sharon L Gansneder, WA 

Kevin A & Victoria L Cleveland, WA 

Kevin B & Carole Bullard, WA 

Kevin C & Jackie L Stone, WA 

Kevin Gundersen, WA 

Kevin J & Shelley A Walker, WA 

Kevin J & Tia McGreevy, WA 

Kevin Johnson & Ashli D. Tyre, WA 

Kevin K & Erica L Ford, WA 

Kevin Kern, WA 

Kevin Leja, WA 

Kevin P & Heather M Joyce, WA 

Kevin P & Susan P Sullivan, WA 

Kevin Schmidt, WA 

Kevin Slaughter, WA 

Kevin T Seward, WA 

Kevin Wickes, WA 

Khuong & Nguyen, Jaclyn Le, WA 

Kiernan Hodge, OR 

Kim & Lewis, Jimmy Merow, WA 
 A-38 

Individuals (cont’d) 

Kim A & Paula Y Crumrine, WA 

Kim Chesley, WA 

Kim L Scott, WA 

Kim Weers, WA 

Kimberly French, WA 

Kimberly M & Edward A Page, WA 

Kimberly Olds-Craig, WA 

Kimberly Serrano, OR 

Kirati & Ladda Mankongvanichkul, WA 

Kirk & Sarah Reid, WA 

Kirk E Hyatt, WA 

Kirk H Prindle, WA 

Kirk R. Nortman, OR 

Kirsten E. Esvelt, WA 

Kit Watts, OR 

Knutson Testamentary Trust & Mark C Knutson, WA 

Krisha Davis, WA 

Kristie L Terrio, WA 

Kristin Barber, WA 

Kristin L Joachim, OR 

Kristina & Chris B Newcomb, WA 

Kristine I & Daniel B Borden, WA 

Kristofer & Stephanie Sparks, WA 

Krystal M. Erickson & Jory L. Clark, WA 

Kuhlman Louis J, WA 

Kurbanali H Merchant, WA 

Kurt & Becky McKibben, WA 

Kurt & Betsi Stich, WA 

Kurt A & Susan H Hamke, WA 

Kyle Hatfield, WA 

L Daloz, WA 

L. A. Kimmet & Brian E. Roberson, WA 

L. K. Althouse, OR 

L. R. Lofgren & H. E. Truitt, WA 

Ladonna & Kummerfeldt, Ryan Meadows, WA 

Lana Massa, WA 

Lana Maupin, OR 

Lance & Tina Larsen, OR 

Langley Family Trust, Mark Langley, WA 

Lanny H. & Jill S. Cawley, WA 

LaRee Johnson, OR 

Larry & Betty Pekkola RLT (Trustees), OR 

Larry & Holly Mahan, WA 

Larry & Kelsey Dungan Rand, WA 

Larry D Chinn, WA 

Larry D Drawhorn, WA 

Larry D. & Margaret Trudeau, WA 

Larry Dale & Kathleen E Loveall, WA 

Larry G & Kathleen S Hittle, WA 

Larry G & Mary Harbison, WA 

Larry Gravely, WA 

Larry K & Sandra D Albertson, CO 

Larry L & L Dianne Pletcher, WA 

Larry Lovelady, OR 

Larry M Wasisco, WA 

Larry M. & Debra L. Lowe, WA 

Larry Mark Bergeson, OR 

Larry R Williamson, CA 

Larry S. Ahl, OR 

Larry Scott McMillan, HI 

Larry Steele, OR 

Larry Troy, WA 

Larry W & Sally S Omo, WA 

Larry Williams, OR 

Laura Alves, OR 

Laura C Cassey, WA 

Laura Golinod Lavato, OR 

Laura Leigh Brakke, WA 

Laura VanFleet, OR 

Laurence W. Brown, WA 

Laurie B Porter, WA 

Laurie Doscher, OR 

Lavon D & Mary M Woodard, WA 

Lawrence & Laura Johnson, WA 

Lawrence A & Patricia A Jones, WA 

Lawrence D James, WA 

Lawrence M Thorpe, OR 

Lawrence R & Elaine Haft, WA 

Leah Matheson, OR 

Lee & Susan Boevers, WA 

Lee B & Natasha Parker, WA 

Lee Labrash, WA 

Lee Miller, WA 

Lee Powell & Joyce Gillingham, WA 

Lee Roy J Engler, WA 

Lee Roy Seymore, WA 

Lee Talbott, OR 

Lee Vern Truman, WA 

Lee Walkling, WA 

Lee Wilson, OR 

Leith Macfarlane, OR 

Leland Seibert, OR 

Lemec & April Pierre, WA 

Lemoine Radford, WA 

Lena Sayers, WA 

Lenoir K Hayward, OR 

Lenora & Guy Anderson, WA 
 A-39

Individuals (cont’d) 

Lenora M. Anderson, WA 

Leo L & Diane Kimmet, WA 

Leon Chow, CA 

Leon J Lara Dolores, WA 

Leon T & Frances S Matz, WA 

Leon Thrane, WA 

Leona Crow, WA 

Leonard & Linda L Ramsdell, WA 

Leonard Brock, WA 

Leonard H & Leila R Brickey, WA 

Leonard Hockley, OR 

Leonard M Roughgarden, WA 

Leonard Maslanka, OR 

Leonard P & Patrice A Vincent, WA 

Leonard V & Lorraine E Simpson, WA 

Leroy B & Laurel A Fay, WA 

Leroy K. & Joyce A. Bruenn Trust, Leroy, WA 

Lesia Montgomery-Toms, WA 

Leslea Steffel-Dennis, WA 

Lesley A & Keller, Benja Colby, WA 

Leslie A Methe, WA 

Leslie E Bailey, WA 

Leslie E Baker, NV 

Leslie J Patterson, WA 

Leslie Myrick, WA 

Leslie Patrick, WA 

Leslie Sonnergren, WA 

Lester A Slead, WA 

Lester H Greene, WA 

Lester Rowles, WA 

Levi Perkins, OR 

Lewey Brown, WA 

Lewis & Diane & Hood, Daryl D Lopes, WA 

Lewis Tiffany, WA 

Li Huan & Wei Wang, WA 

Lijah K Manus, WA 

Lila Mahan, WA 

Lillian Buchanan, WA 

Linda & Robert H Burns, WA 

Linda B. Streitfeld, WA 

Linda Cleckler, WA 

Linda Harkness, Wa 

Linda Hruby, WA 

Linda Kirk, WA 

Linda L DeSitter, OR 

Linda R. Adye & Andrew B. Whitish, WA 

Linda Siverts, WA 

Linda Sloane & Dwain D. Dabney, WA 

Linda Stiles-Taylor, OR 

Linda Thompson, OR 

Linda Versteeg, OR 

Lindsay A Jensen, WA 

Linnea H. Evans, WA 

Lisa A Britto, WA 

Lisa Bull, WA 

Lisa Dekker, WA 

Lisa Fleek, WA 

Lisa Karas, WA 

Lisa Kelsey, WA 

Lisa M. Richards & David M. Richards, WA 

Lisa M. White & Kristofer A. Corning, WA 

Lisa Malland, WA 

Lisa R Resser, WA 

Lisa Stevens, WA 

Lisbet S Johnson, WA 

Liu Yen Ping Chiao, WA 

Llory Boynton, WA 

Lloyd & Gail Wright, OR 

Lloyd C Dally, WA 

Lloyd L Walker, WA 

Logan Rowland, WA 

Lois C Bush, WA 

Lois Eagleton, OR 

Lois J Perrett, WA 

Lois Kieffaber, WA 

Lois Maxine Lee, WA 

Lonn C Sweeney, OR 

Lonnie G & Lucille A Brown, WA 

Lonnie K Sargent, WA 

Lonny J Wolk, WA 

Loraine M Dennett, WA 

Loren & Bonnie Gilderoy, WA 

Loren J & Shelli J Ackerman, WA 

Loretta Orosz, OR 

Lori Ann Disparte Carter, WA 

Lori L. & Michael K. Hogarty, WA 

Lorraine J Holcomb, WA 

Lorraine N King, WA 

Lorree Gardener, WA 

Lorrie L Massie, WA 

Lorrie M Wood, WA 

Louis & Stefanie Mendenhall, WA 

Louis I & Emily M Duran, WA 

Louis Kloewer, WA 

Louise Vinuya & Jeffrey Shands, WA 

Low Alexander, OR 

Luanna Iverson, WA 
 A-40 

Individuals (cont’d) 

Luanne & James Caylor, WA 

Lucas G & Kirstie A Teeter, WA 

Luciguela E King-Smith, WA 

Lucile Brook, OR 

Lucille M Gardner, WA 

Lucy Mead, OR 

Luke J & Brenda L Goethals, WA 

Lulu Heavenrich, OR 

Lyle E & Vicky J Fox, WA 

Lyn Mattei, OR 

Lynda M & Donald T McDaniel, WA 

Lynn C Axtell, WA 

Lynn F Cooke, WA 

Lynne Treat, WA 

M D Shively, WA 

M Ellen Moon, WA 

M Johantgen, WA 

M Michael Slama, CA 

M. L. Tompkins & John F. Forgey, WA 

Madeline Kokes, OR 

Madeline Murphy, OR 

Magdalena S Trotter, WA 

Mahlon D. Heller, CA 

Makarand & Sonali Bhagwat, WA 

Man Pham, WA 

Manila M Cannon, WA 

Manish Ajmera, WA 

Manuel & Zorel Yu, WA 

Marc & Elizabeth Provencher, WA 

Marc P Mattila, WA 

Marc R & Makisha L Norwick, WA 

Marc Ratner, OR 

Marc Vigna, WA 

March Twisdale, WA 

Marcia Gervin-Gillyard, WA 

Marcia L Nanea, WA 

Marcie C. Kahler & James C. Davis, WA 

Marga Stanley, OR 

Margaret & Brian Pomeroy, WA 

Margaret A Maxwell, WA 

Margaret C McNees, WA 

Margaret Fourhman, WA 

Margaret J Steeves, WA 

Margaret J. Worthman, WA 

Margaret L Larson, WA 

Margaret Lemberg, WA 

Margaret M Denison, OR 

Margaret Ross, WA 

Margaret Thompson, OR 

Margarita Calderon & Eduardo Dominguez, WA 

Margie J. Couch & Antonio E., Jr Peralta, WA 

Margitta M Schulz, WA 

Margot Fetz, OR 

Maria I. Gonzales & Juan A. Daza, WA 

Maria Isabel Cuevas & Ricardo Bramila, WA 

Mariah Lindgren & Jacob Tilton, WA 

Marianna Redd, OR 

Maricres M & Clinton D Talley, WA 

Marie Stuckey, OR 

Marily D A Berko, WA 

Marilyn Levin, OR 

Marion M Barr, WA 

Marisol L & Sean P Brice, WA 

Mariya Yagodina, WA 

Marji Westwood, WA 

Marjorie A Noren, WA 

Marjorie Cogan, WA 

Marjorie, Tedrick- Turner, WA 

Mark & Albany Walters, WA 

Mark & Cynthia Harp, WA 

Mark & Jennifer Balentine, WA 

Mark & Judy Franklin, WA 

Mark A Gallegos, WA 

Mark Anderson, WA 

Mark B & Diane A Satterlee, WA 

Mark B. & Gloria G. Cutler, WA 

Mark C & Kim T Hammer, WA 

Mark D & Heidi D Fuller, WA 

Mark D Farman, WA 

Mark E & Jane R McDaniel, WA 

Mark E Cunningham, WA 

Mark E. & Carol A. Schulz, WA 

Mark E. Rosin, WA 

Mark Eagleton, OR 

Mark F & Kimberley E Nygard, WA 

Mark H Hickman, WA 

Mark Hedin, WA 

Mark J Gilbert, WA 

Mark L & Karin A Hettel, WA 

Mark R & Catherine A Nonhoff, WA 

Mark S Edwards, WA 

Mark Sutton, WA 

Mark T Unno, OR 

Markus & Megan Charboneau, WA 

Marlon Montano, OR 

Marni K McGuire-Elhard, MT 

Marshall C., Jr Jones, WA 
 A-41

Individuals (cont’d) 

Marshall T & Cynthia R Blansfield, WA 

Marta Saarheim, OR 

Martha Sucher, WA 

Marthan Walker, NV 

Martin A Nance, WA 

Martin Ed Wise, WA 

Martin Fox, WA 

Martin Nygaard, OR 

Martin Schroeder, OR 

Martin Velez, OR 

Marty & Bian, Knitter Griffith, WA 

Marty E Belfield, WA 

Marvin A & Glenda B & Vreugdenhil, John B Vreugdenhil, WA 

Marvin A. & G. Bernice Vreugdenhil, WA 

Marvin C & Saralee Smith, WA 

Mary A McCann, WA 

Mary Ann Brown, OR 

Mary B Hutson, WA 

Mary Bennett, WA 

Mary Blake, OR 

Mary C. Darling & Mark D. Langen, WA 

Mary Cody, OR 

Mary Colton, WA 

Mary E McKay, WA 

Mary E. Swinnerton, OR 

Mary F Slaight, WA 

Mary Flores, WA 

Mary Gabriele, OR 

Mary Gaughan, WA 

Mary Jane Gray, OR 

Mary K Weller, OR 

Mary Larsen, WA 

Mary Lasswell, OR 

Mary Lou SanBlise, OR 

Mary P. Lang, WA 

Mary P. Scully, OR 

Mary Smith, OR 

Mary VanDer Veen, WA 

Maryann Aborqui, WA 

Mathew & Nicole Zemanek, WA 

Mathew J & Shawna M Fuller, WA 

Mathew J &Robyn N Eldridge, WA 

Matt & Tok Nary Swart, WA 

Matt Hodson, OR 

Matt Mathews, OR 

Matthew & Airen Perry, WA 

Matthew & Caitlin Schweyen, WA 

Matthew & Karli McIver, WA 

Matthew & Lisa Woicik, WA 

Matthew & Ti Fan Bucher, WA 

Matthew A & Angela I Peart, WA 

Matthew D & Nicole L Newsome, WA 

Matthew H Marksbury, WA 

Matthew Hayrynen, WA 

Matthew J Kline, WA 

Matthew L & Donald F & Judith M Olson, WA 

Matthew M & Cindy Hamilton, WA 

Matthew P Bracking, WA 

Matthew S & Jessica M Weber, WA 

Matthew Schiffman, OR 

Maug & Bo Ra Kim, WA 

Maureen Dooney Mosley, OR 

Maureen F. Knutson, WA 

Maureen L Medford, WA 

Maurine & Michael Corcoran, WA 

Max Cameron, WA 

Maynard & Charlotte Trust Westmark, WA 

Megan & Eric M Hall, WA 

Mehrdad Ghaffari, WA 

Melanie Beattie, WA 

Melinda Blackwell, OR 

Melinda Essig, WA 

Melinda Flaig, WA 

Melinda R Lytle, WA 

Melissa & Jon Mortensen, WA 

Melissa A Wallace, OR 

Melody Williamson, OR 

Melony S & Aaron S Cannata, WA 

Melvin (Trustee) Hartill, OR 

Melvin R & Laurie A Rees, WA 

Melvin Ulven, OR 

Merle & Timothy Miller, WA 

Merlin G Rev Liv Trust Bowman, OR 

Merry V. Young, OR 

Meryle A Korn, OR 

Micaela Moore & Michael Muhammad-Powell, WA 

Michael & Brenda Keith, WA 

Michael & Carli Gilbert, WA 

Michael & Cathy Wojtowicz, WA 

Michael & Cindy Smith, WA 

Michael & Connie Wolffe, WA 

Michael & Denise Hines, WA 

Michael & Gwendolyn More, WA 

Michael & Helen A Milyo, WA 

Michael & Kathleen Miele, WA 

Michael & Kathleena Gomes, WA 

Michael & Katie Zinkgraf, WA 
 A-42 

Individuals (cont’d) 

Michael & Kimberly C. & Chesley D. & Jackie D. Tippery, WA 

Michael & Laurie Debus, WA 

Michael & Lesa Springer, WA 

Michael & Lisa Ahlen, WA 

Michael & Lori Bonifant, WA 

Michael & Patty Haukenberry, WA 

Michael & Velva J Lytle Wynne, WA 

Michael A & Angela Parker, WA 

Michael A & Kathleen M Essig, WA 

Michael A & Mariye Ota Cina, WA 

Michael A & Sandro D. Moscone; Teresa Grage & Stewart 

Metcalfe, WA 

Michael A & Sharon L Dahl, WA 

Michael A Sears, OR 

Michael Armstrong, WA 

Michael Ashe, WA 

Michael Aubele, TX 

Michael D & Bianca Lemmons, WA 

Michael D & Elizabeth Swanson, WA 

Michael D & Judy V Flanagan, WA 

Michael D & Sharon M Fogarty, WA 

Michael D & Sherri L Kingsley, WA 

Michael D & Susan M Harris, WA 

Michael D Anderson, WA 

Michael D McDaniel, WA 

Michael D Yandl, WA 

Michael E & Amy L Shappell, WA 

Michael E & Theresa Grijalva, WA 

Michael F Pfister, WA 

Michael F Seibel, WA 

Michael G & Elizabeth Bejarno, WA 

Michael G. & Merrily M. Sloan, WA 

Michael H & Evelyne H Kennedy, WA 

Michael H & Kristi A Keene, WA 

Michael Hampel, WA 

Michael J & Dianne E Grant, WA 

Michael J & Elaine S Moshcatel, WA 

Michael J & Kathleen A Hassur, WA 

Michael J & Kristine L Duncan, WA 

Michael J & Lissa M Smith, WA 

Michael J & Pamela A Degrenier, WA 

Michael J & Wendy M Del Sarto, WA 

Michael J Amrine, WA 

Michael J Devine, WA 

Michael James Lull, WA 

Michael John Dragness, WA 

Michael K & Karen G McNamara, WA 

Michael K Wolf, WA 

Michael Krumper, OR 

Michael L & Sarah A Dotson, WA 

Michael L & Wendy A Young, WA 

Michael L Roesch, WA 

Michael Lombardo, WA 

Michael Mcgee, WA 

Michael O'Neal, WA 

Michael Osborn, WA 

Michael P & Patricia G Anderson, WA 

Michael P & Wendy T Woodward, WA 

Michael P Tipps, WA 

Michael P Vernon, WA 

Michael P Wisniewski, WA 

Michael P. & Amy J. Williams, WA 

Michael R & Susan G Cross, WA 

Michael R. Boehmer & Daniel C Lindstrom, WA 

Michael R. Reed, OR 

Michael Robinson, OR 

Michael S & Carrie A Gove, WA 

Michael S & Lisa N Alexander, WA 

Michael Slaughter, WA 

Michael Snyder, WA 

Michael Sturges, OR 

Michael Swift, NV 

Michael T & Joan K Watson, WA 

Michael T Wooding, WA 

Michael W & Barbara B Hallum, WA 

Michael W & Briana Ethington, WA 

Michael W. & Bonita I. Sours, WA 

Micheal D & Claudia M Ussery, WA 

Michela Bona & Davide Bertolo, WA 

Michele M Durkee, WA 

Michele Mennett, OR 

Michele VanRiper, OR 

Michelle & Ream, Jody Barnett, WA 

Michelle Barnes, OR 

Michelle Debell, WA 

Michelle Downing, WA 

Michelle J & Joshua B Gunia, WA 

Michelle L Darby, WA 

Michelle L Shambo, WA 

Michelle L. Duhaime & Richard D. Duhaime, WA 

Michelle M Evans, WA 

Michelle Rothbauer, WA 

Michelle Stewart, WA 

Mickey W & Kathy Ann Askew, WA 

Miguel & Montes Alicia A Amaral, WA 

Miguel Tadeo Jimenez, WA 

Mike & Debbie Sands, WA 
 A-43

Individuals (cont’d) 

Mike J & Nolly C Bartos, WA 

Mike Kennedy, OR 

Mike/Chris Conroy, WA 

Mildred L Lange, WA 

Miles Martin, OR 

Mitch Pyle, WA 

Mitchell A Noftsger, WA 

Mitchell Ross, OR 

Mitzi Loftus, OR 

Miyuki Peterson, WA 

Mohammad R & Nahid, Hosseini Sianaki, OR 

Molly Brown, OR 

Molly Oberbillig, WA 

Molly Onkka, WA 

Molly Palmer, WA 

Monica Taylor, OR 

Monty J & Fadila Brown, AE 

Monty L & Margaret Ann Price, WA 

Monty R Perrott, AZ 

MoonHill Mushrooms LLC, WA 

Morgan Family Trust, Tom & Leah Morgan, WA 

Mr. David S Gill, CA 

Ms. Charlotte Dinolt, OR 

Ms. Wendy Loren, OR 

Muralikrishnan V & Edavalath, Sunitha T Puthanveetil, WA 

Murugesan S & Nirma Subramani, WA 

Muschi Mayflower, OR 

Mychael A & Wyn U Ta, WA 

Myron & Priscilla Zwadlo, WA 

Myron A & Karin A Struck, WA 

Myrtle M Specht, WA 

Mysti L & Martin R Andrews, WA 

N. C. Caldwell & Thomas C. Lafond, WA 

Nadine L. Vanoverbeke & David J. Lord, WA 

Nan Ellen Haberman & David Ingles Brock, WA 

Nancy A Newell, WA 

Nancy Brock, OR 

Nancy Ceasar, OR 

Nancy E. Jackson & Bruce R. Healy, WA 

Nancy Earnst, WA 

Nancy Ledgerwood, OR 

Nancy Nelson, OR 

Nancy P. White, WA 

Nancy Phillips, OR 

Nancy Smith, WA 

Nancy Spaan, OR 

Nanette Leaman, WA 

Naomi N. Fellows, OR 

Nardito N Ferrer, WA 

Natalie Mercer, WA 

Natalie Mercer, WA 

Nathan A & Janice L Wiggins, WA 

Nathan D & Christina Scherer, WA 

Nathan Scott Lee, OR 

Nathan Visan, WA 

Nathaniel & Stephanie Kenison, WA 

Neal & Serena Friedman, WA 

Neal E & Shannan D Wooten, WA 

Neal Stiffler, OR 

Ned Petrich, OR 

Neenos Rees, WA 

Neil & Kimberly Pedersen, WA 

Neil R & Patricia E Gansler, WA 

Nelson A. & Pamela I. Graham, WA 

Nelson A. Graham, WA 

Nelson H Harano, WA 

Nhu Nguyen, WA 

Nicaela A. Hart & Gregrey R. Hemenway, WA 

Nicholas & Courtney Marg Brunelle, WA 

Nicholas & Danielle Lashbaugh, WA 

Nicholas B & Theresa A Galash, WA 

Nicholas Condon, WA 

Nicholas J & Colleen M Volk, WA 

Nicholas Singer, OR 

Nick & Janet Sprynczynatyk, WA 

Nick Engelfried, OR 

Nick Galaday, OR 

Nicole & Turrie, Matthew Berry, WA 

Nicole Hughes, WA 

Nicole M Martin, WA 

Nikolai Kopets, WA 

Nikolay & Olga Verimeyev, WA 

Nita & Kenneth Waller, WA 

Norman C Grier, WA 

Norman C. Waddell, OR 

Norman G & Lucille S Araki, WA 

Norna M & Michael J Luquette, WA 

Nowell King, OR 

O. Fred Eckhardt, OR 

Olaf L Olsen, WA 

Olga & Grigory Tereshchenko, WA 

Om Prakash & Yadav Niti Ravi, WA 

Ona Elizabeth & Douglas William Nighswonger, WA 

Ordie & Pamela Butterfield, WA 

Orville D Esteb, WA 

P.T. Baldwin, OR 

Paige Maks & Shannon Anderson, WA 
 A-44 

Individuals (cont’d) 

Pamela O Ericson, WA 

Pamela R & Fawcett Schneider, WA 

Panesko Trust, WA 

Paranthaman Sundaravadivelan, WA 

Pascal & Heather Mansy, WA 

Pat Arnold, WA 

Pat Corcoran, OR 

Patrice Pelland, WA 

Patricia A. Ellis, OR 

Patricia A. North, OR 

Patricia Ann Stevens, WA 

Patricia Carpenter, WA 

Patricia Doheny, WA 

Patricia Emerson, VA 

Patricia J Fabian-Chavez, WA 

Patricia K Hayes, WA 

Patricia Kellogg, OR 

Patricia Kennedy, OR 

Patricia Knowles, NV 

Patricia M & Danial R Clay, WA 

Patricia M Miller, WA 

Patricia Otto, WA 

Patricia Terranova, OR 

Patricia Thoe, WA 

Patrick & Jennifer O'Leary, WA 

Patrick & LaDawna Clerget, WA 

Patrick & Michael Dooney, OR 

Patrick & Sharon Hardy, WA 

Patrick A. & Erica L. Griffith, WA 

Patrick C & Verna M. Dessert, WA 

Patrick D Clark, WA 

Patrick G & Kathleen Rua, WA 

Patrick J Gu, WA 

Patrick J., Sr O'Brien, WA 

Patrick K McKillip, WA 

Patrick M & Irma J Morgan, WA 

Patrick M Ryan, WA 

Patrick M. & Cheri A. McClellan, WA 

Paul & Jennifer Tusler, WA 

Paul A Hahn, WA 

Paul C. Crocker, OR 

Paul D Johnson, WA 

Paul E & Vesta L Gibbard, WA 

Paul E. Staub, OR 

Paul J. Lutzenberger, WA 

Paul Johansen, WA 

Paul Johnson, WA 

Paul L & Karen J Tegantvoort, WA 

Paul M & Tatiana J Johnson, WA 

Paul M., II & Sonia G Wright, WA 

Paul Pohlreich, WA 

Paul R & Serena S Messner, WA 

Paul R. & Grace I. Shaw Hill, WA 

Paul S Cho, WA 

Paul Sansone, OR 

Paul Thompson, WA 

Paula M Cook, WA 

Paula Mackrow, WA 

Paula Springer, OR 

Paulette Edmiston, WA 

Pauline M Weber, WA 

Paval A & Olga Magdalin, WA 

Pavel &Chelsea Buzek, WA 

Peg ElliottMayo, OR 

Peggi Erickson, WA 

Per Holten-Andersen, OR 

Perry P Corwin, WA 

Pete II & Sheri Jorgensen, WA 

Peter & Janis L Pikulin, WA 

Peter & Tin Ness Som, WA 

Peter A Blane, WA 

Peter E & Kristin M Carlson, WA 

Peter Henry, WA 

Peter J & Alejandra G Decruz, MS 

Peter J. III Szambelan, OR 

Peter M & Frances A Crosby, WA 

Peter S Ogden, WA 

Peter Truax, OR 

Peter W. & Susan Janicki, WA 

Phil Goldsmith, OR 

Philip & Eileen Laskowski, WA 

Philip & Linda Bye, WA 

Philip & Viola Barber, WA 

Philip A & Joyce E Marick, WA 

Philip B Korthius, WA 

Philip J & Kathleen E Demaree, WA 

Philip M & Fanny Y Yee, WA 

Philip Mahony, OR 

Philip S Erikson, WA 

Phillip & Gorham, Pamela Mills, WA 

Phillip B Halloran, WA 

Phillip C Johnson, WA 

Phillip J & Sarah A Moss, WA 

Phyllis Borden, WA 

Piper Henry-Keller, WA 

Polizois & Tracey Johnston, WA 

Porter B Lombard, OR 
 A-45

Individuals (cont’d) 

Porter H & Jacquelyn L Sigler, WA 

Preston & Jennifer Thorne, WA 

Preston Malzahn, WA 

Qian & Yoke Wong Zhang, WA 

Qian & Yoke Wong Zhang, WA 

Quan & Kristina Wang, WA 

Que Areste, WA 

Quentin L & Molly L Clark, WA 

R Jay & Brenda Allred, WA 

R Wayne & Anne Redington, WA 

R. D. Edfeldt & B. V. Steussy, WA 

R. Duncan MacKenzie, OR 

R. Grant, Jr & Vicki A. Levens, WA 

R. Isaacson, WA 

R. John Spade, WA 

R. W. & Annabelle Bolduc, WA 

Racheal A Bell, WA 

Rachel Gilbert, WA 

Rae Anne Miller, WA 

Rajbir & Rupinder Raju, NJ 

Ralland L Wallace, WA 

Ralph & Marlene Riden, WA 

Ralph & Victoria L Willey, WA 

Ralph David Jones, WA 

Ralph L Edwards, WA 

Ramon Del Puerto, WA 

Randall B & Sonna L Eader, WA 

Randall C & Sheryl A Arens, WA 

Randall D & Melanie J Hanson, WA 

Randall Frable, WA 

Randall Henderson, OR 

Randall J. & Deborah L. Vaughter, WA 

Randall N. Parks, WA 

Randolph A Peters, OR 

Randy & Alberta Cobb, WA 

Randy & Diana Castro- Owens, WA 

Randy Behrendsen, WA 

Randy J & Judy L Sprague, WA 

Randy L & Lori L Olson, WA 

Randy L & Robin J Johnson, WA 

Randy L Chandler, WA 

Randy L Eckstrom, WA 

Randy Lee Sorensen, WA 

Randy R & Debra J Fisler, WA 

Randy Ruggles, OR 

Randy Schleis, WA 

Randy Wiser, WA 

Raphael Donayri, OR 

Raul M & Jennifer Rojas, WA 

Ray Gilbertson, WA 

Ray Hines, WA 

Ray K. Chapman, Jr., WA 

Rayella Oppenlander, OR 

Raymend L & Misty R Dupuis, WA 

Raymond & Mary Hsu, WA 

RAYMOND C & JANET M Christianson, WA 

Raymond D Wilson, WA 

Raymond E & Kassie M Clark, WA 

Raymond E & Theresa J Bentley, WA 

Raymond E Tibeau, WA 

Raymond L & Beverly J Johnson, WA 

Raymond O & Gayle A Goin, WA 

Raymond R & Beverly A Carr, WA 

Raymond T & Gail Arrington, WA 

Rayner Ward, OR 

Rebeca Reese, OR 

Rebecca D. Gray, WA 

Rebecca F Hughes, WA 

Rebecca I Panzer, WA 

Rebecca Pearson, WA 

Rebekah M Mergenthal, WA 

Rem & Joy Heng, WA 

Rene Berblinger, OR 

Renee Smith, WA 

Reuben & Heather Hokanson, WA 

Rex O & Joanne Bratton, WA 

Rhonda Bekker, WA 

Rhonda Peterson, WA 

Ricardo A & Valerie Gallagher, WA 

Richard & Angela Stanley, WA 

Richard & Arlene Nation, WA 

Richard & Cindy Fuhr, CO 

Richard & Claralee Williams, WA 

Richard & Crissy Leigh Dills, WA 

Richard & Delores Irvine, WA 

Richard & Donna Eliason; & Donald & Helen Eliason, WA 

Richard & Judy Inch, WA 

Richard & Kassel Rana Thomasy, WA 

Richard & Kristi Fawver, WA 

Richard & Lana I Zielinski, WA 

Richard & Melinda Mark, WA 

Richard & Rae Hahn, WA 

Richard & Susan Muxen, WA 

Richard A & Andrea Porter, MD 

Richard A & Melinda A Endres, WA 

Richard A Rizzs, WA 

Richard B & Victoria Olsen, WA 
 A-46 

Individuals (cont’d) 

Richard Beckwith, WA 

Richard Bell, OR 

Richard Broome, WA 

Richard Bryant, WA 

Richard C & Judith E McIntosh, WA 

Richard C Winter, WA 

Richard Colombo, OR 

Richard D & Kristina M Jenkins, WA 

Richard D & Phyllis J Krueger, WA 

Richard D Born, WA 

Richard Delamare, WA 

Richard E & Linda G Powell, WA 

Richard F Glad, WA 

Richard G & Sarah J Sando, WA 

Richard H & Dana L Edmondson, WA 

Richard Hanschu, OR 

Richard Houghton, WA 

Richard J & Behrend, Joy R Woods, WA 

Richard J & Joan E Dwyer, WA 

Richard J & Pok Sun Arnold, WA 

Richard J Leon, WA 

Richard J., Jr Kleemeyer, WA 

Richard Jr & Karen D O'Neil, WA 

Richard Keenan, WA 

Richard L & Helen R Orcutt, WA 

Richard L & Susan M Hall, WA 

Richard L., Sr & Mary A Yaple, WA 

Richard M. Schurman (Trust), CA 

Richard M., III Westover, WA 

Richard Magathan, OR 

Richard Nakada, WA 

Richard P & Tam L Nguyen, WA 

Richard P., II & Gretchen A. Austin, WA 

Richard R Carroll, WA 

Richard Schmitz, OR 

Richard Schultz, WA 

Richard T & Tonya R Watanabe, WA 

Richard W & Catherin Flanders, WA 

Richard W & Tina M Bredengerd, WA 

Richard W Drosman, OR 

Richard W. & Elizabeth R. Rathbun, WA 

Richard Winfield & Julie Hart, WA 

Richards Trust, WA 

Rick Martin, WA 

Rick N Young, WA 

Rick R Moser, WA 

Ricky & Rosalinda V Eser-Jose, WA 

Ricky Joseph, Real Property Officer, WA 

Ricky L & Debra L Benner, WA 

Rigoberto & Maria Salinas, WA 

Riley M & Coleen Barlow, WA 

Robert & Cain, Candace Samuels, CA 

Robert & Davis Peggy Fleet, WA 

Robert & Helen Sullivan, OR 

Robert & Jessica Hester, WA 

Robert & Kathleen Clawson Collins, WA 

Robert & Kathleen Schroeder McNeill, WA 

Robert & Kerstin Adams, OR 

Robert & Linda Larrabee, WA 

Robert & Lucinda King, WA 

Robert & Steve Schuler, WA 

Robert A & Cynthia Cox, WA 

Robert A & Tara B Sorensen, WA 

Robert A Silva, WA 

Robert A Wick, WA 

Robert A. Pastorok, WA 

Robert B & Carrol J Grady, WA 

Robert B & Jacquelin Stewart, WA 

Robert B & Shawn M Miller, WA 

Robert B Calkins, WA 

Robert Boyd, WA 

Robert Brady, WA 

Robert C & Aprel D Stegman, WA 

Robert C. Bruner, WA 

Robert C. Mitchell, WA 

Robert Cecil Cooke, OR 

Robert Craig Cornwell, WA 

Robert Crane, OR 

Robert Crepps, WA 

Robert D & Florence Wigre, WA 

Robert D & Lynn D & David Zeigler, WA 

Robert D & Lynn Knight, WA 

Robert D & Marlene L Anunson, WA 

Robert D & Melinda R Arco, WA 

Robert D Mahaffey, WA 

Robert Dean Larsen, WA 

Robert E & Brenda L Smith, WA 

Robert E & Janice Fleishman, WA 

Robert E & Michelle M Welling, WA 

Robert E & Sheri L Critchfield, WA 

Robert E Burton, WA 

Robert E Schellhase, WA 

Robert Eterno, OR 

Robert F Petty, WA 

Robert Fogt, WA 

Robert H Quick, WA 

Robert Holland, OR 
 A-47

Individuals (cont’d) 

Robert J & Delores M Gries, WA 

Robert J & Kimberly A McKeough, WA 

Robert J & Mary E Skillman, WA 

Robert J Black, WA 

Robert Jarvis, OR 

Robert K & Karen V Perrine, WA 

Robert K & Mary E Stone, WA 

Robert Kopka, DC 

Robert Kristopher Pelan, WA 

Robert L & Suzanne C Holmes, WA 

Robert L Rooney, WA 

Robert L. Ensley, WA 

Robert Lee Harding, WA 

Robert Lorey, KS 

Robert Lowrance, OR 

Robert M & Marie A Day, WA 

Robert M Hathaway, WA 

Robert M Koivisto, WA 

Robert M Schoenfeld, WA 

Robert M. Decker, OR 

Robert Mackimmie, OR 

Robert Meyer, WA 

Robert P Johnston, WA 

Robert Pallett, OR 

Robert R & Louise D James, WA 

Robert S & Debra L Cason, WA 

Robert S & Joanne Anderson, WA 

Robert S & Lisa R Williams, WA 

Robert S & Shawna K Bain, WA 

Robert Stang, OR 

Robert Tindall, OR 

Robert VanElverdinghe, OR 

Robert W & Deborah G Parsons, WA 

Robert W & Karen J Backstrom, WA 

Robert W & Susan H Checca, WA 

Robert W Foss, WA 

Robert W Pederson, WA 

Robert W Postma, WA 

Robert Walling, WA 

Robert Winsor, WA 

Roberta Brice, OR 

Robin Johnson, OR 

Robin R Pfander, WA 

Robin Stanley, WA 

Roble Anderson, OR 

Robynn Rodriguez, OR 

Rod E Fenstermaker, WA 

Rod Nelson, WA 

Roderick F & Miriam R Faubion, WA 

Roderick M & Joanne J Toll, WA 

Roderick Morris, OK 

Rodney & Patricia A Pfeifle, WA 

Rodney A & Jaime J Maxie, WA 

Rodney J Wort, WA 

Rodney L. C. Nelson & Laurine D. Newberg, WA 

Rodney R Peterson, WA 

Rodney T & Heidi J Lakey, WA 

Rodney William Lefeber, WA 

Rodney Z James, OR 

Rodolfo Umali, WA 

Roger & Darcie Hays, OR 

Roger A & Debra L Parry, WA 

Roger A & Merry E Pettijohn, WA 

Roger C & Jan A Reed, WA 

Roger G Maki, WA 

Roger H Molvar, WA 

Roger J Widenoja, OR 

Roger K. & Catherine A. Hoesterey, WA 

Roger L & Karen E Crewse, WA 

Roger Lindsley, OR 

Roger R & Teresa E Robert, WA 

Roger Rocka, OR 

Rolf G & Christine M Kruger, WA 

Romit & Carolina Singh, WA 

Ron L & Clark Jenni L Clark, WA 

Ron W. MacKenzie, OR 

Ronald & Molly Giovanetti, WA 

Ronald & Toni Farnsworth, WA 

Ronald Clark, WA 

Ronald Corder, WA 

Ronald D & Pamela M Newman, WA 

Ronald D & Pauline Oberlander, WA 

Ronald D., Jr & Tiffany T. Harmon, WA 

Ronald H Shanander, WA 

Ronald J & Barbara G Campbell, WA 

Ronald K Fox, WA 

Ronald L Newenhof, WA 

Ronald M & Beverly F Nelson, WA 

Ronald M & Caroline J Nichols, WA 

Ronald M & Meehan Ann Rene Rudge, WA 

Ronald Marasco, WA 

Ronald Oathes, Jr., WA 

Ronald S Walt, WA 

Ronald Schiffman, OR 

Ronald Throupe, WA 

Ronald Tokarz, WA 
 A-48 

Individuals (cont’d) 

Ronald W. Tritten, WA 

Ronghua & Ho Geok Chin Jin, WA 

Rose Lee, WA 

Rose M Zinicola, NY 

Ross Bondurant, OR 

Ross W & Marjorie A Silver, WA 

Rostislav & Nataliya Nagulyak, WA 

Roxanne Crocker, WA 

Roy C. Jordan, OR 

Roy E & Margaret A Newman, WA 

Roy H & Lisa F Delavergne, WA 

Roy Hitz, OR 

Roy W & Sheryl M Hill, WA 

Roy Wahle, OR 

Royce D & Sonia L Williams, WA 

Russ Garnett, OR 

Russell A & Deanna L Berglund, WA 

Russell A Silva, WA 

Russell Ashdown-Kroese, OR 

Russell Boehm, WA 

Russell C & Lisa G Jensema, WA 

Russell Hall, OR 

Ruth Bolliger, OR 

Ruth Heft, WA 

Ruth R Allen, WA 

Ryan & Berryessa, Ashley Abel, WA 

Ryan & Jessica Breeden, WA 

Ryan & Spencer, Jessica Williams, WA 

Ryan A & Heather N McBee, WA 

Ryan A Dell, WA 

Ryan Berryhill, WA 

Ryan Castro, WA 

Ryan D Moore, WA 

Ryan Hyke, WA 

Ryan J Dennis, WA 

Ryan M & Diane L Dunne, WA 

Ryan M Grose, WA 

Ryan M Hallock, WA 

Ryan T Mickey, WA 

Ryan VanCleave, WA 

S T Humphries & Helen Reynolds, WA 

Sammie Connors, WA 

Samok & Vandy Ouch, WA 

Samuel A & Sue A Huff, WA 

Samuel L & Jessica L Houston, WA 

Samuel R Christie, WA 

Samuel W., Chick & Michelle M. Henderling, WA 

Sandra Cardenas, WA 

Sandra Ferland, WA 

Sandra K & Michael T Hagadone, WA 

Sandra K & Riche, Ronald A Rice, WA 

Sandra L. From & Kevin M. Mejia, WA 

Sandra Leonard, WA 

Sandra M Seedorf, WA 

Sandra Mitchell, WA 

Sandra Ruzicka, WA 

Sandra S Sircin, WA 

Sandy Murray, OR 

Sara A & Torey G Donovan, WA 

Sara E Griffin, WA 

Sara S. Uzzell-Rindlaub & John V. Rindlaub, WA 

Sarah A Lynch, WA 

Sarah J Hintz, WA 

Sarah Leyrer, WA 

Savin Nou, WA 

Sawvalok Kissner, WA 

Scot D & Deborah K Thomson, WA 

Scott & Daralee Newkirk, WA 

Scott & Holly Smolinsky, WA 

Scott & Jody Wickett, WA 

Scott & Mara Jean McDonald, WA 

Scott & Megan Andrews, WA 

Scott & Nancy Moeller, WA 

Scott & Purdin, Perry Casey, WA 

Scott & Sylvia Robinson, WA 

Scott A & Carlene A Duda, WA 

Scott A & Michele R Darrington, WA 

Scott Ater, WA 

Scott B Murray, WA 

Scott D & Traci Sciuchetti, WA 

Scott D Ringwood, WA 

Scott G. Walker, WA 

Scott H White, WA 

Scott J & Cheryl E Shipman, WA 

Scott J & Corrin A Molvar, WA 

Scott J. Rozenbaum, WA 

Scott O & Kaycee Stackle, WA 

Scott R & Heidi D Bee, WA 

Scott R & Lora R Butterfield, WA 

Sean & Brittanie Pruden, WA 

Sean & Preboski, Emily Michel, WA 

Sean & Rebecca McCullough, WA 

Sean M & Ellen R Lindstrom, WA 

Sean N Moore, WA 

Sean P Nispel, WA 

Seokkyun & Jordan Hong, WA 

Seongho & Jiyoon Kim Wee, WA 
 A-49

Individuals (cont’d) 

Sergey & Ludmila Garkusha, WA 

Sergio & Amy Castaneda, WA 

Sergio B Gonzalez, WA 

Sha Spady, OR 

Shadia & Elbou Ouldtaki Kaiefa, WA 

Shane K & Susan M Tapert, WA 

Shane M & Kimberly J Kelly, WA 

Shane R & Alexis Tackett, WA 

Shane R & Melissa R Larango, WA 

Shannon & Christine Bruil, WA 

Shannon Buck, OR 

Shantanu Subhash & Anagha Deo, WA 

Shari L Fry, WA 

Shari Lee Phillips, WA 

Sharon E Hendrickson, WA 

Sharon E. Robbins & James R. Danforth, WA 

Sharon L Johnston, CA 

Sharon Schrock, OR 

Sharon Verschuyl, WA 

Shaun & Chastity Van Auken, WA 

Shaun D & Christina Stauffer, WA 

Shawn & Rachel Smith, WA 

Shawn Hosford, WA 

Shawn N. C. & Yolanda R. Drennen, WA 

Shawna L Gonzales, WA 

Sheila Conner, WA 

Sheila Lang, WA 

Sheila Warren, OR 

Shel Cantor, OR 

Sheldon J & Karen M Bukantz, WA 

Shelia Starrett, WA 

Shelley Burns, WA 

Shelley S Weber, WA 

Sheri Staley, WA 

Sherif H Mahmoud, WA 

Sherri BOWE, WA 

Sherry L & Larry R Summers, WA 

Sherry L. Vick-McLean & Shawn P. McLean, WA 

Sherry Willoughby, OR 

Sheryl J Lindquist, WA 

Shin & Yumika Kodaira, WA 

Shirlee Nash, OR 

Shirlee Wallot, WA 

Shu-Fang Huang, WA 

Sidney B & Amelia J Stark, WA 

Sigrid Asmus, WA 

Simon Ross, WA 

Sixto & Rosario Zaragoza, WA 

Sol Riou, WA 

Stacey L Jaimes, WA 

Stacey L. Mort, WA 

Stacey Lynne Smythe, WA 

Stacie K. Joyce & Gerald K. Young, WA 

Stan P & Jeff A Olson, UT 

Stanley & Angela Wayment, WA 

Stanley & Teresa Schmidt, WA 

Stanley A & Connie K French, WA 

Stanley C Warzecha, WA 

Stanley G Ford, WA 

Stanley Startzman, WA 

Stanley Taylor, OR 

Stedham Family Living Rev Trust, Ann Stedham, WA 

Steen McFadden, MT 

Stefan E Fafnis, WA 

Stephanie D & Hoover N Wilson, WA 

Stephanie Gay, WA 

Stephanie Horrocks, WA 

Stephanie L Call, WA 

Stephanie M Long, WA 

Stephanie Swift & Jamie Glenisky, WA 

Stephanie Velie & Constance Gee, WA 

Stephen & Brian Davidson, WA 

Stephen & Connie Cross, WA 

Stephen & Maria Dennehy, WA 

Stephen & Roseanna D Cherrington, WA 

Stephen & Sharon Marks, WA 

Stephen Anderson, WA 

Stephen Caldwell, OR 

Stephen D Cottrell, WA 

Stephen H Buroker, WA 

Stephen Ho-Yuen Mak, WA 

Stephen J Bartlett, WA 

Stephen J Caputo, WA 

Stephen J Pogue, WA 

Stephen L & Janet E Holmer, WA 

Stephen L & Poitina Fraser, WA 

Stephen L & Serena A Swanson, WA 

Stephen M & Heather A Rowan, WA 

Stephen M & Sarah Biggerstaff, WA 

Stephen Steinhoff, IA 

Stephen W & Breezy M Hadeen, WA 

Steve & Christofferson Marsha Christofferson, WA 

Steve & Edlyn Warner, WA 

Steve Dragich, WA 

Steve Felkins, OR 

Steve G & Deborah E Ellingson, WA 

Steve L Eggers, WA 
 A-50 

Individuals (cont’d) 

Steve W Blankenship, WA 

Steve Wilson, OR 

Steven & Amy Ensminger, WA 

Steven & Barbara Andersen, WA 

Steven & Georgina Hamm, WA 

Steven & Jolita Truett, WA 

Steven & Kay Johnson, WA 

Steven & Susan Persing McLain, WA 

Steven & Yvonne Honea, WA 

Steven A & Deborah N Ouimet, WA 

Steven B Kenney, WA 

Steven C & Tina M Benekas, WA 

Steven C Hill, WA 

Steven Coleman, OR 

Steven D. & Harriet Koscho, WA 

Steven E & Karen M Johnson, WA 

Steven E Martin, WA 

Steven G & Carmen L Grace, WA 

Steven G & Larae Norbjerg Hopkins, WA 

Steven J & Kathleen M Cummins, WA 

Steven J & Lori R Gordon, WA 

Steven Jacobson, WA 

Steven Jun Kim, WA 

Steven L Fitterer, OR 

Steven Mueller, OR 

Steven P & Marta Masters, WA 

Steven R & Rhonda K Ward, WA 

Steven R Karpman, WA 

Steven Shane & Cynthia Bidwell, WA 

Steven T & Julie D Gutzler, WA 

Steven W & Angela A Watkins, WA 

Stowell & Casey, Shannon Holcomb, WA 

Stuart Poston, WA 

Sue A Tenkley Trust, Gary, WA 

Sue Noble, OR 

Sue Skinner, OR 

Sumanta K & Sanghamitra M Pal, WA 

Sunny R Stiles, WA 

Supratim & Chowdhury, Bonnhi De, WA 

Supriya & Kunal, Gaind Kumari, WA 

Susan A Betts-Donnelly, WA 

Susan Arbor, OR 

Susan Burke-Crum & Marvin, Jr Crum, WA 

Susan C Sheythe, OR 

Susan Chapman, OR 

Susan Cobb, OR 

Susan D George, WA 

Susan E Markley, OR 

Susan F Shemeta, WA 

Susan Fahsel, WA 

Susan Hess, OR 

Susan J Gray, WA 

Susan KhalsaWyborski, OR 

Susan Martin, OR 

Susan Mikkelsen, WA 

Susan Padgett, OR 

Susan Parrish, WA 

Susan Rea Thramer, WA 

Susan Rosen, Wa 

Susan S Neidig, WA 

Susan Zeman, WA 

Susana Gladwin, OR 

Susannah B & Jason D Barr, WA 

Susanne Wilson, WA 

Susheel L & Swaran L David, WA 

Suzan L. Waddington & Charles W. Burr, WA 

Suzanne Bahl, OR 

Sylvia Black, OR 

Sylvia J Hjelmeland, WA 

Sylvia M Madsen, WA 

Sylvia Zingeser, OR 

Sz-Tsung Sun, WA 

T Wasson, WA 

T. K. Stewart & David K. Black, WA 

T. L. Cannon, WA 

Tahj & Emily Bomar, WA 

TAK Memorial Trust, WA 

Tamara Wehrer, WA 

Tammy Chagolla & Matthew R. Noffke, WA 

Tammy R Tiede, WA 

Tanafriti Wright, WA 

Tanja Wilcox, WA 

Tara & Michael Rudolph, WA 

Tatyana A Kimball, WA 

Ted Chism, OR 

Ted Thomas, OR 

Tenzin & Amney, Kensang Dhongthog, WA 

Tera Frydenlund, WA 

Tera McCranie & Todd Green, WA 

Teresa & McDonald, Heath Larson, WA 

Teresa DeLorenzo, OR 

Teresa H. Ralston, WA 

Teresa L Roach, WA 

Terie Remington, OR 

Terrance & Kami Johnson, WA 

Terry & Ingrid Powell, WA 

Terry & Janet Steiner, WA 
 A-51

Individuals (cont’d) 

Terry & Phyllis Posey, WA 

Terry D & Raeann L Laberge, WA 

Terry Hill, WA 

Terry Hughes, WA 

Terry HymanWalsh, WA 

Terry L & Vicki L Machovsky, WA 

Terry L McFarling, WA 

Terry L. & Sandra Day Aho, WA 

Terry Marshall, WA 

Terry N & Sally M Thompson, WA 

Terry S & Donna L Deahl, WA 

Terry W & Edythe R Cottrell, WA 

Terry W & Julie L Lee, WA 

Thad Taylor, WA 

Thea Mae Enright, OR 

Thelma & Gene Neathamer, WA 

Thelma Butzlaff, OR 

Theodore Gibson, WA 

Theodore Vandermey, WA 

Theresa P. Webster, WA 

Thomas & Ann Beaulieu, WA 

Thomas & Kimmie Wilson, WA 

Thomas & Lori Klobucar, WA 

Thomas & Tess Alverson- Hollern, WA 

Thomas (Trustee) Lindberg, OR 

Thomas A & Diana M Loback, WA 

Thomas A & Jamie L Floch, WA 

Thomas C & Janice E Morris, WA 

Thomas Detman, CO 

Thomas E & Catherine A Mooney, WA 

Thomas E & Teresa E Stone, WA 

Thomas Gritzka, OR 

Thomas H & Janice A Reid, WA 

Thomas H Nelson, WA 

Thomas Hardy & Marie A. Tailor, WA 

Thomas J & Catherine W Rogers, WA 

Thomas J Matson, WA 

Thomas J Morraitis, WA 

Thomas J. Abbe & Jolynne Leitzel, WA 

Thomas Johnston, OR 

Thomas L & Susanne S Harvey, WA 

Thomas M & Heidi M Batten, WA 

Thomas M & Rocchetta C Witte, WA 

Thomas M DeSpain, OR 

Thomas Mathews, OR 

Thomas Morrison, OR 

Thomas P & Glenna A Maskal, WA 

Thomas P & Mary T Mathew, WA 

Thomas P & Susan S Nieswander, WA 

Thomas R & Julie A Hargan, WA 

Thomas S Rogers, WA 

Thomas V & Devi D Griswold, WA 

Thomas V & Jane M Rowland, WA 

Thomas W & Paula A Shoemaker, WA 

Thomas W Grossi, WA 

Thome Family Living Trust, Ted, WA 

Thomson Trust, John D. & Joanne L. Thomson, Trustees, WA 

Tiffany A & Marshal Spardo, WA 

Tiffany Greer, WA 

Tiffany Hedrick, WA 

Tiffany P. Mendoza & Adam R. Trantina, WA 

Tiffany S. Daly & Ronald F. Watts, WA 

Tim & Bobbie Smith, WA 

Tim & Diane Dorsey, WA 

Tim & Susan Howard Ebling, WA 

Tim Bero, OR 

Tim C Barnes, OR 

Tim J & Cathy L Harris, WA 

Tim Thuston, TX 

Timothy & Mary Ann Lindberg, WA 

Timothy & Sharlene L Harbison, WA 

Timothy & Susan Heath, WA 

Timothy & Teresa Jenine Schlager Collins, WA 

Timothy A Boullion, WA 

Timothy Bradshaw, WA 

Timothy D Kropf, WA 

Timothy Gansneder, WA 

Timothy J & Danette R StClair, WA 

Timothy K & Julie A Johnson, WA 

Timothy K Boyd, WA 

Timothy P & Mary E Gray, WA 

Timothy Paulsen & Michelle Pease-Paulsen, WA 

Timothy Stanhope, WA 

Timothy Szambelan, WA 

Tina L Dixon & R Paul Stredwick, WA 

Tina L Tricoli, WA 

Tina Zimmer, WA 

Toby S Peterson, WA 

Todd & Michelle Maki, WA 

Todd & Patricia Stuth, WA 

Todd A & Lisa Peters, WA 

Todd A & Lori J Dail, WA 

Todd L & Tracy M Oman, WA 

Todd W. & Carol A. Snyder, WA 

Toji T & Eapen Anu Oommen, WA 

Tom & Lorene Ehlers, WA 

Tom Bender, OR 
 A-52 

Individuals (cont’d) 

Tom Carr, OR 

Tom Finch, CO 

Tom Myers, OR 

Tom Sawtell, OR 

Toni R Burton, WA 

Tony & Megan Navilio, WA 

Tony Bennett, WA 

Tony J Phillips, WA 

Top Family Trust, WA 

Topelagi Siva, WA 

Torben & Marilyn Ferslov-Jensen, WA 

Tracey Chapman, OR 

Tracie A Jarratt, WA 

Tracy Burns, WA 

Tracy Davis, WA 

Tracy S Jilek, WA 

Travis Hayes, WA 

Travis K M Winslow, WA 

Travis R. & Tabatha T. Taylor Olson, WA 

Travis Sessler, WA 

Trent D & Vicki L Taylor, WA 

Trent R Smith, Jensen G. R. 1977 Living Trust, WA 

Trevor W Walstad, WA 

Troy L Church, WA 

Trula J Thompson, WA 

Ty & Rachel Kimball, WA 

Tybalkt J Quale, WA 

Tyler & Jacklyn Whitehouse, WA 

Tyler E Ford, WA 

Tyler R & Stephanie M Berry, WA 

Tyron Lee, OR 

Ubaldo Sanchez, OR 

Uma Subramanian & Srinath Kannan, WA 

V Paul & Carol H Buehler, WA 

Vadim & Yana Bednaruk, WA 

Valerie & Morris Hernandez, WA 

Valerie Hauer, WA 

Vamsi & Kurup Preeti Kuppa, MN 

Vance Chad Pinson, WA 

Vancell Shaw, WA 

Vanessa Lee, WA 

Vanita J Miller, OR 

Varonica Koon, OR 

Venetia A Runnion, WA 

Veniamin & Alla Bidniy, WA 

Vern W Forsberg, WA 

Verne & Margaret Qualls, WA 

Vernon H Crim, WA 

Vernon Suggett, WA 

Vernon W. Chandler & Jennifer M. Gilmon, WA 

Victor B & Dianne M Breen, WA 

Victor G & Judith E Adams, WA 

Victor Phan Tran, WA 

Victoria A Schmidt, WA 

Victoria Dell, WA 

Victoria J & John T Thrush, WA 

Victoria Lowe, OR 

Victoria Meier, OR 

Vincent J & Angela Geglia, II, WA 

Vincent Mustacich, WA 

Vincent O & Dell M Reyes, WA 

Viorel & Nicoleta Chita, WA 

Virgie & Jimmy Bernabe, WA 

Virgil & Leona M Baker, WA 

Virgil C & Marlys M Harberts, WA 

Virginia Allison, WA 

Virginia D Merchant, WA 

Virginia Gibbs, OR 

Virginia Good & Thomas E. Vlahovich, WA 

Vitaliy & Oksana Stryzheus, WA 

Vladimir & Gurtovaya Razinkov, WA 

W & C Rogers, WA 

W T & Sheryl Jean Rogers, WA 

W.A. & A.M. McNamara & Moskowitz-McNamara, WA 

Waid G Easton, WA 

Waite Living Trust, WA 

Wallace D & Darlene K Keen, WA 

Wallace N Soland, WA 

Wallace W Weber, WA 

Wallace W. Mattila, WA 

Walter Aman, OR 

Walter B., III Schroeder, OR 

Walter D Austin, WA 

Walter D Millo, WA 

Walter H Johnson, WA 

Walter L Blinde, OR 

Walter M Thayer, WA 

Walter R & Janet A Ivanoff, OR 

Walter W & Rosetta J Kellogg, WA 

Wanda Collins, WA 

Warren & Juanita Beecroft, WA 

Warren D Aikins, OR 

Warren John West, OR 

Warren Taylor, WA 

Wayne & Sandra Wright, WA 

Wayne & Sharon Rengen, WA 

Wayne A & Cherie R Toso, WA 
 A-53

Individuals (cont’d) 

Wayne E & DeGregory, Carol A Scardigli, WA 

Wayne E & Lynn M Larson, WA 

Wayne Jorgensen, WA 

Wayne R & Leslie R Osborn, WA 

Wayne, Jr Radford, WA 

Wendal H Kuecker, WA 

Wendell H. Lovett, WA 

Wen-Ying & Hao Hung, WA 

Wesley & Christine Pellum, AZ 

Wesley A Christianson, OR 

Wesley P & Jackie K Haynes, WA 

Wilford E Stipp, WA 

Wilfred A Sundstrom, WA 

William & Althea G Heagy, WA 

William & Bella Cooper, WA 

William & Cheryl Chapman, WA 

William & Jodi Halfhill, WA 

William & Kathleen Thias, WA 

William & Kellie Araki, WA 

William & Mayer, Sarah Zetterwall, WA 

William & Melissa Nelson, WA 

William & Sheilla C Hagedorn, WA 

William & Trina Watters, WA 

William & Victoria Zimmerman, WA 

William A & Christine E Price, WA 

William A Tover, WA 

William A. Theiss, OR 

William B. & Jody K. Sorenson, WA 

William Berry Sr & Delina Ann Malcoh, WA 

William Birka, WA 

William Brown, OR 

William C & Priscilla Grover, TX 

William C Elliott, WA 

William C Jr & Carolyn J Game, WA 

William C JR Elliott, WA 

William Conner, WA 

William D & Janice L Thackeray, WA 

William D & Lynn B Keys, WA 

William Dickas, OR 

William E & Jeanene M Speck, WA 

William E & Marilyn M Walner, WA 

William E & Mary C Favier, WA 

William E. & Paulette S. Hartman, WA 

William Earl & Barbara A Mitchell, WA 

William Evans, WA 

William G & Kathleen Hankins, WA 

William G Whiteaker, WA 

William Gefroc, OR 

William H & Mary E Lord, WA 

William H., Jr & Roberta Ingram, WA 

William Harrison Monroe, WA 

William Hart, OR 

William Hundley, OR 

William J & Lisa K Brill, WA 

William J & Phyllis Campbell, WA 

William J & Suzanne F Mortell, WA 

William J & Tonya Pearson, WA 

William J Ingerson, WA 

William J Spagnola, WA 

William L & Joann Wooda Heinz, WA 

William L Baskett, WA 

William M & Denise A Lettig, WA 

William M & Peggy K Keough, WA 

William Marshall, OR 

William N & Silvia E Tester, WA 

William N. & Patty L. Kaaland, WA 

William N. & Patty L. Kaaland; & Jerry L. & J Lorna Allan, WA 

William P & Kathleen S Brown, WA 

William R & Rebecca S Wilder, WA 

William R & Susan I Fox, WA 

William R Banks, WA 

William R ETAL Billups, WA 

William Russell, NV 

William S & Yon O Atkins, WA 

William Schwall, OR 

William Stricklin, CA 

William Sunquist, WA 

William Van Dyke, OR 

William W & Angela L Peak, WA 

William Weinhart, WA 

Wilma Jean Bowen, WA 

Winfred Coleman, WA 

Wu-Shyung Lee, WA 

Yadong Wang, WA 

Yale Smith, WA 

Yandle Moss, WA 

Yeng & Chong Cha, WA 

Ynnette M Collins, WA 

Yolanda Williamson & Paul W. Murray, WA 

Yolande Witter, WA 

Yu-Chin Jou, WA 

Yuriy & Yuliya Mikhalchuk, WA 

Yvette M Nichols, WA 

Yvonne R DeMiranda, OR 

Zach King, OR 

Zhiling Zhang, WA 

Zhorzh & Zhanna Godzyuk, WA 
 A-54 

Individuals (cont’d) 

Zhu Zhuo, OR 

Zsuzsa Mayer, WA 
APPENDIX B 

CONSULTATION AND MEETINGS

Appendix B1: Coast Guard Documents 

Appendix B2: Meetings Hosted by Oregon LNG and Northwest 

Appendix B3: Summary of Tribal Consultations 

APPENDIX B1 

COAST GUARD DOCUMENTS

















APPENDIX B2 

MEETINGS HOSTED BY OREGON LNG AND NORTHWEST 

B2-1 

Table B2-1

Meetings Hosted by Oregon LNG and Northwest 

Date Location Purpose Attendees 

Oregon LNG 

7/8/2008 Conference Call Stream Crossing Subgroup 

Meeting 

FERC, FWS, ODFW, Oregon LNG, CTGR 

8/14/2008 Conference Call Stream Crossing Subgroup 

Meeting 

FERC, ODF, ODFW, CTGR, ODFW, NMFS, 

Oregon LNG, FWS 

11/21/2008 Portland, OR Habitat Categorization 

Subgroup 

FERC, ODFW, Oregon LNG, ODF, FWS 

12/2/2008 Portland, OR Mitigation Subgroup FERC, ODFW, CTGR, ODSL, FWS, ODLCD, 

EPA 

12/2/2008 Portland, OR Interagency Group FERC, Coast Guard, CRITFC, ODFW, Oregon 

LNG, CTGR, ODSL, NMFS, Tillamook County 

Department of Community Development, 

ODLCD, ODE, City of Hillsboro, FWS 

12/9/2008 Portland, OR Fish Terminal Subgroup FERC, Coast Guard, Oregon LNG, NMFS, 

ODFW, CRITFC 

12/17/2008 Conference Call Stream Crossing Subgroup FERC, ODFW, ODSL, NMFS, FWS 

1/16/2009 Portland, OR Washington Agency FERC, WA Ecology, WA ORA, WDFW, 

Wahkiakum County, ODLCD, CREST, USACE, 

ODE, EPA, NMFS, ODFW, WDNR 

1/22/2009 Portland, OR Stream Crossing Subgroup FERC, FWS, ODFW, ODEQ, Oregon LNG, 

CTGR, ODSL, EPA, NMFS 

2/3/2009 Portland, OR Interagency Group FERC, Oregon LNG, Coast Guard, EPA, NMFS, 

ODLCD, ODFW, ODE, CTGR, ODSL, ODF, 

FWS 

2/3/2009 Portland, OR Fish Terminal Subgroup FERC, Oregon LNG, EPA, NMFS, ODFW 

2/3/2009 Portland, OR Dredging Subgroup FERC, Oregon LNG, NMFS, EPA, ODFW 

2/11/2009 Portland, OR Fish Terminal Subgroup FERC, Coast Guard, Oregon LNG, ODFW, 

NMFS 

2/26/2009 Portland, OR Stream Crossing Subgroup FERC, ODFW, NMFS, ODF, FWS, EPA 

3/20/2009 Portland, OR Stream Crossing Subgroup FERC, FWS, ODFW, Oregon LNG, CTGR, 

ODSL, EPA, NMFS, ODF, USACE 

3/23/2009 Portland, OR Dredging Subgroup FERC, CRITFC, Oregon LNG, USACE, NMFS, 

ODLCD, WA Ecology 

4/1/2009 Conference Call Fish Terminal Subgroup FERC, Oregon LNG, NMFS, ODFW 

5/5/2009 Conference Call Fish Terminal Subgroup FERC, Oregon LNG, Coast Guard, NMFS, 

ODFW, Wy’East Marine, CRITFC 

5//7/2009 Portland, OR Stream Crossing Subgroup FERC, FWS, ODFW, Oregon LNG, CTGR, 

ODSL, NMFS, USACE 

8/12/2009 Portland, OR Mitigation Subgroup FERC, Oregon LNG, ODFW, NMFS, FWS 

9/9/2009 Portland, OR Fish Terminal Subgroup FERC, Oregon LNG, NMFS, Coast Guard, 

USACE, FWS, EPA, CTGR, ODFW, ODFW 

10/7/2009 Portland, OR Mitigation Subgroup FERC, Oregon LNG, ODFW, Coast Guard, 

ODFW, CRITFC, WDFW, NMFS 

2/9/2010 Portland, OR Mitigation Subgroup FERC, Oregon LNG, NMFS, FWS, USACE, 

EPA, ODFW, ODSL, CTGR 

4/14/2011 Conference Call Discuss ESA Section 7 

Consultation Process 

FERC, NMFS, Oregon LNG 

9/5/2012 Portland, OR Stream Crossing Subgroup FERC, Oregon LNG, NFMS, EPA, USACE, 

FWS, ODSL, ORA, ODFW, Cowlitz County, WA 

UTC, WDOE, WA Ecology 

9/6/2012 Portland, OR Dredging Subgroup FERC, Oregon LNG, EPA, USACE, NMFS, 

ODSL, ODLCD, ORA, WA Ecology 
B2-2 

Table B2-1

Meetings Hosted by Oregon LNG and Northwest 

Date Location Purpose Attendees 

10/23/2012 Columbia County, 

OR 

Stream Crossing Subgroup FERC, Oregon LNG, EPA, NMFS, USACE, 

FWS, ODFW, CTGR 

10/30/2012 Cowlitz County, 

WA 

Stream Crossing Subgroup FERC, NMFS, WDFW, ORA, USACE, FWS, 

WDNR, NMFS 

11/07/2012 Deer Island, 

Columbia County, 

OR 

Stream Crossing Subgroup FERC, WDFW, Dyno Nobel, USACE, ODFW, 

FWS 

11/4/2013 Lacey, WA 

Vancouver, WA 

Conference Call 

Washington Permit 

Applications 

FERC, FWS, NMFS, USACE, WA Ecology, 

ORA, WSDOT, WDFW, WDNR, WA UTC, City 

of Woodland, Cowlitz County, Northwest 

Northwest 

10/17/2012 Lacey, WA Interagency Meeting FERC, Northwest, USACE, NMFS, FWS 

12/3/2013 Lacey, WA JARPA Pre-application 

Meeting 

FERC, Northwest, USACE, WA Ecology 

4/21-25/2014 WA Waterbody Crossing Site 

Review 

FERC, Northwest, WA Ecology, WDFW, FWS, 

NMFS, WDNR 

8/18-21/2014 WA Wetland Crossing Site 

Review 

FERC, Ecology, WDFW, Northwest 

11/19/2014 Whatcom County, 

WA 

Recreation and Conservation 

Areas of Interest Site Review 

FERC, Northwest, Whatcom County Land Trust 

_____________

Coast Guard U.S. Coast Guard 

CRITFC Columbia River Inter-Tribal Fish Commission 

CTGR Confederated Tribes of Grand Ronde 

EPA U.S. Environmental Protection Agency 

FERC Federal Energy Regulatory Commission or HDR Inc. representing FERC 

FWS U.S. Fish and Wildlife Service 

NMFS National Marine Fisheries Service 

Northwest Northwest Pipeline LLC 

ODE Oregon Department of Energy 

ODEQ Oregon Department of Environmental Quality 

ODF Oregon Department of Forestry 

ODFW Oregon Department of Fish and Wildlife 

ODLCD Oregon Department of Land Conservation and Development 

ODSL Oregon Department of State Lands 

ORA Washington Governor’s Office of Regulatory Assistance 

USACE U.S. Army Corps of Engineers 

WA Ecology Washington State Department of Ecology 

WA UTC Washington Utilities and Transportation Commission 

WDFW Washington State Department of Fish and Wildlife 

WDNR Washington Department of Natural Resources 
APPENDIX B3 

SUMMARY OF TRIBAL CONSULTATIONS

 B3-1 

Table B3-1 

Summary of Tribal Consultations for the Oregon LNG Project

Native Americans or Tribes Contacted by FERC Native Americans or Tribes Contacted by Oregon LNG 

Affiliated Tribes of Northwest Indians Sent NOI for Oregon LNG import project issued August 24, 2007 c/o Lynn Dennis. 

 No response to N

Sent NOI for export project issued September 24, 2012 c/o Lynn Dennis. 

 No response to N

Columbia River Inter-Tribal Fish Commission Sent NOI for Oregon LNG import project issued August 24, 2007 c/o Olney Patt, Executive Director; Rob Lothrup; Julie Carter, Policy Analyst; Patti Howard, Water Quality Coordinator; and Jamie Pinkham. 

Sent letter about LNG import project to CRITFC on June 28, 2007. Telephone contact on October 5, 2007. Meetings with CRITFC on November 5, 2007, and in August 2008. 

No response to N

Sent NOI for export project issued September 24, 2012. No response to N Sent letter on May 16, 2012, to Paul Lumley, Executive Director of 

CRITFC, about the export project and request for information. 

No comments on FERC. 

 Sent copy of cultural resources survey report to Paul Lumley on 

August 12, 2013. 

No comments on 

Chehalis Confederated Tribes Sent NOI for Oregon LNG import project issued August 24, 2007 c/o David Burnett, Chair. 

 No response to N

Sent NOI for export project issued September 24, 2012 c/o David Burnett, Chair; Nancy Romero, Cultural Resources; and Mark White, Natural Resources. 

 No response to N

Sent letter about export project on January 16, 2013 to David Burnett, Chair. 

 No response to le

Chinook Nation Sent NOI for Oregon LNG import project issued August 24, 2007 c/o Gary Johnson, Chair. 

 No response to N

Sent NOI for export project issued September 24, 2012 c/o Ray Gardner, Chair. 

 No response to N

Clatsop-Nehalem Confederated Tribes Sent NOI for Oregon LNG import project issued August 24, 2007 c/o Joseph Scovell. 

 No response to N

Sent NOI for export project issued September 24, 2012 c/o Joseph Scovell 

 No response to N
 B3-2 

Table B3-1 

Summary of Tribal Consultations for the Oregon LNG Project

Native Americans or Tribes Contacted by FERC Native Americans or Tribes Contacted by Oregon LNG 

Cow Creek Band of Umpqua Tribe of Indians FERC staff met with representatives of Cow Creek Band on January 24, 2008. Cowlitz Indian Tribe Sent NOI for Oregon LNG import project issued August 24, 2007 c/o John Barnett, Chair; Ted Sprague, President Economic Council; and Mike Iyall, Natural Resource Director. 

 No response to N

Sent letter about LNG import project on October 22, 2007 to John Barnett, Chair 

 No response to le

 Sent letter on May 16, 2012, to Dave Burlingame, Cultural 

Resources Director of Cowlitz Tribe, about the export project and request for information. 

No response to thFERC. 

Sent NOI for export project issued September 24, 2012 c/o John Barnett, Chair; Mike Iyall, Natural Resources; and Ed Arthur, Cultural Resources. 

 No response to N

Sent letter about export project on January 16, 2013 to William Iyall, Chair. 

 Cowlitz Tribe sent 

2013 stating that area of concern aPlan should be pa

 Sent copy of cultural resources survey report to Cowlitz tribe on 

August 12, 2013. 

No comments on 

 Sent email on August 12, 2013 informing tribe of opportunity to 

participate in ethnographic studies. 

No response filed 

Confederated Tribes of the Grand Ronde Community Sent NOI for Oregon LNG import project issued August 24, 2007 c/o Cheryle Kennedy, Chair, and Khani Schultz, Cultural Resources. 

Sent letters on June 28, 2007 and September 10, 2007 about LNG import project. Met with Grand Ronde Tribes on February 26 and May 30, 2008. Sent Grand Ronde Tribes copy of its draft Resource Report 4 on February 13, 2008. 

In response to NOrequested meetinGrand Ronde Tribon February 12, 2Grand Ronde Tribemail to Oregon Lcomments on surv

Sent letter about LNG import project on October 22, 2007 to Cheryle Kennedy, Chair 

 No response to le

FERC staff met with Grand Ronde representatives on January 24, February 25, and March 31, 2008. 

Participated in meeting with FERC staff and Grand Ronde Tribes on January 24, 2008, February 25, 2008, and March 31, 2008. 

Grand Ronde Tribstudy, and monitoarea. 
 B3-3 

Table B3-1 

Summary of Tribal Consultations for the Oregon LNG Project

Native Americans or Tribes Contacted by FERC Native Americans or Tribes Contacted by Oregon LNG 

Sent NOI for export project issued September 24, 2012 c/o Brandy Humphreis, Khanai Shultz, Michael Karnesh, Eirik Thorsgard, and David Lewis. 

 No response to N

Sent letter about export project on January 16, 2013 to Reynold Leno, Chair. 

 In response to the 

Tribes sent an em18, 2013 requestiresources survey 

 Sent letter on May 16, 2012, to Eirik Thorsgard, Cultural Resources 

Director for Grand Ronde Tribes, about the export project and request for information. 

No comments on FERC. 

 Sent copy of cultural resources survey report to Eirik Thorsgard on 

August 12, 2013. 

No comments on 

 On August 12, 2013, called Eirik Thorsgard to inform tribe of the 

opportunity to participate in ethnographic studies. 

No response filed 

Kikiulus Indian Tribe Sent NOI for export project issued September 24, 2012 c/o Kurt Weinreich, Cultural Resources. 

 No response to N

Lummi Nation Sent NOI for export project issued September 24, 2012 c/o Merle Jefferson, Natural Resources, and Lena Tso, Cultural Resources. 

 No response to N

Sent letter about export project on January 16, 2013 to Clifford Cultee, Chair. 

 No response to le

Muckelshoot Tribe Sent NOI for export project issued September 24, 2012 c/o Virginia Cross, Chair; Karen Walter, Habitat Program; and Melissa Calvert, Preservation Department. 

 No response to N

Sent letter about export project on January 16, 2013 to Virginia Cross, Chair. 

 No response to le

Nez Perce Tribe Sent NOI for Oregon LNG import project issued August 24, 2007 c/o Rebecca Miles, Chair; Gary Green, Executive Committee; Randall Minthorn, Execitive Committee; and Ryan Sudbury, Attorney. 

Sent letter to Nez Perce Tribe on March 12, 2008. No response to N

Sent letter about LNG import project on October 22, 2007 to Samuel Penny, Executive Committee. 

 No response to le
 B3-4 

Table B3-1 

Summary of Tribal Consultations for the Oregon LNG Project

Native Americans or Tribes Contacted by FERC Native Americans or Tribes Contacted by Oregon LNG 

 Sent letter on May 16, 2012, to Vera Sonneck, Cultural Resources 

Director for Nez Perce Tribe, about the export project and request for information. 

No response to Oproject filed with F

Sent NOI for export project issued September 24, 2012 c/o Brooklyn Baptiste, Chair, and Ryan Sudbury, Legal 

 No response to N

Sent letter about export project on January 16, 2013 to Silas Whitman, Chair. 

 No response to le

 Sent copy of cultural resources survey report to Vera Sonneck on 

August 12, 2013. 

No comments on 

Nisqually Tribe Sent NOI for Oregon LNG import project issued August 24, 2007 c/o Dorian Sanchez, Chair, and Thor Hoyte. 

 No response to N

Sent NOI for export project issued September 24, 2012 c/o Dorian Sanchez, Chair. 

 No response to N

Sent letter about export project on January 16, 2013 to Cynthia Iyall, Chair 

 No response to le

Nooksack Tribe Sent NOI for export project issued September 24, 2012 c/o Robert Kelly, Chair; Greg MacWilliams, Natural Resources; and George Swanaset, Cultural Resources 

 No response to N

Sent letter about export project on January 16, 2013 to Robert Kelly, Chair 

 No response to le

Puyallup TribeSent NOI for export project issued September 24, 2012 c/o Herman Dillon, Chair; Brandon Reynon, Tribal Archaeologist; Joseph Anderson, Director Fisheries Department; and Bill Sullivan, Natural Resources. 

 In October 9, 201

Puyallup Tribe reqabout the Washin(WEP) (see table 

Sent letter about export project on January 16, 2013 to Herman Dillon, Chair. 

 No response to le

Samish Nation Sent NOI for export project issued September 24, 2012 c/o Tom Wooten, Chair; Jacquelyn Ferry, Cultural Resources; and Christine Woodward, Natural Resources. 

 Samish Nation se

October 8, 2012, resources report f(WEP). 

Sent letter about export project on January 16, 2013 to Tom Wooten, Chair. 

 Samish Nation se

February 4, 2013 report (see table B
 B3-5 

Table B3-1 

Summary of Tribal Consultations for the Oregon LNG Project

Native Americans or Tribes Contacted by FERC Native Americans or Tribes Contacted by Oregon LNG 

Sauk-Suiattle Tribe Sent NOI for export project issued September 24, 2012 c/o Norma Joseph, Chair; Dora Dailey, Cultural Resources; and Richard Wolten, Natural Resources. 

 No response to N

Sent letter about export project on January 16, 2013 to Norma Joseph, Chair. 

 No response to le

Shoalwater Bay Tribe Sent NOI for Oregon LNG import project issued August 24, 2007 c/o Charlene Nelson, Chair. 

 No response to N

Sent letter about LNG import project on October 22, 2007 to Charlene Nelson, Chair. 

 No response to le

Sent NOI for export project issued September 24, 2012 c/o Charlene Nelson, Chair. 

 No response to N

Sent letter about export project on January 16, 2013 to Charlene Nelson, Chair. 

 No response to le

 Sent copy of cultural resources survey report to Earl Davis, Cultural 

Resources for Shoalwater Bay Tribe, on August 12, 2013. 

No comments on 

 Sent email on August 12, 2013 informing tribe of opportunity to 

participate in ethnographic studies. 

No response filed 

Confederated Tribes of Siletz Indians Sent NOI for Oregon LNG import project issued August 24, 2007 c/o Delores Pigsley, Chair, and Robert Kentta, Cultural Resources. 

Sent letters about LNG import project on June 28, 2007 and September 10, 2007. 

In response to NOmeeting with FER

Sent letter about LNG import project on October 23, 2007 to Delores Pigsley, Chair 

 No response to le

FERC staff met with Siletz representatives on January 24, 2008. 

Oregon LNG participated in January 24, 2008 meeting between FERC staff and Siletz Tribes. 

Siletz Tribes requ

 Sent letter on May 16, 2012, to Robert Kentta, Cultural Resources 

Director, about the export project and request for information. 

No comments on FERC. 

Sent NOI for export project issued September 24, 2012 c/o Delores Pigsley, Chair, and Robert Kentta, Cultural Resources. 

 No response to N

Sent letter about export project on January 16, 2013 to Delores Pigsley, Chair. 

 No response to le

 Sent copy of cultural resources survey report to Robert Kentta on 

August 12, 2013. 

No comments on 
 B3-6 

Table B3-1 

Summary of Tribal Consultations for the Oregon LNG Project

Native Americans or Tribes Contacted by FERC Native Americans or Tribes Contacted by Oregon LNG 

 Sent email on August 12, 2013 informing tribe of opportunity to 

participate in ethnographic studies. 

No response filed 

Snoqualmie Tribe Sent NOI for export project issued September 24, 2012 c/o Shelley Burch, Chair; Steven Mullen Moses, Director Archaeology & Historic Preservation; and Cindy Spiry, Natural Resources. 

 No response to N

Sent letter about export project on January 16, 2013 to Shelly Burch, Chair. 

 No response to le

Stillaguamish Tribe Sent NOI for export project issued September 24, 2012 c/o Shawn Yanity, Chair; Tara Duff, Cultural Resources; Jay Harvey, Cultural Resources; and Pat Stevenson, Natural Resources. 

 No response to N

Sent letter about export project on January 16, 2013 to Shawn Yanity, Chair. 

 No response to le

Suquamish Indian Tribe Sent NOI for export project issued September 24, 2012 c/o Leonard Forsman, Chair. 

 No response to N

Sent letter about export project on January 16, 2013 to Leonard Forsman, Chair. 

 No response to le

Swinomish Tribal Community Sent NOI for export project issued September 24, 2012 c/o M. Brian Cladoosby, Chair, and Charles O’Hara, Director Planning & Environment. 

 No response to N

Sent letter about export project on January 16, 2013 to Brian Cladoosby, Chair. 

 In letter to FERC 

Swinomish Tribal would participate extent practicable

Tulalip Tribes of the Tulalip Reservation Sent NOI for export project issued September 24, 2012 c/o Melvin Sheldon, Chair, and Hank Gobin, Director Cultural Center. 

 No response to N

Sent letter about export project on January 16, 2013 to Melvin Sheldon, Chair. 

 No response to le
 B3-7 

Table B3-1 

Summary of Tribal Consultations for the Oregon LNG Project

Native Americans or Tribes Contacted by FERC Native Americans or Tribes Contacted by Oregon LNG 

Confederated Tribes of the Umatilla Indian Reservation Sent NOI for Oregon LNG import project issued August 24, 2007 c/o Antone Minthorne, Chair; Carey Miller, THPO; Bruce Zimmerman; and Carl Merkle, Salmon Policy Analyst 

 No response to N

Sent letter about LNG import project on October 23, 2007 to Antoine Minthorn, Chair. 

 No response to le

 Sent letter on May 16, 2012, to Teara Farrow, Cultural Resources 

Director, about the export project and request for information. 

No comments on FERC. 

Sent NOI for export project issued September 24, 2012 c/o Eric Quaempti, Board of Trustees; Carey Miller; and Teara Farrow, Cultural Resources. 

 No response to N

Sent letter about export project on January 16, 2013 to Les Minthorn, Chair. 

 No response to le

 Sent copy of cultural resources survey report to Catherine Dickson 

on August 12, 2013. 

No comments on 

Upper Skagit Indian Tribe Sent NOI for export project issued September 24, 2012 c/o Jennifer Washington, Chair. 

 No response to N

Sent letter about export project on January 16, 2013 to Jennifer Washington, Chair 

 No response to le

Confederated Tribes of the Warm Springs Reservation  Sent NOI for Oregon LNG import project issued August 24, 2007 c/o Ron Suppah, Chair, and Sally Bird, Cultural Resources. 

Sent letters about import project on June 28, 2007 and September 10, 2007. CH2M HILL met with Warm Springs Tribes on February 26, 2008. 

In response to the requested a meet

Sent letter about LNG import project on October 22, 2007 to Ron Suppah, Chair 

 No response to le

FERC staff met with Warm Springs representatives on January 24, February 25, and March 31, 2008. 

Participated in meeting with FERC staff and Warm Springs Tribes on January 24, 2008, February 25, 2008, and March 31, 2008. 

Warm Springs Tristudy. 

 Sent letter on May 16, 2012, to Sally Bird, Cultural Resources 

Director, about the export project and request for information. 

No comments on FERC. 

Sent NOI for export project issued September 24, 2012 c/o Ron Suppah, Chair, and Sally Bird, Cultural Resources. 

 No response to N

Sent letter about export project on January 16, 2013 to Stanley Smith, Chair 

 No response to le

 Sent copy of cultural resources survey report to Sally Bird on 

August 12, 2013. 

No comments on 
 B3-8 

Table B3-1 

Summary of Tribal Consultations for the Oregon LNG Project

Native Americans or Tribes Contacted by FERC Native Americans or Tribes Contacted by Oregon LNG 

 On August 12, 2013, called Sally Bird to inform tribe of the 

opportunity to participate in ethnographic studies. 

No response filed 

Confederated Tribes and Bands of the Yakama Nation Oregon LNG Project NOI issued August 24, 2007 c/o Jerry Meninick, Chair. 

 No response to N

Sent letter about LNG import project on October 22, 2007 to Lavina Washines, Chair. 

 No response to le

 Sent letter on May 16, 2012, to Johnson Mennick, Cultural 

Resources Director, about the export project and request for information. 

No comments on FERC. 

Sent NOI for export project issued September 24, 2012 c/o Jerry Mennick, Chair; Johnson Mennick, Cultural Resources; and Philip Rigdon, Natural Resources. 

 No response to N

Sent letter about export project on January 16, 2013 to Harry Smiskin, Chair. 

 No response to le

 Sent copy of cultural resources survey report to Johnson Mennick 

on August 12, 2013. 

No comments on 
 B3-9 

Table B3-2 

Summary of Tribal Consultations for WEP

Native Americans and Indian Tribes Contacted by FERC Native Americans and Indian Tribes Contacted by Northwest 

Affiliated Tribes of Northwest Indians Sent NOI for WEP issued September 24, 2012 c/o Lynn Dennis. 

 No response to N

Columbia River Inter-Tribal Fish Commission Sent NOI for WEP issued September 24, 2012. No response to NChehalis Confederated Tribes Sent NOI for WEP issued September 24, 2012 c/o David Burnett, Chair; Nancy Romero, Cultural Resources; and Mark White, Natural Resources. 

 No response to N

 Sent letter on September 28, 2012 to Chair Burnett describing WEP 

and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to David Burnett, Chair. 

 No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) 

on September 24, 2013 to Richard Bellon, Cultural Resources and Mark White, Natural Resources. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Chinook Nation Sent NOI for WEP issued September 24, 2012 c/o Ray Gardner, Chair. 

 No response to N

 Sent letter on September 28, 2012 to Chair Gardner describing the 

WEP and including its cultural resources research design. 

No response to le

 Sent cultural resource survey report, (McClintock et al. June 2013) 

on September 24, 2013 to Ray Gardner, Chair, and Tony Johnson, Cultural Resources. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 
 B3-10 

Table B3-2 

Summary of Tribal Consultations for WEP

Native Americans and Indian Tribes Contacted by FERC Native Americans and Indian Tribes Contacted by Northwest 

Clatsop-Nehalem Confederated Tribes Sent NOI for WEP issued September 24, 2012 c/o Joseph Scovell 

 No response to N

Cowlitz Indian Tribe Sent NOI for WEP issued September 24, 2012 c/o John Barnett, Chair; Mike Iyall, Natural Resources; and Ed Arthur, Cultural Resources. 

. No response to N

 Sent letter on September 28, 2012 to Chair Iyallt describing the 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to William Iyall, Chair. 

 The Cowlitz India

on April 24, 2013 within the tribe’s arecommended lanInadvertent Disco

 Sent cultural resource report (McClintock et al June 2013) on 

September 24, 2013 to Ed Arthur and Dave Burlingame of Cultural Resources, and Taylor Aalvik of Natural Resources. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Duwamish Tribe  Sent revised addendum survey report on September 3, 2014. No comments on Confederated Tribes of the Grand Ronde Community Sent NOI for WEP issued September 24, 2012 c/o Brandy Humphries, Khanai Shultz, Michael Karnesh, Eirik Thorsgard, and David Lewis. 

 No response to N

 Sent letter on September 28, 2012 to Chair Kennedy describing 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Reynold Leno, Chair. 

 In response to the 

Tribes sent an em18, 2013 requestiresources survey Project (see table consultation). 

 Sent cultural resource survey report (McClintock et al. June 2013) to 

David Lewis and Eirik Thorsgard, Cultural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 
 B3-11 

Table B3-2 

Summary of Tribal Consultations for WEP

Native Americans and Indian Tribes Contacted by FERC Native Americans and Indian Tribes Contacted by Northwest 

Kikiallus Indian Tribe Sent NOI for WEP issued September 24, 2012 c/o Kurt Weinreich, Cultural Resources. 

 No response to N

 Sent letter on September 28, 2012 to Administrator Weinreich 

describing the WEP and including its cultural resources research design. 

No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Administrator Weinreich on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014 

No comments on 

Lummi Nation Sent NOI for WEP issued September 24, 2012 c/o Merle Jefferson, Natural Resources, and Lena Tso, Cultural Resources. 

 No response to N

 Sent letter on September 28, 2012 to Chair Cultee describing WEP 

and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Clifford Cultee, Chair. 

 No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Lena Tso, Cultural Resources, and Merle Jefferson, Natural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014 

No comments on 

Muckleshoot Tribe Sent NOI for WEP issued September 24, 2012 c/o Virginia Cross, Chair; Karen Walter, Habitat Program; and Melissa Calvert, Preservation Department. 

 In November 7, 2

Indian Tribe Fisheprovided commenwork directly with to determine poteriparian areas. Thof the Draft EIS bthe Muckleshoot ICultural/Preserva

 Sent letter on September 28, 2012 to Chair Cross describing the 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Virginia Cross, Chair. 

 No response to le
 B3-12 

Table B3-2 

Summary of Tribal Consultations for WEP

Native Americans and Indian Tribes Contacted by FERC Native Americans and Indian Tribes Contacted by Northwest 

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Laura Murphy, Cultural Resources, and Karen Walter, Natural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report on September 3, 2014 No comments on Nez Perce Tribe Sent NOI for WEP issued September 24, 2012 c/o Brooklyn Baptiste, Chair, and Ryan Sudbury, Legal 

 No response to N

Sent letter about WEP on January 16, 2013 to Silas Whitman, Chair. 

 No response to le

Nisqually Tribe Sent NOI for WEP issued September 24, 2012 c/o Dorian Sanchez, Chair. 

 No response to N

 Sent letter on September 28, 2012 to Chair Iyall describing the WEP 

and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Cynthia Iyall, Chair 

 No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Joe Kalama and Fabio Apolito, Cultural Resources, and David Troutt, Natural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014 

In September 8, 2Indian Tribe statereport and had no concerns at this tiinformed if there adiscoveries of archuman remains. 

Nooksack Tribe Sent NOI for WEP issued September 24, 2012 c/o Robert Kelly, Chair; Greg MacWilliams, Natural Resources; and George Swanaset, Cultural Resources 

 No response to N

 Sent letter on September 28, 2012 to Chair Kelly describing the 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Robert Kelly, Chair 

 No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) to 

George Swanaset, Cultural Resources, and Gary MacWilliams and Jeffery Thomas, Natural Resources, on September 24, 2013. 

No comments on 
 B3-13 

Table B3-2 

Summary of Tribal Consultations for WEP

Native Americans and Indian Tribes Contacted by FERC Native Americans and Indian Tribes Contacted by Northwest 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Puyallup TribeSent NOI for WEP issued September 24, 2012 c/o Herman Dillon, Chair; Brandon Reynon, Tribal Archaeologist; Joseph Anderson, Director Fisheries Department; and Bill Sullivan, Natural Resources. 

 In an October 9, 2

Puyallup Tribe reqregarding the WETribe’s usual and 

 Sent letter on September 28, 2012 to Chair Dillon describing the 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Herman Dillon, Chair. 

 No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Bill Sullivan, Natural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Samish Nation Sent NOI for WEP issued September 24, 2012 c/o Tom Wooten, Chair; Jacquelyn Ferry, Cultural Resources; and Christine Woodward, Natural Resources. 

 Samish Nation se

October 8, 2012, cultural resources Washington. 

 Sent letter on September 28, 2012 to Chair Wooten describing the 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Tom Wooten, Chair. 

 Samish Nation se

February 4, 2013 the survey report. 

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Jacky Ferry, Cultural Resources, and Christine Woodward, Natural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

In September 4, 2emails to Northwewas not interested 

Sauk-Suiattle Tribe Sent NOI for WEP issued September 24, 2012 c/o Norma Joseph, Chair; Dora Dailey, Cultural Resources; and Richard Wolten, Natural Resources. 

 No response to N
 B3-14 

Table B3-2 

Summary of Tribal Consultations for WEP

Native Americans and Indian Tribes Contacted by FERC Native Americans and Indian Tribes Contacted by Northwest 

 Sent letter on September 28, 2012 to Chair Hoffman describing the 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Norma Joseph, Chair. 

 No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Norma Joseph, Cultural Resources, and Richard Wolten, Natural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Shoalwater Bay Tribe Sent NOI for WEP issued September 24, 2012 c/o Charlene Nelson, Chair. 

 No response to N

 Sent letter on September 28, 2012 to Chair Nelson describing the 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Charlene Nelson, Chair. 

 No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Earl Davis and Tony Johnson, Cultural Resources, and Gary Burns, Natural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Confederated Tribes of Siletz Indians Sent NOI for WEP issued September 24, 2012 c/o Delores Pigsley, Chair, and Robert Kentta, Cultural Resources. 

 No response to N

Sent letter about WEP on January 16, 2013 to Delores Pigsley, Chair. 

 No response to le

Snohomish Tribe Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Snoqualmie Tribe Sent NOI for WEP issued September 24, 2012 c/o Shelley Burch, Chair; Steven Mullen Moses, Director Archaeology & Historic Preservation; and Cindy Spiry, Natural Resources. 

 No response to N

 Sent letter on September 28, 2012 to Chair Burch describing the 

WEP and including its cultural resources research design. 

Snoqualmie IndiaNorthwest on Octmore information 
 B3-15 

Table B3-2 

Summary of Tribal Consultations for WEP

Native Americans and Indian Tribes Contacted by FERC Native Americans and Indian Tribes Contacted by Northwest 

Sent letter about WEP on January 16, 2013 to Shelly Burch, Chair. 

 No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Stephen Mullen-Moses, Cultural Resources, and Cindy Spiry, Natural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014 

No comments on 

Steilacoom Tribe 

Sent letter on September 28, 2012 to Chair Marshall describing the WEP and including its cultural resource research design. .

No response to le

Sent cultural resource survey report (McClintock et al. June 2013) to Danny Marshall, Chair, on September 24, 2013. 

No comments on 

Sent revised addendum survey report (McClintock and Wilt September 2014) on September 3, 2014 

No comments on 

Stillaguamish Tribe Sent NOI for WEP issued September 24, 2012 c/o Shawn Yanity, Chair; Tara Duff, Cultural Resources; Jay Harvey, Cultural Resources; and Pat Stevenson, Natural Resources. 

 No response to N

 Sent letter on September 28, 2012 to Chair Yanity describing WEP 

and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Shawn Yanity, Chair. 

 No response to le

 Sent electronic copies of the prefiling versions of Resource Reports 

1 and 4 to Kerry Lyste on February 15, 2013. 

No comments file

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Jay Harvey, Cultural Resources, and Pat Stevenson, Natural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Suquamish Indian Tribe Sent NOI for WEP issued September 24, 2012 c/o Leonard Forsman, Chair. 

 No response to N

 Sent letter on September 28, 2012 to Chair Forsman describing the 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Leonard Forsman, Chair. 

 No response to le
 B3-16 

Table B3-2 

Summary of Tribal Consultations for WEP

Native Americans and Indian Tribes Contacted by FERC Native Americans and Indian Tribes Contacted by Northwest 

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Dennis Lewarch, Cultural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Swinomish Tribal Community Sent NOI for WEP issued September 24, 2012 c/o M. Brian Cladoosby, Chair, and Charles O’Hara, Director Planning & Environment. 

 No response to N

 Sent letter on September 28, 2012 to Chair Cladoosby describing 

the WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Brian Cladoosby, Chair. 

 In a letter to FERC 

the Swinomish Trit would participatthe extent practica

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Larry Campbell, Cultural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Tulalip Tribes of the Tulalip Reservation Sent NOI for WEP issued September 24, 2012 c/o Melvin Sheldon, Chair, and Hank Gobin, Director Cultural Center. 

 No response to N

 Sent letter on September 28, 2012 to Chair Sheldon describing 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Melvin Sheldon, Chair. 

 No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Richard Young, Cultural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Confederated Tribes of the Umatilla Indian Reservation Sent NOI for WEP issued September 24, 2012 c/o Eric Quaempti, Board of Trustees; Carey Miller; and Teara Farrow, Cultural Resources. 

 No response to N

 Sent letter on September 28, 2012 to Chair Minthorn describing the 

WEP and including its cultural resources research design. 

Sent letter about WEP on January 16, 2013 to Les Minthorn, Chair. 

 No response to le
 B3-17 

Table B3-2 

Summary of Tribal Consultations for WEP

Native Americans and Indian Tribes Contacted by FERC Native Americans and Indian Tribes Contacted by Northwest 

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Teara Farrow and Catherine Diickson, Cultural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Upper Skagit Indian Tribe Sent NOI for WEP issued September 24, 2012 c/o Jennifer Washington, Chair. 

 No response to N

 Sent letter on September 28, 2012 to Chair Washington describing 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Jennifer Washington, Chair 

 No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Scot Schuyler, Cultural Resources, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

Confederated Tribes of the Warm Springs Reservation Sent NOI for WEP issued September 24, 2012 c/o Ron Suppah, Chair, and Sally Bird, Cultural Resources. 

 No response to N

Sent letter about WEP on January 16, 2013 to Stanley Smith, Chair 

 No response to le

Confederated Tribes and Bands of the Yakama Nation Sent NOI for WEP issued September 24, 2012 c/o Jerry Mennick, Chair; Johnson Mennick, Cultural Resources; and Philip Rigdon, Natural Resources. 

 No response to N

 Sent letter on September 28, 2012 to Chair Smishin describing 

WEP and including its cultural resources research design. 

No response to le

Sent letter about WEP on January 16, 2013 to Harry Smiskin, Chair. 

 No response to le

 Sent cultural resource survey report (McClintock et al. June 2013) to 

Kate Valdez, Cultural Resources, and Philip Rigdon, Natural Resouces, on September 24, 2013. 

No comments on 

 Sent revised addendum survey report (McClintock and Wilt 

September 2014) on September 3, 2014. 

No comments on 

APPENDIX C 

SAFETY ADVISORY REPORT AND MOU BETWEEN OREGON LNG AND 

OREGON DEPARTMENT OF ENERGY

Appendix C1: Response of the Federal Energy Regulatory Commission to the Safety Advisory Report 

of the Oregon Department of Energy for the Oregon LNG Terminal Project and ODE 

Safety Advisory Report 

Appendix C2: MOU between Oregon LNG and ODE 

APPENDIX C1 

RESPONSE OF THE FEDERAL ENERGY REGULATORY COMMISSION 

TO THE SAFETY ADVISORY REPORT OF THE OREGON DEPARTMENT 

OF ENERGY FOR THE OREGON LNG TERMINAL PROJECT AND ODE

SAFETY ADVISORY REPORT

Oregon LNG Terminal Project C-1 Response to ODE’s Safety Advisory Report 

1.0 INTRODUCTION 

The Natural Gas Act (NGA), as modified by the Energy Policy Act of 2005 (EPAct), requires that the 

Federal Energy Regulatory Commission (FERC or the Commission) consult with the state in which a 

liquefied natural gas (LNG) terminal is proposed to be located regarding state and local safety matters. 

The governor of Oregon designated the Oregon Department of Energy (ODE) as the state agency that the 

FERC should consult with on safety and siting matters for the Oregon LNG Terminal and Pipeline 

Project. On November 10, 2008, the ODE submitted its Safety Advisory Report to the FERC. In the 

report, ODE addressed state and local considerations for the project. 

The EPAct also stipulates that before the Commission may issue an order authorizing an LNG terminal, it 

must “review and respond specifically” to the safety matters raised by the state agency designated as the 

lead for the state and local safety matters. Table C1-1 of this appendix provides the FERC’s response to 

the ODE Safety Advisory Report for the Oregon LNG Terminal Project. Section 3.0 contains the Safety 

Advisory Report. 

2.0 FERC RESPONSE TO THE SAFETY ADVISORY REPORT 

The ODE identified the following key categories of potential safety concerns in the Safety Advisory 

Report: 

 Emergency Planning and Response; 

 Security Zone; 

 Seismic Design; 

 Terminal Design; 

 Hazard Identification; 

 Quality Assurance; 

 Safety Issues; and 

 Emergency Response Capabilities near the Facility Location. 

The Safety Advisory Report included both general and specific safety matters that ODE requested to be 

included in the FERC’s review of the Oregon LNG application. The FERC’s specific responses to those 

concerns are presented in tabular format in table C1-1 in the order of the issues presented in the report. 

Where appropriate, the response identifies the section of the EIS where information on the issue of 

concern is addressed. 

As described in sections 1.0 and 2.1 of the EIS, the Coast Guard has shared responsibility with FERC in 

reviewing the Oregon LNG Terminal Project and has summarized portions of its review in its Letter of 

Recommendation (LOR). In addition to including the LOR in the EIS, we have summarized portions of it 

in the EIS. As a result, for some concerns presented in the Safety Advisory Report, we have noted that 

the issue is addressed in the LOR, as well as the specific section of the EIS where the concern is 

addressed. 
Oregon LNG Terminal Project C-2 Response to O

TABLE C1-1 

The FERC’s Responses to Concerns Presented in the ODE Safety Advisory Report for the Oregon LNG Terminal P

Topic Issue Respo

Emergency Planning and Response 

The FERC should require an applicant to commit to covering 100 percent of the safety and security costs directly associated with the LNG vessel transits, the facility, and the pipeline. 

We included a recommendation that the include a Cost-Sharing Plan identifying project-specific security/emergency ma

imposed on state and local agencies. T

of the EIS. 

 The safety/security zones proposed for the vessel in transit and the vessel 

at dock must be sufficiently calculated and justified. The applicant or the Coast Guard must thoroughly explain any changes to those zones that might accompany heightened national security as well as any resulting impacts. 

In its LOR Analysis, the Coast Guamoving safety/security zone around thwaterway where no other vessel mpermission from the COTP. While the swill be a 200-yard security zone around the Captain of the Port’s (COTP) Repreand patrol assets to control traffic, and Safety/Security zone based on a casethe scene. Escort resources would be movements such that the LNG carrier is 

 The FERC should require the applicant to complete an acceptable 

Emergency Response Plan prior to any Commission decision on its application and in conjunction with the Coast Guard’s validation of the WSA. The applicant’s Emergency Response Plan must be developed in full cooperation with state and local authorities. The applicant’s Emergency Response Plan must sufficiently and accurately characterize the emergency response capabilities along the vessel transit route and near the facility, including response times and must include measures to mitigate for any safety gaps. 

In accordance with the Energy Policy Aprior to any project construction. We in

4.1.13.9 that, prior to initial site preparaan Emergency Response Plan (includin

procedures with the Coast Guard; stateplanning groups; fire departments; state appropriate federal agencies. 

 The applicant’s Emergency Response Plan must include all potentially 

affected communities along the LNG vessel route and near the terminal in a comprehensive, thoroughly publicized warning system. The applicant’s Emergency Response Plan must account for potential population increases due to tourism. 

Part of the Emergency Response Plan (must include at a minimum: procedures recreational users within areas of potenpermanent sirens and other warning dewe included in section 4.1.13.9 would reemergency planning groups in developi
Oregon LNG Terminal Project C-3 Response to O

TABLE C1-1 

The FERC’s Responses to Concerns Presented in the ODE Safety Advisory Report for the Oregon LNG Terminal P

Topic Issue Respo

 Any FERC authorization for an LNG terminal and associated pipeline in 

Oregon must fully comply with Oregon state and local laws and regulations, including energy facility siting laws. 

As a matter of foreign commerce, the imsubject to federal, not state, control. Altexclusive jurisdiction over the proposed and licenses are the responsibility of othlocal authorities. The Commission encoproject applicants and these agencies. issued with respect to the jurisdictional Commission must be consistent with the 

Seismic Design The Oregon Department of Geology (DOGAMI) has recommended that the 

design basis tsunami height be raised and concerns over the liquefiable soils at the terminal site be addressed. 

In the DEIS, Section 4.1.1.1, subsectionSeismic-induced Subsidence, Tsunami, 

Settlement provide a detailed descriptio

tsunami height and addresses concerns 

The design height is based upon a site 

Coast and Harbor in 2013. This analyselevation would range between +8 and 

site considering the tsunami occurred a

is estimated during the CSZ earthquake

7.6 feet due to tectonic subsidence. Thelevation would range between +15.6 fe

tsunami wave, tidal, and subsidence effEarthquake hazard maps of the Astoriaindicate that the terminal area has a higLNG’s geotechnical assessment (CH2M settlement of up to 2.4 feet may occur fduring a large earthquake. The design 

Terminal Design In Oregon LNG’s application, Resource Report 11 references the 2001 

edition of NFPA 59A, but the NFPA website states that the current edition is 2009. FERC should use the latest edition as its acceptance criteria. 

On April 9, 2004, the DOT revised 49 Cedition of NFPA 59A. Portions of the 20storage tank seismic design, have also To date, the DOT has not incorporated FERC will continue to use the approved 

Hazard Identification In Oregon LNG’s application, Resource Reports 1 and 11 state that the 

terminal would be designed to accommodate ships with capacities up to 250,000 m3. The reference at the end of Resource Report 11 includes the 

original 2004 Sandia Report that reports the zones of concern based on ships smaller than 150,000 m3. FERC should base its analysis on the most 

recent Sandia Report and include a recommendation to limit ships to be no larger than those assumed in any heat flux and vapor dispersion calculations. 

The Coast Guard has taken into accounships in accordance with NVIC 01-11 wSandia 2008 specifically addresses largproposed by Oregon LNG. The updateSection 4.1.13.7.
Oregon LNG Terminal Project C-4 Response to O

TABLE C1-1 

The FERC’s Responses to Concerns Presented in the ODE Safety Advisory Report for the Oregon LNG Terminal P

Topic Issue Respo

 The FERC should verify that the assumption of pure methane cargoes is 

not representative of actual cargoes and may not be conservative. 

The presence heavier hydrocarbons suimported LNG with concentrations from discussed in section 4.1.13.6 of the EIS

Quality Assurance The State of Oregon expects the Commission to describe and impose a 

condition requiring Oregon LNG to adopt a rigorous and comprehensive quality assurance program applicable during both construction and operation of the import terminal. 

Quality assurance and control programs equipment fabrication, and installation wEngineering, Procurement, and Constru

the project applicant if the project is autwould also have a similar program to prstaff would review these programs durinWe have also included a condition requ

quality assurance and quality control plaDuring the operational phase of the probe required to file with the Secretary seidentify changes in facility design and ooperating experiences, activities (includcomposition of imported LNG, vaporizatetc.), plant modifications including future The proposed terminal would also be su

technical reviews and site inspections ofrequently if circumstances indicate. 

Safety Issues The California Energy Commission advisory report for the proposed Long 

Beach import terminal suggests a lower heat flux level of 1.5 kw/m2. 

Oregon LNG should calculate the distance to this heat flux level for a design basis event and issue a figure showing the results. 

The DOT examined this issue during thestablished the thermal exclusion zone 

Notice of Proposed Rulemaking (Notice which was used to develop 49 CFR Parkw/m2 (1,000 Btu/ft2-hr) as an acceptab

to thermal flux. After the public review pevidence and information supported the 

the limit for direct human exposure. Alson July 7, 2010, DOT confirmed that the the 2001 edition of NFPA 59A comply w193.2057. 
Oregon LNG Terminal Project C-5 Response to O

TABLE C1-1 

The FERC’s Responses to Concerns Presented in the ODE Safety Advisory Report for the Oregon LNG Terminal P

Topic Issue Respo

Additional Comments on the Associated Pipeline 

The pipeline associated with OLNG goes through more populated lands than the Pacific Connector pipeline that was associated with JCEP. FERC should take into account the rapid population growth close to Warrenton and in western Washington County, particularly near Forest Grove. The same comment would apply to portions of Marion County near Woodburn. This would make it appropriate for FERC to require pipeline design and block valve spacing for a higher population category. Category 3 should be a minimum, and even category two design specifications would be 

appropriate in sections near these rapidly growing exurbs. 

As described under pipeline safety in seMemorandum of Understanding on Nat

dated January 15, 1993 between the DOexclusive authority to promulgate federa

transportation of natural gas. Section 1regulations requires that an applicant ceinspect, test, construct, operate, replacea Certificate is requested in accordance plans for maintenance and inspection. certify that it has been granted a waiver standards by the DOT in accordance wiPipeline Safety Act. The FERC accepts impose additional safety standards for p

 FERC should also note that in Oregon, the Public Utility Commission 

(OPUC) has inspection and enforcement authority for regulations of USDOT, under a delegation from USDOT. The OPUC has implemented pipeline safety regulations that include, and sometimes exceed, the USDOT regulations at 49 CFR 192. FERC should consult directly with the 

pipeline safety section of the OPUC for a full comparison. The State of Oregon expects that wherever there is a difference between USDOT and OPUC pipeline safety rules, the stricter of the two will apply. 

Section 4.1.13.13 of the EIS states that provides for a state agency to assume aintrastate facilities by adopting and enfomay also act as DOT's agent to inspect boundaries; however, the DOT is respo

Oregon, the Public Utility Commission (enforcement authority for regulations of DOT. The OPUC has implemented pipand sometimes exceed, the USDOT reg
Oregon LNG Terminal Project C-6 Response to O

TABLE C1-1 

The FERC’s Responses to Concerns Presented in the ODE Safety Advisory Report for the Oregon LNG Terminal P

Topic Issue Respo

Emergency Response Capabilities Near the Facility Location 

The Emergency Response Plan must address all identified emergency situations, and that all costs attributable to insuring public safety must be borne by the applicant. The State is also concerned about the effect of impasse during negotiations for the Emergency Response Plan and urges 

the Commission to adopt a clear, expeditious process for addressing disagreements between the applicant and state and local governments. 

In accordance with the Energy Policy Aprior to any project construction. We in

4.1.13.9 that Oregon LNG develop an E(including evacuation) and coordinate pstate, county, and local emergency planand local law enforcement; and approprincludes a Cost-Sharing Plan that would funding all project-specific security/emewould be imposed on state and local agAs an update in an email communicatioOctober 30, 2014 (FERC eLibrary AcceODE staff indicates that Oregon LNG haMemorandum of Understanding, and thprograms included in the MOU. ODE sMOU would specify documents to be de

Oregon LNG in order for ODE to reach preparedness approach committed to band security standards, including, but nResponse Plan; 2) Resource List that idequipment and systems needed to implAgreement with state and local agencieidentified in the ERP and Resource List

 FERC should make the development of the Emergency Response Plan as 

transparent to the public as possible, including the essential elements of the plan. Although details of the WSA and Emergency Response Plan are withheld from public disclosure, information regarding measures to protect the public during an event should be a part of public outreach and should be available before the issuance of a FERC construction permit. 

Information in the Emergency Response off-site emergency response and proce

evacuation would be subject to public dthe EIS. 
VIA Electronic Filing 

The Honorable Kimberly D. Bose, Secretary 

Federal Energy Regulatory Commission 

888 First Street, N.E. 

Washington, D.C. 20426 

Re: Oregon LNG Project, Docket No. CP09-6 and CP09-7 

Dear Ms. Bose: 

OREGON 

DEPART.'v\ENl Or 

ENERGY 

November 10, 2008 

On October 10, 2008, Oregon LNG filed an application for construction of a terminal for importation of 

liquefied natural gas (LNG). Oregon LNG will be an onshore LNG receiving terminal on the east bank of 

the Skipanon Peninsula near the confluence of the Skipanon and Columbia Rivers at Warrenton, Clatsop 

County, Oregon. The proposed facility includes a turning basin and berth for unloading LNG carriers and 

facilities to receive and regasify LNG. 

The sendout pipeline associated with this project is the proposed Oregon Pipeline, approximately 121 miles 

of36-inch pipeline from Warrenton to Molalla OR. This pipeline will interconnect at the Molalla Gate 

Station near Molalla, Oregon, with other natural gas pipelines including Northwest Natural Gas Co.'s South 

Mist Pipeline Extension and Williams' Northwest Pipeline. 

The pipeline design includes one electrically driven gas compressor station just south of the Timber area on 

Longview Fiber land in Washington County, Oregon. 

The Energy Policy Act of2005, enacted on August 8, 2005, specifies in Section 31 l(d) that the Governor 

of a state where a proposed LNG terminal would be located shall designate a state agency to consult with 

the Federal Energy Regulatory Commission regarding applications and that this state agency may prepare a 

safety advisory report that addresses state and local safety considerations. This provision in the Energy bill 

appears to be specific to the terminal and not to any associated pipeline. The report is due 30 days from the 

application filing date. 

The Governor of Oregon has designated the Oregon Department of Energy as the agency responsible for 

preparation of a safety advisory report for the proposed Bradwood Landing LNG terminal. Therefore, 

enclosed for filing in the above-mentioned proceeding, please find an electronic copy of the safety advisory 

report for the proposed LNG terminal. If you have any questions in this matter, please contact Tom Stoops 

at (503) 378-8328 or tom.stoops@state.or.us. 

Sincerely, 

Ken Niles, Assistant Director 

Nuclear Safety and Energy Facility Siting 

Jordan Cove Safety Advisory Report 

11-10-08 

Page2 

SAFETY ADVISORY REPORT 

ON THE PROPOSED 

OREGON LNG LIQUEFIED NATURAL GAS TERMINAL 

SKIPANON PENSINSULA 

NEAR WARRENTON, OREGON 

PREPARED BY THE STAFF 

OF THE OREGON DEPARTMENT OF ENERGY 

November 10, 2008 
Jordan Cove Safety Advisory Report 

11-10-08 

Page 3 

SAFETY ADVISORY REPORT 

ON THE PROPOSED 

OREGON LNG LIQUEFIED NATURAL GAS TERMINAL 

SKIPANON PENSINSULA 

NEAR WARRENTON, OREGON 

The Oregon Department of Energy (ODOE) issues this Safety Advisory Report on behalf of the State 

of Oregon pursuant to section 31 l(d) of the Energy Policy Act of2005 (the Act). The report concerns 

the application to the Federal Energy Regulatory Commission (FERC) by Oregon LNG, LLC, to build 

an onshore LNG receiving terminal on the east bank of the Skipanon Peninsula near the confluence of 

the Skipanon and Columbia Rivers at Warrenton, Clatsop County, Oregon. The proposed facility 

includes a turning basin and berth for unloading LNG carriers and facilities to receive and regasify 

LNG and a 121 mile sendout pipeline from Warrenton to Molalla OR. Oregon LNG filed its 

application with FERC on October 10, 2008. 

The Act allows the state to file an advisory report that identifies "state and local safety considerations" 

within 30 days of the date the application is filed. The "safety" information solicited in the advisory 

report is largely repetitive of information that Oregon LNG itself provides in its application to FERC in 

its terminal application and in its Waterway Suitability Assessment to the Coast Guard. It is 

information that Oregon LNG also must provide in its emergency response plan to be developed in 

conjunction with the Coast Guard, the state, and appropriate local jurisdictions prior to any 

construction. 

The State of Oregon has been intimately involved in reviewing and commenting on Oregon LNG's 

pre-filing and application resource reports, and is involved with the Coast Guard in reviewing the 

project's WSA. To the extent that the State disagrees with the information Oregon LNG has provided 

or will provide on safety issues in those venues, the state will pursue corrections or changes through 

the above review processes. For example, Oregon LNG has not accurately or adequately characterized 

in its Waterway Suitability Assessment (WSA) the area's emergency response capabilities. The 

Department will work with the Coast Guard, other state agencies and local jurisdictions to correct the 

information under the WSA process. 

The State considered providing FERC with specific scenarios for evaluating accidental or intentional 

releases of LNG from a vessel or the facility itself. Again, however, such scenarios play a role both in 

the WSA and in the forthcoming emergency response planning. Moreover, based on recent 

Commission approvals of LNG terminal projects, the Stale believes the Commission will find that the 

risk of any potential LNG release scenario can be reduced to an acceptable minimum. 

On June 15, 2006, the Commission approved three new LNG terminal projects: Sempra's Port Arthur 

LNG in Port Arthur, Texas; Cheniere's Creole Trail LNG in Cameron Parish, Louisiana; and BP 

America Production Company's Crown Landing LNG in Logan Township in New Jersey. The 

language in the Commission's Creole Trail decision about the risk of an accidental LNG release is 

mirrored in the other two decisions: 
Jordan Cove Safety Advisory Report 

11-10-08 

Page4 

Based on the extensive operational experience of LNG shipping, the structural design of 

an LNG vessel, and the operational controls imposed by the Coast Guard and the local 

pilots, a cargo containment failure and subsequent LNG spill from a vessel casualtycollision, grounding, or allision - is highly unlikely. For similar reasons, an accident 

involving the onshore LNG import terminal is unlikely to affect the public. As a result, 

the FEIS determined that the risk to the public from accidental causes is negligible. 

Further, the language in the Commission's Creole Trail decision about the risk of an intentional LNG 

release is also mirrored in the other two decisions: 

Unlike accidental causes, historical experience provides little guidance in estimating the 

probability of a terrorist attack on an LNG vessel or onshore storage facility. For a new 

LNG import terminal proposal having a large volume of energy transported and stored 

near populated areas, the perceived threat of a terrorist attack is a serious concern of the 

local population and requires that resources be directed to mitigate possible attack 

paths. If the Coast Guard issues a Letter of Recommendation finding the waterway 

suitable for LNG marine traffic, the operational restrictions that would be imposed by 

the Lake Charles Pilots on LNG vessel movements through this area, as well as the 

requirements that the Coast Guard would impose, would minimize the possibility of a 

hazardous event occurring along the vessel transit area. While the risks associated with 

the transportation of any hazardous cargo can never be entirely eliminated, we are 

confident that they can be reduced to minimal levels and that the public will be well 

protected from harm. 

For the above reasons, what the State provides in this advisory report largely is broad safety policy 

statements about the proposed Oregon LNG project along with a limited amount of specific, technical 

comments. In addition, the State is attaching one letter each from the cities of Warrenton and Astoria 

and a package of information from Clatsop County for FERC's consideration. i\s \Vell, the State of 

Oregon incorporates by reference the safety comments included in previous filings to the FERC 

docket, including CP06-365 Bradwood Landing and CP07-441 Jordan Cove. 

Although the application to FERC is limited in scope to the LNG terminal and associated pipeline, we 

consider the risks from a release of LNG on the mouth of the Columbia River to be among the most 

significant safety concerns associated with the facility. The safety of the LNG terminal is strongly 

connected to the question of safety on the waterway and in the nearby communities of Warrenton and 

Astoria .. We expect FERC to address issues and concerns raised by stakeholders in those communities 

and to consider the safety of those communities in determining whether to approve the LNG terminal 

and associated pipeline. 

Each of the state and local agencies in Oregon, whether or not they contributed to this advisory report, 

reserve their right to file additional joint or separate comments and/or evidence on safety and other 

issues. 
Jordan Cove Safety Advisory Report 

11-10-08 

Page 5 

State of Oregon General Policy Comments 

1. FERC should require an applicant to commit to 100 percent of the safety and security costs 

directly associated with the LNG vessel transits, the facility and the pipeline. 

Under Section 311 ( e )(2), an emergency response plan to be developed prior to construction must 

include a cost-sharing plan that includes a "description of any direct cost reimbursements that the 

applicant agrees to provide to any State and local agencies with responsibility for security and 

safety at the LNG terminal and in proximity to vessels that serve the facility." The State 

understands and appreciates that Oregon LNG has agreed thus far to pick up the costs of most 

safety and security needs that the company has identified as necessary. However, the local 

jurisdictions are not in a position to dedicate their own limited funds to any LNG safety and 

security measures that may be required. In addition, local jurisdictions may not agree with an 

applicant about the level of resources required. An applicant should first be required to pay for an 

adequate assessment of safety and security needs and then pay for all infrastructure, planning, 

emergency exercises and other associated costs identified in an emergency response plan agreed to 

by the state and local jurisdictions. Should FERC not require the applicant to commit to I 00 

percent of the costs, FERC should explain its authority for imposing such costs on local 

jurisdictions and the state. 

2. The safety/security zones proposed for the vessel in transit and the vessel at dock must 

be sufficiently calculated and justified. The applicant or Coast Guard must thoroughly 

explain any changes to those zones that might accompany heightened national security as 

well as any resulting impacts. 

Some area residents have expressed concern that the safety/security zones will be so large that they 

will impact traffic on the Columbia River. Others have expressed concern that the safety/security 

zones will be too small, sized to avoid the above concern rather than for adequate safety protection. 

Any zones proposed should provide a rationale for their size. 

3. FERC should require an applicant to complete an acceptable emergency response plan 

prior to any Commission decision on an application and in conjunction with the Coast 

Guard's validation of the Waterway Suitability Assessment. 

Under Section 31 l(e)(l), FERC will not require Oregon LNG to create an emergency response 

plan until after a positive decision by the Commission and just before any final approval to begin 

construction. However, to the extent that Oregon LNG's Waterway Suitability Assessment relies 

on the creation of a satisfactory emergency response plan to ensure that the Columbia River is 

suitable for LNG, that emergency response plan must be available for review prior to any decisions 

on both the WSA and the FERC application. Again learning from the Bradwood Landing and the 

JCEP experience, the recommended conditions in the DEIS would require the applicant for that 

facility to develop the Emergency Response Plan (ERP) prior to construction, but after the 

Commission's decision to approve the project. It would be illogical for either the Commission or 

the Coast Guard to decide that LNG is safe for the region without knowing first if a suitable 

emergency response plan can be enacted along the vessel route and at the facility. 

4. The applicant's Emergency Response Plan must be developed in full cooperation with 

state and local authorities. 

Emergency response planning must be an integrated, carefully developed effort that involves every 

entity that is potentially affected by the LNG import terminal. 
Jordan Cove Safety Advisory Report 

11-10-08 

Page 6 

5. The applicant's Emergency Response Plan must sufficiently and accurately characterize 

the emergency response capabilities along the vessel transit route and near the facility, 

including response times. The Plan must mitigate for any safety gaps. 

Thus far, the state and local jurisdictions have not reached agreement as to which jurisdiction will 

have primary responsibility and authority in the event of an accident or intentional breach. 

Agreement also has not been reached on the resource gaps, and proper allocation of supplemental 

resources. The USCG and FERC should not find that the waterway is suitable until it is known 

that these issues have been resolved. 

6. The applicant's Emergency Response Plan must include all potentially affected communities 

along the LNG vessel route and near the terminal in a comprehensive, thoroughly publicized 

warning system. 

Any community located within one of the three Sandia zones of impact must be considered in 

emergency response plans, including access to a reverse 911 system and sirens. 

7. The applicant's Emergency Response Plan must account for potential population 

increase due to tourism. 

According to a 2004 Clatsop County Grand Jury Report, Clatsop County's population can increase 

by 50-to-l 00 percent or more during high tourism season. Depending on the location of those 

visitors, the influx may bring challenges for LNG emergency response education as well as LNG 

ship transit education. 

8. Auy FERC authorization for an LNG terminal and associated pipeline in Oregon must 

fully comply with Oregon state and local laws and regulations, including energy facility siting 

laws. 

In particular, the State of Oregon requires large energy facilities to provide a bond or letter of credit 

to ensure that the proposed site can be restored to a useable, non-hazardous condition. We consider 

the bond or letter of credit to be a safety precaution against a potentially abandoned or otherwise 

vacated site. Thus far, the applicant does not appear to have addressed this issue in its application 

materials. 

State of Oregon Specific Comments 

Seismic Design 

The Department is particularly concerned about the potential for tsunami. Of the three LNG terminals 

proposed along the Oregon coast since 2004, the Oregon LNG site is by far the most susceptible to 

tsunami. This is partly because the location facing the mouth of the Columbia is in the direct path of a 

design basis tsunami, with no breakwater or other shielding. Members of the Oregon Department of 

Geology (DOGAMI) went to Sumatra after the 2005 tsunami, and have recommended that design basis 

tsunami height be raised considerably. Also, DOGAMI has raised serious concern over the liquefiable 

soils at the terminal site. This is in contrast to other sites that were either several miles up the river, or 

located on more stable soils. 
Jordan Cove Safety Advisory Report 

11-10-08 

Page 7 

For this reason, any emergency plan proposed for the OLNG facility should be based on the premise 

that a tsunami could be the initiating event, and that emergency response capabilities will be 

challenged by the tsunami itself. 

Terminal Design 

Resource reports I and 11 consistently commit lo compliance with NFPA 59A and codes referenced 

therein, but with little information on the actual details of compliance. Resource report 11 references 

the 2001 edition ofNFPA 59A, but the NFPA website states that the current edition is 2009. FERC 

should use the latest edition as its acceptance criteria. Even if detailed design information were 

available, the short deadline for this advisory report does not permit a detailed design review, sufficient 

to audit Oregon LNG's design againstNFPA code requirements on a line-by-line basis. We expect 

FERC to perform this detailed design review, and reserve the right to comment on design issues as 

more time and more information become available. 

Hazard Identification 

The safety discussion in Resource Report 11 appears to rely heavily on the 2004 Sandia Report, and 

particularly on the Zones of Concern identified in that report and cited in NVIC 05-05. The references 

at the end of Resource Report 11 include the original 2004 Sandia Report, but there is no mention of 

the more recent "Sandia II", which addresses larger ships. FERC should base its hazards analysis on 

the more recent recommendations of Sandia II. 

Resource report I of Oregon LNG's application state sthat the terminal will be designed to 

accommodate ships with capacity up to 250,000 m1 The zones of concern in the 2004 Sandia report 

were based on ships smaller than 150,000 m1 FERC's recommendation for this project should be 

conditioned on ships no larger than those assumed in any heat flux and vapor dispersion calculation. 

The assumption of pure methane is probably not representative of actual cargo and may not be 

conservative. Oregon LNG has not committed to receiving its supply from any particular producing 

nation, and therefore we must assume that product would be received from nations where the LNG has 

a higher concentration of natural gas liquids such as propane. Some of these higher-weight 

hydrocarbons have higher potential for vapor dispersion than pure methane. We expect FERC to 

verify that conservative assumptions were used for all parameters, including the hydrocarbon content 

of the product, in NFPA 59A required calculations. The EIS for this project should explain how these 

assumptions were made and why they are the most conservative. 

Quality Assurance 

In our Safety Advisory Report for Bradwood Landing, dated June 2006 and for JCEP, dated October 

2007, ODOE included extensive comments on the need for a rigorous Quality Assurance program that 

would be subject to regulatory review prior to start of construction. We note that the Bradwood DEIS 

and FEIS as well as the JCEP DEIS do not include a discussion of such a program, and we renew the 

recommendation and incorporate our comments from that June 2006 report into this one. The State 

expects the Commission to describe and impose a condition requiring Oregon LNG to adopt a rigorous 

and comprehensive quality assurance program applicable during both construction and operation of the 

import terminal. 
Jordan Cove Safety Advisory Report 

11-10-08 

Page 8 

Our review of 49 CFR 193 and NFPA 59A did not reveal any standards for an acceptable QA program. 

We would expect to see evidence that the QA function is independent of operations, scheduling or 

budgeting. We would expect to see steps to ensure that: 

metal components are fabricated of metals with the specified metallurgical content and 

properties, 

11 concrete or other strnctural materials are tested to the strength specified, 

m vendors of equipment and material are audited by qualified auditors, 

IV nondestructive tests are observed and approved by independent quality control personnel, 

v personnel performing safety related construction or operation activities are properly qualified, 

with documentation of that qualification available for audit, 

VI constrnction and operations are performed in accordance with approved procedures, 

vii only controlled copies of design documents are used in construction, with only the current 

revision used in the field, 

viii all changes in design documents are carried forward to other related and associated design 

documents, 

IX measurements are made with equipment that is calibrated and traceable, 

x conditions adverse to quality are subject to a corrective actions program that results in actions 

to prevent recurrence. 

Safety Issues 

The State of Oregon has reviewed the Safety Advisory Report on the proposed LNG terminal at the 

Port of Long Beach (POLB) issued by the California Energy Commission (CEC). That report relies 

largely on material taken from two readily available reports: (I) the Sandia Labs' November 2004 

report "Guidance on Risk Analysis and Safety Implications of a Large Liquefied Natural Gas (LNG) 

Spill Over Water" (Sandia Report) and (2) Richard Clark's "LNG Facilities in Urban Areas." 

The safety significant events listed in Sandia and Clark and quoted in the CEC advisory report could 

apply to any terminal at any location and need not be repeated in this report. However, we agree with 

CEC that the 5 kw/m2 is described in the Sandia Report as "the pennissible level for emergency 

operations lasting several minutes with appropriate clothing" (Table 6, p.38). This is the lowest heat 

flux shown in the tables that describe the exclusion zone calculations in Resource report 11 .. Because 

the people occupying the nearest residences or businesses (in Warrenton) are relatively far from the 

nearest fire station and do not have the appropriate clothing or emergency training, thermal radiation 

calculations should show the point at which worst case heat flux will permit safe evacuation, possibly 

requiring more than "several minutes" and without appropriate clothing or emergency training. We 

especially note that U.S. highway 101 can reach a virtual standstill during weekends, even in winter, so 

that evacuation may not be quick or eve practical. Therefore, an exclusion distance should be chosen 

that ensures a low enough heat flux for those people who cannot move away quickly. The CEC 

advisory report at p. 15 suggests 1.5 kw/m2. Oregon LNG should calculate the distance to this heat 

flux for a design basis event at Oregon LNG and issue a figure showing the results. 
Jordan Cove Safety Advisory Report 

11-10-08 

Page 9 

Additional Comments on the Associated Pipeline 

Resource Report 11 includes substantive information on pipeline safety as well as terminal safety. The 

pipeline associated with OLNG goes through more populated lands than the Pacific Connector pipeline 

that was associated with JCEP. FERC should take into account the rapid population growth close to 

Warrenton and in western Washington County, particularly near Forest Grove. The same comment 

would apply to portions of Marion County near Woodburn. This would make it appropriate for FERC 

to require pipeline design and block valve spacing for a higher population category. Category 3 should 

be a minimum, and even category two design specifications would be appropriate in sections near 

these rapidly growing exurbs. 

FERC should also note that in Oregon, the Public Utility Commission (OPUC) has inspection and 

enforcement authority for regulations ofUSDOT, under a delegation from USDOT. The OPUC has 

implemented pipeline safety regulations that include, and sometime exceed, the USDOT regulations at 

49 CFR 192. For example, OPUC rules for cathodic protection exceed the federal regulations and 

require that such protection be operational immediately as start of operation, without the six month lag 

allowed by federal rules. There are other examples where PUC rules exceed those ofUSDOT. FERC 

should consult directly with the pipeline safety section of the OPUC for a full comparison. The State 

of Oregon expects that wherever there is a difference between USDOT and OPUC pipeline safety 

rules, the stricter of the two will apply. 

Emergency Response Capabilities near the Facility Location 

The State appreciates that the Commission has provided draft guidance for preparing the required 

Emergency Response Plan for an LNG import terminal. However, the State remains concerned that 

the guidance will be viewed by applicants as an upper limit on their responsibility for ensuring the 

safety of surrounding communities. The State views the guidance as just that: guidance, and urges the 

Commission to affirmatively state that the ERP must ERP must address all identified emergency 

situations, and that all costs attributable to insuring public safety must be borne by the applicant. 

Furthermore, the State remains concerned that FERC's guidance fails to provide minimum resource 

and training standards for LNG emergency preparedness and response. The state is concerned about 

the effect of impasse during negotiations for the ERP. As a result, the state established minimum 

standards for any LNG developer desiring to build and operate an LNG import terminal in Oregon. 

The state urges the Commission to require Oregon LNG to establish a Memorandum of Understanding 

agreeing to comply with Oregon's minimum standards for emergency preparedness to prevent 

disagreements between the applicant and state and local governments on what is adequate LNG 

preparedness. 

Finally, whatever criteria are used to generate the ERP, FERC should make the process as transparent 

to the public as possible, including the essential elements of an emergency plan. Although the details 

of the WSA and ERP are withheld from public disclosure, information regarding measures to protect 

the public during a design basis event should be a part of public outreach and should be available 

before the issuance of a FERC construction permit. 
CERTIFICATE OF SERVICE AND MAILING 

I hereby certify that I have this day served by electronic mail, and for those parties for 

which service is not specified at an electronic mail address, by U.S. mail, first class postage 

prepaid, the foregoing document on all parties listed on the official service list complied on this 

proceeding. 

Date: November 10, 2008. 

Janet L. Prewitt, -~ #85307 

Assistant Attorney General 

#1145573 -CERTIFICATE OF SERVICE AND MAILING 

Page I 

APPENDIX C2 

MOU BETWEEN OREGON LNG AND ODE 



APPENDIX D 

TERMINAL DIAGRAMS


-

.

/

0

1

2

3






.

-

Zd,^d/KE

Zd,^d/KE
/

0
1

2
3



King

Lower

Columbia

Sub-basin

W99CL0024Estuarine and Marine Wetland

W99CL0027Estuarine and Marine WetlandE2USN

W99CL0025Estuarine and Marine WetlandE2EMN

W99CL0026Estuarine and Marine WetlandE2EMN

W5BCL019

Depressional

PEM

W5BCL016

Tidal

PEM

W5BCL023

Depressional

PEM

W5BCL049A

TBD

PSS W5BCL048

DepressionalPEM

W5BCL049B

TBD

PSS

W5BCL050DepressionalPSS

W5BCL059DepressionalPEM

W5BCL058

Depressional

PEM

W5BCL052

Depressional

PEM

W4BCL01

Tidal

PSS

W4BCL02TidalPSS

W4BCL03TidalPSS

W4BCL04TidalPSS

W4BCL07

Tidal

EEM

W4BCL06TidalEEM W4BCL05

Tidal

EEM

W4BCL11Tidal

W4BCL09 EEM

Tidal

PEM

W4BCL08Tidal

W4BCL12 EEM

Tidal

EEM

W5BCL057DepressionalPEMW5BCL054

DepressionalPEM

W5BCL020

Depressional

PEM

W5BCL020DepressionalPEM

W5BCL020

Depressional

PEM

0

W5BCL018SP1

W5BCL016SP1

W5BCL016SP2

W5BCL016SP3

W5BCL057SP1

W5BCL054SP1

W5BCL050SP1

W5BCL058SP1

W5BCL059SP1

W5BCL019SP1

W4BCL07SP1

W4BCL12SP1

W4BCL06SP2

W4BCL06SP1

W4BCL05SP1

W4BCL09SP1

W4BCL02SP1

W4BCL02SP2

W4BCL04SP1

W4BCL04SP2

W4BCL01SP2

W4BCL01SP1

W5BCL048SP1

W5BCL020SP1

W5BCL020SP2

W5BCL049BSP1

W5BCL049BSP2

W5BCL019SP2

PUBLIC
NW DATE AVE

Warrenton

5th

7th

Warrenton

NW 3RD ST

Cedar

NW CEDAR CT

NW 5TH ST

Unnamed Street

4th

4th

NW 4th

Cedar

Cedar

1st

1st

1st

Date

NW Date

Cedar

NW Cedar

Birch

NW Cedar

Date

NW Fir

Date

7th

Cedar

Cedar

Main

Skipanon

Main

Lower

Columbia

Sub-basin

S5BCL075

W99CL0007

Freshwater Forested/Shrub Wetland

PFOA

W99CL0002Freshwater Forested/Shrub WetlandPFO/SSC

W99CL0003

Freshwater Emergent Wetland

PEM/SSC

W99CL0008Freshwater Emergent WetlandPEMC

W99CL0005

Freshwater Emergent Wetland

PEMC

W99CL0009

HYDRIC

PFO

W99CL0001

HYDRIC

PFO

W99CL0006

HYDRIC

PFO

W99CL0004HYDRICPSS

W99CL0010

HYDRIC

PEM

W5BCL0

Depressio

P

W5BTidaPEM S5BCL075

IRCH AVE

PUBLIC
Marlin

SE 1ST ST

RAILROAD AVE

2nd

Heron

Hwy 101

1st

Marlin

SE 5TH ST

Iredale

SE 4TH ST

NE IREDALE AVE

NE NEPTUNE AVE

Harbor

SE 2ND ST

Harbor

SE 4TH ST

King

SE LAKE AVE

Galena

Marlin

Harbor

Heron

Harbor

Unnamed Street

Marlin

NE HARBOR PL

1st

2nd

Unnamed Street

Harbor

Neptune

Harbor

King

Lower

Columbia

Sub-basin

S5BCL075

W99CL0019Estuarine and Marine DeepwaterE1UBL

W99CL0021Estuarine and Marine E2USN

W99CL0024Estuarine and Marine WetlandE2EMP

W99CL0025Estuarine and Marine WetlandE2EMN

W5BCL019

Depressional

PEM

W5BCL023

Depressional

PEM

W5BCL050

Depressional

PSS

W5BCL059DepressionalPEM

W5BCL058

Depressional

PEM

W5BCL052

Depressional

PEM

W5BCL021DepressionalPEM

W5BCL085

Depressional

PFO

W5BCL086DepressionalPSS

W5BCL018

Tidal

PEM

W5BCL057

Depressional

PEM

W5BCL054DepressionalPEM

W5BCL084

Depressional

PFO

W5BCL020DepressionalPEM

W5BCL020

Depressional

PEM

W5BCL020

Depressional

PEM

S5BCL075

0.25

W5BCL020SP1 0.5

W5BCL021SP1 W5BCL023SP1

W5BCL057SP1

W5BCL054SP1

W5BCL086SP1

W5BCL052SP1

W5BCL050SP1

W5BCL058SP1

W5BCL085SP1

W5BCL084SP1

W5BCL023SP2

W5BCL020SP1

W5BCL020SP2

W5BCL023SP1

W5BCL021SP2

W5BCL023SP2

PUBLIC


Skipanon River

Youngs Bay E Harbor St.

NE King Ave.

 R:\LNGDEVELOPMENT_355036\MAPDOCUMENTS\2013_FILING\RESOURCEREPORTS\MISC_REQUESTS\TERMINAL_HIGHTIDELINE_MHW.MXD LCLARK 4/22/2015 12:36:41 PM
 ́

0 325 650

Feet

Area of Interest

CLATSOP

TILLAMOOK WASHINGTON

MULTNOMAH

PACIFIC LEWIS

WAHKIAKUM

COWLITZ

CLARK

COLUMBIA

Legend

Pipeline Route

Wetland

Temporary and Permanent

Wetland Disturbance

Estuarine 

Palustrine 

Note:

Impacts encompass the permanent footprint

for Terminal operation and the temporary footprint

for construction. The Terminal water/wastewater

lines, wastewater pump station, and access road are 

not included. 

Figure does not show wetlands 

on the west bank of the 

Skipanon River because this 

area was outside the study area.

Figure 8
APPENDIX E 

OREGON LNG PIPELINE FACILITY MAPS AND DRAWINGS

Appendix E1: Pipeline Location Maps; Construction Staging/Storage Areas 

Appendix E2: Pipeline Construction Right-of-way Cross Sections 

Appendix E3: Pipeline Route Minor Variations

Appendix E4: Additional Temporary Workspace for the Pipeline; Additional Temporary Workspaces 

within 50 Feet of Wetlands and Waterbodies 

Appendix E5: Maps and Table of Access Roads 

Appendix E6: Site-specific Residential Construction Plans 

 

APPENDIX E1 

PIPELINE LOCATION MAPS; CONSTRUCTION 

STAGING/STORAGE AREAS

D

D

D

D

D

D

D

D

D

D

kj

kj

kj

kj

kj

!.

!.

US 101-101

Warrent

o

n

Astoria Hwy

12th Pl

Harbor St

Marlin Dr

0

0.25

0.5

0.75

1

1.25

1.5

Skipanon Slough

Skipanon

River

Vera Creek

Adair Slough

Figure 1

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

kj

!.

kj

!.

!.

!.

US

101

-Warrenton

Astoria

Hwy

US 101-Warrenton Astoria Hwy

US 101-105 Clatsop Airport Rd

Airport Rd

Fort Clatsop Rd

3

2.75

2.5

1.5

1.75

2

2.25

Adair Slough

Vera Creek

Lewis And Clark River

Figure 2

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

kj

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

US 101-Warrenton Astoria Hwy

US

101-105

Clatsop Airport Rd

Fo

rt

C

l

a

t

s

o

p

Rd

Lewis

4

3

4.25

3.75

3.25 3.5

4.5

Jeffers Slough

Green Slough

Lewis And Clark River

Barrett Slough

Figure 3

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

kj

kj

kj

kj

!.

!.

!.

!.

!.

!.

!.

!.

!.!.

!.

!.

!.

!.

Lewis

Fort Clatsop Rd

Fort Clatsop Rd

6

5

5.25

5.75

4.75

5.5

4.5

Green Slough

Peterson Slough Johnson Slough

Barrett Slough

Lewis And Clark River

Figure 4

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

kj

!.!.

!.

Lewis

Lewis

Fort Clatsop Rd

7 6.25 7.5 7.25

6.75

6.5

Abercrombie Creek

Lewis And Clark River

Heckard Creek

Johnson Slough

Figure 5

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

!.

!.

!.

!.

!.

!.

Lewis

Lewis

9

8

8.5

8.25

7.75

8.75

Johnson Slough

Heckard Creek

Figure 6

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

kj

kj

!.

!.

!.

!.

!.

!.

!.

!.

11

10

9

9.75

10.75

9.5

9.25

10.5

10.25

Speelyai Creek

And Clark Lewis River Cullaby Creek

Heckard Creek

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace

Figure 7

Aerial Maps of the Pipeline
D

D

D

D

D

D

D

D

D

kj

kj

!.

!.

Lewis

12

11

10.75

11.75

11.5

11.25

Loowit Creek

Klickitat Creek Speelyai Creek

Lewis And Clark River

Figure 8

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

!.

!.

!.!.

!.

!.

13

12

12.25

13.5

13.25

12.75

13.75

12.5

Speelyai Creek Klickitat Creek

Hortill Creek

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace

Figure 9

Aerial Maps of the Pipeline
D

D

D

D

D

D

D

D

!.

!.

!.

!.

!.!.

!.

!.

!.!.

15

14

14.5

15.25

14.25

14.75

13.75

Youngs River

Figure 10

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

D

!.

!.

!.

!.

!.

!.

!.

!.

17

16

15

16.75 15.5

15.25

16.5

16.25

15.75

Bayney Creek

Youngs River

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace

Figure 11

Aerial Maps of the Pipeline
D

D

D

D

D

D

D

D

D

!.!.

!.

!.

!.

!.

!.

!.

!.

Saddle Mountain Rd

18 17 17.5 17.75 17.25 18.5 18.25

Rock Creek

Youngs River

Figure 12

Aerial Maps of the Pipeline

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND

!. Stream Crossing - Listed Fish

!. Stream Crossing - No Listed Fish

kj HDD Entry/Exit Point

D Pipeline Route Milepost (Qtr Mile)

") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.

!.!.

!.

!.

!.

!.

!.

!.

Saddle Mountain

Rd

19

18.75

19.75

18.5

19.5

19.25

Osgood Creek

Rock Creek

Youngs River

Figure 13

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

!.

!.

Saddle Mounta ni Rd

20 21

20.25

21.25 20.5 20.75

Fox Creek

Youngs River

Figure 14

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

!.!.

!.!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

22

22.75

21.5 21.25

22.5

22.25

21.75

Mabel Creek

South Fork Youngs River

Youngs River

Figure 15

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

DD

D

!.

!.!.

!.

!.!.

!.

!.

!.

!.!.

!.

!.

!.

!.

22.75 23 23.25 23.5 23.75 24 Youngs River Fall Creek

Figure 16

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

25

24

24.5 24.75

25.5

24.25

25.25

Little Fishhawk Creek

Fall Creek

Figure 17 

Aerial Maps of the Pipeline

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND

!. Stream Crossing - Listed Fish

!. Stream Crossing - No Listed Fish

kj HDD Entry/Exit Point

D Pipeline Route Milepost (Qtr Mile)

") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

27

26

25.75

25.5

26.75

26.5

26.25

Little Fishhawk Creek

Figure 18

Aerial Maps of the Pipeline

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND

!. Stream Crossing - Listed Fish

!. Stream Crossing - No Listed Fish

kj HDD Entry/Exit Point

D Pipeline Route Milepost (Qtr Mile)

") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

28

28.5

27.25

28.25

27.75

27.5

28.75

Little Fishhawk Creek

Figure 19

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.

!.

!.

!.

!.

!.

!.

30 29

29.75

29.5

29.25

30.25

28.75

East Humbug Creek

Figure 20

Aerial Maps of the Pipeline

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND

!. Stream Crossing - Listed Fish

!. Stream Crossing - No Listed Fish

kj HDD Entry/Exit Point

D Pipeline Route Milepost (Qtr Mile)

") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

!.

!.

!.

!.

!.

!.

!.!.

!.

!.

31 30.75

30.5 31.5 31.75

31.25

Cedar Creek

Alder Creek

Figure 21

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

kj

kj

!.

!.

!.

!.

!.

!.!.

!.

33

32

32.25

31.75

32.75

33.5

32.5

33.25

Larsen Creek

Nehalem River

Figure 22

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

kj

kj

!.

!.

US

26-Sunset

Hwy

103

103

35

33.75 34 34.25

34.75

33.5

34.5

Cow Creek

Nehalem River

Figure 23

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

!.

!.!.

US 26-Sunset Hwy

36 35 35.5 35.25 35.75 36.25 36.5

Osweg Creek

Cow Creek

Figure 24

Aerial Maps of the Pipeline

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND

!. Stream Crossing - Listed Fish

!. Stream Crossing - No Listed Fish

kj HDD Entry/Exit Point

D Pipeline Route Milepost (Qtr Mile)

") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

!.

!.

!.

US 26-Sunset Hwy

38 36.75 37 37.75 36.5 37.25 37.5

Cow Creek

Osweg Creek

Quartz Creek

South Fork Quartz Creek

North Fork Quartz Creek

Figure 25

Aerial Maps of the Pipeline

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND

!. Stream Crossing - Listed Fish

!. Stream Crossing - No Listed Fish

kj HDD Entry/Exit Point

D Pipeline Route Milepost (Qtr Mile)

") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.

!.

!.

!.

US 26-Sunset Hwy

39

38

38.75

38.5

38.25

39.5

39.25Military Creek

North Fork Quartz Creek

South Fork Quartz Creek

Figure 26

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

kj

kj

!.

!.

!.

!.

US 26-Sunset Hwy

40 40.25 39.75

40.75

39.5

40.5

Rock Creek

Military Creek

Figure 27

Aerial Maps of the Pipeline

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND

!. Stream Crossing - Listed Fish

!. Stream Crossing - No Listed Fish

kj HDD Entry/Exit Point

D Pipeline Route Milepost (Qtr Mile)

") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

kj

kj

!.

!.

!.

!.

!.

US

26

-Su

nset

H

wy

42

41

41.5

41.25

42.5

42.25 41.75

Rock Creek

South Fork Rock Creek

Figure 28

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

kj

kj

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

!.

US

26

-

Su

n

set

H

w

y

43

42.5 42.75 43.75

43.5

43.25 Bear Creek South Fork Rock Creek

Figure 29

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.

!.

!.

!.

!. !.

!.

US 26-Sunset Hwy

45

44

44.25

45.25 43.75

44.75

44.5

South Fork Rock Creek

Bear Creek

Wolf Creek

Figure 30

Aerial Maps of the Pipeline

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND

!. Stream Crossing - Listed Fish

!. Stream Crossing - No Listed Fish

kj HDD Entry/Exit Point

D Pipeline Route Milepost (Qtr Mile)

") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D D

D

D

US 26-Sunset Hwy

46

46.5 45.25

46.25 45.75 45.5

North Fork Wolf Creek

Wolf Creek

Figure 31

Aerial Maps of the Pipeline

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND

!. Stream Crossing - Listed Fish

!. Stream Crossing - No Listed Fish

kj HDD Entry/Exit Point

D Pipeline Route Milepost (Qtr Mile)

") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

!.

!.

US

26-Sunset

Hwy

48

47

47.75

47.25

48.25

46.75

47.5

Coal Creek

Wolf Creek North Fork Wolf Creek

Figure 32

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

!.

49

48.75

48.5

49.75

49.5

48.25

49.25

North Fork Green Timber Creek

South Fork Clear Creek

Figure 33

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

!.

51

50

51.5

50.25

51.25

49.75

50.75

50.5

North Fork Green Timber Creek

Green Timber Creek

Lower North Fork

Clear Creek

Figure 34

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

52

51.5 52.75

52.5

52.25

51.75

Lower North Fork

Figure 35

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

!.

54

53

53.75

53.5

54.5

53.25

54.25

Fall Creek

Weed Creek

Figure 36

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

!.

!.

56 54.75 55

55.5 55.75

55.25

Nehalem River

Weed Creek

Cedar Creek

Figure 37

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

kj

kj

!.

!.

!.

!.

57

56 57.5 56.25

57.25

56.75

56.5

Figure 38

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

DD

D

D

D

D

D

kj

!.

!.

!.!.D

kj

57.5 58 59

58.75

58.5

58.25

59.25

57.75Rock Creek

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace

Figure 39

Aerial Maps of the Pipeline
D

D

D

D

D

D

D

D

60

59.75

59.5

60.5 59.25

60.25

Figure 40

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

61 62

61.75

60.75

61.5

61.25

Figure 41

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

kj

!.

SR 47-Nehalem Hwy

63

62

63.25

62.75

62.5

62.25

63.5

Nehalem River

Figure 42

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

kj!.

kj

SR 47-Nehalem Hwy

65

64

64.5

63.75 64.25

64.75

63.5

East Fork Nehalem River Nehalem River

Figure 43

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

!.

66

65

65.5

65.25

66.5

66.25

65.75

Oak Ranch Creek

Figure 44

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!. !.

68

67

66.75 67.75 67.5 67.25

Dog Creek

Oak Ranch Creek

Figure 45

Aerial Maps of the Pipeline

 ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND

!. Stream Crossing - Listed Fish

!. Stream Crossing - No Listed Fish

kj HDD Entry/Exit Point

D Pipeline Route Milepost (Qtr Mile)

") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.

!.

!.

!.

69

68 69.25

68.75

68.5

68.25

69.5

Figure 46

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.!.!.

!.

!. !.

!.

!.

!.

71 70

70.5

70.25

69.75

70.75

69.5

Clatskanie River

Figure 47

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.

!.

!.

72

71

71.75 71.5 71.25

72.5

72.25

Clatskanie River

Little Clatskanie River

Figure 48

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

!.

!.

!.

!.

74

73

72.75

73.75

72.5

73.5

73.25

Apilton Creek

Milton Creek

Figure 49

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.

!.

75

75.25

74.75

74.5

74.25 75.5

Apilton Creek

Milton Creek

Figure 50

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.

77

76

76.5

76.25

75.75

76.75

75.5

Merrill Creek

Figure 51

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.

!.

!.

78

77

77.75

78.75

77.5

77.25 78.5

78.25

Merrill Creek

Figure 52

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

!.

!.

!.

80

79

80.25

78.75

79.75

79.5

79.25

Figure 53

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

kj

!.

!.

!.

US 30-Columbia

River Hwy

81

80

80.25

81.25

80.5 80.75

82

81.5

81.75

Figure 54

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

kj

!.

!.

83

82

82.5

83.5

82.75

82.25

83.25

Martin Slough

McBride Creek

Burris Creek

Columbia River

Figure 55

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D

D

D

D

D

!.

Burke Rd

Dike Access Rd

Guild Rd

Robinson Rd

85

84

83.5

84.5

83.75

83.25

84.75

84.25

85.25

Burris Creek

Figure 56

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
D

D

D

D

D

D

D SR 503-Lewis River Rd

§ ̈¦5§ ̈¦5

§ ̈¦5

Goerig St

Dike

Access

Rd

Scott Ave

Old Pacific Hwy

Exit21

86

85.5

86.5 85.75

85.25

86.25

86.75

Burris Creek

Figure 57

Aerial Maps of the Pipeline  ́

0 600 1,200

Feet

Area of Interest

#*

Clatsop

Cowlitz

Columbia

Tillamook Washington

Clark

LEGEND !. Stream Crossing - Listed Fish !. Stream Crossing - No Listed Fish kj HDD Entry/Exit Point D Pipeline Route Milepost (Qtr Mile) ") Compressor Station

Pipeline Route

Terminal Layout

Pipeline Permanent, Temporary,

and Additional Temporary 

Workspace

Permanent

Temporary Workspace

Additional Temporary Workspace
Area 1:

Tongue

Point

809020000400

809000000

809020000300

809020000100

809020000500

809020000101

809020000600

80903D000200

809020000200

809020000108

80903D001600

80903D001300

809020000106

809020000280

809020090044

809020090042

809020090055

809020090053

809020000103

809020000105

809020090040

809020000109

809020090051

809020000107

809020090049

809020090039

809020090033 80910AA02700

80910AA03100 809020090027 809020090172

809020090178 809020090021

80910AA03400

809020090017

80910AA02201 80910AA03600

809020090013

80910AA02100

809020090005

80910AA00200

80910AA00100

80910AA04400 809020090118

809110005800

809020090004

809020090124

809110001000

809110000900

809110000800 809110000700

809100000200

80910AA06200

80910AA06300

809120000100

809110000100

809110000600 809110000500

809110000300

809100001000

809100000600

809100000500

809100000700 809100000400

809100000800

809110001100

809100000902

809110000200

809110001500 809110001800 809110001600

809110001900

809110005900

809110002100

809110002000

809100001100

809110002300 809110002400

809110002500 809110002200

809110002600

809120000102

80911AD00100

809110001200 809110006000 80911AD01000

809110002700

80911AD01200

80911AD00900

809110002800 809110004700 80911AD01100 80911AD00200 

Library Ln

Vista Way

Valmay Pl

Firehouse Way

Tongue Point Rd

53rd St

Birch St

Bayview St

Tongue Point Rd

Alder 

St

Hwy 30 Pier St

Country Ln

Woodbine Way Ash St

Tongue Po ni t Way

Maritime Rd

Tongue Point St

54th St

Blue Ridge Dr

Cedar St

E Columbia River Hwy

Columbia River Hwy

Nimitz Dr

US Hwy 30

Old US Hwy 30

Lee Dr

Recreation Row

Tongue 

Pt

Island View Cir

Millcreek Rd

Front St

Columbia St

Lagoon Rd

Railroad Ave

Railroad Ave
Area 2: Hwy

26 and NW

Timber Rd

51

50.25

51.25

50.75

50.5

Clear Creek Rd 

PDX \\ROSA\PROJ\LNGDEVELOPMENT\355036\GIS-PDX\MAPDOCUMENTS\2012\RESOURCEREPORTS\RR01_GENERALPROJECTDESCRIPTION\ACCESSROADS.MXD LCLARK 5/6/2013 4:41:11 PM
Area 3: Off of

Pittsburg Rd

64

62.75 63.75 63.5

54W23D000500

5

54W23D000201

54W23D000200

54W23D000600

54W23D000300

54W23D000400

54W23D001000 54W23D000900

54W23D001100 54W23D000800

54W23D000801

54W2

C Burns Rd

Crooked 

Creek Mnln Pittsburg Rd

Scappoose Vernonia Hwy

Coates Mnln

Sleepy Ln

Crooked Creek Mnln

Nehalem Hwy N

Nehalem Hwy N
Area 4:

Off of

Pittsburg Rd

69

68

67.75

68.75

68.5

68.25

Camp 9 Rd

Pittsburg Rd
Area 5: Hwy 30 and

Dike Rd, Rail Siding near

Compressor Station

82

81

81.5

80.25

80.75

80.5

81.75

51W170000100

51W08C000100

51W080000100 Chaney Rd

Dike Rd

US Hwy 30

Weigh Station Turnoff
Area 6: Off

of Port Rd

in Kalama

6352201

63556

63558

63559

63569001

63570

63557

63569

738602

777904

6355801

63569002

703755077

7957

WC2108006

WC2001009 WC2001012

WC2004019

WC2007007

WC2007009

WC2004004

WC2004008

WC2007002

WC2007003

WC2102014

WC2102002 WC21

WC2108018

WC2108010

WC2109001

WC2109003

WC2109008

WC2109012

WC2110005

WC2110022

WC2111009

WC2109013

WC2109015

WC2109016

WC2111003

WC2001007

WC2001026

WC2004016

WC2004017

WC2007012

WC2007013

WC2007014

WC2007016

WC2102003

WC2103006

WC2103009

WC2109006

WC2109007

WC2110019

WC2110021 WC2110

WC2001010

WC2001023

WC2001028

WC2007008

WC2007017

WC2103003

WC2103012

WC2103016

WC2108002

WC2109002

WC2109009

WC2109011 WC2109018

WC2110014

WC211000

WC2001005

WC2004005

WC2004003

WC2004010

WC2004011

WC2004012

WC2108017

WC2001004

WC2001006

WC2109005

WC2007011

WC2007004 WC2007001

WC2004006

63522

635220103

635220104

635220105

635220106

635220102

635220107 635220108 635220109

WC2015002

WC2015011

WC2015010

635220101

WC2015001

60066

WC2015003

WC2109004

WC2108011

WC2110017

WC211

WC2109023

WC2109021

WC2109022

WC2109025

WC2109017

WC2111017

WC2111006

WC2109019

WC2111008

WC2111005

WC2111011

WC2004001

WC2111002

411650100

411660100

411630100

411640100

411620100

WC2004020

WC2004013

WC2004009

411610100

63535

63542

WC2007012N

63534

WC2004007

WC2007005

411540100

WC2007018

600540200

635440

635440531

6355501

63552

63556003 63556002

635440403

6354403

635440301

635550101

63544053 

635450200

63545

63549

635480105

635480103

635480104

63556001

WC2111012

WC2111014

W

WC2111010

63547

63546

63548

635480101

635480107

635480106

635480100

635550200

63555

635550300

635550400

635450100

63544021

63544025

WC2015009

WC2015004

WC2015008

WC2015005

60061

6005501

6006603

6354404

6354404

63544054 63544052

WC2001025

411520100

WC2111001

WC2111004 WC2111001N

6005308

6005401

411490100

60061

635

6356801

635

635480102

63544056

6357201 6357

63544051

Hideaway Ln

Todd Rd

Dupont Rd

T di ewater Dr

Todd Rd

Vincent Rd

River Ridge Ln

Robb Rd

Toteff Rd

Hendrickson Dr

Elevator Dr

Cloverdale Rd

Kilkelly Rd

Port Rd

Old 99

I- 5

I- 5

Nimmo Rd

APPENDIX E2 

PIPELINE CONSTRUCTION RIGHT-OF-WAY CROSS SECTIONS 







APPENDIX E3 

PIPELINE ROUTE MINOR VARIATIONS

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

3

0

2.75

0.25

2.5

3.25

0.5

0.75

1

1.25

1.5

1.752

2.25

Highway

101

Adairs

Slough

Terminal

Reroute

Seppa

Dairy

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend D Pipeline Route Milepost (Qtr Mile) #* Northwest Pipeline Interconnect #* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline

Figure 1

Proposed and Minor 

Alternative Pipeline

Route Variations
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

6

5

4

3

4.25

6.25

5.25

3.75

5.75 4.75

3.5

5.5

3.25

4.5

Clatsop

County 1

Lewis and

Clark River

Highway

101

Seppa

Dairy

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend D Pipeline Route Milepost (Qtr Mile) #* Northwest Pipeline Interconnect #* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline

Figure 2

Proposed and Minor 

Alternative Pipeline

Route Variations
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

9

8

7

6.25

7.5

7.25

8.25 8.5

9.5

6.75 9.25

7.75

6.5 8.75

Seppa

Dairy

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend D Pipeline Route Milepost (Qtr Mile) #* Northwest Pipeline Interconnect #* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline

Figure 3

Proposed and Minor 

Alternative Pipeline

Route Variations
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

13

12

11

10

9

12.25

9.75

13.25

10.75

9.5

11.75

9.25

10.5

12.75

10.25

11.5

11.25

12.5

Speelyai

Creek

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend D Pipeline Route Milepost (Qtr Mile) #* Northwest Pipeline Interconnect #* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline

Figure 4

Proposed and Minor 

Alternative Pipeline

Route Variations
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

16

15

14 13

13.5 15.5

13.25

14.5

15.25

12.75 14.25

14.75

13.75

15.75

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend D Pipeline Route Milepost (Qtr Mile) #* Northwest Pipeline Interconnect #* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline

Figure 5

Proposed and Minor 

Alternative Pipeline

Route Variations
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

18

17

16

16.75

17.75

16.5 18.75

16.25

17.5 17.25

18.5

18.25

15.75

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend D Pipeline Route Milepost (Qtr Mile) #* Northwest Pipeline Interconnect #* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline

Figure 6

Proposed and Minor 

Alternative Pipeline

Route Variations
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

21

20

19 20.25

21.5 21.25

18.75

19.75

20.75

19.25 19.5 21.75

20.5

Youngs

River

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline

Figure 7

Proposed and Minor 

Alternative Pipeline

Route Variations
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

24

23

22

22.75

21.5

24.75

23.75

22.5

24.5

22.25

23.5

24.25

23.25

21.75

Youngs

River

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline

Figure 8

Proposed and Minor 

Alternative Pipeline

Route Variations
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

27

26

25 27.25

24.75

24.5

25.75

25.5

26.75

26.5

27.75

25.25

27.5

26.25

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend D Pipeline Route Milepost (Qtr Mile) #* Northwest Pipeline Interconnect #* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline

Figure 9

Proposed and Minor 

Alternative Pipeline

Route Variations
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

31

29 30

28

28.5

29.75

29.5

30.75

28.25

30.5

29.25

30.25

27.75

28.75

Figure 10

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

34

33

32

31

32.25

34.25 30.75

31.75 33.75

31.5

32.75

33.5

32.5

31.25

33.25

Wilson

Parcel

Christmas

Tree Road

Nehalem

River

Red Bluff

Road

Figure 11

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend D Pipeline Route Milepost (Qtr Mile) #* Northwest Pipeline Interconnect #* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

37 36

35

34

36.75 34.25

35.5 35.25

36.5

36.25

37.25

34.75

35.75

34.5

Nehalem

River

Jewell

Junction

Christmas

Tree Road

Clatsop

County 2

Figure 12

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

40 D

38 39

40.25 37.75

38.75

37.5 39.75

37.25

38.5

38.25

39.5

39.25

Clatsop

County 2

Figure 13

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

43

42

41

40 40.25

41.5

42.75

41.25

42.5

42.25

40.75

43.25

41.75

40.5

Sunset

Springs

Rest Area

Figure 14

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

46

45

44

43

44.25 45.25

43.75

43.5

44.75

44.5

45.75

43.25

45.5

Sunset

Springs

Rest Area

Figure 15

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

PUBLIC

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

49

48

47

46

46.5

47.75

48.75

46.25

48.5

47.25

48.25

49.25

46.75

47.5

North

Fork Wolf

Creek

Topography

Reroute A

Figure 16

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

52

51

50

51.5

52.75

50.25

52.5

51.25

52.25

49.75

49.5

50.75

50.5

51.75

49.25

Clear Creek 2

Rocky

Point

Road

Topography

Reroute A

Clear

Creek 1

Figure 17

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

55

54

53

52.75

52.5

53.75

53.5

54.5 54.75

55.75

53.25

55.5

54.25

55.25

Rocky

Point

Road

Cedar

Creek

Weed

Creek

Road

Figure 18

Proposed and Minor 

Alternative Pipeline

Route Variations  ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend D Pipeline Route Milepost (Qtr Mile) #* Northwest Pipeline Interconnect #* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

59

58

57

56

57.5

58.75

56.25

58.5

57.25

58.25

55.75

56.75

56.5

57.75

Weed

Creek

Road

Cedar

Creek

Rock

Creek

Figure 19

Proposed and Minor 

Alternative Pipeline

Route Variations  ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend D Pipeline Route Milepost (Qtr Mile) #* Northwest Pipeline Interconnect #* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

62

61

60 59

59.75

61.75

59.5

60.75

61.5

60.5

59.25

61.25

60.25

Coates

Mnln

Rock

Creek

Figure 20

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

65

64

63

62

63.25

64.5

64.25

61.75

62.75

62.5 63.75

64.75

62.25

63.5

Baker

Point

Coates

Mnln

Pittsburg

Road

Figure 21

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

68

67

66

65

66.75

65.5

67.75

65.25

66.5

66.25

67.5

67.25

64.75

65.75

Pittsburg

Road

Baker

Point

Figure 22

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

71

70 69

68

69.25

70.5

70.25

68.75

69.75

68.5

70.75

68.25

69.5

Clatskanie

RiverClatskanie

River

Schaffer

Road

Clatskanie

River

Figure 23

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend D Pipeline Route Milepost (Qtr Mile) #* Northwest Pipeline Interconnect #* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

74

73

72

71

71.75

72.75

71.5

73.75

71.25

72.5

72.25

73.5

73.25

74.25

Clatskanie

Clatskanie River River

Schaffer

Road

Clatskanie

River

Topography

Reroute B

Figure 24

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D D

D

D

D

D

D

D

D D

D

D

77

76

74 75

75.25

76.5

76.25

77.25

74.75

75.75

74.5 76.75

74.25

75.5

Topography

Reroute C

Pinkney

Road

Topography

Reroute B

Figure 25

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

80

79

78

77

77.75

80.25

78.75

77.5

79.75

77.25

78.5

78.25

79.25 79.5

80.5

Topography

Reroute D

Topography

Reroute C

Knife

River

Quarry

Figure 26

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline
D D

D

D

D

D

D

D D D

D

D D D D D

Proposed Woodland

High School Location

81

80.25

81.25

80.75

80.5

83

82 82.5

83.5

81.5

81.75

82.75 82.25 83.25 Option

D1

Deer

Island 2

Deer Island 1

Knife

River

Quarry

I-5

Median

Deer Island

Figure 27

Proposed and Minor 

Alternative Pipeline

Route Variations

 ́

0 1,000 2,000

Feet

Clatsop

Columbia

Tillamook

Washington

Multnomah

Yamhill

Grays

Harbor

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

Legend

D Pipeline Route Milepost (Qtr Mile)

#* Northwest Pipeline Interconnect

#* Alternative Interconnect

Pipeline Route

Variation Not Selected

Deer Island Route Variation

Green Mountain Route Variation

Northwest Pipeline

APPENDIX E4 

ADDITIONAL TEMPORARY WORKSPACE FOR THE PIPELINE;

ADDITIONAL TEMPORARY WORKSPACES WITHIN 50 FEET OF 

WETLANDS AND WATERBODIES

E4-1

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Clatsop 0.1 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 100 0.02 

0.10 

Clatsop 0.2 Point of Intersection Additional Spoils Area 407 x 123 1.12 

0.03 

Clatsop 0.6 Slough/Waterbody Additional Spoil Area/Staging Area 175 x 50 0.20 Clatsop 0.6 Slough/Waterbody Additional Spoil Area/Staging Area 175 x 100 0.41 Clatsop 0.8 Highway 101 Crossing Additional Spoil Area/Staging Area 512 x 50 0.56 Clatsop 0.8 Highway 101 Crossing Additional Spoil Area/Staging Area 373 x 117 0.74 Clatsop 0.8 Highway 101 Crossing Additional Spoil Area/Staging Area 85 x 50 0.07 

0.03 

Clatsop 1.1 Slough/Waterbody Additional Spoil Area/Staging Area 535 x 180 1.73 Clatsop 1.5 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 1.7 Airport Road Bore Pit and Equipment 50 x 175 0.10 Clatsop 1.7 Airport Road Bore Pit and Equipment 50 x 175 0.08 Clatsop 1.7 Airport Road Bore Pit and Equipment 50 x 175 0.20 Clatsop 1.7 Airport Road Bore Pit and Equipment 50 x 175 0.21 Clatsop 1.8 Point of Intersection Additional Spoils Area 50 x 100 0.17 Clatsop 2.3 Clatsop Airport Road Bore Pit and Equipment 50 x 150 0.17 

0.03 

Clatsop 2.4 Clatsop Airport Road Bore Pit and Equipment 50 x 425 0.51 

0.01 

0.03 

Clatsop 2.4 Clatsop Airport Road Bore Pit and Equipment 50 x 200 .02 

.02 

0.19 

0.02 

Clatsop 2.4 Clatsop Airport Road Bore Pit and Equipment 50 x 175 0.12 

0.09 

Clatsop 2.8 Lewis and Clark River HDD Equipment Pad 125 x 300 0.21 

0.76 

Clatsop 3.4 Lewis and Clark River HDD Equipment Pad/Pullback 150 x 300 0.95 Clatsop 3.7 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 500 0.57 Clatsop 4.0 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 770 0.88 Clatsop 4.1 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 400 0.46 
 E4-2 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Clatsop 4.2 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 350 0.32 

0.08 

Clatsop 4.4 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 1100 1.27 Clatsop 4.6 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 125 0.14 Clatsop 4.6 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 175 0.20 Clatsop 4.7 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 150 0.17 Clatsop 4.8 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 250 0.29 Clatsop 4.9 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 325 0.37 Clatsop 5.0 Lewis and Clark River Bank HDD Equipment Pad 80 x 300 0.55 Clatsop 5.4 Lewis and Clark River HDD Pullback 75 x 410 0.70 Clatsop 5.5 Lewis and Clark River Bank HDD Equipment Pad/Pullback/ Additional 

Spoil Area/Staging Area 

50 x 325 & 75 x 1300 2.50 

Clatsop 5.5 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 225 0.27 Clatsop 5.5 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 320 0.37 Clatsop 5.6 Slough/Waterbody Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 5.6 Lewis and Clark River HDD Equipment Pad 80 x 250 0.46 Clatsop 6 Lewis and Clark River HDD Equipment Pad 80 x 300 0.55 Clatsop 6.1 Point of Intersection Additional Spoil Area 50 x 300 0.36 Clatsop 6.2 Point of Intersection Additional Spoil Area 50 x 175 0.20 Clatsop 6.3 Point of Intersection Additional Spoil Area 50 x 175 0.05 

0.10 0.05 

Clatsop 6.3 Point of Intersection Additional Spoil Area 50 x 175 0.20 Clatsop 6.8 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 6.9 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 7.6 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 7.8 Wetland Additional Spoil Area 50 x 150 0.17 Clatsop 8.0 Wetland Additional Spoil Area 50 x 250 0.29 Clatsop 8.2 Wetland/Stream Additional Spoil Area/Staging Area 50 x 700 0.79 Clatsop 8.7 Wetland/Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 8.9 Wetland/Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 9.3 Point of Intersection Additional Spoil Area 50 x 100 0.15 Clatsop 9.6 Point of Intersection Additional Spoil Area 50 x 100 0.15 Clatsop 9.9 Stream Additional Spoil Area/Staging Area 50 x 60 0.07 
 E4-3 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Clatsop 10.0 Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 10.0 Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 10.1 Wetland Additional Spoil Area 50 x 500 0.59 Clatsop 10.3 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 10.7 Point of Intersection Additional Spoil Area 50 x 100 0.15 Clatsop 10.9 Lewis and Clark River HDD Equipment Pad 80 x 300 0.63 

0.01 

Clatsop 11.2 Lewis and Clark River HDD Equipment Pad 80 x 300 0.33 

0.01 0.02 0.32 

Clatsop 12.2 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 12.4 Wetland Additional Spoil Area 50 x 205 0.24 Clatsop 12.5 Wetland/Stream Additional Spoil Area/Staging Area 50 x 385 0.44 Clatsop 12.6 Wetland/Stream Additional Spoil Area/Staging Area 50 x 110 0.13 Clatsop 12.7 Stream Additional Spoil Area/Staging Area 50 x 400 0.48 Clatsop 12.8 Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 13.1 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 13.3 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 13.6 Point of Intersection Additional Spoil Area 50 x 260 0.26 Clatsop 13.8 Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 13.8 Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 14.0 Point of Intersection Additional Spoil Area 50 x 100 0.13 Clatsop 14.1 Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 14.1 Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 14.2 Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 14.2 Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 14.3 Point of Intersection Additional Spoil Area 50 x 100 0.12 Clatsop 14.8 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 15.2 Steep Terrain/Stream Additional Spoil Area/Staging Area 50 x 600 0.75 Clatsop 15.4 Steep Terrain/Stream Additional Spoil Area/Staging Area 50 x 335 0.35 Clatsop 15.5 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 15.6 Stream Additional Spoil Area/Staging Area 50 x 150 0.16 Clatsop 15.7 Stream Additional Spoil Area/Staging Area 50 x 150 0.17 
 E4-4 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Clatsop 15.8 Wetland/Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 16.0 Wetland/Stream Additional Spoil Area/Staging Area 50 x 300 0.36 Clatsop 16.2 Wetland/Stream Additional Spoil Area/Staging Area 50 x 150 0.17 Clatsop 16.4 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 16.9 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 17.3 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 17.3 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 17.4 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 17.4 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 17.6 Point of Intersection Additional Spoil Area 50 x 100 0.13 Clatsop 17.9 Stream Additional Spoil Area/Staging Area 50 x 160 0.19 Clatsop 18.2 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 18.3 Wetland/Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 18.3 Wetland/Stream Additional Spoil Area/Staging Area 50 x 175 0.20 Clatsop 18.4 Wetland/Stream Additional Spoil Area/Staging Area 50 x 315 0.36 Clatsop 18.4 Wetland/Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 18.6 Wetland/Stream Additional Spoil Area/Staging Area 50 x 150 0.17 Clatsop 18.7 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 18.9 Point of Intersection Additional Spoil Area 50 x 150 0.04 

0.14 

Clatsop 18.9 Point of Intersection Additional Spoil Area 50 X 90 0.10 Clatsop 19.0 Wetland Additional Spoil Area/Staging Area 50 x 80 0.04 Clatsop 19.1 Wetland Additional Spoil Area/Staging Area 50 x 100 & 50 x 150 0.25 Clatsop 19.2 Point of Intersection/Wetland Additional Spoil Area 50 x 75 & 50 x 350 0.10 

0.37 0.04 

Clatsop 19.4 Wetland/Stream Additional Spoil Area/Staging Area 50 x 110 & 50 x 220 0.02 

0.31 

Clatsop 19.5 Wetland/Stream Additional Spoil Area/Staging Area 50 x 600 0.70 Clatsop 19.6 Wetland/Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 19.8 Wetland Additional Spoil Area 50 x 200 0.23 Clatsop 19.8 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 20.0 Stream Additional Spoil Area/Staging Area 50 x 300 0.35 Clatsop 20.0 Stream Additional Spoil Area/Staging Area 50 x 100 0.12 
 E4-5 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Clatsop 20.1 Stream Additional Spoil Area/Staging Area 50 x 310 0.36 Clatsop 20.2 Stream Additional Spoil Area/Staging Area 50 x 310 0.36 Clatsop 20.7 Point of Intersection Additional Spoil Area 50 x 100 0.12 Clatsop 20.8 Point of Intersection Additional Spoil Area 50 x 100 0.12 Clatsop 21.3 Stream Additional Spoil Area/Staging Area 50 x 200 0.22 Clatsop 21.5 Stream Additional Spoil Area/Staging Area 50 x 175 0.20 Clatsop 21.7 Steep Terrain Additional Spoil Area 50 x 800 0.94 Clatsop 21.9 Steep Terrain Additional Spoil Area 50 x 390 0.44 Clatsop 21.9 Wetland/Stream Additional Spoil Area/Staging Area 50 x 320 0.35 Clatsop 22.1 Wetland/Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 22.2 Wetland/Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 22.3 Point of Intersection/Wetland Additional Spoil Area/Staging Area 50 x 340 0.37 Clatsop 22.5 Wetland/Stream Additional Spoil Area/Staging Area 50 x 550 0.63 Clatsop 23.0 Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 23.0 Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 23.4 Stream/Riparian Area Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 23.5 Stream/Riparian Area Additional Spoil Area/Staging Area 50 x 200 0.26 Clatsop 24.3 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 24.4 Wetland/Stream Additional Spoil Area/Staging Area 50 x 150 0.20 Clatsop 24.5 Wetland/Stream Additional Spoil Area/Staging Area 50 x 150 0.20 Clatsop 24.7 Wetland/Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 24.9 Wetland/Stream Additional Spoil Area/Staging Area 50 x 220 0.25 Clatsop 25.0 Point of Intersection/Stream Additional Spoil Area/Staging Area 50 x 480 0.52 Clatsop 25.2 Wetland/Stream Additional Spoil Area/Staging Area 50 x 125 0.15 Clatsop 25.3 Wetland/Stream Additional Spoil Area/Staging Area 50 x 225 0.27 Clatsop 25.3 Wetland/Stream Additional Spoil Area/Staging Area 50 x 175 0.22 Clatsop 25.4 Stream Additional Spoil Area/Staging Area 50 x 125 0.15 Clatsop 25.4 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 25.5 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 25.6 Point of Intersection Additional Spoil Area 50 x 100 0.13 Clatsop 25.6 Stream Additional Spoil Area/Staging Area 50 x 240 0.29 Clatsop 25.6 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 25.8 Stream Additional Spoil Area/Staging Area 50 x 300 0.34 
 E4-6 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Clatsop 26 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 26.1 Point of Intersection Additional Spoil Area 50 x 125 0.16 Clatsop 26.2 Point of Intersection Additional Spoil Area 50 x 125 0.15 Clatsop 26.3 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 26.3 Stream Additional Spoil Area/Staging Area 50 x 95 0.11 Clatsop 26.4 Point of Intersection/Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 26.5 Steep Additional Spoil Area/Staging Area 50 x 580 0.68 Clatsop 26.7 Stream Additional Spoil Area/Staging Area 50 x 120 0.15 Clatsop 26.7 Point of Intersection/Stream Additional Spoil Area/Staging Area 50 x 700 0.82 Clatsop 26.9 Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 26.9 Stream Additional Spoil Area/Staging Area 50 x 200 0.23 Clatsop 27.1 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 27.2 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 27.3 Stream Additional Spoil Area/Staging Area 50 x 170 0.19 Clatsop 27.4 Stream Additional Spoil Area/Staging Area 50 x 220 0.25 Clatsop 27.9 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 28.1 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 28.1 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 28.3 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 28.7 Point of Intersection Additional Spoil Area 50 x 100 0.15 Clatsop 29 Point of Intersection Additional Spoil Area 50 x 100 0.13 Clatsop 29.4 Point of Intersection/Stream Additional Spoil Area/Staging Area 50 x 140 0.18 Clatsop 29.6 Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 29.6 Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 29.6 Point of Intersection Additional Spoil Area 50 x 100 0.13 Clatsop 30.1 Point of Intersection/Wetland Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 30.1 Point of Intersection/Wetland Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 30.5 Point of Intersection Additional Spoil Area 50 x 100 0.13 Clatsop 30.8 Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 31.3 Wetland/Stream Additional Spoil Area/Staging Area 50 x 420 0.48 Clatsop 31.4 Point of Intersection/Stream Additional Spoil Area/Staging Area 50 x 320 0.38 Clatsop 31.4 Point of Intersection/Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 31.6 Point of Intersection/Stream Additional Spoil Area/Staging Area 50 x 450 0.40 Clatsop 31.7 Point of Intersection/Stream Additional Spoil Area/Staging Area 50 x 375 0.43 Clatsop 32.9 Point of Intersection Additional Spoil Area 50 x 125 0.16 Clatsop 33.3 Nehalem River HDD Equipment Pad 80 x 300 0.66 
 E4-7 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Clatsop 33.7 Nehalem River HDD Equipment Pad/Pullback 80 x 300 & 75 x 625 1.85 Clatsop 33.9 Point of Intersection Additional Spoil Area/Staging Area 50 x 100 0.05 

0.16 

Clatsop 33.9 Point of Intersection Additional Spoil Area/Staging Area 50 x 100 0.11  0.10 Clatsop 34.0 Point of Intersection Additional Spoil Area/Staging Area 50 x 100 0.21  0.01 Clatsop 34.0 Point of Intersection Additional Spoil Area/Staging Area 50 x 100 0.08  0.11  0.02 Clatsop 34.4 Stream Additional Spoil Area/Staging Area 50 x 150 0.17 Clatsop 34.5 Point of Intersection/Wetland Additional Spoil Area/Staging Area 50 x 100 0.14 Clatsop 35.2 Point of Intersection Additional Spoil Area 50 x 110 0.13 Clatsop 35.2 Point of Intersection Additional Spoil Area 50 x 125 0.14 Clatsop 35.3 Point of Intersection Additional Spoil Area 50 x 110 0.13 Clatsop 36.3 Wetland Additional Spoil Area 50 x 150 0.03 

0.14 

Clatsop 36.4 Wetland Additional Spoil Area/Staging Area 50 x 150 0.11 

0.06 

Clatsop 36.9 Steep Terrain/Wetland Additional Spoil Area 50 x 100 0.03 

0.09 

Clatsop 37.1 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 37.4 Steep Terrain/Point of Intersection Additional Spoil Area 50 x 1325 1.50 Clatsop 37.4 Stream Additional Spoil Area/Staging Area 50 x 300 0.33 Clatsop 37.6 Stream Additional Spoil Area/Staging Area 50 x 100 0.12 

0.02 

Clatsop 37.8 Steep Terrain Additional Spoil Area 50 x 1460 1.67 Clatsop 38.3 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 38.4 Point of Intersection/Wetland Additional Spoil Area/Staging Area 50 x 200 0.26 Clatsop 38.6 Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Clatsop 39.2 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 39.4 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 39.4 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 39.7 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 40.1 Steep Terrain/Point of Intersection Additional Staging Area 50 x 2500 2.59 
 E4-8 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Clatsop 40.5 Point of Intersection Additional Spoil Area/Staging Area 50 x 1500 1.88 Clatsop 40.8 Point of Intersection Additional Spoil Area 50 x 100 0.14 Clatsop 40.9 Steep Terrain Additional Spoil Area 150 x 175 0.68  0.001 Clatsop 40.9 Steep Terrain Additional Spoil Area 50 x 100 0.12 Clatsop 41.3 Highway 26 Crossing HDD Exit 50 x 400 0.47 Clatsop 41.4 Highway 26 Crossing HDD Pullback 80 x 1850 3.46 Clatsop 41.5 Wetland Additional Spoil Area 50 x 260 0.30 Clatsop 41.6 Wetland Additional Spoil Area 50 x 500 0.57 Clatsop 41.8 Wetland Additional Spoil Area 50 x 300 0.36 Clatsop 41.9 Wetland Additional Spoil Area 50 x 300 0.34 Clatsop 42.2 Point of Intersection/Wetland Additional Spoil Area/Staging Area 50 x 425 0.48 Clatsop 42.2 Point of Intersection/Wetland Additional Spoil Area/Staging Area 50 x 100 0.13 Clatsop 42.4 Wetland/Stream Additional Spoil Area/Staging Area 50 x 150 0.17 Clatsop 42.4 Wetland/Stream Additional Spoil Area/Staging Area 50 x 150 0.17 Clatsop 42.6 Wetland/Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 42.7 Wetland/Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 43.1 Point of Intersection Additional Spoil Area/Staging Area 100 x 300 0.92 Clatsop 43.6 Hwy 26 HDD Equipment Pad 80 x 300 0.63 Clatsop 43.7 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 43.8 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Clatsop 44 Point of Intersection Additional Spoil Area 50 x 100 0.12 Tillamook 44.1 Wetland/Stream Additional Spoil Area/Staging Area 50 x 300 0.34 Tillamook 44.2 Point of Intersection Additional Spoil Area 50 x 100 0.12 Tillamook 44.5 Point of Intersection Additional Spoil Area 50 x 100 0.13 Tillamook 44.7 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Tillamook 44.8 Stream Additional Spoil Area/Staging Area 50 x 100 0.11 Tillamook 45.6 Wetland Additional Spoil Area 50 x 200 0.23 Tillamook 45.7 Point of Intersection Additional Spoil Area 50 x 100 0.14 Tillamook 45.8 Point of Intersection Additional Spoil Area 50 x 100 0.04  0.09 Tillamook 46.4 Point of Intersection Additional Spoil Area 50 x 100 0.11 Tillamook 46.7 Point of Intersection Additional Spoil Area 50 x 100 0.12 
 E4-9 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Tillamook 47.3 Wetland Additional Spoil Area 100 X 50 0.11 Columbia 47.7 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 47.9 Steep Terrain Additional Cut/Fill Area 100 x 50 0.11 Columbia 48.0 Steep Terrain Additional Cut/Fill Area 100 x 50 0.10 Columbia 48.2 Point of Intersection/Road Crossing Additional Spoil Area/Staging Area 350 x 50 & 200 x 50 0.59 Columbia 48.3 Steep Terrain/Wetland Additional Cut/Fill Area 200 x 50 0.23 Columbia 48.9 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 49.1 Steep Terrain Additional Spoil Area 400 x 50 0.46 Columbia 49.2 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 49.4 Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.11 Columbia 49.5 Steep Terrain Additional Cut/Fill Area 450 x 50 0.52 Columbia 49.7 Steep Terrain Additional Cut/Fill Area 900 x 50 1.03 Columbia 49.9 Point of Intersection Additional Spoil Area 100 x 50 0.08 Columbia 50.1 POI/Steep Terrain Additional Cut/Fill Area 1100 x 50 1.28 Columbia 50.3 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 50.4 Point of Intersection Additional Spoil Area 140 x 50 0.14 Columbia 50.4 Point of Intersection Additional Spoil Area 100 X 50 0.11 Columbia 50.5 Stream Crossing Additional Spoil Area/Staging Area 100 x 50 0.09 Columbia 50.6 Wetland Additional Spoil Area/Staging Area 100 x 50 0.10 Columbia 50.8 Steep Terrain/Wetland Additional Cut/Fill Area 100 x 50 0.08 Columbia 50.9 Point of Intersection Additional Spoil Area 150 x 50 0.20 Columbia 51.6 Stream Crossing Additional Spoil Area/Staging Area 1400 x 50 1.61 Columbia 51.8 Steep Terrain Additional Cut/Fill Area 100 x 50 0.09 Columbia 51.9 Point of Intersection Additional Spoil Area 800 x 50 0.92 Columbia 51.9 Point of Intersection Additional Spoil Area 100 x 50 0.13 Columbia 52.1 Steep Terrain Additional Cut/Fill Area 800 x 50 0.90 Columbia 52.7 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 52.9 Steep Terrain Additional Cut/Fill Area 800 x 50 0.92 Columbia 53.1 Point of Intersection Additional Spoil Area 100 x 50 0.12 Columbia 53.3 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 53.4 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 53.5 Steep Terrain Additional Cut/Fill Area 500 x 50 0.57 Columbia 53.6 Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.12 
 E4-10 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Columbia 53.6 Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.12 Columbia 53.8 Steep Terrain Additional Cut/Fill Area 1480 x 50 1.71 Columbia 54.3 Steep Terrain Additional Cut/Fill Area 1200 x 50 1.40 Columbia 55.4 Wetland Additional Spoil Area 100 x 50 0.12 Columbia 55.4 Wetland Additional Spoil Area 100 x 50 0.12 Columbia 55.7 Wetland Additional Spoil Area 100 x 50 0.06 

0.06 

Columbia 55.8 Wetland Additional Spoil Area 100 x 50 0.11 

0.01 

Columbia 55.9 POI/Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.14 Columbia 55.9 POI/Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.14 Columbia 56.6 POI/Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.10 Columbia 57.1 Rock Creek HDD Pullback 775 x 75 1.29 Columbia 57.3 Rock Creek HDD Pullback 1926 x 75 3.43 Columbia 57.4 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 57.5 Steep Terrain Additional Cut/Fill Area 300 x 80 0.55 Columbia 58.1 Rock creek HDD Entry 300 x 80 0.55 Columbia 58.4 Steep Terrain Additional Cut/Fill Area 1045 x 50 1.19 Columbia 58.5 Point of Intersection Additional Spoil Area 100 x 50 0.18 Columbia 58.7 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 58.8 Point of Intersection Additional Spoil Area 100 x 50 0.13 Columbia 59.0 Point of Intersection Additional Spoil Area 100 x 50 0.15 Columbia 59.1 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 59.2 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 59.9 Point of Intersection Additional Spoil Area 100 x 50 0.09 Columbia 60.1 Point of Intersection Additional Spoil Area 100 x 50 0.13 Columbia 60.4 Point of Intersection Additional Spoil Area 100 x 50 0.12 Columbia 61.3 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 61.7 Steep Terrain/Road Crossing Additional Cut/Fill Area 100 x 50 0.13 Columbia 61.7 Stream Crossing/Road Crossing Additional Cut/Fill Area 600 x 500 0.13 Columbia 62.1 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 62.2 Steep Terrain/Road Crossing Additional Cut/Fill Area 1000 x 50 1.15 Columbia 62.3 Steep Terrain/Road Crossing Additional Cut/Fill Area 950 x 50 1.09 Columbia 62.4 Steep Terrain Additional Cut/Fill Area 250 x 170 0.57 
 E4-11 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Columbia 62.7 Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.11 Columbia 62.8 Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.11 Columbia 63.0 Point of Intersection Additional Spoil Area 100 x 50 0.09 Columbia 63.1 Steep Terrain Additional Cut/Fill Area 350 x 120 0.96 Columbia 63.6 Nehalem River Crossing HDD Entry/Equipment Pad 300 x 80 0.32 

0.23 

Columbia 64.3 Nehalem River Crossing HDD Exit/Equipment Pad 300 x 80 0.55 Columbia 64.3 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 64.7 Nehalem River Crossing HDD Pullback 2470 x 75 4.56 Columbia 64.8 Point of Intersection Additional Spoil Area 100 x 50 0.13 Columbia 64.9 Steep Terrain Additional Cut/Fill Area 100 x 50 0.12 Columbia 65.2 Steep Terrain Additional Cut/Fill Area 708 x 50 0.83 Columbia 65.6 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 65.7 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 66.5 Steep Terrain Additional Cut/Fill Area 520 x 50 0.61 Columbia 67.2 Steep Terrain Additional Cut/Fill Area 670 x 50 0.77 Columbia 68.0 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 68.3 POI/Steep Terrain Additional Cut/Fill Area 250 x 50 0.31 Columbia 68.7 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 69.5 Point of Intersection Additional Spoil Area 100 x 50 0.12 Columbia 69.7 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 70.4 Point of Intersection Additional Spoil Area 100 x 50 0.12 Columbia 70.6 Point of Intersection Additional Spoil Area 100 x 50 0.12 Columbia 70.6 Point of Intersection Additional Spoil Area 100 x 50 0.12 Columbia 70.7 Wetland Additional Spoil Area 100 x 50 0.12 Columbia 70.7 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 70.7 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 70.9 Point of Intersection Additional Spoil Area 100 x 50 0.12 Columbia 71.1 Point of Intersection Additional Spoil Area 100 x 50 0.12 Columbia 71.6 POI/Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.12 Columbia 71.7 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 72.1 Point of Intersection Additional Spoil Area 100 x 50 0.13 Columbia 72.8 Point of Intersection Additional Spoil Area 100 x 50 0.09 
 E4-12 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

Columbia 72.9 Road/Stream crossing Additional Spoil Area/Staging Area 565 x 50 0.42 

0.10 

Columbia 73.4 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 73.5 Point of Intersection Additional Spoil Area 100 x 50 0.12 Columbia 73.9 Point of Intersection Additional Spoil Area 100 x 50 0.15 Columbia 74.8 Stream Crossing Additional Spoil Area/Staging Area 100 x 50 0.11 Columbia 75.1 Point of Intersection Additional Spoil Area 100 x 50 0.09 Columbia 75.7 Point of Intersection Additional Spoil Area 100 x 50 0.12 Columbia 76.0 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 76.3 Stream Additional Spoil Area/Staging Area 1075 x 50 1.24 Columbia 76.9 Point of Intersection Additional Spoil Area 260 x 50 0.28 Columbia 77.9 Point of Intersection Additional Spoil Area 100 x 50 0.14 Columbia 78.0 Point of Intersection Additional Spoil Area 100 x 50 0.11 Columbia 78.1 Point of Intersection Additional Spoil Area 100 x 50 0.15 Columbia 78.4 POI/Stream crossing Additional Spoil Area/Staging Area 100 x 50 0.09 Columbia 78.6 Point of Intersection Additional Spoil Area 100 x 50 0.10 Columbia 78.8 POI/Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.12 Columbia 78.9 POI/Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.11 Columbia 79.2 Wetland Additional Spoil Area 100 x 50 0.11 Columbia 79.8 Steep Terrain Additional Cut/Fill Area 535 x 50 0.61 Columbia 80.1 Point of Intersection Additional Spoil Area 100 x 50 0.14 Columbia 80.3 Point of Intersection Additional Spoil Area 100 x 50 0.08 Columbia 80.5 Point of Intersection Additional Spoil Area 100 x 50 0.09 Columbia 80.5 Point of Intersection Additional Spoil Area 100 x 50 0.09 Columbia 80.6 Point of Intersection Additional Spoil Area 100 x 50 0.09 Columbia 80.6 Compressor Station Additional Staging Area 198 x 50 0.27 Columbia 80.6 Compressor Station Additional Staging Area 100 x 50 0.09 Columbia 81.2 Columbia River Crossing HDD Equipment Pad/Staging Area 3575 x 50 0.37 

3.06 

Columbia 81.4 Columbia River Crossing Additional Staging Area 50 x 100 0.15 

0.003 

Columbia 81.5 Columbia River Crossing Additional Staging Area 50 x 170 0.20  0.01 Columbia 81.6 Columbia River Crossing Additional Staging Area 50 x 856 0.56 
 E4-13 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

0.43 

 0.02 Columbia 81.6 Columbia River Crossing Additional Staging Area 50 x 170 0.20 

0.01 

Columbia 81.7 Columbia River Crossing Additional Staging Area 50 x 138 0.06 

0.10 

Columbia 81.7 Columbia River Crossing Additional Staging Area 150 x 50 0.01 

0.09 0.07 

Columbia 81.8 Columbia River Crossing Additional Staging Area 80 x 305 0.07 

0.50 

Cowlitz 82.8 Columbia River Crossing Additional Staging Area 350 x 80 0.62 Cowlitz 82.8 Columbia River Crossing Additional Staging Area 50 x 200 0.22 Cowlitz 82.9 Columbia River Crossing Additional Staging Area 50 x 185 0.22 Cowlitz 82.9 Columbia River Crossing Additional Staging Area 200 x 50 0.22 Cowlitz 83.2 Columbia River Crossing Additional Spoil Area/Staging Area 200 x 50 0.23 Cowlitz 83.4 Columbia River Crossing Additional Spoil Area/Staging Area 200 x 50 0.23 Cowlitz 84.2 POI/Road Crossing Additional Spoil Area/Staging Area 50 x 175 0.20 Cowlitz 84.3 POI/Road Crossing Additional Spoil Area/Staging Area 50 x 175 0.20 Cowlitz 84.3 Point of Intersection Additional Staging Area 100 x 50 0.11 Cowlitz 84.6 Point of Intersection Additional Staging Area 50 x 100 0.17 Cowlitz 84.8 Point of Intersection Additional Staging Area 50 x 175 0.26 Cowlitz 85.1 Point of Intersection Additional Spoil Area 50 x 200 0.17 Cowlitz 85.1 Point of Intersection Additional Spoil Area 50 x 260 0.19 

0.07 

Cowlitz 85.1 Point of Intersection Additional Spoil Area 50 x 360 0.40 

0.10 

Cowlitz 85.3 Point of Intersection Additional Spoil Area 23 x 100 0.06 Cowlitz 85.4 Point of Intersection Additional Spoil Area 100 x 50 0.11 Cowlitz 85.6 Point of Intersection Additional Spoil Area 100 x 50 0.15 Cowlitz 85.7 I-5 Additional Spoil Area/Staging Area 175 x 50 0.12 

0.09 

Cowlitz 85.7 I-5 Additional Spoil Area/Staging Area 50 x 175 0.16 

0.03 

Cowlitz 85.9 POI/Road Crossing Additional Spoil Area/Staging Area 175 x 50 0.10 
 E4-14 

Table E4-1 

Additional Temporary Workspace for Oregon LNG Pipeline 

County Milepost Crossing Description 

Dimensions 

(feet) Acreage 

0.10 

Cowlitz 85.9 POI/Road Crossing Additional Spoil Area/Staging Area 50 x 143 0.20 Cowlitz 86.0 POI/Road Crossing Additional Spoil Area/Staging Area 100 x 50 0.11 Cowlitz 86.1 Point of Intersection Additional Spoil Area 50 x 175 0.26 Cowlitz 86.2 Point of Intersection Additional Spoil Area 50 x 200 0.17 Cowlitz 86.4 Point of Intersection Additional Spoil Area 50 x 200 0.18 Cowlitz 86.4 Point of Intersection Additional Spoil Area 50 x 110 0.17 Cowlitz 86.5 Point of Intersection Additional Spoil Area 50 x 112 0.01 

0.15 

Total for Additional Temporary Workspaces 138.90 

_________ 

Abbreviations of Land Use Classifications AG = Agriculture AW = Agricultural Wetland CI = Commercial/Industrial EW = Estuarine Wetland FW = Forested Wetland IF = Industrial Forest OS = Open Space PEM = Palustrine Emergent Wetlands PFO = Palustrine Forested Wetlands PSS = Palustrine Scrub-Shrub Wetlands RE = Residential ROW = Right-of-Way UF = Upland Forest Precision loss may occur because of rounding.
Table E4-2: Additional Temporary Workspaces within 50 Feet of Wetlands and Waterbodies 

Milepost County Crossing 

Dimensions

(feet) 

Wetland 

Water ID 

Land Use in 

Additional 

Temporary 

Workspaces 

Distance to 

Wetland 

(feet) Descriptio

0.1 Clatsop Slough/Waterbody 50 x 100 W5BCL020 OS, EM 9.5 Additional Spoil 

Area/Staging Area 

W5BCL058 0 

0.2 Clatsop Point of Intersection 407 x 123 W5BCL021 EW, OS 0 Additional Spoils A

W5BCL052 0 

0.6 Clatsop Slough/Waterbody 175 x 50 W99CL0021 EW 0 Additional Spoil A

Staging Area 

0.6 Clatsop Slough/Waterbody 175 x 100 W99CL0021 EW 0 Additional Spoil A

Staging Area 

0.8 Clatsop Highway 101 Crossing 512 x 50 W99CL0021 EW 0 Additional Spoil A

Staging Area 

0.8 Clatsop Highway 101 Crossing 373 x 117 Additional Spoil A

Staging Area 

W99CL0021 EW 0 

0.8 Clatsop Highway 101 Crossing 50 x 85 W99CL0021 EW, OS 0 Additional Spoil A

Staging Area 

1.1 Clatsop Slough/Waterbody 535 x 180 W99CL0021A EW 0 Additional Spoil A

Staging Area 

1.5 Clatsop Slough/Waterbody 50 x 200 W5BCL015O AW 0 Additional Spoil A

Staging Area 

1.7 Clatsop Airport Road 50 x 175 W5BCL015O AW 0 Bore Pit and Equip1.7 Clatsop Airport Road 50 x 175 W5BCL015O AW 0 Bore Pit and Equip1.7 Clatsop Airport Road 50 x 175 W5BCL015O AW 0 Bore Pit and Equip1.7 Clatsop Airport Road 50 x 175 W5BCL060 AW 0 Bore Pit and Equip2.4 Clatsop Clatsop Airport Road 50 x 200 W38CL083 

W99CL202 

EM, ROW, AG, PSS 

0 Bore Pit and Equip

2.4 Clatsop Clatsop Airport Road 50 x 425 W5BCL066 EM, OS, PSS 0 Bore Pit and Equip

W5BCL067 0 

2.4 Clatsop Clatsop Airport Road 50 x 175 W5BCL066 EM, PSS, 0 Bore Pit and Equip

E4-15
2

Table E4-2: Additional Temporary Workspaces within 50 Feet of Wetlands and Waterbodies 

Milepost County Crossing 

Dimensions

(feet) 

Wetland 

Water ID 

Land Use in 

Additional 

Temporary 

Workspaces 

Distance to 

Wetland 

(feet) Descriptio

W5BCL067 0 

2.8 Clatsop Lewis and Clark River 125 x 300 W40CL001 UF, PSS 0 HDD Equipment P3.4 Clatsop Lewis and Clark River 150 x 300 W40CL010 AW 0 HDD Equipment P

Pullback 

3.7 Clatsop Slough/Waterbody 50 x 500 W99CL077A AW 0 Additional Spoil A

Staging Area 

4.0 Clatsop Slough/Waterbody 50 x 770 W5BCL042F AW 0 Additional Spoil A

Staging Area 

4.1 Clatsop Slough/Waterbody 50 x 400 W5BCL042F AW 0 Additional Spoil A

Staging Area 

4.2 Clatsop Slough/Waterbody 50 x 350 S5BCL063 EM, AW 50 Additional Spoil A

Staging Area 

W42CL001 0 W5BCL042F 0 

4.4 Clatsop Slough/Waterbody 50 x 1100 W42CL001 EM 0 Additional Spoil A

Staging Area 

S5BCL064 0 

4.6 Clatsop Slough/Waterbody 50 x 125 W42CL001 EM 0 Additional Spoil A

Staging Area 

W5BCL042C 48W5BCL043 0 S5BCL066 48

4.6 Clatsop Slough/Waterbody 50 x 175 W5BCL042C AW 0 Additional Spoil A

Staging Area 

4.7 Clatsop Slough/Waterbody 50 x 150 S5BCL065 AW 48 Additional Spoil 

Area/Staging Area 

S5BCL068 50W42CL002 0 W40CL016 0 

4.8 Clatsop Slough/Waterbody 50 x 250 W40CL016 AW 0 Additional Spoil A

Staging Area 

S5BCL068 49W42CL002 0 

E4-16
Table E4-2: Additional Temporary Workspaces within 50 Feet of Wetlands and Waterbodies 

Milepost County Crossing 

Dimensions

(feet) 

Wetland 

Water ID 

Land Use in 

Additional 

Temporary 

Workspaces 

Distance to 

Wetland 

(feet) Descriptio

W5BCL042C 0 

4.9 Clatsop Slough/Waterbody 50 x 325 W39CL004 AW 0 Additional Spoil A

Staging Area 

W40CL016 AW 0 

W5BCL042D AW 0 

5.0 Clatsop Lewis and Clark River 

Bank 

80 x 300 W39CL004 AW 0 HDD Equipment P

W40CL016

5.4 Clatsop Lewis and Clark River 75 x 410 S99CL034 AW, AG 0 HDD Pullback 

W40CL023

5.5 Clatsop Slough/Waterbody 50 x 320 W99CL074 AW 0 Additional Spoil A

Staging Area 

W40CL023 0 

5.5 Clatsop Slough/Waterbody 50 x 225 W40CL023 AW 0 

W99CL074 AW 0 

5.5 Clatsop Lewis and Clark River 

Bank 

50 x 325 & 75 

x 1300 

W40CL023 AW, AG 0 HDD Equipment P

Pullback/ AdditionaArea/ Staging Area 

5.6 Clatsop Lewis and Clark River 80 x 250 W99CL073 AW 0 HDD Equipment P5.6 Clatsop Slough/Waterbody 50 x 200 W99CL073 AW 0 Additional Spoil A

Staging Area 

6.3 Clatsop Point of Intersection 50 x 175 W38CL007B EM 0 Additional Spoil A6.3 Clatsop Point of Intersection 50 x 175 W38CL007B EM, IF, AG 0 Additional Spoil A8.0 Clatsop Wetland 50 x 250 W1BCL003 IF 50 Additional Spoil A

10.9 Clatsop Lewis and Clark River 80 x 300 W99CL004 EM, ROW 0 HDD Equipment P

W99CL007 EM 0 

19.4 Clatsop Wetland/Stream 50 x 110 W7BCL004 EM, IF 0 Additional Spoil A

Staging Area 

19.4 Clatsop Wetland/Stream 50 x 220 W7BCL004 IF, EM 0 Additional Spoil A

Staging Area 

29.0 Clatsop Point of Intersection 50 x 100 S5BCL001 IF 50 Additional Spoil A

E4-17
4

Table E4-2: Additional Temporary Workspaces within 50 Feet of Wetlands and Waterbodies 

Milepost County Crossing 

Dimensions

(feet) 

Wetland 

Water ID 

Land Use in 

Additional 

Temporary 

Workspaces 

Distance to 

Wetland 

(feet) Descriptio

33.9 Clatsop Point of Intersection 50 x 100 W39CL014 AG, AW 0 Additional Spoil A

Staging Area 

W39CL015 46

33.9 Clatsop Point of Intersection 50 x 100 W39CL014 AG, AW 0 Additional Spoil A

Staging Area 

W39CL015 46

34.0 Clatsop Point of Intersection 50 x 100 W39CL014 AW, ROW 46 Additional Spoil A

Staging Area 

W39CL015 0 

34.0 Clatsop Point of Intersection 50 x 100 W39CL014 AW, AG, ROW 46 Additional Spoil A

Staging Area 

W39CL015 0 

36.3 Clatsop Wetland 50 x 150 W3BCL101 PSS, UF 0 Additional Spoil A

W3BCL101 0 

36.4 Clatsop Wetland 50 x 150 S3BCL102 UF, PSS 50 Additional Spoil A

Staging Area 

W3BCL101b 0 W3BCL101 0 

36.9 Clatsop Steep Terrain/ 

Wetland 

50 x 100 W3BCL101b UF, PSS 0 Additional Spoil A

37.6 Clatsop Stream 50 x 100 W8BCL004 EM, IF 0 Additional Spoil A

Staging Area 

40.9 Clatsop Steep Terrain 150 x 175 W8BCL007C IF 20 Additional Spoil A40.9 Clatsop Steep Terrain 150 x 175 W8BCL007A IF, PSS 36 Additional Spoil A

W8BCL007C IF 0 

42.6 Clatsop Wetland/Stream 50 x 100 S1BCL020 IF 50 Additional Spoil A

Staging Area 

W1BCL040 5034 

42.7 Clatsop Wetland/Stream 50 x 100 S1BCL020 IF 50 Additional Spoil A

Staging Area 

W1BCL040 IF 34

48.2 Columbia Point of Intersection 

/Road Crossing 

350 x 50 & 

200 x 50 

W1BCO001 IF 50 Additional Spoil A

Staging Area 

48.3 Columbia Steep Terrain/Wetland 200 x 50 W1BCO003 IF 40 

E4-18
Table E4-2: Additional Temporary Workspaces within 50 Feet of Wetlands and Waterbodies 

Milepost County Crossing 

Dimensions

(feet) 

Wetland 

Water ID 

Land Use in 

Additional 

Temporary 

Workspaces 

Distance to 

Wetland 

(feet) Descriptio

S1BCO000 IF 49 Additional Spoil A

Staging Area 

50.6 Columbia Wetland 100 x 50 W3BCO111 IF 0 Additional Spoil A

Staging Area 

55.4 Columbia Wetland 100 x 50 W3BCO109 IF 34 Additional Spoil A55.7 Columbia Wetland 100 x 50 W3BCO107 EM, IF 0 Additional Spoil A55.8 Columbia Wetland 100 x 50 W3BCO107 IF, EM 0 Additional Spoil A63.6 Columbia Nehalem River 

Crossing 

300 x 80 W3BCO103c EM,IF 0 HDD Entry/Equipm

Pad 

W3BCO103

70.7 Columbia Wetland 100 x 50 S99CO020 IF 36 Additional Spoil A72.9 Columbia Road/Stream crossing 565 x 50 W3BCO007 IF,FW Additional Spoil A

Staging Area 

81.2 Columbia Columbia River 

Crossing 

3575 x 50 W5BCO013 UF, OS 2 HDD Equipment P

Staging Area 

81.4 Columbia Columbia River 

Crossing 

50 x 100 W5BCO013 FW, UF 0 Additional Staging 

81.5 Columbia Columbia River 

Crossing 

50 x 170 W5BCO013 

W99CO030 

FW 0 Additional Staging 

81.6 Columbia Columbia River 

Crossing 

50 x 856 W99CO005 

W99CO030 W99CO031 W99CO032 

EM, FW, OS 0 

0 0 0 

Additional Staging 

81.6 Columbia Columbia River 

Crossing 

50 x 170 W99CO030 

W99CO031 

EM, FW 0 

0 

Additional Staging 

81.7 Columbia Columbia River 

Crossing 

50 x 138 W99CO005 

W99CO030 W99CO031 

EW, FW 0 

0 0 

Additional Staging 

E4-19
6

Table E4-2: Additional Temporary Workspaces within 50 Feet of Wetlands and Waterbodies 

Milepost County Crossing 

Dimensions

(feet) 

Wetland 

Water ID 

Land Use in 

Additional 

Temporary 

Workspaces 

Distance to 

Wetland 

(feet) Descriptio

81.7 Columbia Columbia River 

Crossing 

150 x 50 W99CO006 

W99CO007 W99CO032 

ROW, EM, FW 0 

0 0 

Additional Staging 

81.8 Columbia Columbia River 

Crossing 

80 x 305 W99CO006 ROW, FW 0 Additional Staging 

82.8 Cowlitz Columbia River 

Crossing 

350 x 80 W99CW001 EM 0 Additional Staging 

82.8 Cowlitz Columbia River 

Crossing 

50 x 200 W99CW001 EM 0 Additional Staging 

83.2 Cowlitz Columbia River 

Crossing 

200 x 50 W99CW002 EM 0 Additional Spoil 

Area/Staging Area 

83.4 Cowlitz Columbia River 

Crossing 

200 x 50 W99CW002 EM 0 Additional Spoil 

Area/Staging Area 

85.7 Cowlitz I-5 175 x 50 W99CW022 EM, OS 0 Additional Spoil 

Area/Staging Area 

85.7 Cowlitz I-5 50 x 175 W99CW022 EM, OS 0 Additional Spoil 

Area/Staging Area 

85.9 Cowlitz POI/Road Crossing 175 x 50 W99CW022 EM, RE 0 Additional Spoil 

Area/Staging Area 

85.9 Cowlitz POI/Road Crossing 50 x 143 S99CW022 RE 0 Additional Spoil 

Area/Staging Area 

86.0 Cowlitz POI/Road Crossing 100 x 50 S99CW022 UF 0 Additional Spoil 

Area/Staging Area 

86.4 Cowlitz Point of Intersection 50 x 110 S99CW023 OS 0 Additional Spoil A86.5 Cowlitz Point of Intersection 50 x 112 W99CW011 

S99CW023 

EM, OS 0 Additional Spoil A

Notes: AG = Agriculture ATWS = Additional Temporary Workspaces AW = Agricultural Wetland 

E4-20
Table E4-2: Additional Temporary Workspaces within 50 Feet of Wetlands and Waterbodies 

Milepost County Crossing 

Dimensions

(feet) 

Wetland 

Water ID 

Land Use in 

Additional 

Temporary 

Workspaces 

Distance to 

Wetland 

(feet) Descriptio

EM = Emergent Wetland EW = Estuarine Wetland FW = Forested Wetland IF = Industrial Forest OS = Open Space PSS = Palustrine Scrub-Shrub Wetland RE = Residential ROW = Right-of-Way UF = Upland Forest Precision loss may occur because of rounding. 

E4-21

APPENDIX E5 

MAPS AND TABLE OF ACCESS ROADS

Oregon LNG

Terminal

Access Road

(DVW+DUERU 6WUHHW

Youngs

Bay

Skipanon River

Clatsop

Columbia

Tillamook Washington

Multnomah

Pacific Wahkiakum

Cowlitz

Clark

LEGEND

Terminal Layout

Terminal Access Road

0 500 1,000 250

Feet

Area of Interest

Figure 1

Access Roads for the Project
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

US 101-104

US 101-101

US 101-105

US 101-Warrenton Astoria Hwy

US 101-Warrenton

Astoria

Hwy

US 101-105

US 101-101

US 101-101

Main

Ave

Clatsop Airport Rd

Marlin Dr

Harbor St

Airport Rd

Fort Clatsop

Rd

12th Pl

3

0

2.75

0.25

2.5

3.25

0.5

0.75 1

1.25

1.5

1.75

2

2.25

Figure 2

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

US 101-105

US

101-105 Clatsop Airport Rd

Logan Rd

Lewis Fort C

l

a

t

s

o

p

Rd

6

5

4

3

4.25

6.25

5.25

3.75

5.75

4.75

3.5

5.5

3.25

T

4.5

AR 3.8

TAR 10

.3

TAR 8.0

PAR 4.8

Figure 3 

Access Roads for the Project

LEGEND D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road  ́0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

Fort Clatsop

Rd

Logan

Rd

Lo

gan Rd

Lewis

8 9

7

6.25

7.5

7.25

8.25 8.5

9.5

6.75 9.25

7.75

6.5 8.75

TAR 13.0A

TAR 7.0

TAR 6.5

TA R 7.5

TAR 8.0

TAR 8.0 TAR 8.0 TAR 8.0 TAR 8.0 TAR 8.0

TAR 8.0

TAR 8.0

TAR 8.0

TAR 8.0

TAR 10.3 TAR 10.3

TAR 10.3

TAR 10.3

TAR 10.3 TAR 10.3 TAR 10.3 TAR 10.3 TAR 10.3

TAR 10.3

Figure 4

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

Lewis

13

12

11

10

9

12.25

9.75

13.25

10.75

9.5

11.75

9.25

10.5

12.75

10.25

11.5 11.25

12.5

TAR 12.8

TAR 13.8

TAR 13.0A

TAR 1 3.0

TAR 9.8

TAR 13.8

TAR 13.8

TAR 11.0

T

T

AR 11.0

AR 11.0

TAR 11.0

TAR 11.0

TAR 11.0

TAR 10.3

TAR 10.3 TAR 10.3

TAR 10.3

TAR 10.3

TAR 10.3

TAR 11.5

TAR 11.5

TAR 11.5

TAR 11.5

TAR 11 5.

TAR 11.5

TAR 11.5

TAR 11.5

Figure 5

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

16

15

14 13

13.5

15.5 13.25

14.5

15.25

12.75 14.25

14.75

13.75 15.75

TAR 11.0

TAR 12.8

TAR 14.3

TA R 14.8

TAR 13.0A

TA R 11 .5

TAR 11.5 TAR 11.5

TA R 11.5

TAR 14.5 TAR 14.5

TAR 14.5

TA R 14.5

TAR 1 4.5

TAR 13 0.

TAR 13.0

TAR 13 0.

TAR 13.0

TAR 13.0

TAR 13.0

TAR 13.0

TAR 13.8

TAR 13.8

TAR 13.8

TAR 13.8

TAR 13 8.

TAR 1 3.8

TAR 13.8

TAR 15.3

TAR 15.3

TAR 15.3

TAR 15.3

TAR 15.3

TAR 15.3

TAR 15.3

TAR 13.5

Figure 6

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

Saddle Mountain Rd

18

17

16

16.75

17.75

16.5 18.75

16.25

17.5

17.25

18.5

18.25

15.75

TAR 18.0

TAR 17.3

TAR 1 6.0

TAR 16.0 TAR16.0

TAR 14.5 TAR 14.5

TAR 14.5

TAR 1 4.5

TAR 16.5

TAR 16.5

TAR 16.5

TAR 16.5

TAR 16.5

TAR 15.3

TAR 15.3

TAR 15.3

TAR 15.3 TAR 15.3

TAR 15.3

TAR15.3

TAR 15.3

TAR 15.3 TAR 15.3

Figure 7

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

Saddle Mountain

R d

Saddle Moun ta in Rd

21 20

19

20.25 21.5

21.25 18.75

19.75

20.75 19.5

21.75

19.25

20.5

TAR 18.0

TAR 19.5

TAR 20.3

TAR20.3 TAR 20.3

TAR 20.8

TAR 20.8

TAR 20.8

TAR 20.8

TAR 15.3

T AR 15.3

TAR 15.3 TAR 15.3

TAR 15.3

TAR 15.3 TAR 15.3 TAR 15.3 TAR 15.3 TAR15.3

TAR 15.3

TAR 18.8

TAR 20.8

Figure 8 

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

24

23

22

22.75

21.5

23.75

22.5

24.5

22.25 23.5

24.25

23.25

21.75 TAR 24.3 TAR 23.5

TAR27 8.

TAR 15.3

TAR 24.8A

TA R 24.5

TAR 24.5

TAR 23.0

TAR 23.0 TAR 23.0

TAR 23.0

TAR 21.5

TAR 21.5

TAR 21.5

TAR 21.5

TAR 2 1.5

PAR 23.8

PAR 23.8

PAR 23.8

PAR 23.8

PAR 23 8.

PAR 23.8

TAR 22.3

TAR 22.3

TAR 22.3

TAR 22.3

TAR 22.3

TAR22.3

PAR 15.3

PAR 15.3

PAR 15.3 PAR 15.3

PAR 15 3.

PAR 15.3

PAR 15.3

PAR 21.5

PAR 21.5

PAR 21.5

PAR 21.5

PAR 21.5

PAR 2 1.5

PAR 21.5

PAR 21.5

TAR 22.3

PAR 15.3

Figure 9 

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

27

26

25

27.25

24.75

25.75

25.5

26.75

26.5

27.75

25.25

27.5

26.25

TAR 21.5

TAR 27.8

T A R 26 3.

TAR 27.0

TA R 24.3

TAR 26.0

TAR 26.8

TAR 24.5

TAR 24.5

TAR 21.5

TAR 21.5

TAR 21.5

TAR 21.5

TAR 24.8

TAR 24.8

TAR 24.8

TAR 24 .8 TAR 24.8

TAR 24.8A

TA R 24.8A TAR 24.8A TAR 24.8A

T AR 24.8A

T A R

25.5

TAR 25. 5

TAR 25.5

TAR 25.5

TAR 25 .5

TAR 25.5

TAR 25.5

TAR 27.8

TAR 27.8

TAR 27.8

TAR 27 8.

TAR 27.8

TAR 27.8 TAR 27.8

TAR 27.8

TAR 27.8

TAR 27.8

Figure 10

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest

DVR \\MNUSTRICTGFS01\PROJECTS\LNGDEVELOPMENT_355036\MAPDOCUMENTS\2013_FILING\RESOURCEREPORTS\RR01\ACCESSROADS.MXD LCLARK 3/20/2014 10:32:32 AM
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

31

29 30

28

29.75

29.5

30.75

28.25

30.25 30.5

27.75

28.75

TAR 27.0

TAR 2 8.8A

TAR 27.5

TAR 28.0

TAR 27.8A

TAR 2 7.8A

TAR 30.3

TAR 25.5

TAR 25.5

TAR 28.3

TAR 28.3

TAR 29.3

TAR 29.3

TAR 29.3

TAR 31.3

TAR 31.3 TAR 31.3

TAR

30. 0

TAR 30.0 TAR 30.0

TAR 30.0

TAR 30.0

TA R 27.8

TAR 27.8

TAR 27.8

TAR 27.8

TAR 27.8

TAR 27.8

TAR 27.8

TAR 27.8

TAR 28. 8

TAR 28.8

TAR 28.8 TAR 28.8

TAR 28.8

TAR 28.8

TAR 28.8

TAR 28.8

TAR 28.8

TAR 27.8

Figure 11

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

US 26-Sunset Hwy

Fishhawk

Falls

Lower Nehalem Rd

103

103

34

33

32

31

32.25

30.75 34.25

31.75

33.75

31.5

32.75

33.5

32.5

31.25

33.25

TAR 30.0

TAR 32.5

TAR 32.0

TAR30 .3

TAR 31.5

TAR 31.3

TAR 31.3

TAR 31.3

TAR 31.3

TAR 31.3

AT

R 31.3

TAR 31.3

AT

R28.8

TAR28.8

TAR 31.0

T A R 31.0 TAR 31.0

TAR32.3 TAR 32 . 3

TAR32.3

TAR32.3

TAR 32.3

TAR 32.3

TAR 3 2. 3

TAR 32.3

Figure 12

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

US 26-Sunset Hwy

103

37

36

35

34

36.75

34.25 35.25 35.5

36.25 36.5

37.25

34.75

35.75

34.5

TAR 36.3

TAR 36.8

TAR 36.8

TAR 36.8

TAR 36.8 TAR 36.8

TAR 35.5 TAR 35.5 TAR 35.5 TAR 35.5

TAR 35.5

TAR 35.5

Figure 13

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

US 26-Sunset Hwy

40 39

38

40.25 37.75 38.75

37.5

39.75

37.25

38.5

38.25

39.5

39.25

PAR 38.8

T A R 36.8

TAR 36.8

TAR 39.3 TAR 3 9.3

TAR 39.3

TAR 38.8

TAR 38.8

TAR 38 .8

TAR38.8

Figure 14

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest

DVR \\MNUSTRICTGFS01\PROJECTS\LNGDEVELOPMENT_355036\MAPDOCUMENTS\2013_FILING\RESOURCEREPORTS\RR01\ACCESSROADS.MXD LCLARK 3/20/2014 10:32:32 AM
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

US 26-Sunset Hwy

43

42

41

40

40.25

41.5

42.75

41.25

42.5

42.25

40.75 43.25

41.75

TAR 39.3

40.5 TAR 42.8

TAR 40.8

TAR 41.8

Figure 15

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

US 26-Sunset Hwy

46

45

44

43

44.25 45.25

43.75 43.5

44.75

44.5

45.75

43.25

45.5

TAR 43.5

TAR 45.0

TAR 42.8

Figure 16

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

US

26-Sunset

Hwy

49

48

47

46

46.5

47.75

48.75

46.25 48.5

47.25

48.25

49.25

46.75

47.5

TAR 50.2

TAR

46

.3

TA R

48.6

TAR

48

.

3

TAR

4

8

.

3

TAR 49.2

TAR 49.2

TAR 49.2

TAR 49.2 TAR 49.2 TAR

49

.2

TA

R

49.2

Figure 17

Access Roads for the Project

LEGEND D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road  ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

Timber Rd

52 51

50

51.5

50.25

52.5

51.25

49.75

49.5

50.75

50.5

51.75

49.25

TAR 51.2

TAR 52 7.

TAR 52.7

TAR 50.2

TAR 50 5.

TAR 49.2

TAR 52.2 T AR 52.2

TAR 53.6

TAR 53.6

TAR 53.6

TAR 53.6

TAR 53.6

TAR 53.6

TAR 51.4

T AR 51.4

TAR 51.4

TAR 51. 4

TAR 51.4

TAR 51.4 TAR 51.4

TAR 50.2

TAR 50.2

TA R 50.2

TAR 50.2

TAR 50.2

TAR 50.2

TAR 50.2 TAR 50.2

TAR 50.2

TAR 50.2

TAR 50.2

TAR 50.2

TAR 52.7

Figure 18

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

Ti

TimberRd

mber Rd

55

54

53

52.75

52.5

53.75 53.5

54.5 54.75 55.75

53.25

55.5

54.25

55.25

TAR 56.1

TAR 52.2

TAR 52.7

TAR 56.1

TAR 55.4

TAR 55.4

TAR 57.0

TAR 57.0

TAR 57.6

TAR 57.6

TAR 54.2

TAR 54 .2

TAR 56.6

TAR 56.6 TAR 56.6

TAR 54.9

TAR 54.9

TAR 54.9

TAR 54.9

TAR 55.8

TAR 5 5.8

TAR 55.8

TAR 55.8

TAR 5 5.8

TAR 5 3.6

TAR 53.6

TAR 53.6

TAR 53.6

TAR 53.6

TAR 53.6 TAR 53.6

TAR53.6

TAR 53.6

TAR 53.6

TAR 53.6 TAR 53.6

TAR 52.7

Figure 19

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

Timbe

Rd

r

59

58

57

57.5

58.75

56.25

57.25 58.5

58.25

55.75

56.75

56.5

57.75

TAR 56.1

TAR 57.0

TAR 54.9

TAR 55.4

T AR 58. 2

TAR 55.8

TAR 55 8.

TAR 55.8

TAR 56.1

TAR 56.1 TAR 56.1 TAR 56.1

TAR 56.6

TAR 56.6

TAR 56.6

TAR 56.6 TAR 56.6

TAR 58.7

T AR 58.7

TAR 58.7

TAR 58.7

TAR 5 8.7

TAR 57.6

TAR 57.6

TAR 57.6 TAR 57.6 TAR 57.6

TAR 57.6 TAR 57.6

TAR 57.6

TAR 57.6

Figure 20

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

62 D

61

60 59

59.75

61.75

59.5

60.75

61.5

60.5

59.25

61.25

60.25

TAR 60.5

TAR 59.2 TAR59.2

TAR59.2

TAR 59.2

TAR 59.2

TAR 59.2

TAR 59.2

TAR 59.2

TAR 59.2

TAR

59.2 TAR 59.2

Figure 21

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

TAR 64.7

SR 47-Nehalem Hwy

Scappoose Vernonia Hwy

65

64

63

62

63.25

64.5

64.25

61.75

62.75

62.5 63.75

62.25

63.5

TAR 64.7

TAR 62.7

TAR 64.1

TAR 63.4

TAR 63.4

TAR 59.2

TAR 59.2

TAR 59.2

TAR 59.2

TAR 59.2

PAR 64.5

PAR 64.5

PAR 64.5

PAR 64.5 PAR 64.5

PAR 64.5

Figure 22

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

TAR 64.7

68

67

66

65 66.75

65.5

67.75

65.25

66.5

66.25 67.5

67.25

65.75

TAR 64.7

TAR 68.1

TAR 68 1.

PAR 64.5

PAR 64.5

PAR 64.5

PAR 64.5 PAR 6 4.5

PAR 64.5

PAR 64.5

PAR 64.5 PAR 64.5

PAR 64.5

PAR 64.5

PAR 64.5

TAR 65.4 T AR 65.4

TAR65.4

TAR 65.4 TAR65.4

TAR 65.4

TAR 65.4

TAR 65.4

TAR 65.4

TAR 65.4

TAR 65.4 TAR 65.4

TAR 65.4

T AR 65.4

TA R 65.4

TAR 65.8

TAR 66.9

PAR 64.5

Figure 23

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

71

70 69

68

69.25

70.5

70.25

68.75

69.75

68.5

70.75

68.25

69.5

TAR 69.6

TAR 68.1

PAR 69.1 PAR 69.1

TAR 71.1 TAR 71 1.

TAR 71.1

TAR 70.3

TAR 70.3

TAR 70.3 TAR 70.3

TAR 70.3

TAR 70.3 TAR 70.3

PAR 64.5

PAR64.5

PAR 64.5

PAR64.5

PAR 64.5

PAR 64.5

PAR 64.5

PAR 64.5

PAR 64.5

PAR 64.5

PAR 64.5

PAR 64.5 PAR 64.5

Figure 24

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

74

73

72

71

71.75

72.75

71.5

73.75

71.25

72.5

72.25

73.5

73.25

74.25

TAR 72. 0

TAR 72.9

TA

R

72.9

TAR 72.9

TAR 72.9

TAR 71.1

TAR 71.1

TAR 71

.1

TAR 71.1

TAR 71.1

TAR 71.1

TAR 71.1

TAR

71

.1

TAR

71

.

1

TAR 71.1

TAR 71

.1

TAR 71.1 TAR 71.1

TAR 71.1

TAR 71.1

Figure 25

Access Roads for the Project

LEGEND D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road  ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D D

D

D

D

D

D

D

D D

D

D

77

76

74 75

75.25

76.5

76.25

74.75

75.75

74.5 76.75

74.25

75.5

TAR 72.9

TAR 76.7 TAR 76.7

TAR 76.7

TAR 76.7

TAR 76.7

TAR 75.4

TAR 75.4

TAR 75.4

TA R 75.4

TAR 75.4

TAR 76 3.

TAR 76.3

TAR 76.3

TAR 76.3

TAR 76.3

TAR 76.3

TAR 76.3

TAR 76.3

Figure 26

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

D

US

30-Columbia

River Hwy

80

79

78

77 80.25

78.75

77.5

79.75

77.25

78.5 78.25

79.5

79.25

80.5

TAR 76.7

TAR 76.7

TAR 76.7

TAR 78.2

TAR 78.2 TAR 78.2 TAR 78.2

TAR 78.2

TAR 79.3

TAR 79 3.

TAR 79.3 TAR 79.3 TAR 79.3

TAR 76.3 TAR 76.3

TAR 76.3

TAR 76.3

TAR 76.3

TAR 76.3

TAR 76.3

TAR 76.3

TAR 76.3

TAR 76.3 TAR 76.3

TAR 79.3

Figure 27

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D D

D

D

D

D

D

D D D

D

D

D D D

D

US

30-Columbia

River Hwy

6th St

81

80.25

81.25

80.75

80.5

83

82 82.5 83.5

81.5 81.75

82.75 82.25 TAR 82.9 83.25 TAR 81.0

TAR81.8

TAR81 .8

Figure 28

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest
D

D

D D

D

D

D

D D

D

D

D

D

D

D

SR 503-Goerig St

SR 503-Lewis River Rd

§ ̈¦5

§ ̈¦5

§ ̈¦5

Goerig St

Burke Rd

Pacific Ave

Scott Ave

Guild Rd

Dike Access Rd

Old

Pacific Hwy

86

85

84 83.5

84.5

85.5

86.5

83.75

84.75

84.25

85.75

85.25

86.25

86.75 TAR 86.8

TAR 86.2

Figure 29

Access Roads for the Project

LEGEND

D Pipeline Route Milepost

(Qtr Mile)

Pipeline Route

New Access Road

Existing Access Road

 ́

0 1,000 2,000

Feet

#*

Clatsop

Cowlitz

Columbia

Clark

Tillamook Washington

Area of Interest

E5-1 

Appendix E5 

Access Roads for Oregon LNG Pipeline

Access 

Road ID Milepost Existing/New 

Temporary/ 

Permanent 

Length 

(feet) 

Width 

(feet) Acres Surface Type Existing Land Use 

TAR 3.8 3.9 Existing Temporary 1,170 12.0 0.3 Dirt Private Road PAR 4.8 4.8 Existing Permanent 2,150 30.0 1.48 Gravel Private Road TAR 6.5 6.9 Existing Temporary 2,000 12.0 0.6 Gravel Private Road TAR 7.0 7.6 Existing Temporary 2,000 12.0 0.6 Gravel Private Road TAR 7.5 8.1 Existing Temporary 2,100 12.0 0.6 Unknown Private Road TAR 8.0 8.5 Existing Temporary 16,100 12.0 4.4 Gravel Private Road TAR 9.8 10.2 Existing Temporary 1,650 12.0 0.5 Gravel Private Road TAR 10.3 10.6 Existing Temporary 22,500 18.0 9.3 Gravel Private Road TAR 11.0 11.9 Existing Temporary 9,600 12.0 2.6 Gravel Private Road TAR 11.5 12.0 Existing Temporary 13,300 12.0 3.7 Gravel Private Road TAR 12.8 13.0 Existing/New Temporary 500 12.0 0.1 Gravel Private Road/ 

Industrial Forest 

400

conrigh

TAR 13.0 13.5 Existing Temporary 12,750 12.0 3.5 Gravel Private Road TAR 13.0A * Existing Temporary 16,350 14.0 5.3 Gravel Private Road TAR 13.5 14.0 Existing/New Temporary 700 12.0 0.2 Gravel Private Road/ 

Industrial Forest 

200

conrigh

TAR 13.8 14.3 Existing Temporary 14,600 12.0 4.0 Gravel Private Road TAR 14.3 14.8 Existing Temporary 800 12.0 0.2 Gravel Private Road TAR 14.5 15.8 Existing/New Temporary 9,050 12.0 2.5 Gravel Private Road Ass

(ap

lead

TAR 14.8 15.1 Existing Temporary 1,150 12.0 0.3 Gravel Private Road TAR 15.3 * Existing Temporary 46,510 18.0 19.2 Gravel Private Road PAR 15.3 15.3 Existing Permanent 69,670 18.0 28.8 Gravel Private Road TAR 16.0 16.6 Existing Temporary 4,350 12.0 1.2 Gravel Private Road TAR 16.5 17.0 Existing Temporary 8,550 12.0 2.4 Gravel Private Road TAR 17.3 17.8 Existing Temporary 2,350 12.0 0.6 Gravel Private Road TAR 18.0 18.6 Existing Temporary 300 12.0 0.1 Gravel Private Road TAR 18.8 19.3 Existing Temporary 100 12.0 <0.1 Gravel Private Road TAR 19.5 20.1 Existing Temporary 1,800 12.0 0.5 Gravel and Dirt Private Road TAR 20.3 20.8 Existing Temporary 4,650 12.0 1.3 Gravel Private Road TAR 20.8 21.3 Existing Temporary 7,950 12.0 2.2 Gravel Private Road TAR 21.5 * Existing Temporary 11,720 12.0 3.2 Gravel Private Road 
E5-2 

Appendix E5 

Access Roads for Oregon LNG Pipeline

Access 

Road ID Milepost Existing/New 

Temporary/ 

Permanent 

Length 

(feet) 

Width 

(feet) Acres Surface Type Existing Land Use 

PAR 21.5 21.5 Existing Permanent 25,600 12.0 7.1 Gravel Private Road TAR 22.3 22.8 Existing Temporary 11,900 12.0 3.3 Gravel Private Road TAR 23.0 23.5 Existing Temporary 7,400 12.0 2.0 Gravel Private Road TAR 23.5 24.0 Existing Temporary 800 12.0 0.2 Gravel Private Road PAR 23.8 23.8 Existing Permanent 10,800 12 3.0 Gravel Private Road TAR 24.3 24.7 Existing Temporary 500 12.0 0.1 Gravel Private Road TAR 24.5 24.5 Existing Temporary 4,700 12.0 1.3 Gravel Private Road TAR 24.8 25.4 Existing Temporary 9,150 12.0 2.5 Gravel Private Road TAR 24.8A * Existing Temporary 8,775 12.0 2.4 Gravel Private Road TAR 25.5 26.1 Existing Temporary 14,300 12.0 3.9 Gravel Private Road TAR 26.0 26.5 Existing Temporary 800 12.0 0.2 Dirt and Grass Private Road TAR 26.3 26.7 Existing/New Temporary 1,100 12.0 0.3 Dirt and Grass Private Road/ 

Industrial Forest 

300

conrigh

TAR 26.8 27.2 Existing/New Temporary 1,600 12.0 0.4 Gravel Private Road/ 

Industrial Forest 

1,50

conof-w

TAR 27.0 27.6 Existing/New Temporary 1,300 12.0 0.4 Gravel Private Road/ 

Industrial Forest 

300

conrigh

TAR 27.5 27.9 Existing Temporary 1,550 12.0 0.4 Gravel Private Road TAR 27.8 28.3 Existing Temporary 31,650 16.0 11.6 Gravel Private Road TAR 27.8A * Existing Temporary 3,000 12.0 0.8 Gravel Private Road TAR 28.0 28.7 Existing Temporary 2,100 12.00 0.6 Gravel Private Road TAR 28.3 28.8 Existing Temporary 3,600 16.0 7.8 Gravel Private Road TAR 28.8 29.2 Existing Temporary 21,100 12.0 5.8 Gravel Private Road TAR 28.8A 29.3 Existing Temporary 600 12.0 0.2 Gravel Private Road TAR 29.3 29.7 Existing Temporary 4,900 12.0 1.3 Gravel Private Road TAR 30.0 30.6 Existing Temporary 9,300 12.0 2.6 Gravel Private Road TAR 30.3 31.0 Existing Temporary 3,200 12.0 0.9 Gravel Private Road TAR 31.0 31.5 Existing Temporary 4,900 12.0 1.3 Gravel Private Road TAR 31.3 31.7 Existing Temporary 9,600 12.0 2.6 Gravel Private Road TAR 31.5 31.9 Existing Temporary 1,600 12.0 0.4 Gravel Private Road TAR 32.0 32.4 Existing Temporary 700 12.0 0.2 Gravel Private Road TAR 32.3 32.8 Existing Temporary 14,100 14.0 4.5 Gravel Private Road 
E5-3 

Appendix E5 

Access Roads for Oregon LNG Pipeline

Access 

Road ID Milepost Existing/New 

Temporary/ 

Permanent 

Length 

(feet) 

Width 

(feet) Acres Surface Type Existing Land Use 

TAR 32.5 33.1 Existing/New Temporary 1,150 12.0 0.3 Gravel Private Road/ 

Industrial Forest 

250

conof-w

TAR 35.5 35.2 Existing Temporary 10,250 12.0 2.8 Gravel Private Road TAR 36.3 36.6 Existing Temporary 150 12.0 <0.1 Gravel Private Road TAR 36.8 37.2 Existing Temporary 9,400 12.0 2.6 Gravel Private Road TAR 38.8 39.1 Existing Temporary 6,950 22.0 3.5 Gravel Private Road TAR 39.3 40.0 Existing Temporary 5,100 22.0 2.6 Gravel Private Road TAR 40.8 * Existing Temporary 2,500 22.0 0.3 Gravel Private Road TAR 41.8 42.3 Existing Temporary 2,150 22.0 1.1 Gravel Private Road TAR 42.8 43.1 Existing Temporary 600 22.0 0.3 Gravel Private Road TAR 43.5 44.1 Existing Temporary 250 25.0 0.1 Gravel Private Road TAR 45.0 45.6 Existing/New Temporary 950 15.0 0.3 Gravel Private Road/ Upland 

Forest 

400

conof-w

TAR 46.3 46.7 Existing Temporary 650 20.0 0.3 Gravel Private Road TAR 48.3 48.3 Existing Temporary 2,640 12.0 0.7 Gravel Private Road TAR 48.6 48.7 Existing Temporary 1,056 12.0 0.3 Gravel Private Road TAR 49.2 49.2 Existing Temporary 20,064 14.0 6.4 Gravel Private Road TAR 50.2 50.2 Existing Temporary 22,704 14.0 7.3 Gravel Private Road TAR 50.5 50.5 Existing Temporary 2,640 12.0 0.7 Dirt/Gravel Private Road TAR 51.2 51.2 Existing Temporary 600 12.0 0.2 Gravel Private Road TAR 51.4 51.4 Existing Temporary 11,088 12.0 3.1 Gravel Private Road TAR 52.2 52.3 Existing Temporary 2,640 12.0 0.7 Gravel Private Road TAR 52.7 52.8 Existing/New Temporary 4,224 12.0 1.2 Dirt/Gravel Private Road 3,17

conpipe

TAR 53.6 53.6 Existing Temporary 27,984 16.0 10.3 Gravel Private Road TAR 54.2 54.2 Existing Temporary 4,224 12.0 1.2 Gravel Private Road TAR 54.9 54.9 Existing Temporary 7,392 12.0 2.0 Gravel Private Road ReqTAR 55.4 55.4 Existing Temporary 3,168 12.0 0.9 Gravel Private Road TAR 55.8 55.8 Existing Temporary 9,504 12.0 2.6 Gravel Private Road TAR 56.1 56.1 Existing Temporary 7,920 12.0 2.2 Gravel Private Road TAR 56.6 56.6 Existing Temporary 13,200 14.0 4.2 Gravel Private Road TAR 57.0* N/A Existing Temporary 8,976 12.0 2.5 Gravel Private Road TAR 57.6 57.6 Existing Temporary 16,896 12.0 4.7 Gravel Private Road 
E5-4 

Appendix E5 

Access Roads for Oregon LNG Pipeline

Access 

Road ID Milepost Existing/New 

Temporary/ 

Permanent 

Length 

(feet) 

Width 

(feet) Acres Surface Type Existing Land Use 

TAR 58.2 58.2 Existing Temporary 2,112 12.0 0.6 Gravel Private Road TAR 58.7 58.7 Existing Temporary 8,976 12.0 2.5 Gravel Private Road TAR 59.2 59.2 Existing/New Temporary 24,816 14.0 8.0 Gravel Private Road 500

conpipe

TAR 60.5 60.5 Existing Temporary 440 12.0 0.1 Gravel Private Road TAR 62.7 62.7 Existing Temporary 1,056 12.0 0.3 Gravel Private Road TAR 63.4 63.5 Existing Temporary 3,168 14.0 1.0 Gravel Private Road 11‐fTAR 64.1 64.1 Existing Temporary 2,112 12.0 0.6 Dirt/Gravel Private Road PAR 64.5* N/A Existing Permanent 53,856 16.0 19.8 Gravel Public Road TAR 64.7 64.8 Existing Temporary 440 12.0 0.1 Gravel Private Road TAR 65.4 65.4 Existing Temporary 25,344 12.0 7.0 Gravel Private Road TAR 65.8 65.8 Existing Temporary 400 12.0 0.1 Gravel Private Road TAR 66.9 66.9 Existing Temporary 520 12.0 0.1 Gravel Private Road TAR 68.1 68.1 Existing Temporary 2,640 12.0 0.7 Gravel Private Road PAR 69.1 69.1 Existing Permanent 3,696 12.0 1.0 Gravel Public Road TAR 69.6 69.6 Existing Temporary 1,056 12.0 0.3 Gravel Private Road TAR 70.3 70.4 Existing Temporary 12,144 12.0 3.3 Gravel Private Road TAR 71.1 71.1 Existing Temporary 35,376 12.0 9.7 Gravel Private Road RemTAR 72.0 72.0 Existing Temporary 2,112 12.0 0.6 Gravel Private Road TAR 72.9 72.9 Existing Temporary 2,112 12.0 0.6 Gravel Private Road TAR 75.4 75.4 Existing Temporary 9,504 12.0 2.6 Gravel Private Road TAR 76.3 76.3 Existing Temporary 31,152 12.0 8.6 Gravel Private Road TAR 76.7 76.7 Existing/New Temporary 10,560 12.0 2.9 Gravel Private Road 9.5‐TAR 78.2 78.2 Existing Temporary 8,976 12.0 2.5 Gravel Private Road TAR 79.3 79.3 Existing Temporary 11,616 12.0 3.2 Gravel Private Road TAR 81.0 81.0 Existing/New Temporary 114 12.0 0.03 Gravel Private Road 90‐f

exisrigh

TAR 81.8 81.8 Existing Temporary 4,752 12.0 1.3 Gravel Private Road TAR 82.9 82.9 Existing Temporary 650 12.0 0.2 Dirt/Grass Private Road ImpTAR 86.2 86.2 Existing Temporary 548 12.0 0.2 Gravel/Dirt Private Road TAR 86.8 86.8 Existing Temporary 550 12.0 0.2 Gravel Private Road 

_________

* = Road does not intersect pipeline right-of-way. N/A = not applicable Precision loss may occur because of rounding. 
APPENDIX E6 

SITE-SPECIFIC RESIDENTIAL CONSTRUCTION PLANS

 

ES030613113935PDX 199863.RR.14

Mitigation Steps:

1) Meet with land owner(s) of impacted residence at the project site at least 21 days prior to beginning of construction. 

a) Review construction procedures, locations of permanent and temporary easements, and ATWS. 

b) Identify trees, other vegetation, and objects that land owner(s) desire to have protected during construction. 

To the extent practical, protect these items during construction, or move and replace after construction if possible.

2) At least 7 days prior to construction, survey locations of easements and ATWS and mark locations using wooden laths or other markers. 

3) Conduct a preconstruction survey of the impacted residence. Preconstruction survey shall include photographs and video of vegetation, 

fences, driveways, stone walls, structures, residences, sidewalks, and water systems preconstruction conditions. 

4) Erect orange barrier fencing and erosion control features that include, at a minimum, silt fence inside the boundaries of the ATWS 

and temporary easement nearest the pole barns and house.

5) Conduct construction activities between Stations B586+00 and B596+00 only between the hours of 8 a.m. and 5 p.m. 

6) Upon completion of pipeline installation, reseed disturbed ground, repair access roads, graveled or paved areas, sidewalks, fences, 

stone walls, structures, water supply systems, and septic systems, and conduct other mitigation to reestablish preconstruction conditions. 

5 '

25 '

25 '

50 '

5 '

17 '

25 ' 25 '

4584+00

4583+00 4582+00

TWS

PERM ROW

RESIDENTIAL

STRUCTURE

PIGGING/METER

STATION

UNKNOWN STRUCTURE

(NONRESIDENTIAL)

UNKNOWN STRUCTURE

(NONRESIDENTIAL)

RESIDENTIAL

STRUCTURE

TIE IN AT

NORTHWEST

PIPELINE

INTERCONNECT

100' x 100'

WILLIAMS CUSTODY

TRANSFER METERING

SKID

NO. DATE REVISION BY APVD.

DSGN. DR CHK APVD.

SCALE

VERIFY SCALE

0 1"

BAR IS ONE INCH ON

ORIGINAL DRAWING

IF NOT ONE INCH,

ADJUST SCALE 

ACCORDINGLY PROJ. DATE:

OREGON PIPELINE COMPANY

PIPELINE

WARRENTON TO WOODLAND

DWG: REVISION:

RESIDENTIAL MITIGATION PLAN

Legend

ATWS (ADDITIONAL TEMPORARY WORKSPACE)

TWS (TEMPORARY WORKSPACE)

PERMANENT EASEMENT LINE

ALIGNMENT PI

PROPERTY LINE

 86.6 MP

PS MC EC MARCH 27, 2014 1

Document Path: M:\199863_Oregon_LNG\MapFiles\MXD\Residentials\Residential_Mitigation.mxd

100 50 0 100 Feet

SCALE IN FEET

N

1" = 100'

199863 C-533

APPENDIX F 

OREGON LNG MITIGATION AND MONITORING PLANS

Appendix F1: Stormwater Pollution Prevention Plan for Construction of the Oregon LNG Terminal and 

Pipeline, Including Erosion Prevention and Sediment Control Plan; Spill Prevention, 

Control, and Countermeasures Plan; and Frac-Out Contingency Plan 

Appendix F2: Agricultural Impact Mitigation Plan 

Appendix F3: Conceptual Mitigation Plan for the Oregon LNG Terminal and Oregon Pipeline Project 

Appendix F4: Wetland Mitigation Plan 

Appendix F5: Technical Memorandum: Oregon LNG Pipeline Waterbody Crossing: Fish Salvage Plan 

Appendix F6: Technical Memorandum: Migratory Birds—Regulatory Review and Mitigation 

APPENDIX F1 

STORMWATER POLLUTION PREVENTION PLAN FOR CONSTRUCTION 

OF THE OREGON LNG TERMINAL AND PIPELINE, INCLUDING 

EROSION PREVENTION AND SEDIMENT CONTROL PLAN; SPILL 

PREVENTION, CONTROL, AND COUNTERMEASURES PLAN; AND FRACOUT CONTINGENCY PLAN

R eport

Stormwater Pollution Prevention Plan

for Construction of the Oregon LNG 

Terminal and Pipeline, Including 

Erosion Prevention and Sediment 

Control Plan; Spill Prevention, Control,

and Countermeasures Plan; and 

Frac-Out Contingency Plan

Prepared for

LNG Development Company, LLC (d/b/a Oregon LNG)

and

Oregon Pipeline Company, LLC

May 2013

Prepared by

Contents

Section Page

Acronyms and Abbreviations.............................................................................................................................v

1.0 Stormwater Pollution Prevention Plan and Erosion Prevention and Sediment Control Plan................. 1-1

2.0 Description of Covered Activities....................................................................................................... 2-1

2.1 Scope of Activities............................................................................................................................ 2-1

2.2 Runoff Coefficient of Soils ............................................................................................................... 2-1

2.3 Discharge and Receiving Waters ..................................................................................................... 2-2

2.3.1 Waterbody Crossings.......................................................................................................... 2-2

2.3.2 Wetland Crossings.............................................................................................................. 2-4

2.3.3 Backfill Material Source and Volumes................................................................................ 2-5

2.4 Potential Sources of Contamination from Construction ................................................................. 2-5

2.4.1 Vehicle and Equipment Fueling and Maintenance............................................................. 2-5

2.4.2 Materials Handling/Loading and Unloading Areas............................................................. 2-5

2.4.3 Erosion................................................................................................................................ 2-6

2.4.4 Tracking............................................................................................................................... 2-6

2.4.5 Drilling................................................................................................................................. 2-6

2.4.6 Trenching ............................................................................................................................ 2-6

2.4.7 Grading and Site Preparation ............................................................................................. 2-6

2.4.8 Hazardous Material Storage Areas..................................................................................... 2-6

2.4.9 Storage Yards...................................................................................................................... 2-6

2.4.10 Mobile Equipment.............................................................................................................. 2-6

2.4.11 Painting............................................................................................................................... 2-6

3.0 Best Management Practices .............................................................................................................. 3-1

3.1 Erosion Prevention and Sediment Controls..................................................................................... 3-1

3.2 Shoreline Stabilization ..................................................................................................................... 3-2

3.2.1 Shoreline............................................................................................................................. 3-2

3.2.2 Dunes.................................................................................................................................. 3-3

3.3 Streambank Stabilization................................................................................................................. 3-3

3.3.1 Minimizing Disturbance during the Construction Phase.................................................... 3-3

3.3.2 Streambank Stabilization.................................................................................................... 3-4

3.4 Stabilization ..................................................................................................................................... 3-5

3.5 Stockpile Management.................................................................................................................... 3-6

3.6 Environmental Inspector................................................................................................................. 3-6

4.0 Maintenance and Inspection Procedures ........................................................................................... 4-1

4.1 Areas to Be Inspected...................................................................................................................... 4-1

4.2 Inspection Schedule......................................................................................................................... 4-1

4.3 Disturbed Areas............................................................................................................................... 4-1

4.4 Inspection Content and Activities.................................................................................................... 4-2

5.0 Plan Modification.............................................................................................................................. 5-1

6.0 Required Reports, Documents, and Record Keeping........................................................................... 6-1

7.0 Spill Prevention, Containment, and Countermeasures Plan ................................................................ 7-1

7.1 Planning and Prevention.................................................................................................................. 7-1

7.2 Roles and Responsibilities ............................................................................................................... 7-1

7.3 Project Materials ............................................................................................................................. 7-2

ES030613113935PDX III
CONTENTS, CONTINUED

7.4 Spill Prevention and Mitigation Measures ...................................................................................... 7-2

7.4.1 Container Storage............................................................................................................... 7-3

7.4.2 Secondary Containment..................................................................................................... 7-3

7.4.3 Leak and Integrity Inspections............................................................................................ 7-3

7.4.4 Fuels and Hazardous Materials Handling ........................................................................... 7-4

7.4.5 Materials on Hand .............................................................................................................. 7-4

7.4.6 Restricted Areas.................................................................................................................. 7-4

7.4.7 Restricted Refueling Areas ................................................................................................. 7-5

7.4.8 Other Material-Specific Measures...................................................................................... 7-5

7.5 Spill Preparedness Practices............................................................................................................ 7-5

7.6 Spill Response Procedures............................................................................................................... 7-5

7.6.1 Initial Spill Management..................................................................................................... 7-5

7.6.2 Mobilization of Additional Resources................................................................................. 7-6

7.7 Spill Containment and Cleanup ....................................................................................................... 7-6

7.7.1 Wetlands or Waterbody Response..................................................................................... 7-7

7.8 Material Disposal............................................................................................................................. 7-7

8.0 Horizontal Directional Drilling Frac-out Contingency Plan................................................................... 8-1

8.1 Planning and Prevention.................................................................................................................. 8-1

8.1.1 Frac-out Monitoring ........................................................................................................... 8-2

8.1.2 Frac-Out Response.............................................................................................................. 8-2

8.1.3 Surface Frac-Out Containment and Response ................................................................... 8-2

8.1.4 Frac-Out Notifications ........................................................................................................ 8-3

8.1.5 Borehole Abandonment..................................................................................................... 8-3

9.0 Certifications .................................................................................................................................... 9-1

9.1 Oregon LNG Certification................................................................................................................. 9-1

9.2 Contractor/Subcontractor(s) Certification ...................................................................................... 9-1

Attachments

1 Best Management Practices Information

2 Emergency Response Numbers

Tables

1 Horizontal Directional Drilling Locations...................................................................................................... 2-3

2 Example Techniques for Bank Armor and Protection (after McCullah and Gray, 2005).............................. 3-5

3 Typical Fuels, Lubricants, and Hazardous Materials..................................................................................... 7-2

4 Agency Contact List In the Event of a Frac-Out............................................................................................ 8-3

iv ES030613113935PDX
Acronyms and Abbreviations

BPA Bonneville Power Administration

BMP best management practice

CFR Code of Federal Regulations

EI Environmental Inspector 

EPA United States Environmental Protection Agency

EPSCP Erosion Prevention and Sediment Control Plan

ERC Emergency Response Contractor

FERC Federal Energy Regulatory Commission

FERC Plan FERC Upland Erosion Control, Revegetation, and Maintenance Plan

FERC Procedures FERC Wetland and Waterbody Construction Mitigation Procedures

HDD horizontal directional drilling

hp horsepower

LCC Land Capability Class 

LNG liquefied natural gas

MP milepost

MSDS material safety data sheet

MW megawatt

NPDES National Pollutant Discharge Elimination System

OD outside diameter

ODFW Oregon Department of Fish and Wildlife

ODEQ Oregon Department of Environmental Quality

RQ reportable quantity 

SPCC Spill Prevention, Containment, and Countermeasures 

SWPPP Stormwater Pollution Prevention Plan

Terminal liquefied natural gas bidirectional terminal

TESC temporary and permanent erosion and sediment control

TSS total suspended solids

WEG Wind Erodibility Group 

ES030613113935PDX V

SECTION 1.0

Stormwater Pollution Prevention Plan and Erosion 

Prevention and Sediment Control Plan

In June 2006, the United States Environmental Protection Agency (EPA) published a final rule for 40 Code of 

Federal Regulations (CFR) Part 122 to include Amendments to the National Pollutant Discharge Elimination System 

(NPDES) Regulations for Storm Water Discharge Associated with Oil and Gas Exploration, Production, Processing, 

or Treatment Operations or Transmission Facilities. This rule modified the NPDES regulations to exempt certain 

stormwater discharges from field activities or operations, including construction associated with oil and gas 

exploration, production, processing, or treatment operations or transmission facilities. These discharges are 

exempt from permitting requirements except in situations when the construction-related activities result in the 

discharge of a hazardous substance or oil in “reportable” quantities or in situations when the discharge of a 

pollutant other than sediment contributes to a violation of an applicable water quality standard.

The rule also encouraged the application of best management practices (BMPs) for oil and gas field activities and 

operations to (a) minimize the discharge of pollutants in stormwater runoff and (b) protect water quality both 

during and after construction activities.

Installation of effective BMPs will help protect surface water during storm events, as well as help ensure that 

there is no discharge of a reportable quantity (RQ) or violation of the water quality standard.

This Stormwater Pollution Prevention Plan (SWPPP) has been developed to meet the spirit of the law. This plan 

has three elements, all intended to provide methods and procedures so the construction activities do not 

adversely affect the water quality of the receiving water bodies during construction. The three elements of this 

plan that are discussed in the following sections are as follows:

• Erosion Prevention and Sediment Control Plan (EPSCP)

• Spill Prevention, Containment, and Countermeasures Plan (SPCC Plan)

• Horizontal Directional Drilling Frac-out Contingency Plan

The purpose of this document is to describe the proposed construction activities and all temporary and 

permanent erosion and sediment control (TESC) measures, pollution prevention measures, inspection/monitoring 

activities, spill prevention measures and countermeasures, frac-out procedures, and record keeping that will be 

implemented during the construction Project. Included in this SWPPP are the following:

• Covered activities

• Best management practices to prevent erosion and sedimentation (in the EPSCP), and to identify, reduce, 

eliminate, or prevent stormwater contamination and water pollution from construction activity and to 

receiving water bodies

• Maintenance and inspection procedures

• Plan modification

• Required reports, documents, and record keeping

• Spill Prevention, Containment, and Countermeasures Plan

• Horizontal Directional Drilling Frac-out Contingency Plan

• Certifications

All personnel engaging in construction activities will follow this SWPPP.

ES030613113935PDX 1-1

SECTION 2.0

ES030613113935PDX 2-1 

Description of Covered Activities 

2.1 Scope of Activities 

LNG Development Company, LLC (d/b/a Oregon LNG) proposes to own, construct, and operate a liquefied natural

gas (LNG) bidirectional terminal (Terminal) consisting of marine facilities, LNG storage tanks, LNG vaporization

facilities, natural gas liquefaction facilities, and associated support facilities, to be located in Warrenton, Oregon.

The Terminal will have a base load liquefaction capacity of 9.6 million metric ton per year, which requires

approximately 1.25 billion standard cubic feet per day of pretreated natural gas; and a base load regasification

capacity of 0.5 billion standard cubic feet per day.

Natural gas will be transported to and from the Terminal via an approximately 86.8‐mile‐long, 36‐inch‐outside‐

diameter (OD) bidirectional pipeline (Pipeline) that is being developed by Oregon Pipeline Company, LLC (Oregon

Pipeline; and together with LNG Development Company, LLC, Oregon LNG).1 The Pipeline will interconnect with

the interstate transmission system of Northwest Pipeline GP (Northwest), a subsidiary of the Williams Companies,

at the Northwest Pipeline Interconnect near Woodland, Washington.2 The Pipeline will be routed through Clatsop,

Tillamook, and Columbia counties in Oregon, and Cowlitz County in Washington. An electrically driven gas

compressor station (Compressor Station) will be constructed at milepost (MP) 80.8 of the Pipeline. The Terminal,

Pipeline, and Compressor Station are collectively referred to as the Bidirectional Project or Project.

A complete description of the Project can be found in Resource Report 1—General Project Description.

2.2 Runoff Coefficient of Soils 

During construction of the Project, existing vegetation will be removed and the risk that erosion may affect soils

will increase. Soil erosion is strongly influenced by soil texture, soil structure, percent organic matter, vegetation

or mulch cover, length and percent surface slope, and rainfall or wind intensity. Soils most susceptible to erosion

are those with low cohesion (silts and very fine sand with little organic matter), low permeability, high surface

slope and/or long slope lengths, and soils exposed to water and wind with little vegetation or surface mulch

protection. The primary negative impact of soil erosion is the resulting loss of fertile topsoil and reduced site

productivity.

The risk of soil erosion by water was based upon the Land Capability Class (LCC) and Subclass for each soil. Soils

with an LCC of 3 or higher and a Subclass denoted with an “e” (i.e., soils with severe limitations because of

erosion) were determined to have a high potential for water erosion. Also, any area designated in the soil surveys

as water was considered to have high erosion potential. This includes areas covered by water (oceans, rivers, and

lakes), as well as seasonally wet areas (wetlands, depressions, etc.). Seasonally wet areas often have reduced

vegetation cover and are subject to drainage that increases the risk of erosion.

The risk of soil erosion by wind was based upon Wind Erodibility Groups (WEGs), which are a set of classes given

to soils based on properties of the surface horizon such as texture, organic matter content, and aggregate stability

that are considered particularly susceptible to wind erosion. WEGs of 1 or 2 out of 8 total groups denote the most

severe erosion potential from wind. These values were derived from the SSURGO database.

The LCCs and Subclasses, WEGs, and identification of highly erodible soils are provided in Appendices 7C and 7D

of Resource Report 7—Soils for the Pipeline route.

                                                            

1 The Terminal and Pipeline are proposed at the site, and along the route, of Oregon LNG’s proposed LNG import terminal and 

proposed pipeline that currently are pending before the Federal Energy Regulatory Commission in Docket Numbers CP09-6-

000 and CP09-7-000, as amended in Docket Number PF12-18-000. 

2 A separate application will be filed by Northwest for the Washington Expansion Project, a capacity expansion to Northwest’s 

existing natural gas transmission facilities along the Interstate 5 corridor in the state of Washington. 
2.0 DESCRIPTION OF COVERED ACTIVITIES

The proposed construction work areas will be protected against erosion and restored in accordance with the 

Federal Energy Regulatory Commission (FERC) Wetland and Waterbody Construction Mitigation Procedures (FERC 

Procedures) and the FERC Upland Erosion Control, Revegetation, and Maintenance Plan (FERC Plan). Temporary 

erosion controls specified in the FERC Plan include temporary slope breakers, sediment barriers, and mulching. To 

further minimize wind erosion, dust control measures will be used under conditions of high wind erosion 

potential, including routine wetting of the construction workspace where soils are exposed. Permanent erosion 

control measures will include (as specified in the FERC Plan) trench breakers, permanent slope breakers, and 

revegetation. Disturbed areas will be seeded using appropriate seeding dates as well as hardy, well-adapted 

species.

2.3 Discharge and Receiving Waters

2.3.1 Waterbody Crossings

The Pipeline, a 36-inch-OD pipe, will be constructed from the Terminal (MP 0.0) to an interconnect with the 

Northwest Pipeline system near Woodland, Washington (MP 86.8). The Pipeline will be configured for a potential 

interconnection with the 24-inch Northwest Natural Gas Company and South Mist Pipeline Extension at 

approximately MP 63.5 in Columbia County, Oregon.

A block valve, bidirectional metering, and pig launching facility will be located immediately adjacent to the

Woodland interconnect location. The pressure of the gas will be boosted at the Compressor Station located 

approximately 6 miles from the interconnect near the west bank of the Columbia River in Oregon. A pig receiving 

and launching station will be located at the Compressor Station. A bidirectional metering and pig receiving/

launching facility will be located at the Terminal. The 48,000-horsepower (hp) Compressor Station will need 

approximately 40 megawatts (MW) of electric power to compress the natural gas at peak flow. The proposed 

source of the power is the 115-kilovolt (kV) Bonneville Power Administration (BPA) power line that runs north to 

south approximately 1⁄2 mile west of the Compressor Station.

No waterbodies will be crossed at the Terminal site, excluding intertidal areas of the Lower Columbia River 

Estuary. The Oregon LNG Pipeline will cross all waterbodies in accordance with the Procedures (Appendix 2B of 

Resource Report 2—Water Use and Quality). In general, Oregon LNG will construct waterbody crossings so that 

they are as perpendicular to the axis of the waterbody channel as engineering and routing conditions allow, 

reduce the amount of clearing on stream banks to that which is necessary, maintain ambient downstream flow 

rates, and limit the amount of equipment and activities in water bodies to that which is necessary to construct the 

crossing.

Intermittent and ephemeral streams that are dry at the time of crossing will be crossed using conventional upland 

construction techniques. The installation of the Pipeline and bedding material will be designed to withstand 

future flooding of these ephemeral streams. Other water bodies will be crossed using the most practical 

techniques identified based on the condition of the waterbody at the time of construction and in compliance with 

the regulatory permits and approvals and the FERC Procedures. Construction activities will be scheduled so that 

the Pipeline trench is excavated immediately prior to pipe-laying activities. In accordance with the FERC 

Procedures, the duration of construction will be limited to 24 hours across minor waterbodies (10 feet wide or 

less) and 48 hours across intermediate water bodies (between 10 and 100 feet wide). Excavated spoils will be 

stockpiled at least 50 feet from the edge of the waterbody, and appropriate erosion control devices will be

installed (as discussed in Section 3.5). Site-specific HDD and waterbody crossing plans based on available information 

(for waterbodies greater than 100 feet wide) are included in Resource Report 1—General Project Description.

Depending on site conditions at the time of construction and within allowable conditions of all required state and 

federal permits, Oregon LNG may modify its crossing techniques. These crossing methods—and all other 

specialized construction methods to be used in wetland and stream crossings—are described in the Procedures 

(Appendix 2B of Resource Report 2).

Many of the streams in the Project area that will be crossed by the Pipeline are cold-water fisheries and require 

dry-crossing methods, unless approved otherwise by the Oregon Department of Fish and Wildlife (ODFW). In2-2 ES030613113935PDX
2.0 DESCRIPTION OF COVERED ACTIVITIES

water construction will be limited to ODFW-recommended work timing windows, unless otherwise authorized by 

ODFW (see construction schedule in Resource Report 1). Surface-water crossing methods for each stream were 

determined based on field surveys, review of fisheries data, and review of stream data. The general crossing 

methods are outlined below, and the selected crossing method for each stream is shown in Appendix 2Q of

Resource Report 2. Those waterbodies where HDD will be used are shown in Table 1.

2.3.1.1 Crossing Method 1 (Dry Crossing—0 to 30 Feet)

This method is applicable to perennial (with flow) or intermittent and ephemeral streams between 0 and 30 feet 

in width that are cold-water fisheries and to perennial streams that may not be fish-bearing but are tributary to 

fish-bearing streams. Streamflow may be channeled into one or multiple flume pipes to convey water across the 

trench and maintain downstream flow. The trench will be excavated from under the flume pipe, the Pipeline will 

be threaded under the flume, the trench will be backfilled, and the flume pipe will be removed to restore natural 

downstream flow. If no fish are present in the stream, the crossing method may be modified with a dam and 

pump arrangement to convey stream water around the construction area. If the stream is dry at the time of 

construction, then method 3, below, will be the crossing method.

2.3.1.2 Crossing Method 2 (Horizontal Directional Drilling—HDD)

The HDD method is applicable to those waterbodies designated to be directionally drilled and shown in Table 1.

Oregon LNG has developed an HDD Frac-Out Contingency Plan, included in Chapter 8 of this document, along with 

HDD site-specific drawings, provided separately in this filing. The location and depth of the Pipeline for this 

crossing method will be deep enough so that the Pipeline is not affected by the natural fill and scour process of 

the rivers during peak flow events.

TABLE 1

Horizontal Directional Drilling Locations

Drilling Location

Milepost

Begin End Length (feet)

Pipeline

Highway 101 and Adair Slough @ MP 1 0.9 1.1 1,210

Lewis and Clark River @ MP 3 2.8 3.4 2,950

Lewis and Clark River @ MP 5.0 5.0 5.5 2,450

Lewis and Clark River @ MP 5.5 5.6 6.0 2,100

Lewis and Clark River @ MP 11 10.9 11.2 1,320

Nehalem River @ MP 33.5 33.3 33.7 2,010

Highway 26 @ MP 41 40.9 41.3 1,910

Highway 26 @ MP 43.5 43.1 43.6 2,920

Rock Creek @ MP 57.5 57.5 58.1 3,000

Nehalem River @ MP 64 63.6 64.3 3,370

Columbia River @ MP 82.5 81.8 83.0 6,100

Water Supply Pipeline

Skipanon River NA NA 2,200

2.3.1.3 Crossing Method 3 (Wet Crossing)

This method is applicable to intermittent and ephemeral streams that are not fish-bearing, as well as to fishbearing intermittent or ephemeral streams if dry at the time of construction. Perennial streams that are minor, 

non-fish-bearing, and not directly tributary to a fish-bearing stream may also use this crossing method. This 

ES030613113935PDX 2-3
2.0 DESCRIPTION OF COVERED ACTIVITIES

method is the open-cut method allowable for the crossing of minor or intermediate water bodies. The restrictions 

on instream work time (24 to 48 hours), restoration of preconstruction contours, limitations on equipment 

operating in the waterbody, or required bridging identified in the Procedures (Appendix 2B of Resource Report 2) 

will be followed.

The FERC Procedures specify the following practices for open-cut crossings:

• Limit the use of the equipment operating in the waterbody to only the needed equipment.

• Complete trenching and backfilling within 24 continuous hours for minor water bodies and 48 hours for 

intermediate water bodies.

• Return the waterbody to its preconstruction contours.

• Stabilize channel banks and install temporary sediment barriers within 24 hours after completing the crossing.

• Revegetate disturbed riparian areas.

To implement the above practices, the Pipeline will cross streams and wetlands. Appendix 2Q of Resource 

Report 2 describes each stream crossing, including the length of the crossing and the method used for installing 

the Pipeline.

2.3.2 Wetland Crossings

Efforts will be made before, during, and after Terminal and Pipeline construction to minimize the extent and 

duration of Project-related disturbance to wetland resources. A detailed discussion of construction and mitigation 

measures within wetlands and waterbodies is provided in the FERC Procedures, and in the Wetland Mitigation 

Plan prepared for this Project (Appendix 2P of Resource Report 2). Four general construction procedures are 

typically used to minimize impacts associated with construction of the Terminal and Pipeline on water resources,

as described below.

2.3.2.1 Crossing Method 1

This method will be used in dry wetlands where soils are stable enough to support equipment without sinking 

(e.g., mineral hydric soils), or in wetlands that have already been disturbed to provide sufficient traffic access. A 

reduced construction easement of 75 feet will be adhered to and upland construction techniques will be used, 

unless alternative measures are required by site conditions, are approved by FERC, and would achieve a 

comparable level of mitigation. Topsoil will be segregated, and no matting will be used if conditions are dry.

Excessive rutting will be avoided.

2.3.2.2 Crossing Method 2

This method will be used in wetlands where the soils are too wet (e.g., permanently or semi-permanently 

saturated and/or histic epipedon) to support mainline construction equipment. Timber mats will be used as 

necessary to support the construction equipment. A reduced construction easement of 75 feet will be adhered to 

and upland construction techniques will be used, unless alternative measures are approved. Topsoil will not be 

segregated.

2.3.2.3 Crossing Method 3

This method will be used in wetlands with standing water (permanently or semi-permanently flooded) where it is 

necessary to use push/pull construction techniques. A construction corridor wide enough for only a single tractor 

to work on timber mats will be used. The trench will be dug and the pipe will be pulled into place. There will be no 

passing or working lanes, only room for spoil on each side of the trench with the digging/pulling tractor in the 

middle. A reduced construction easement of 75 feet will be maintained and upland construction techniques will 

be used, unless alternative measures are approved.

2-4 ES030613113935PDX
2.0 DESCRIPTION OF COVERED ACTIVITIES

2.3.2.4 Crossing Method 4

Horizontal directional drilling methods will be used for specialized crossings of large wetland areas. In general, 

because an open-cut trench is not required, directional drilling results in fewer adverse impacts and less turbidity 

than conventional excavation methods. Directional drilling is limited in application and dependent on critical 

wetland characteristics, including subsurface lithology, crossing length, burial depth, sediment composition, bank 

conditions, and access. Adverse environmental impacts that may result from drilling operations on waterway 

crossings would be related to discharge and transportation of drilling fluid; however, aside from turbidity effects, 

drilling fluid is a relatively environmentally benign substance. Mitigation of any adverse impact from drilling fluid 

would be by collection and cleanup of spilled material.

Oregon LNG intends to restore and, where necessary, compensate for disturbance to wetlands associated with 

construction and operation of the Project, as described in the Procedures (Appendix 2B to Resource Report 2). 

Along the Pipeline easement, forested wetlands that will become part of the permanent easement will be 

rehabilitated to and maintained in an herbaceous, scrub-shrub, and small tree state. Forested wetlands and scrubshrub wetlands cleared for temporary workspace (i.e., construction easement) will be disturbed only temporarily 

and allowed to revert to their preconstruction condition. Scrub-shrub wetlands, herbaceous wetlands, and in 

some locations, forested wetlands will be allowed to revert to their preconstruction condition on the permanent 

easement. In both former scrub-shrub and forested wetlands, however, a corridor centered on the Pipeline and 

up to 10 feet wide will be maintained with herbaceous wetland species. Trees that establish within 15 feet of the 

Pipeline and grow greater than 15 feet in height may be cut and removed from the permanent easement 

following revegetation.

2.3.3 Backfill Material Source and Volumes

The source of backfill material will be the material removed from the trench for emplacement of the pipe. This 

same material, less the volume occupied by the 36-inch pipe or 24-inch pipe, will be returned to the trench.

2.4 Potential Sources of Contamination from Construction

The potential sources of pollutants that could be discharged in the receiving water bodies through contact with 

stormwater during construction activities include the following:

• Vehicle and equipment fueling and maintenance areas

• Materials handling/loading and unloading areas

• Erosion (wind, water, ice)

• Tracking from equipment

• Grading and site preparation

• Drilling

• Trenching

• Hazardous material storage areas

• Storage yards

• Mobile equipment

• Painting

2.4.1 Vehicle and Equipment Fueling and Maintenance

Fueling and minor maintenance of vehicles and equipment are conducted on some construction sites. These 

activities can be potential sources of leaks and incidental spills of fuel (during fueling), oil, and grease.

2.4.2 Materials Handling/Loading and Unloading Areas

Materials handling/loading and unloading activities are common on construction sites. Materials may be spilled, 

leaked, or lost during loading and unloading, and may collect in the soil or other surfaces and be carried away in 

stormwater. Machines used to unload materials also may be a source of stormwater pollution.

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2.0 DESCRIPTION OF COVERED ACTIVITIES

2.4.3 Erosion

Erosion is caused where soil is exposed to water, wind, or ice. Erosion can be caused by removing vegetation, 

compacting or disturbing the soil, changing natural drainage patterns, and covering the ground with impermeable 

surfaces (buildings, pavement, or concrete), all of which are integral parts of construction projects. Erosion is a 

source of sediment in stormwater.

2.4.4 Tracking

Construction equipment and construction vehicles have the potential to track soils from the construction Project 

into public roadways. Any soils tracked may be a possible source of sediment in stormwater.

2.4.5 Drilling

Horizontal drilling will be used at various locations throughout the Project. Mud rotary techniques will be used to 

transport the cuttings to bins. The rotary mud could become a potential source of sediment-laden water if not 

managed appropriately.

2.4.6 Trenching

During the installation of Pipeline sections, open trenching will be used in various locations throughout the 

Project. During this type of installation, the stockpiled material will be exposed, and it could be a source of 

sediment if not managed appropriately.

2.4.7 Grading and Site Preparation

Grading and site preparation may be required at some locations and can be major contributors of suspended 

solids concentrations in stormwater. The increased possibility of erosion exists throughout the grading and site 

preparation phases of construction projects until construction is complete.

2.4.8 Hazardous Material Storage Areas

Hazardous material storage areas have the potential to release hazardous substances that may pose a threat to 

human health or the environment. Hazardous materials may be toxic, corrosive, ignitable, explosive, or chemically 

reactive. There is a potential for hazardous materials to be stored on construction sites. Outdoor storage areas 

include drums, sheds, clamshells, and yellow flammable cabinets.

2.4.9 Storage Yards

Storage yards may contain equipment, construction materials, and construction debris that, when exposed to 

runoff, may pollute stormwater. A wide range of contaminants (metals, oil, and grease) may enter the 

environment by washing off or dissolving from stored material.

2.4.10 Mobile Equipment

Portable tanks and other mobile equipment are used extensively on construction sites. This equipment may 

generate fuel or oil leaks or spills. Portable tanks and bins will be used to store wastes generated during this 

Project.

2.4.11 Painting

During painting and paint removal activities, materials may be used (and wastes created) that are harmful to 

humans and the environment. Pollutants may include solvents, solids, and metals.

2-6 ES030613113935PDX
SECTION 3.0

Best Management Practices

Erosion Prevention and Sediment Control Plan BMPs are controls (both structural and nonstructural) used to 

prevent erosion and control sedimentation, which could lead to stormwater leaving the construction site and

degrading the water quality of receiving water bodies. Fundamental BMPs shall be those stated in the FERC 

Procedures and the FERC Plan.

As part of the NPDES permit program, a 1200-C stormwater construction permit will be obtained from the Oregon 

Department of Environmental Quality (ODEQ). The 1200-C permit requires the preparation and implementation of 

an EPSCP. The EPSCP will describe in detail the BMPs that will be selected and implemented prior to, during, and 

after construction. The BMPs described in this SWPPP will be included in the EPSCP. The following guidelines will 

be used in the selection, design, and implementation of BMPs:

• The construction-phase erosion and sediment controls will be designed to prevent and minimize erosion and 

retain sediment onsite to the extent practical, and to ensure that no significant changes occur in the volume 

or characteristics of stormwater runoff to receiving waters.

• All erosion and sediment control measures will be properly selected, installed, and maintained in accordance 

with the manufacturer’s specifications and good engineering practices.

• If sediment-laden stormwater is conveyed beyond the construction site, controls will be used to minimize 

offsite impact, and additional BMPs will be implemented to prevent further migration offsite.

• Litter, construction debris, temporary stockpiles, exposed soil, and construction chemicals exposed to 

stormwater will be prevented from becoming pollutant sources for stormwater discharges.

3.1 Erosion Prevention and Sediment Controls

Erosion prevention and sediment controls that will be implemented include the following:

• Runoff Controls

− Diversion of run-on

− Minimizing total suspended solids (TSS) during instream construction

− Instream diversion techniques

− Instream isolation techniques

• Erosion Prevention

− Scheduling

− Preserving of existing vegetation

− Topsoiling

− Temporary and permanent seeding and planting

− Mulching

• Sediment Control

− Sediment fence

− Compost berms and socks

− Fiber rolls or wattles

− Temporary sediment basin

− Entrance/exit tracking controls

− Entrance/exit tire wash

− Minimizing TSS during instream construction

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3.0 BEST MANAGEMENT PRACTICES

− Instream diversion techniques

− Instream isolation techniques

• Nonstormwater Pollution Control

− Dewatering and ponded water management

− Vehicle and equipment cleaning

− Vehicle and equipment fueling, maintenance, and storage

− Material delivery and storage controls

− Material use

− Stockpile management

− Spill prevention and control procedures

− Solid waste management

− Hazardous materials and waste management

− Sanitary waste management

− Liquid waste management

− Training and signage

The BMPs identified in this SWPPP represent the minimum requirements that will be documented in the EPSCP 

and implemented during construction. As construction progresses, additional BMPs will be implemented as 

needed to remain in compliance with the 1200-C construction general stormwater permit.

All BMPs will be installed per manufacturer’s recommendations and good engineering practices. All BMPs will be 

maintained in effective operating condition. Routine inspections, as discussed in Section 4, will be performed to 

confirm that the erosion and sediment control BMPs are effective, to identify problems with existing BMPs, and to 

identify the need for changes in BMPs. Maintenance activities will be performed as needed.

Properly operating BMPs will be maintained to ensure continued effectiveness. When BMPs are not operating 

properly, maintenance will be performed within 24 hours (if practical) or at least before the next storm event, as 

necessary to maintain the continued effectiveness of stormwater controls. If maintenance prior to the next 

anticipated storm event is impractical, maintenance will be accomplished as soon as practical. If implementation 

before the next storm event is impractical, the situation will be documented in the inspection report and 

alternative BMPs will be implemented as soon as practical. BMPs that may be used for this Project are included in 

Attachment 1. The pages in Attachment 1 were taken from Appendix D of the Oregon Department of 

Environmental Quality Erosion and Sediment Control Manual (ODEQ, 2005).

3.2 Shoreline Stabilization

3.2.1 Shoreline

Concern has been expressed about potential impacts on aquatic habitats through alterations of nearshore 

environments at the Terminal. Based on anticipated activities during Terminal construction and operation, no 

special shoreline stabilization measures are proposed. No hard armoring of the shoreline is planned. Berm 

construction and maintenance will occur above the high tide elevation, and site rehabilitation measures for 

temporary impacts generally will occur away from the shoreline environment.

Ships traveling through the Columbia River Estuary produce waves and an uprush. Wave characteristics on 

beaches with slopes less than 5 percent exhibit total wave excursion across the beach face, from maximum 

drawdown to maximum run-up, ranging from 11.8 to 256 feet.1 Drawdown refers to the condition in which the 

water moves down the beach slope away from the still water line. Run-up or surge refers the condition in which, 

1 Pearson, W.H., J.R. Skalski, K.L. Sobocinski, M.C. Miller, G.E. Johnson, G.D. Williams, J.A. Southard, and R.A. Buchanan. 

2006. A Study of Stranding of Juvenile Salmon by Ship Wakes along the Lower Columbia River using a Before and After 

Design: Before-Phase Results. PNNL-15400, Prepared for the U.S. Army Corps of Engineers, Portland District, by Pacific 

Northwest National Laboratory, Marine Sciences Laboratory, Sequim, Washington.

3-2 ES030613113935PDX

 
3.0 BEST MANAGEMENT PRACTICES

after drawdown, the water returns up the beach slope, moving past the initial still water line and continuing up 

the beach slope. Run-up and drawdown distances tend to be slightly different, with a mean run-up of 30.5 feet

and drawdown of 41.3 feet. The maximum vertical extent (drawdown height to run-up height) of ship waves 

ranged from about 0.3 to over 2.3 feet, with a mean of 0.8 feet. However, susceptibility of shorelines in the lower 

10 miles of the Columbia River to high run-up and drawdown distances is minimal (W.H. Pearson, W.C. Fleece, 

K. Gabel, S. Jenniges, and J.R. Skalski. 2008. Spatial Analysis of Beach Susceptibility for Stranding of Juvenile 

Salmonids by Ship Wakes, Final Report. ENTRIX, Inc., Olympia, WA).

During Terminal operation, LNG vessels will produce negligible shoreline impact because they will move relatively 

slowly under limited maneuvering power with tug assist. Tugs will be high powered, and have potential to cause 

shoreline erosion when pointing their screws at the shore. However, the Terminal dock is almost 3,000 feet from 

dry land, so the probability of increased shoreline erosion caused by tugs is low. Tidal mudflats are closer to the 

dock and more exposed; however, the probability of increased erosion at mudflats is low outside the dredge area, 

especially if side slopes are 5:1 (horizontal:vertical), as planned.

Ambient significant wind-wave heights at the dock range from 0.61 to 3.64 feet for a 1-year return interval storm 

event, and from 1.61 to 5.68 feet for a 100-year return interval storm event, depending on wind direction.2 Shipwave energy should not exceed ambient wind-wave conditions.

If shoreline erosion monitoring during Terminal operations determines that potentially damaging erosion is 

occurring and that stabilization measures would reduce erosion potential, appropriate measures would be 

implemented pursuant to federal and state removal/fill approvals. Emphasis would be placed on soft armoring 

techniques, such as vegetation and brush layering.

3.2.2 Dunes

Temporary impacts to soil surfaces at the Terminal site will be rehabilitated using methods described in the 

previous section, and wetland rehabilitation techniques described in Resource Report 2. Much of the existing 

ground surface at the Terminal site is exposed and unvegetated, resulting from droughty, excessively drained 

dune sands and infertile conditions of dredge spoil. A significant proportion of the Terminal site soil has poor 

revegetation potential and high erosion potential. Although stability improvement of exposed surface soils that 

are temporarily disturbed to conditions equal to or better than preconstruction conditions may be impractical, 

the following site-specific, supplemental EPSCP BMPs should be considered:

• Crimping of straw mulch and reapplication of mulch, if necessary prior to vegetation establishment to ensure 

appropriate erosion control

• For plantings/seedings outside of the winter wet period (November-March), provide temporary or permanent

irrigation to ensure rapid establishment

3.3 Streambank Stabilization

3.3.1 Minimizing Disturbance during the Construction Phase

The following EPSCP BMPs shall be used at stream crossings:

• Limit clearing of vegetation to the temporary and permanent easements.

• Locate all extra work areas (such as staging areas and additional spoil storage areas) at least 50 feet away 

from water’s edge, if possible. Limit the size of extra work areas to the minimum needed to construct the 

waterbody crossing.

• Limit use of equipment operating in the waterbody to that needed to construct the crossing.

2 Coast & Harbor Engineering. 2007. Technical Report—Draft Oregon LNG Facility Coastal & Hydraulic Modeling Study. Coast 

& Harbor Engineering, Edmonds, WA.

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3.0 BEST MANAGEMENT PRACTICES

• All spoil from minor and intermediate waterbody crossings, and upland spoil from major waterbody crossings, 

must be placed at least 10 feet from the water’s edge or in additional extra work areas.

• Use sediment barriers to prevent the flow of spoil or heavily silt-laden water into any waterbody. Install 

sediment barriers immediately after initial disturbance of the waterbody or adjacent upland. Sediment 

barriers must be properly maintained throughout construction and reinstalled as necessary (such as after

backfilling of the trench) until replaced by permanent erosion controls or until restoration of adjacent upland 

areas is complete.

• Install sediment barriers across the entire construction easement at all waterbody crossings, where necessary 

to prevent the flow of sediments into the waterbody. In the travel lane, these may consist of removable 

sediment barriers or driveable berms. Removable sediment barriers can be removed during the construction 

day, but must be re-installed after construction has stopped for the day or when heavy precipitation is 

imminent.

• Where waterbodies are adjacent to the construction easement, install sediment barriers along the edge of the 

construction easement as necessary to contain spoil and sediment within the construction easement.

• Use trench plugs at all waterbody crossings, as necessary, to prevent diversion of water into upland portions 

of the Pipeline trench and to keep any accumulated trench water out of the waterbody.

• At dam and pump and flume crossings, prevent streambed scour at pump discharge.

3.3.2 Streambank Stabilization

The following Streambank Stabilization BMPs shall be used after construction at all stream crossings, whether 

perennial or not flowing at the time of construction:

• Use clean gravel or native cobbles for the upper 1 foot of trench backfill in all waterbodies that contain 

coldwater fisheries.

• For open-cut crossings, stabilize waterbody banks and install temporary sediment barriers within 24 hours of 

completing instream construction activities. For dry-ditch crossings, complete streambed and bank 

stabilization before returning flow to the waterbody channel.

• Return all waterbody banks to preconstruction contours or to a stable angle of repose, as approved by the 

Environmental Inspector.

• Employ primarily bioengineering techniques for bank armoring and protection. Apply site-specific BMPs, such 

as those described by McCullah and Gray.3 Examples of streambank stabilization techniques that can be 

adapted to site conditions are provided in Table 2.

• Riprap shall not be used for bank stabilization unless a geotechnical or environmental engineer determines 

that alternative soft armoring methods will be inadequate. If riprap is used, it shall be limited to the minimum 

required stream length.

• Revegetate disturbed riparian areas with conservation grasses and legumes or native plant species, preferably 

woody species.

• Install a permanent slope breaker across the construction easement at the base of slopes greater than 

5 percent that are less than 50 feet from the waterbody, or as needed to prevent sediment transport into the 

waterbody.

• At dam and pump and flume crossings, repair unavoidable streambed scour at pump discharges with clean 

gravel.

• Remove all non-native materials from the crossing after construction and stabilization are complete.

3 McCullah, John and Donald Gray. 2005. Environmentally Sensitive Channel- and Bank-Protection Measures. National 

Cooperative Highway Research Program, Transportation Research Board, Washington, DC. NCHRP Report 544.

3-4 ES030613113935PDX

 
3.0 BEST MANAGEMENT PRACTICES

TABLE 2

Example Techniques for Bank Armor and Protection (after McCullah and Gray, 2005)

Vegetation Alone Vegetation is established on bare soils to 

help prevent surficial erosion, minimize 

shallow seated mass movement, provide 

habitat, and enhance aesthetics or visual 

appearance. 

Live Staking Used for revegetation, soil reinforcement, 

and anchoring erosion control materials. 

Willow cuttings are typically 1.5 – 3.3 ft 

long. The portion of the stem in the soil 

will grow roots and the exposed portion 

will develop into a bushy riparian plant.

Turf Reinforcement 

Mats

Long lasting, designed to resist shear and 

tractive forces, and specified for banks 

subjected to flowing water. Mats are UV 

fibers in a three-dimensional matrix. TRMs 

work with plant roots and shoots to be 

mutually reinforcing.

Erosion Control 

Blankets 

Temporary rolled erosion control products 

consisting of flexible nets or mats, 

manufactured from both natural and 

synthetic materials, usually straw, wood, 

excelsior, or coconut. Various grades of 

biodegradable fibers and netting available.

Rootwad 

Revetments 

Interlocking tree materials, continuous and 

resistive. Primarily intended to resist 

erosive flows, usually on the outer bank of 

a meander bend when habitat diversity is 

desirable and woody materials are 

available.

Live Gully Fill 

Repair

Alternating layers of live branch cuttings 

and compacted soil. This reinforced fill can 

be used to stabilize trench backfill. 

Suitable for filling and repairing elongated

voids in a slope.

3.4 Stabilization

Appropriate BMPs will be implemented and maintained at the construction site from the initiation of construction 

through final stabilization. “Final stabilization” refers to the time when all soil-disturbing activities at the site have 

been completed and one of the following criteria has been met:

• The area has been compacted, surfaced, or built upon for final use.

• Permanent planting and seeding have been established.

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3.0 BEST MANAGEMENT PRACTICES

• Equivalent permanent stabilization measures (such as the use of riprap, gabions, or geotextiles) have been 

used.

• In land used for agricultural purposes (such as crop or range land), the disturbed land is returned to its 

preconstruction grade for potential agricultural use.

3.5 Stockpile Management

Numerous BMPS will be implemented and maintained at the construction site to adequately manage stockpiles 

created during construction. To facilitate installation of the Pipeline and various components, excavations will be 

created. The soil from these excavations will be temporarily stockpiled and used as backfill over the Pipeline and 

associated components. Stockpile management will consist of the following:

• While the material is stockpiled, silt fencing or straw wattles will be used as perimeter control.

• Stockpiled material will be covered with a thick layer of mulch or by plastic sheeting that is adequately 

anchored. Inactive stockpiles will be covered immediately. Active stockpiles will be covered at the end of each 

work week, or if inclement weather is forecasted.

• Stockpiles from trenching must be kept a minimum of 25 – 30 feet from streams.

• Stockpiles will also be constructed to have stable slopes to prevent the potential for erosion.

3.6 Environmental Inspector

One Environmental Inspector (EI) will be assigned per construction spread to help with stormwater management.

The EI will also act as the designated site inspector required by the 1200-C permit. The EI must be an individual 

who is qualified and knowledgeable about erosion and sediment control installations, practices, and inspections.

Each EI will be responsible for ensuring that contractors meet the goals of the SWPPP and EPSCP, and also for 

BMP installation and maintenance.

The EI will update this SWPPP and the EPSCP when the need for modifications of site-specific BMPs (or the use of 

additional or different BMPs) is identified; the EI will maintain a log and will note these changes. The EI will also be 

responsible for conducting site inspections once per week, and within 24 hours of a rain event that creates 

stormwater runoff. The requirements of these inspections are discussed in Section 4.

Any modifications or changes to the selected BMPs will be implemented within 24 hours, if practical. Otherwise,

the changes will be implemented as soon as practical before the next storm event. The situation will be 

documented in the inspection report, and one or more alternative BMPs will be implemented as soon as practical.

Modifications to major BMPs (such as sediment basins) at a site will be noted on the site diagrams within 7 days, 

and submitted to ODEQ in the form of an Action Plan. These changes will also be noted in the site SWPPP and 

EPSCP.

3-6 ES030613113935PDX
SECTION 4.0

Maintenance and Inspection Procedures

The EI will perform inspections throughout construction until all disturbed areas of the construction site reach 

final stabilization. The EI will be listed as the designated site inspector as part of the 1200-C permit. The EI is a

person who:

• Is knowledgeable in the principles and practice of erosion and sediment control

• Possesses the skills needed to assess conditions at the construction site that could affect stormwater quality

• Possesses the skills needed to assess the effectiveness of any sediment and erosion control measures selected 

to control the quality of stormwater discharges from the construction activity

• Is familiar with this Project and this SWPPP

Furthermore, the EI must be an individual who:

• Is a Certified Professional in Erosion and Sediment Control; or

• Is a Certified Erosion and Sediment Control Lead; or:

• Can document having at least 200 hours of on-the-job-experience associated with installation, maintenance, 

and selection of BMPs

4.1 Areas to Be Inspected

Inspections will include all areas of the site disturbed by construction activity and areas used for storage of 

materials. This includes, but is not limited to: construction areas that have not reached final stabilization, areas 

used for storage of materials that are exposed to precipitation (prevents inspection at a warehouse site), staging 

areas, temporary contractor yards, access roads, structural controls, locations where vehicles enter or exit the 

site, waterbody crossings, and locations of the withdrawal and discharge to the extent practical.

The receiving waterbody will be inspected upgradient, downgradient, and in areas where stormwater enters the 

receiving waterbody. At each of these locations, visual observations of the stormwater will be documented.

If part of the construction area has reached final stabilization, the site will be recorded and mapped as final.

Inspections will be discontinued upon confirmation of final stabilization.

4.2 Inspection Schedule

Inspections will be completed on a daily basis in active areas of construction. In inactive construction areas,

inspections will take place weekly or within 24 hours of a significant precipitation event that could create 

stormwater runoff. Inspections will be performed until final stabilization is achieved in all disturbed areas.

4.3 Disturbed Areas

EIs will inspect disturbed areas of the construction corridor, storage areas that are exposed to precipitation 

events, structural control measures, and high-traffic areas. Sediment and erosion control measures will be 

inspected to confirm that they are operating properly. Areas of entrance and egress for Project traffic will be 

inspected for evidence of offsite sediment tracking. Inspections in disturbed areas will continue until final 

stabilization has occurred.

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4.0 MAINTENANCE AND INSPECTION PROCEDURES

4.4 Inspection Content and Activities

Inspections will be conducted as follows:

• Inspect all control measures. All control measures will be maintained in good working order. When repair is 

necessary, it should begin within 24 hours after the deficiency is noted. If weather or other factors prevent 

initiation of corrective actions within 24 hours, the corrective action will be completed as soon as practical.

• Inspect all disturbed areas for evidence of or potential for pollutants entering the drainage system. Sediment 

from silt fences should be removed regularly and the fences inspected to ensure that the bottom remains 

embedded in the ground. Damaged straw wattles or compost socks will be replaced as necessary.

• Inspect all material storage areas, where materials are exposed to precipitation, for evidence of or potential 

for pollutants entering the drainage system.

• Inspect areas of vehicle entrance and egress for evidence of offsite sediment tracking.

• Inspect all discharge points, if accessible, to determine whether erosion control measures are effective in 

preventing significant impacts on receiving waters. If these points are inaccessible, inspect nearby 

downstream locations.

• Visually observe and document the receiving water bodies, both upgradient and downgradient from the 

active construction areas. These observations should include color, odor, presence or absence of floating 

materials, debris, sheens, oil, and grease.

• Inspect vegetation to determine the success of revegetation.

• Document each inspection with an inspection report completed after each inspection.

• Update the site diagrams to show current BMPs.

4-2 ES030613113935PDX
SECTION 5.0

Plan Modification

This SWPPP may be modified based on the results of routine inspections and visual monitoring of the receiving 

water bodies. Modifications may address additional or modified BMPs designed to correct identified deficiencies.

Modifications will be completed within 7 days after the inspection. Any modifications resulting in additional BMPs 

or in replacing of ineffective BMPs will be submitted to ODEQ in the form of an Action Plan. If existing BMPs need 

to be modified, the work will be completed as soon as practical.

ES030613113935PDX 5-1

SECTION 6.0

Required Reports, Documents, and Record Keeping

A copy of this SWPPP and the EPSCP will be maintained at the construction headquarters for each construction 

section. Construction activity records, including inspection, monitoring, and maintenance reports and erosion 

control maintenance records, will be maintained. At a minimum, records of the following will be kept:

• Weekly summaries of construction activities

• Periods when major grading or excavation activities occur

• Completions of temporary or permanent construction activities

• Date(s) when an area is stabilized, on either an interim or a final basis

• Functionality of all installed BMPs

• Date(s) when maintenance of installed BMPs occurred

• Any modifications to the selected BMPs

• Results of visual inspections 

All documentation associated with this SWPPP and EPSCP will be maintained for a period of 3 years from the date 

on which final stabilization of the site has been achieved.

ES030613113935PDX 6-1

SECTION 7.0

Spill Prevention, Containment, and Countermeasures 

Plan

7.1 Planning and Prevention

This Spill Prevention, Containment, and Countermeasures Plan (SPCC Plan) provides preventive and mitigative 

measures to be used by Oregon LNG and its contractors during construction of the Pipeline.

The measures detailed in the subsequent sections of this SPCC Plan are intended to minimize the possible

environmental impact associated with spills or releases of fuels, lubricants, or hazardous materials during routine

upland construction and refueling activities. The HDD Frac-out Contingency Plan (Chapter 8) includes measures 

that will be taken during HDD installations in the event of a “frac-out,” which could lead to the possible release of 

drilling fluids.

The location of fuel storage facilities, fueling activities, and construction equipment maintenance along the 

construction easement are defined and included in the subsequent sections. The procedures, materials, and lines 

of communication to facilitate prevention, containment, and cleanup of spills during construction are discussed in 

the following subsections.

The SPCC Plan includes the minimum standards for storing and handling regulated substances. The contractors 

who participate in construction and/or restoration activities associated with construction of the Pipeline will 

adopt and implement the SPCC Plan for all aspects of construction.

The goal of the SPCC Plan is to minimize the potential for a fuel, lubricant, or hazardous materials spill; to contain 

any spillage to the smallest area practical; and to protect areas that are considered environmentally sensitive.

7.2 Roles and Responsibilities

The EI will verify that all Project contractors implement the measures outlined in this SPCC Plan. Other roles and 

responsibilities are outlined below:

• The contractors will be responsible and accountable for their activities and the activities of their 

subcontractors with respect to environmental regulations and applicable requirements. This includes all 

regulatory requirements for spill prevention, response, agency notification, and cleanup. All contractors and 

subcontractors will comply with this SPCC Plan.

• The EI will provide environmental spill prevention and containment training to all appropriate construction 

personnel.

• Each contractor and subcontractor will ensure that all their personnel involved in fueling and maintenance 

activities will receive SPCC specific training and carry appropriate response equipment before beginning work 

on the Project. Each contractor will maintain appropriate training documentation for all fueling and 

maintenance personnel.

• Each contractor will designate an independent contractor that is an expert in environmental cleanup

(Emergency Response Contractor [ERC]). The ERC will respond immediately to any and all remediating spill 

events that are considered beyond the capabilities of the contractor. Attachment 2 contains the ERC contact 

information, as well as contact information for other members of the emergency response team.

• Material safety data sheets (MSDSs) for all chemicals brought onto the construction site will be kept onsite.

• The contractor will be considered the Waste Generator for all spills caused by construction activity.

• The contractor will identify all approved waste transporters and disposal sites for hazardous and 

nonhazardous materials that are located in the proximity of construction activities.

ES030613113935PDX 7-1
7.0 SPILL PREVENTION, CONTAINMENT, AND COUNTERMEASURES PLAN

• The contractor will prepare a written inventory of all approved waste transporters and disposal sites for both 

hazardous and nonhazardous wastes near construction activities.

7.3 Project Materials

Within 1 week after mobilizing to the Project site, the contractor will submit to the EI a written inventory of 

lubricants, fuels, and other materials planned to be on the job site or stored within the easement and 

construction laydown area(s). The written inventory will also include the reportable quantities for each of the 

identified materials. For this type of construction Project, materials stored onsite will include diesel and gasoline, 

various oils and lubricants, antifreeze, paints, and fertilizers. Table 3 shows typical hazardous substances onsite 

for construction projects. One week after mobilization, the exact quantities stored within the easement and 

laydown areas will be known, and this table will be revised in the field copy of the SWPPP. 

TABLE 3

Typical Fuels, Lubricants, and Hazardous Materials

Product

Typical

Quantitya Method of Storage Storage Location

Diesel Fuel 5,000-10,000 Tank or tankers Contractor yard warehouse

Gasoline 5,000-10,000 Tank or tankers, 5-gallon containers, 

vehicle tanks

Contractor yard warehouse

Engine Oil <100 Bulk storage or retail packaging Contractor yard warehouse

Transmission Drive Train Oil <50 Retail packaging on service trucks Contractor yard warehouse, service trucks

Hydraulic Oil <100 Bulk storage or retail packaging Contractor yard warehouse, service trucks

Gear Oil <50 Retail packaging on service trucks Contractor yard warehouse, service trucks

Lubricant Grease <25 Tubes stored in paper cases Contractor yard warehouse, service trucks

Ethylene Glycol <100 Bulk storage or retail packaging Contractor yard warehouse, service trucks

Propylene Glycol <100 Bulk storage or retail packaging Contractor yard warehouse, service trucks

Power Steering Fluid <50 Retail packaging on service trucks Contractor yard warehouse, service trucks

Brake Fluid <50 Retail packaging on service trucks Contractor yard warehouse, service trucks

Propane 25-100 Pressurized tanks Contractor yard warehouse, service trucks

Paint <50 5-gallon containers Contractor yard warehouse

Fertilizers <500 pounds 50-pound bags Contractor yard warehouse

a Units are gallons except as noted.

7.4 Spill Prevention and Mitigation Measures

BMPs will be implemented to prevent spills. BMPs will be used to reduce the risk of spills and other accidental 

exposures that could potentially result in impacts to stormwater quality. Good housekeeping BMPs will be 

implemented during all phases of construction to prevent spills, as feasible. Good housekeeping BMPs include the 

following:

• Container Storage

• Secondary Containment

• Leak and Integrity Inspections

• Fueling and Material Handling

• Materials on Hand

• Restricted Fueling Areas

• Restricted Areas

• Material Specific Procedures

7-2 ES030613113935PDX
7.0 SPILL PREVENTION, CONTAINMENT, AND COUNTERMEASURES PLAN

7.4.1 Container Storage

The following structural and nonstructural BMPs will be implemented to prevent the direct release of any product 

(hazardous or nonhazardous):

• Only enough products required to do the job will be brought onto and stored within the site.

• Product will be stored only in containers sized appropriately for the job.

• All storage will occur more than 150 feet from any surface water (including wetlands).

• No storage will occur within 200 feet of a private water supply well, or within 400 feet of a municipal water 

supply well.

• All fuel or hazardous material containers of 55 gallons or more will be stored in designated work areas 

equipped with secondary containment.

• All product will be stored in containers that are in good condition.

• All product containers will be stored underneath a roof or cover to prevent release of materials during a 

storm event.

• All product containers will be stored in a neat and orderly fashion, and will be properly labeled. The labels will 

be visible, correct, and legible.

• The inventory of all MSDSs for each chemical will be available at each storage location.

• Products will be kept in original containers with the original manufacturer’s label still affixed. If the original 

container is not resealable, then the product will be transferred to an appropriate container that is properly 

labeled.

• Drain valves on any temporary storage tanks will be locked to prevent accidental or unauthorized discharges.

• Whenever practical, all contents of a container will be used before it is disposed of.

• Any surplus product must be disposed of in accordance with the manufacturer’s and state and local methods 

for proper disposal.

7.4.2 Secondary Containment

• Secondary containment will provide a minimum containment volume equal to 100 percent of the volume of 

the largest storage vessel and will include at least 1 foot of freeboard.

• Earthen secondary containment areas will be underlined with plastic sheeting (minimum of 60-mil).

• Polyethylene drum spill skids will be used for storage of 55-gallon drums of fuel or hazardous materials that 

may be placed temporarily in the immediate work area.

• The contractor will construct temporary liners and seamless berms around aboveground bulk storage tanks.

• Secondary containment structures will be constructed as dictated by the construction design drawings. Any 

uncontaminated accumulated precipitation within the secondary containment may be discharged if 

authorized by an EI, based on the absence of visible sheen. Accumulated precipitation that has a visible sheen 

will be collected for proper storage and disposal.

7.4.3 Leak and Integrity Inspections

The contractor will be responsible for daily leak inspection and for the integrity of all construction equipment and 

vehicles and material storage areas (including secondary containment structures):

• The contractor will visually inspect aboveground tanks daily, and whenever the tank is refilled.

ES030613113935PDX 7-3
7.0 SPILL PREVENTION, CONTAINMENT, AND COUNTERMEASURES PLAN

• The contractor will repair visible leaks in tanks immediately. Tanks with leaks will not be refilled until repaired 

and tested.

• All onsite construction equipment and vehicles will be inspected for leaks daily.

• During construction activities, contractor personnel will conduct leak and integrity inspections of equipment, 

vehicles, secondary containment areas (tank and drum storage areas), and spill response supply areas.

7.4.4 Fuels and Hazardous Materials Handling

Specific procedures and practices will be implemented during construction activities to prevent the release of fuel 

or hazardous materials. The following nonstructural and structural BMPs will be implemented:

• Fuels and lubricants will be stored only at designated staging areas and in appropriate service vehicles. The 

storage area will be at least 150 feet from the edge of the nearest waterbody (including wetlands), at least 

200 feet from the nearest private water supply well, and at least 400 feet from the nearest municipal water 

supply well

• The drivers of tank trucks are responsible for spill prevention during tank unloading. Procedures for loading 

and unloading tank trucks will meet the applicable minimum requirements established by the U.S. 

Department of Transportation. Drivers will observe and control fueling operations at all times to prevent

overfilling.

• The drivers of tank trucks will inspect all outlets of the vehicle prior before they leave the construction site to 

prevent leakage while in transit.

• All fuel nozzles will be equipped with functional automatic shut-off valves.

7.4.5 Materials on Hand

Spill response equipment will be stored onsite in the designated fueling areas and at designated locations 

throughout the Project area. The minimum materials will be stored onsite:

• A sufficient supply of sorbent and barrier materials will be kept at the construction staging areas to allow the 

rapid containment and recovery of a spill.

• Sorbent and barrier materials will also be used to contain runoff from spill areas.

• Shovels and labeled 55-gallon drums will be kept at each staging area.

• Small quantities of soil that has become contaminated within the staging areas will be collected and placed in 

the drums.

• Large quantities of contaminated soil will be collected using heavy equipment and stored in properly labeled 

drums or other suitable containers prior to disposal. Emergency spill response materials will also be located 

within the designated areas.

7.4.6 Restricted Areas

The following restrictions apply for all construction activities within the easement:

• The contractor will refuel equipment and transfer material only in designated areas. The designated areas 

must be away from all water resources. The minimum distances that must be adhered to are as follows:

− 150 feet away from any and all surface water sources (including wetlands, ephemeral streams, seasonal 

streams, lakes, and rivers)

− 200 feet away from any private water supply well

− 400 feet away from any municipal water supply well

7-4 ES030613113935PDX
7.0 SPILL PREVENTION, CONTAINMENT, AND COUNTERMEASURES PLAN

• The contractor will conduct routine equipment maintenance, such as oil changes, in staging areas. The 

contractor will dispose of waste oil in an appropriate manner.

• Equipment will not be washed in streams or within 150 feet of water bodies, including wetlands.

7.4.7 Restricted Refueling Areas

In addition to the restrictions noted in the previous section, all refueling activities will also adhere to the following 

conditions:

• The EI will verify that signs are in place identifying restricted areas.

• In large wetlands where no upland site is available for refueling, auxiliary fuel tanks may be mounted on 

equipment to minimize the need for refueling.

• Personnel trained in these spill prevention and mitigation procedures will be available for refueling in these 

areas.

• Auxiliary tanks will be mounted on or affixed to equipment such as large, stationary pumps as appropriate. 

The auxiliary tanks will be placed within secondary containment.

• Refueling within restricted areas will take place in designated areas. Fuel trucks with a capacity in excess of 

300 gallons will not be permitted within the refueling areas unless adequate secondary containment is 

provided.

• Refueling of any portable equipment will be performed using approved containers with a maximum volume of 

5 gallons.

7.4.8 Other Material-Specific Measures

• Paints: Containers will be tightly sealed and stored in the designated area. Paint containers will not be left 

outside of the designated storage area. Excess paint will be properly disposed of according to manufacturer’s 

instructions and federal, state, and local regulations.

• Concrete Trucks: Concrete trucks will be allowed to wash out or discharge surplus concrete or drum wash 

water on the site in designated areas only. The designated concrete washout area will include sediment 

controls installed around the perimeter of the area. This area must be at least 150 feet away from any surface 

water feature. After construction, the concrete washout area will be restored.

7.5 Spill Preparedness Practices

The following preparedness BMPs will be implemented during the Project:

• Each contractor will know the RQ for all materials onsite.

• Fuel and service trucks will carry adequate spill response materials, including suitable commercial absorbent 

and barrier materials.

• The contractor will determine whether additional spill response material is required, based on volume and 

level of hazardous materials transported, proximity of refueling equipment to sensitive areas, and any other 

unforeseen factors that could increase the likelihood, impact, or size of potential releases.

7.6 Spill Response Procedures

7.6.1 Initial Spill Management

Immediately upon any spill of fuel, oil, hazardous material, or other pollutant, the person discovering the situation 

will initiate the following actions:

• Assess the safety of the situation; if necessary, call the Supervisor immediately for help.

ES030613113935PDX 7-5
7.0 SPILL PREVENTION, CONTAINMENT, AND COUNTERMEASURES PLAN

• If conditions are not safe, block access to the spill site and/or evacuate the area.

• If conditions are safe, the initial response should include:

− Remove sources of ignition.

− Shut off the source of the spill.

− Begin spill containment.

• Notify the Supervisor and the EI.

• For any release or spill (regardless of volume) in designated vulnerable aquifer areas, immediately notify 

Oregon LNG’s representative and the EI. Spill containment response actions will be followed, all affected soils 

will be immediately excavated, and affected soils will be stored and disposed of in accordance with the 

procedures outlined in this SPCC Plan.

7.6.2 Mobilization of Additional Resources

Other resources may be mobilized at the discretion of the highest-ranking responder. Resources will be mobilized 

as follows:

• Based on the severity of the situation, the Supervisor will notify local emergency response agencies (e.g., 

police or fire department).

• The Supervisor will immediately notify Project inspectors (Oregon LNG Project Manager and EI) and all 

applicable contractor supervisors and/or managers of any spill, except minor spills that have been managed 

by the first responder. Specifically, a spill is exempt if it has:

− No potential to be reportable

− No potential or actual impact on the environment

− No potential to cause other liabilities

• If spill containment and cleanup are beyond the capabilities of the contractor, the ERC will clean up the spill.

• If the spill or response is likely to affect the operation of existing facilities, the Oregon LNG Project Manager 

will be notified.

• The contractor will begin documenting the spill event, notifications, and response immediately.

7.7 Spill Containment and Cleanup

It is Oregon LNG’s objective to restore land to its preconstruction condition. The procedures outlined below will 

be followed for containment and/or cleanup of spills:

• The type of material and quantity released will be identified and the response will be appropriately managed.

Personal protective equipment will be worn as recommended on the MSDS of the specific product. All 

procedures will be in compliance with Hazardous Waste Operations and Emergency Response standards, as 

applicable.

• Oregon LNG will be consulted by the EI and/or the contractor for any spill requiring implementation of this 

SPCC Plan.

• Containment will be initiated as soon as it can be safely performed. A spill on dry ground will require the 

construction of berms (earthen dikes) to contain the spill. Commercially available spill kits will be used and 

sorbent materials will be applied to the spill area. Traffic on contaminated soils will be avoided.

• If the spill is large enough, where the material can be safely pumped into the appropriate container, then 

pumping will be implemented after containment is achieved.

• Removal of soil and spilled material will rely on visual observations to determine the extent of removal. Soil 

and spilled materials will be removed until no visible evidence of spilled materials remains.

7-6 ES030613113935PDX
7.0 SPILL PREVENTION, CONTAINMENT, AND COUNTERMEASURES PLAN

• All spills will be cleaned up and removed to the satisfaction of the EI and Oregon LNG personnel.

• Contaminated soils and vegetation will be stored in appropriate and properly labeled containers, and 

managed appropriately until they are disposed of at an approved facility.

7.7.1 Wetlands or Waterbody Response

For any spill (regardless of volume) that occurs near or into a waterbody (stream, wetland, river, or other type of 

waterbody), the following specific actions must be applied. The procedures are in addition the ones described 

above in this Plan:

• For reportable spills into streams, lakes, or other water bodies containing standing or flowing water, the

responder will immediately notify the EI and Oregon LNG personnel.

• For a spill threatening a waterbody, berms and/or trenches will be constructed to contain the spill prior to 

entry into a waterbody. The spilled product will be removed and the contaminated area cleaned up in 

accordance with procedures referenced in this SPCC Plan and applicable state and local guidelines.

• If a spill enters surface water, containment booms or other containment methods will be implemented.

Product will be removed with a vacuum truck or pumps and stored in appropriate containers.

• Contaminated soil in wetlands will be excavated and placed in an approved containment area (berms, 

underlined with plastic, and covered and anchored) a minimum of 150 feet from the wetland or waterbody.

7.8 Material Disposal

As soon as practical, the Contractor will dispose of contaminated soil or water and any other materials associated 

with spill containment and cleanup at an approved disposal facility.

• The Contractor will supply Oregon LNG with all documentation concerning the disposal of contaminated 

media.

ES030613113935PDX 7-7

SECTION 8.0

Horizontal Directional Drilling Frac-out Contingency

Plan

This Horizontal Directional Drilling Frac-out Contingency Plan is a supplement to the SPCC Plan and provides 

specific preventive and mitigative measures to be used by Oregon LNG and its contractors during HDD installation. 

This is a preliminary plan, and more specific procedures will be developed during final design for each location 

based on site-specific conditions. HDD operations potentially pose a risk to wetlands and water bodies through 

frac-outs. A frac-out occurs when the drilling fluid is released through fractured bedrock and sands. Drilling fluid 

typically consists of a mixture of bentonite, water, and soil cuttings. This mixture is not hazardous or toxic, but it 

could potentially affect the water quality of any waterbody if it were introduced.

Frac-outs can occur at any place along any point of an HDD installation, although they are more likely to be 

observed at the entry and exit points (locations where the drilling bit or head is shallow). If a frac-out occurs and 

no control measures are in place, the drilling fluid could potentially reach the surface water or wetland that is 

above the HDD installation. The contingency plan detailed in the following subsections will outline measures to 

minimize the potential for frac-outs. This plan also addresses the methodology that will be used for detection of 

frac-outs, as well as countermeasures to be taken should a frac-out be detected.

8.1 Planning and Prevention

HDD crossings will be conducted only during recommended in-water work periods to minimize impacts from 

potential frac-outs. Oregon LNG will use nontoxic bentonite-clay mixtures of drilling mud to ensure that, if a fracout occurred, it would not result in toxicity to aquatic life in the stream.

The contractor performing the HDD must have experienced personnel onsite who are familiar and experienced 

with the procedures for this type of installation. Before drilling activities begin, the contractor must submit any 

certifications and documentation of at least 2 years of experience for all personnel who will be performing drilling 

work. The EI must be present for all HDD activities. Before any HDD occurs, a safety meeting will take place, the 

frac-out contingency plan will be discussed, and any questions will be answered.

Prior to drilling, the work area(s) will be flagged and the limits defined. The work area will not exceed 10 feet on 

either side of the centerline of the proposed boring. Erosion and sediment controls (including silt fence, straw 

wattles, and temporary sediment trap) will be installed at the entrance/exit pits. Additional materials will be kept 

onsite at a designated location, and the presence of these materials will be verified prior to any drilling activities. 

These materials will be placed in a dedicated location and denoted as the frac-out containment response kit. The 

kit will include the following items:

• Silt fence

• Straw wattles

• Silt curtain (in-water work)

• Straw bales

• Submersible pumps

• Specialized filters

• Generator

• Appropriate hand tools

• Vacuum truck (available on call)

• Light towers for work at night

• Heavy equipment, such as backhoe or dozer, for containment and cleanup of drilling mud

• Boat for major waterbody crossings to allow for monitoring of releases to water

ES030613113935PDX 8-1
8.0 HORIZONTAL DIRECTIONAL DRILLING FRAC-OUT CONTINGENCY PLAN

8.1.1 Frac-out Monitoring

Once HDD begins, specific monitoring will need to be done to determine whether a frac-out occurs. The bentonite 

mixture will be adjusted to match the conditions of the subsurface. The pressure levels will be set as low as 

possible, and they will be closely monitored to ensure that the pressure on the drilling fluid is set to match the 

formation. The pressure should not exceed what is needed to penetrate the formation.

During drilling, the pressures will be closely watched and randomly checked by the EI. As the boring progresses,

the pressure will be inspected and documented. Any drop in the pressure could indicate a potential frac-out, and 

drilling will be halted immediately.

The drill mud will also be monitored, inspected, and documented. If there is a noticeable drop in the return of the 

drill mud, the drilling will stop immediately.

8.1.2 Frac-Out Response

Should the results of the monitoring indicate that a frac-out has occurred, the drilling will be stopped 

immediately, and the following procedures will be implemented:

• Slowly pull the stem back to relieve pressure on the potential frac-out.

• Wait for the drill mud to settle.

• Assess the situation to determine whether the frac-out has reached the surface.

− If the frac-out has reached the surface, immediately implement containment and notifications, as 

discussed below.

− If the frac-out has not reached the surface and is not threatening sensitive areas, use a leak-stopping 

compound to correct the frac-out.

• If the leak-stopping compound has been successful (100 percent containment), continue with drilling.

• If the leak-stopping compound has not been successful, redirect the boring to an area where a frac-out has 

not occurred.

• If the frac-out cannot be contained, abandon the borehole, as discussed below.

8.1.3 Surface Frac-Out Containment and Response

Should a frac-out occur and result in release to the surface, drilling will halt immediately and the severity of the 

release will be determined. If the release to the surface is minor, the following procedures will be implemented:

• Identify the extent of the release.

• Create a containment area with the use of a silt curtain, straw wattles, fiber rolls, and/or constructed earthen

dikes.

− If the frac-out release to the surface occurred upland or in riparian areas, allow the material to dry prior 

to excavation.

− If the frac-out release to the surface occurred in a waterbody, immediately remove the material.

• For minor releases that are not widespread, remove bentonite-contaminated material with the use of hand 

tools to a depth of 2 feet.

• For larger releases, that are (or have the potential to be) widespread, mobilize the vacuum truck to remove 

the material. Place the submersible pumps within the release area to capture material until the vacuum truck 

arrives.

• Place excavated material in an appropriate container.

• Backfill with clean sand.

8-2 ES030613113935PDX
8.0 HORIZONTAL DIRECTIONAL DRILLING FRAC-OUT CONTINGENCY PLAN

• Dispose of material at an approved facility and as required by regulations.

After successful containment and removal of the released material, operations will be able to continue (with the 

appropriate agencies’ approval). All the activities associated with the frac-out response will be documented, and 

measures to prevent another release will be discussed. Before restarting drilling operations, the boring will be 

redirected to an area that has not had a frac-out, or the borehole will be abandoned.

8.1.4 Frac-Out Notifications

In the event of an HDD drilling fluid release to water bodies, sensitive areas, or riparian areas, appropriate local, 

state, and federal agencies will be notified. All appropriate agencies will be notified of the frac-out within 

24 hours. The agencies that will be notified are presented in Table 4. The following information will be provided:

• Time of frac-out release

• Location of release

• Quantity and type of material released and amount of recovered materials

• Containment and cleanup measures

• Location of sensitive areas near the release

TABLE 4

Agency Contact List In the Event of a Frac-Out

Agency Contact Person Position Location Contact Number

Oregon Department of Fish and Wildlife Chris Knutsen North Coast Watershed District Fish 

Biologist

503.842.2741 ext 231

Oregon Department of Fish and Wildlife Tom Murtagh/

Todd Alsbury 

North Willamette Watershed District 

Fish Biologist 

971.673.6011

Oregon Department of Forestry Todd Reinwald Assistant District Forester, Forest 

Grove District

Forest 

Grove

Office: 503.359.7493

Cell: 503.260.2057

Oregon Department of State Lands Sarah Kelly Resource Coordinator DOE Clatsop 

and Columbia Counties

Salem 503.986.5219

USEPA Contacted by the National Response Hotline 

United States Fish and Wildlife Service Mike Szumski, NRDA Coordinator Portland 503.231.6179

Washington Department of Fish and 

Wildlife

TBD Regional Manager

Washington Department of Natural 

Resources

TBD Forest Practices Division Manager

8.1.5 Borehole Abandonment

A borehole will need to be abandoned if a frac-out cannot be avoided, or if a frac-out has occurred that cannot be 

controlled. The borehole will be completely abandoned and a new location determined. Any borehole 

abandonment locations will be documented and shown on any as-built documents.

The following steps will be implemented during abandonment of the borehole:

• Determine the new location for the HDD crossing.

• Insert casing, as necessary to remove the pilot string.

• Pump a thick grout plug into the borehole to securely seal the abandoned borehole.

ES030613113935PDX 8-3

SECTION 9.0

Certifications

9.1 Oregon LNG Certification

To the best of my knowledge and belief, the information submitted in this SWPPP is true, accurate, and complete.

Signed: Date:

Print Name:

Title:

Company:

9.2 Contractor/Subcontractor(s) Certification

To the best of my knowledge and belief, the information submitted in this SWPPP is true, accurate, and complete.

Signed: Date:

Print Name:

Title:

Company:

ES030613113935PDX 9-1

Attachment 1

Best Management Practices Information

Oregon DEQ 

OREGON MANUAL-APPENDICES.DOC Erosion and Sediment Control Manual

 April 28, 2005

APPENDIX D 

RUNOFF CONTROL BMPS 

 RC-1 Slope Drain 

 RC-2 Energy Dissipator 

 RC-3 Diversion of Run-on 

 RC-4 Temporary Diversion Dike 

 RC-5 Grass-lined Channel (Turf Reinforcement 

 Mats) 

 RC-6 Trench Drain 

 RC-7 Drop Inlet 

 RC-8 Minimizing TSS During Instream 

 Construction 

 RC-9 Instream Diversion Techniques 

 RC-10 Instream Isolation Techniques 

 RC-11 Check Dams
DIVERSION OF RUN-ON – RC-3 

Page 1 of 2 

Diversion consists of measures that intercept, divert and convey surface run-on, generally sheet flow, to 

prevent erosion and transport of pollutants through and from the site.

Construction Specifications: 

• Construct diversion channels consisting of drainage swales; earth dikes; or other means such as sand 

bag barriers to intercept and divert run-on to avoid sheet flow over sloped surfaces and work areas 

(See SC-2 “Sand Bag Barrier”). 

• Construct diversion structure to adequately convey storm flows based on careful evaluation of the 

risks due to erosion of the measure, soil types, over topping, flow backups, washout, and drainage 

flow patterns for each project site. 

• Use other soil stabilization and sediment controls, such as check dams, plastics, and blankets, as 

necessary to prevent scour and erosion in newly graded dikes, swales and ditches. 

• Correctly size and locate earth dikes, drainage swales and lined ditches. Excessively steep, unlined 

dikes and swales are themselves subject to erosion and gully formation. 

• Stabilize conveyances as necessary and use a lined ditch for high flow velocities. Refer to EC-10 

entitled “Erosion Control Blankets and Mats” or line with permanent, erosion-resistant material. 

• Where appropriate, use natural streambed materials such as large cobbles and boulders for temporary 

embankment/slope protection, or other temporary soil stabilization methods. 

• Compact any fills to prevent unequal settlement. 

• Divert runoff to an appropriate downstream location. 

• Use level spreaders (i.e., outlets for dikes and flow channels consisting of an excavated depression 

constructed at zero grade across a slope), to convert concentrated runoff into sheetflow onto areas 

stabilized by existing vegetation. 

• Do not divert runoff from the project to adjacent properties without permission. 

• When possible, install and utilize permanent dikes, swales and ditches early in the construction 

process. 

• Convey collected run-on/concentrated flows down slopes in accordance with the RC-1 (“Slope 

Drain”) 

• Provide stabilized outlets. Refer to RC-2 entitled “Energy Dissipator.” 

Minimum BMP standards are provided on the following detail. 

Inspection and Maintenance:

• Inspect temporary measures before, during and after rain events, and regularly. 

• Inspect ditches and berms for washouts. Replace lost riprap, damaged linings or soil stabilizers as 

needed. 

• Inspect channel linings, embankments, and beds of ditches and berms for erosion and accumulation 

of debris and sediment. Remove debris and sediment, and repair linings and embankments as 

needed or as directed by the engineer. 

• Temporary conveyances shall be completely removed as soon as the surrounding drainage area has 

been stabilized, or at the completion of construction. 
DIVERSION OF RUN-ON – RC-3 

Page 2 of 2 
MINIMIZING TOTAL SUSPENDED SOLIDS (TSS) RC-8

Page 1 of 2 

Construction Specifications 

Whatever technique you decide to implement, an important thing to remember is that dilution 

can sometimes be the solution. A probable “worst time” to release high TSS into a stream 

system might be when the stream is very low; summer low flow, for example. During these 

times, the flow may be low while the biological activity in the stream is very high. Conversely, 

the addition of high TSS or sediment during a big storm discharge might have a relatively low 

impact, because the stream is already turbid, and the stream energy is capable of transporting 

both suspended solids, and large quantities of bedload through the system. The optimum time to 

“pull” in-stream structures may be during the rising limb of a storm hydrograph. 

Techniques to Minimize Total Suspended Solids (TSS) 

Padding 

Padding, usually manufactured from coir and or other natural fibers, that is laid in the stream 

below the work site may trap some solids that are deposited in the stream during construction. 

After work is done, the padding is removed from the stream, and placed on the bank to assist in 

revegetation. 

Clean, washed gravel 

Clean, washed gravel can be placed on the stream bottom both during and after construction to 

minimize re-mobilizing the “fines”. Clean gravel or spawning gravel can often be specified to 

mitigate or enhance the existing substrate. Therefore, gravel “injection” can minimize TSS 

during construction while providing environmental and habitat enhancements with long-term 

benefits. 

Excavation using a large bucket 

Each time a bucket of soil is excavated or placed in the stream, a portion is of the soil is 

suspended. The resulting amount of sediment suspended increases proportionally to the number 

of scoops rather than the total of excavated soil. Therefore, using a large excavator bucket 

instead of a small one will reduce the total amount of soil that is suspended and available to wash 

downstream. Each time a bucket of soil is placed in the stream, a portion is suspended. 

Approximately the same amount is suspended whether a small amount of soil is placed in the 

stream, or a large amount. 

Use of dozer for backfilling 

Using a dozer for backfilling instead of a backhoe follows the same principles – the fewer times 

soil is deposited in the stream, the less soil will be suspended. 

Partial dewatering with a pump 

Partially dewatering a stream with a pump reduces the amount of water, and thus the amount of 

water that can suspend sediment. 

How to know if you have high TSS: 

Some commonly accepted standards for high TSS are: 

• 50 mg/l or 

• 10 mg/l above background TSS or, 

• 10% above background TSS. 

These standards are very stringent, and are very difficult to achieve in many situations. The 

background + 10 % (mg/l) is probably the most realistic and reasonable standard for protecting 

the aquatic resources, while allowing a restoration project to be implemented. Check with local 

ordinances for standards. 
MINIMIZING TOTAL SUSPENDED SOLIDS (TSS) RC-8

Page 2 of 2 

Inspection and Maintenance 

• Inspect the stability and performance of all erosion and sediment control measures during 

construction. 

• Monitor TSS levels before, during and after construction. 
IN-STREAM DIVERSION TECHNIQUES RC-9

Page 1 of 2

Construction Specifications

A stream diversion is a temporary bypass through a pipe, flume, or excavated channel that carries water 

flow around work areas. Stream diversion is commonly used during culvert installation or replacement. 

Where possible, a stream diversion should be the first choice to control erosion and sediment during the 

construction of culverts or other in-stream structures. During construction in a watercourse, particularly 

culvert installation and repair, these temporary water bypass structures are an effective sediment and 

erosion control technique. Check with local, state and federal regulatory authorities for permitting and 

design requirements. 

Design Considerations

The selection of which stream diversion technique to use will depend upon the type of work involved, 

physical characteristics of the site, and the volume of water flowing through the project. 

Advantages of a pumped diversion include: 

• Downstream sediment transport can almost be eliminated 

• De-watering of the work area is possible 

• Pipes can be moved about to allow construction operations 

• The dams can serve as temporary access. 

• Increased flows can be managed by adding more pumping capacity. 

Some disadvantages of a pumped diversion are: 

• Flow volume is limited by pump capacity 

• Requires 24-hour monitoring of pumps 

• Sudden rain could overtop dams 

• Minor in-stream disturbance to install and remove dams 

Advantages of excavated channels and flumes are: 

• Isolates work from water flow and allows dewatering 

• Can handle larger flows than pumps 

Disadvantages of excavated channels and flumes are: 

• Bypass channel or flume must be sized to handle flows, including possible floods 

• Channels must be protected from erosion 

• Flow diversion and then re-direction with small dams causes in-stream disturbance and 

sediment 

Stream diversions should not be used: 

• Without identifying potential impacts to the stream channel 

• In or adjacent to water bodies until all necessary permits have been obtained 

Installation 

• The pumped diversion is suitable for intermittent and low flow streams that can be pumped. 

Pump capacity must be sufficient for design flow. The upper limit is about 10ft3

/sec (0.28 

m3

/sec), the capacity of two 8 inch (20 cm) pumps. 

• A temporary dam is constructed upstream and downstream of the work area and water is pumped 

through the construction project in pipes. Dam materials should be selected to be erosion 

resistant, such as steel plate, sheetpile, sandbags, continuous berms, inflatable water bladders, etc. 

• A temporary bypass channel can also be constructed by excavating a temporary channel or 

passing the flow through a heavy pipe (called a “flume”), and excavating a trench under it. 

Typical stream sizes are less than 20 ft (6 m) wide and less than 100 ft3

/sec (2.8 m3/sec). 
IN-STREAM DIVERSION TECHNIQUES RC-9

Page 2 of 2

Inspection and Maintenance

• All stream diversions must be closely maintained and monitored 

• Pumped diversions require 24-hour monitoring of pumps 

• Upon completion of the work performed, the stream diversion should be removed and flow 

should be re-directed through the new culvert or back into the original stream channel. 
INSTREAM ISOLATION TECHNIQUES RC-10

Page 1 of 5

Portable dams installed in Santa Cruz Ca. and in Alberta Canada. 

Construction Specifications 

An instream isolation technique is a temporary structure built into a waterway to enclose a construction 

area and reduce sediment pollution from construction work in or adjacent to water. The structures may be 

made of rock, sand bags, wood or water-filled geotextiles (aqua barriers). During construction in a 

watercourse, these structures are designed to reduce turbidity and sediment discharge, allowing 

contractors to follow clean water regulations. 

Design Considerations 

Isolation structures may be used in construction activities such as streambank stabilization, culvert 

installation, bridges, piers or abutments. It may be used in combination with other methods such as clean 

water bypasses and/or pumps. 

This technique should not be used: 

• If there is insufficient streamflow to support aquatic species. 

• In deep water unless designed or reviewed by and engineer. 

• To completely dam streamflows. 

Installation 

When used in watercourses or streams, cofferdams must be used in accordance with permit requirements. 

Materials for cofferdams should be selected based on ease of maintenance and complete removal 

following construction activities. 

Inspection and Maintenance

• During construction, inspect daily. 

• Schedule additional inspections during storm events. 

• Immediately repair any gaps, holes or scour. 

• Upon construction completion, the structure is removed. 

• Remove sediment buildup. 

• Remove structure. Recycle or re-use if applicable. 

• Revegetate areas disturbed by cofferdam removal if applicable. 
INSTREAM ISOLATION TECHNIQUES RC-10

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INSTREAM ISOLATION TECHNIQUES RC-10

Page 3 of 5
INSTREAM ISOLATION TECHNIQUES RC-10

Page 4 of 5
INSTREAM ISOLATION TECHNIQUES RC-10

Page 5 of 5
Oregon DEQ 

OREGON MANUAL-APPENDICES.DOC Erosion and Sediment Control Manual

 April 28, 2005

APPENDIX E 

EROSION PREVENTION BMPS 

 EP-1 Scheduling 

 EP-2 Preservation of Existing Vegetation 

 EP-3 Surface Roughening 

 EP-4 Topsoiling 

 EP-5 Temporary Seeding and Planting 

 EP-6 Permanent Seeding and Planting 

 EP-7 Mycorrhizae / Biofertilizers 

 EP-8 Mulches 

 EP-9 Compost Blankets 

 EP-10 Erosion Control Blankets and Mats 

 EP-11 Soil Binders 

 EP-12 Stabilization Mats 

 EP-13 Wind Erosion Control 

 EP-14 Live Staking 

 EP-15 Pole Planting 

 EP-16 Live Fascines and Brush Wattles 

 EP-17 Brush Box 

 EP-18 Fascines with Subdrains 

 EP-19 Live Pole Drains 

 EP-20 Brush Packing or Live Gully Fill Repair 

 EP-21 Sodding 
SCHEDULING – EP-1 

 Page 1 of 2 

Scheduling involves sequencing construction activities and the installation of erosion and sediment 

control measures to reduce the amount and duration of soil exposed to erosion by wind, rain, runoff and 

vehicle tracking. The timing of soil-disturbing activities and the timing of implementation of BMPs are 

both critical to the prevention of accelerated erosion and transport of sediment off-site. The scheduling of 

grading should take into account the rainy season and should minimize the length of the time that soils are 

left exposed, and reduce the total area of exposed soil during the rainy season. Consideration should be 

given to phasing the grading and construction so that critical areas (such as highly erodible soils, areas 

adjacent to receiving waters, etc.) are not disturbed until the non-rainy season, and so the entire area that 

is disturbed at any one time is kept to a size that can be controlled effectively. 

Construction Specifications: 

• The optimum grading period is when the chance for precipitation is minimized (e.g., the non-rainy 

season), particularly for the critical areas. If precipitation is likely during grading, minimize the 

length of time that soils are exposed, and the total area of exposure. 

• Materials used for erosion and sediment control shall be on site at all times. 

• Take the following measures when precipitation is forecast: 

o Minimize the length of time that the soils are left exposed. 

o Reduce the total area of exposed soil. 

o Protect critical areas such as drainage channels, streams, and natural water courses. 

o Stabilize exposed areas quickly. 

• The schedule shall clearly show how regional precipitation trends relate to soil-disturbing and restabilization activities. The construction schedule shall be incorporated into the Erosion and 

Sediment Control Plan. 

• The schedule shall include detail on the implementation and deployment of temporary soil 

stabilization measures, temporary sediment controls, tracking controls, wind erosion controls, nonstorm water pollution controls (including waste management and materials pollution controls). 

• The schedule shall also include dates for significant long-term operations or activities that may have 

planned non-storm water discharges such as dewatering, saw cutting, grinding, drilling, boring, 

crushing, blasting, painting, hydro-demolition, mortar mixing, bridge cleaning, etc. 

• Develop the sequencing and timetable for the start and completion of each item such as site clearing 

and grubbing, grading, excavation, paving, pouring foundations, installing utilities, etc., to minimize 

the active construction area during the rainy season. 

• Schedule major grading operations when the chances of precipitation are minimized when practical. 

• Schedule the installation, removal, or modification of run-on controls and flow conveyance 

structures for the non-rainy season or when there is a low probability of precipitation to reduce the 

likelihood of uncontrolled flow across and from the site. 

• Stabilize non-active areas after the cessation of soil-disturbing activities or prior to the onset of 

precipitation in accordance with local requirements. 

• Monitor the weather forecast for rainfall. 

• When rainfall is predicted, adjust the construction schedule to allow the implementation of soil 

stabilization and sediment controls and sediment treatment controls on all disturbed areas prior to the 

onset of rain. 

• Be prepared year-round to deploy soil stabilization and sediment control practices. Erosion may be 

caused during dry seasons by unseasonable rainfall, wind, and vehicle tracking. Keep the site 

stabilized year-round, and retain and maintain sediment trapping devices in operational condition. 

• Sequence trenching activities so that most open portions are closed before new trenching begins. 

• Incorporate staged seeding and re-vegetation of graded slopes as work progresses. 

• Consider scheduling when establishing permanent vegetation (appropriate planting time for specified 

vegetation). 

Inspection and Maintenance: 
SCHEDULING – EP-1 

 Page 2 of 2 

• Verify that work is progressing in accordance with the schedule. If progress deviates, take corrective 

actions. 

• Amend the schedule when changes are warranted. 

• Amend the schedule to show updated information on the deployment and implementation of 

construction site BMPs. 
PRESERVATION OF EXISTING VEGETATION / BUFFER STRIPS – EP-2 

Page 1 of 2 

Maintaining existing vegetation or placing vegetative buffer strips can have numerous benefits for 

stormwater quality, erosion and sediment control, as well as landscape beautification, dust control, noise 

reduction, shade and watershed protection. 

Construction Specifications: 

Preservation of Existing Vegetation: 

Timing 

• Preservation of existing vegetation shall be provided prior to the commencement of clearing and 

grubbing operations or other soil-disturbing activities in areas identified on the plans to be preserved, 

especially on areas designated as Environmentally Sensitive Areas (ESAs) or where no construction 

activity is planned or will occur at a later date. 

• Limits of clearing and grubbing should be clearly marked prior to any grading or clearing activities. 

• Preservation of existing vegetation shall conform to scheduling requirements and local permitting 

agency requirements. 

Design and Layout 

• Mark areas to be preserved with temporary fencing made of orange polypropylene that is stabilized 

against ultraviolet light. The temporary fencing shall be at least 3.2. ft (1 meter) tall and shall have 

openings not larger than 2 in by 2 in (50 mm by 50 mm). 

• Fence posts shall be either wood or metal as appropriate for the intended purpose. The post spacing 

and depth shall be adequate to completely support the fence in an upright position. 

• Minimize the disturbed areas by locating temporary roadways to avoid stands of trees and shrubs and 

to follow existing contours to reduce cutting and filling. 

• Consider the impact of grade changes to existing vegetation and the root zone. 

• Construction materials, equipment storage, and parking areas shall be located where they will not 

cause root compaction. 

• Keep equipment away from trees to prevent trunk and root damage at least to drip line. 

• Maintain existing irrigation systems. 

• Employees and subcontractors shall be instructed to honor protective devices. No heavy equipment, 

vehicular traffic, or storage piles of any construction materials shall be permitted within the drip line 

of any tree to be retained. Removed trees shall not be felled, pushed, or pulled into any retained trees. 

Fires shall not be permitted within 100 ft (30 m) of the drip line of any retained trees. No toxic or 

construction materials (including paint, acid, nails, gypsum board, chemicals, fuels, and lubricants) 

shall be stored within 50 ft (15 m) of the drip line of any retained trees, nor disposed of in any way 

which would injure vegetation. 

Trenching and Tunneling 

• Trenching shall be as far away from tree trunks as possible, usually outside of the tree drip line or 

canopy. Curve trenches around trees to avoid large roots or root concentrations. If roots are 

encountered, consider tunneling under them. When trenching and/or tunneling near or under trees to 

be retained, tunnels shall be at least 18 in (450 mm) below the ground surface, and not below the tree 

center to minimize impact on the roots. 

• Tree roots shall not be left exposed to air; they shall be covered with soil as soon as possible, 

protected, and kept moistened with wet burlap or peat moss until the tunnel and/or trench can be 

completed. 
PRESERVATION OF EXISTING VEGETATION / BUFFER STRIPS – EP-2 

Page 2 of 2 

• The ends of damaged or cut roots shall be cut off smoothly. 

• Trenches and tunnels shall be filled as soon as possible or in accordance with local requirements. 

Careful filling and tamping will eliminate air spaces in the soil which can damage roots. 

• Remove any trees intended for retention if those trees are damaged seriously enough to affect their 

survival. 

• After all other work is complete, fences and barriers shall be removed last. This is because protected 

trees may be destroyed by carelessness during the final cleanup and landscaping. 

Vegetative Buffer Strips: 

• Vegetated buffer strips (vegetated filter strips, filter strips, and grassed filters) are vegetated surfaces 

that are designed to treat sheet flow from adjacent surfaces. Filter strips function by slowing runoff 

velocities and allowing sediment and other pollutants (e.g., total and dissolved metals) to settle and 

partially infiltrate into underlying soils. With proper design and maintenance, filter strips can provide 

relatively high pollutant removal. 

• Designate watercourse buffer-filter strips on the site design plan. 

• The width of a buffer strip (i.e., flow path length) shall be maximized to the extent feasible with a 15 

foot suggested minimum width. Buffer strips shall be sized in accordance with site conditions and 

local requirements. 
TOPSOILING – EP-4 

Page 1 of 1 

Topsoiling is the practice of stripping and stockpiling existing topsoil and then spreading it in graded 

areas to encourage future vegetation growth. 

Construction Specifications: 

Planning:

• Determine whether the quality and quantity of available topsoil justifies selective handling and in 

consideration of local requirements. 

• Soils of the textural class of loam, sandy loam, and silt loam are best; sandy clay loam, silty clay 

loam, clay loam, and loamy sand are fair. Do not use heavy clay and organic soils such as peat or 

muck as topsoil. 

Stripping and Stockpiling: 

• Strip topsoil only from those areas that will be disturbed by excavation, filling, or compacting by 

equipment. A 4-6 inch (0.1-0.2 m) stripping depth is common, but depth varies depending on the site. 

• Determine depth of stripping by taking soil cores at several locations within each area to be stripped. 

Topsoil depth generally varies along a gradient from hilltop to toe of the slope. 

• Put sediment basins, diversions, and other controls into place before stripping. 

• Select stockpile location to avoid slopes, natural drainage ways, and traffic routes. On large sites, respreading is easier and more economical when topsoil is stockpiled in small piles located near areas 

where they will be used. 

• Use sediment fences or other barriers where necessary to retain sediment. 

• Protect topsoil stockpiles by temporarily seeding and/or mulching as soon as possible to assure the 

stored material is not unnecessarily exposed and allowed to erode. Use locally grown and native seed 

stocks when possible that are mycorrhizal-dependent. 

• Topsoil stockpiles should be low n height (ideally <1 meter) and flat and be used within 6 months to 

promote healthy soil organisms and microbes. Stockpiles not used within 6 months should be 

reseeded with a species that is mycorrhizal-dependent to avoid the development of anaerobic 

conditions in the stockpile. In addition, topsoil stockpiles can be turned periodically to keep 

organisms alive for larger stockpiles and during extremely hot weather. 

Spreading: 

• Before spreading topsoil, establish erosion and sediment control practices such as diversions, berms, 

dikes, waterways, and sediment basins. 

• Where the pH of the existing subsoil is 6.0 or less, or the soil is composed of heavy clays, incorporate 

agricultural limestone in amounts recommended by soil tests or specified for the seeding mixture to 

be used. Incorporate lime to a depth of at least 2 inches (51 mm) by disking. Ensure that all of the 

lime mixture is incorporated into the soil to minimize direct contact with storm water runoff and 

handle lime in accordance with manufacturing recommendations or NS-7 (Materials Delivery and 

Storage). 

• Immediately prior to spreading the topsoil, loosen the subgrade by disking or scarifying to a depth of 

at least 3 inches (76 mm), to ensure bonding of the topsoil and subsoil. If no amendments have been 

incorporated, loosen the soil to a depth of at least 6 inches (0.15 m) before spreading topsoil. 

• Uniformly distribute topsoil to a minimum compacted depth of 2 inches (51 mm) on 3:1 slopes and 4 

inches (0.1 m) on flatter slopes. 

• Do not spread topsoil while it is frozen or muddy or when the subgrade is wet or frozen. 

• Correct any irregularities in the surface that result from topsoiling or other operations to prevent the 

formation of depressions or water pockets. 

• Compact the topsoil enough to ensure good contact with the underlying soil, but avoid excessive 

compacting, as it increases runoff and inhibits seed germination. Light packing with a roller is 

recommended where high maintenance turf is to be established. 
TEMPORARY SEEDING AND PLANTING EP-5

Page 1 of 4 

Temporary seeding and planting consists of the establishment of temporary vegetative cover on disturbed 

areas to reduce erosion by seeding with appropriate and rapidly growing annual grasses and forbs. 

Construction Specifications 

Conditions Where Practice Applies 

• Cleared or graded areas that are exposed and subject to erosion for extended periods (e.g., 14 to 

30 days depending on local requirements). 

• Cleared or graded areas exposed to seasonal rains. 

• Areas that will not be subjected to heavy wear by construction equipment. 

• Temporary seeding is encouraged whenever possible to aid in reducing erosion on construction 

sites. Temporary seeding is an important component of "phased" construction activities. 

Permanent seeding shall be applied to areas intended to be left dormant for a year or more. 

The following chart shows recorded shear stress and velocities withstood by grass mixtures and 

applications. 

Shear Velocity Bank Material/Protection

lb/ft2 N/m2 ft/s m/s

Reference

Sandy Loam 0.0167 1.75 0.53 Design Temple, 1980

Silt Loam 0.0218 2 0.61 Design Temple, 1980

Alluvial silts 0.0218 2 0.61 Design Temple, 1980

Ordinary firm loam 0.0341 2.5 0.76 Design Temple, 1980

Very light loose sand, no 

vegetation or protection 1-1.5 .3-.46 Limit Fortier & Scobey, 1926

Average sandy soil 2-2.5 .61-

.76 Limit Fortier & Scobey, 1926

Stiff clay, ordinary gravel soil 4-5 1.2-

1.5 Limit Fortier & Scobey, 1926

Bermuda grass, erosion resistant 

soils, 0-5% slope 8 2.4 Design USDA, 1947

Bermuda grass, erosion resistant 

soils, 5-19% slope 7 2.1 Design USDA, 1947

Bermuda grass, erosion resistant 

soils, over 10% slope 6 1.8 Design USDA, 1947

Bermuda grass, easily eroded soils, 

0-5% slope 6 1.8 Design USDA, 1947

Bermuda grass, easily eroded soils, 

5-10% slope 5 1.5 Design USDA, 1947

Bermuda grass, easily eroded soils, 

over 10% slope 4 1.2 Design USDA, 1947

Grass mixture, erosion resistant 

soils, 0-5% slope 5 1.5 Design USDA, 1947

Grass mixture, erosion resistant 

soils, 5-10% slope 4 1.2 Design USDA, 1947

Grass mixture, easily eroded soils, 

0-5% slope 4 1.2 Design USDA, 1947

Grass mixture, easily eroded soils, 

5-10% slope 3 0.91 Design USDA, 1947
TEMPORARY SEEDING AND PLANTING EP-5

Page 2 of 4 

1” riprap 0.33 16 Limit Chen & Cotton, 1988

2” riprap 0.67 33 Limit Chen & Cotton, 1988

6” riprap 2 98 Limit Chen & Cotton, 1988

12” riprap 4 196 Limit Chen & Cotton, 1988

Dense sod, fair condition (class 

D/E), moderately cohesive soil 0.35 17 Limit Austin & Theisen, 1994

Bermuda grass, fair stand <12 cm 

tall, dormant 0.9 44 Limit Parsons, 1963

Bermuda grass, good stand <12 cm 

tall, dormant 1.1 54 Limit Parsons, 1963

Bermuda grass, excellent stand 20 

cm tall, dormant 2.7 132 Limit Parsons, 1963

Bermuda grass, excellent stand 20 

cm tall, green 2.8 137 Limit Parsons, 1963

Bermuda grass, excellent stand 

>20 cm tall, green 3.2 156 Limit Parsons, 1963

12.5 cm of excellent growth of 

grass/woody veg on outside bend 1 49 Limit Parsons, 1963

Flume trials, fabric reinforced 

vegetation – failed after 50 hours 5 244 Limit Theisen, 1992

Flume trials, fabric reinforced 

vegetation – failed after 8 hours 8 391 Limit Theisen, 1992

Sod revetment, short period of 

attack 0.41 20.09 Design Schoklitsch, 1937

Wattle (coarse sand between) 0.2 9.8 Design Schoklitsch, 1937

Wattles (gravel between) 0.31 15.19 Design Schoklitsch, 1937

Wattles (parallel or oblique to 

current) 1 49 Design Schoklitsch, 1937

Fascine revetment 1.4 68.6 Design Schoklitsch, 1937

Cribs with stone 30 1470 Design Schoklitsch, 1937

Turf (immediately after 

construction) 0.2 10 Limit Schiechtl & Stern, 1994

Turf (after 3-4 seasons) 2.04 100 Limit Schiechtl & Stern, 

1994

Site Considerations 

• Prior to seeding, install necessary erosion control practices such as temporary continuous berms, 

diversion dikes, channels, and sediment basins. 

• Proper seedbed preparation and the use of quality seed are important in this practice just as in 

permanent seeding. Failure to carefully follow sound agronomic recommendations will often 

result in an inadequate stand of vegetation that provides little or no erosion control. 

• Annual plants which sprout rapidly and survive for only one growing season are suitable for 

establishing temporary vegetative cover. Consider mixes because they are more adaptable than 

single species. 

• Check with local municipalities for local specifications and requirements prior to seeding and 

planting. 
TEMPORARY SEEDING AND PLANTING EP-5

Page 3 of 4 

• Mulching is commonly used with seeding practices for temporary cover and to aid in the 

establishment of vegetation. 

• Temporary seeding also prevents costly maintenance operations on other erosion control systems. 

For example, sediment basin maintenance (clean-out) will be reduced if the drainage area has 

temporary vegetative cover when grading and construction are not taking place. (Temporary 

seeding is essential to preserve the integrity of earthen structures used to control sediment, such 

as diversion dikes, and sediment basins) 

• To reduce the amount of fertilizer, pesticides and other inputs needed, choose adapted varieties 

based on environmental conditions, management level desired, and the intended use. Check with 

local municipalities prior to use of fertilizer or pesticides. 

Timing

The proper time to seed is dependent upon the climate of the area and the species of seed selected. To 

determine seeding dates for temporary cover, consult the seed supplier. 

Seed Mixes 

• All seed should be selected in accordance with local municipality requirements. 

• Select plants appropriate to the season and site conditions. 

• The seeding rates are based on a minimum acceptable pure live seed (PLS) of 80%. When PLS is 

below 80% adjust rates accordingly. 

• Legumes should be inoculated with the proper rhizobium bacteria before planting. Pellet 

inoculated seed can be purchased or inoculation can be done in the field. Use only fresh, age 

dated inoculate specifically labeled for use with the legume you are using. 

Site Preparation

• Grade as needed and feasible to permit the use of equipment for seedbed preparation. 

• Install needed erosion control practices, such as sediment basins, diversion dikes and channels, 

prior to seeding. Divert concentrated flows away from seeded areas. 

• Soil tests should be done to determine the nutrient and pH content of soil. Depending on the 

results of soil tests, soil management may be necessary to adjust the pH to between 6.5 and 7.0 

(for most conditions). All lime, fertilizer and other soil amendments should be added following 

sound soil management practices. 

• Surface roughening: If the area has been recently loosened or disturbed, no further roughening is 

required. When the area is compacted, crusted or hardened the soil should be loosened with 

discing, raking or harrowing. Tracking with bulldozer cleats is very effective on sandy soils. 

• Hydroseeding and hydraulic planting generally require less seedbed preparation. 

• Generally, slopes steeper than 2:1 that cannot have good seedbed preparations with equipment 

will require hydraulic planting techniques. 

• Seed to soil contact is the key to good germination. Prepare a 3-5 inch (76-127 mm) deep 

seedbed, with the top 3-4 inches (76-102 mm) consisting of topsoil. Note that the earth bed upon 

which the topsoil is to be placed should be at the required grade. 

• The seedbed should be firm but not compact. The top 3 inches (76 mm) of soil should be loose, 

moist and free of large clods and stones. For most applications, all stones larger than 2 inches (51 

mm) in diameter, roots, litter and any foreign matter should be raked and removed. The topsoil 

surface should be in reasonably close conformity to the lines, grades and cross sections shown on 

the grading plans. 
TEMPORARY SEEDING AND PLANTING EP-5

Page 4 of 4 

Hydroseeding site in September 2003 December 2003 

April 2004 

Planting: 

• Seed should be applied as soon after seedbed preparation as possible, when the soil is loose and 

moist. 

• Always apply seed before mulch, unless seed is applied with a hydraulic matrix or bonded fiber 

matrix (See BMP EP-8, Mulches). 

• Apply seed at the rates specified using calibrated spreaders, cyclone seeders, mechanical drills, or 

hydroseeders so the seed is applied uniformly on the site. 

• If seed is applied with a bonded fiber matrix, apply BFM from multiple directions to adequately 

cover the soil. Application from a single direction can result in shadowing, uneven coverage, and 

failure of the BFM. 

• Apply fertilizer if required. Seed and fertilizer should be incorporated into the soil by raking or 

chain dragging, or otherwise floated, then lightly compacted to provide good seed-soil contact. 

• Straw mulch, erosion control blankets or mulch and tackifiers/soil binders should be applied over 

the seeded areas. 

Inspection and Maintenance: 

• Newly seeded areas need to be inspected frequently to ensure the grass is growing. Areas that fail 

to establish cover adequate to prevent sheet and rill erosion will be reseeded as soon as such areas 

are identified. Spot seeding can be done on small areas to fill in bare spots where grass did not 

grow properly. 

• If the seeded area is damaged due to concentrated runoff, additional practices may be needed. 

• Temporary vegetated areas will be maintained until permanent vegetation or other erosion control 

practices can be established. 
PERMANENT SEEDING AND PLANTING EP-6 

Page 1 of 2 

Permanent seeding involves the establishment of a permanent, perennial vegetative cover on disturbed 

areas from seed. Refer to BMP EP-21 for installation of sod. Planting of shrubs, trees, and container 

plants should be conducted in accordance with project landscaping specifications and local requirements. 

The use of native, indigenous, or naturally-occurring grasses is recommended for biotechnical works. 

These “native” grasses have evolved in a manner that will not compete with or preclude the 

establishment, or natural recruitment, of naturally-occurring woody vegetation. Establishment of 

permanent vegetation provides natural erosion and sediment control by trapping particulates, slowing 

runoff velocities and enhancing infiltration. Permanent vegetation also is beneficial for long-term 

aesthetics and wildlife habitat. 

Construction Specifications 

Conditions Where Practice Applies 

• Graded, final-graded or cleared areas where permanent vegetative cover is needed to stabilize the 

soil. Permanent seeding with perennial grasses is recommended when fibrous and deeply rooted 

are needed to provide slope and soil reinforcement. 

• Slopes designated to be treated with erosion control blankets should be seeded first. 

• Grass-lined channels or waterways designed to be treated with turf reinforcement mats, fiber 

roving systems, or other channel liners will require special grass blends. 

Materials 

Proper seed selection is very important. Choose climatically adapted perennial species that are longlived, hearty and require low inputs of fertilizer, irrigation and mowing. You may consider a locally 

occurring species for native grass establishment. Consider seed blends because they are more adaptable. 

Use seeds appropriate to the season and site conditions. Use a seed blend, which include annuals, 

perennials and legumes. Legumes should be inoculated with the proper rhizobium bacteria before 

planting. Pellet inoculated seed can be purchased or inoculation can be done in the field. Unless 

otherwise specified by local requirements, use seed rates based on minimum pure live seed (PLS) of 80%. 

When PLS is below 80% adjust rates accordingly. Consult a local seed supplier, landscape architect, or 

erosion control specialist for appropriate seed blends. Seed should be selected in accordance with local 

regulations. 

Installation 

The probability of successful plant establishment can be maximized through good planning, knowledge of 

soil characteristics, selection of appropriate seed blends for the site, good seedbed preparation, and timely 

planting. Prior to seeding, install necessary erosion control practices such as diversion dikes, channels, 

and sediment basins. Site area should be at final grade and not be disturbed by future construction 

activities. 

Timing 

• Apply permanent seeding on areas left dormant for 1 year or more. 

• Apply permanent seeding when no further disturbances are planned. 

• To determine optimum seeding schedule, consult a local agronomist or erosion control specialist. 

• Apply permanent seeding before seasonal rains or freezing weather is anticipated. 

• Use dormant seeding for late fall or winter seeding schedules. 

Seed Mixes 

• Use seeds appropriate to the season and site conditions. 

• Consult local agronomist or erosion control specialists for seed mix. 

• Use a seed blend to include annuals, perennials and legumes. 
PERMANENT SEEDING AND PLANTING EP-6 

Page 2 of 2 

• Use seed rates based on pure live seed (PLS) of 80%. When PLS is below 80% adjust rates 

accordingly. 

Site Preparation 

• Bring the planting area to final grade and install the necessary erosion control BMPs (i.e., 

sediment basins and temporary diversion dikes). 

• Divert concentrated flows away from the seeded area. 

• Conduct soil test to determine pH and nutrient content. Roughen the soil by harrowing, tracking, 

grooving or furrowing. 

• Apply amendments as needed and permitted by local municipalities to adjust pH to 6.0-7.5. 

Incorporate these amendments into the soil. Prepare a 3-5 in (76-127 mm) deep seedbed, with the 

top 3-4 in (76-102 mm) consisting of topsoil. The seedbed should be firm but not compact. The 

top three inches of soil should be loose, moist and free of large clods and stones. The topsoil 

surface should be in reasonably close conformity to the lines, grades and cross sections shown on 

the grading plans. 

Planting: 

• Seed to soil contact is the key to good germination. 

• Seed should be applied immediately after seedbed preparation while the soil is loose and moist. If 

the seedbed has been idle long enough for the soil to become compact, the topsoil should be 

harrowed with a disk, spring tooth drag, spike tooth drag, or other equipment designed to 

conditions the soil for seeding. 

• Harrowing, tracking or furrowing should be done horizontally across the face of the slope. 

• Always apply seed before applying mulch, unless using a hydraulic matrix or bonded fiber matrix 

where seed is mixed with mulch prior before application. 

• Apply seed at the rates specified using calibrated seed spreaders, cyclone seeders, mechanical 

drills, or a hydroseeder so the seed is applied uniformly on the site. 

• Broadcast seed should be incorporated into the soil by raking or chain dragging, and then lightly 

compacted to provide good seed-soil contact. 

• Apply fertilizer as specified and allowed by local municipalities. 

• Apply mulch or erosion control blanket, as specified, over the seeded areas. 

Inspection and Maintenance 

• Newly seeded areas need to be inspected frequently to ensure the grass is growing. 

• If the seeded area is damaged due to runoff, additional stormwater measures may be needed. 

• Spot seeding can be done on small areas to fill in bare spots where grass did not grow properly. 

• Irrigation/watering should be used as necessary and recommended to establish vegetation in 

accordance with local regulations. 
MULCHES – EP-8 

Page 1 of 3 

Mulching is the process of applying bulk materials to the soil surface to reduce rainfall impact, increase 

infiltration and in some cases, aid in revegetation. Common types of mulch include vegetable fibers, 

green material, hydraulic mulches from recycled paper or wood fibers, hydraulic matrices, and straw 

mulch. Mulches may include a tackifier to increase the longevity of the application. 

Construction Specifications: 

• Mulch should be used for temporary applications only; permanent erosion control measures should 

also be applied. 

• Prior to application, roughen embankment and fill areas by rolling with a crimping or punching type 

roller or by track walking. Track walking shall only be used where other methods are impractical. 

• Avoid mulch over-spray onto the traveled way, sidewalks, lined drainage channels, and existing 

vegetation. 

Wood Fiber Mulch – Materials and Application Procedures 

• Wood fiber mulch is a component of hydraulic applications. It is usually used in combination with 

seed and fertilizer. It is typically applied at the rate of 2,000 to 4,000 lb/ac (2,250 to 4,500 kg/ha) with 

0-5% by weight of a stabilizing emulsion or tackifier (e.g., guar, psyllium, acrylic copolymer) and 

applied as a slurry. This type of mulch is manufactured from wood or wood waste from lumber mills 

or from urban sources. 

• Wood fiber mulch can be specified with or without a tackifier; previous work has shown that wood 

fiber mulches with tackifiers have better erosion control performances. 

• Materials for wood fiber based hydraulic mulches and hydraulic matrices shall conform to Oregon 

DOT Standard Specifications Sections 01030.15 and 01030.16 and local municipality requirements 

and specifications. 

Recycled Paper Mulch – Materials and Application Procedures 

• Recycled paper mulch contains fibers of shorter length than wood fiber mulches and is typically made 

from recycled newsprint, magazine, or other waste paper sources. It is a component of hydraulic 

applications and is usually used in combination with seed and fertilizer. It is typically applied at the 

rate of 1 to 2 tons/ac (2,250 to 4,500 kg/Ha). It can be specified with or without a tackifier. 

Green Material – Materials and Application Procedures 

• This type of mulch is produced by recycling vegetation trimmings such as grass, shredded shrubs and 

trees. Methods of application are generally by hand, although pneumatic methods are available. 

Mulch shall be composted to kill weed seeds. 

• It may be used as a temporary ground cover with or without seeding. 

• The green material shall be evenly distributed on site to a depth of not more than 2 in (50 mm). 

Hydraulic Matrix – Materials and Application Procedures 

• Hydraulic matrix is a combination of wood fiber mulch and a tackifier applied as a slurry. It is 

typically applied at the rate of 2,000 to 4,000 lb/ac (2,250 to 4,500 kg/ha) with 5-10% by weight of a 

stabilizing emulsion or tackifier (e.g., guar, psyllium, acrylic copolymer). 

• Materials for wood fiber based hydraulic mulches and hydraulic matrices shall conform to Oregon 

DOT Standard Specifications Sections 01030.15 and 01030.16 and local municipality requirements 

and specifications. 

• Hydraulic matrices require 24 hours to dry before rainfall occurs to be effective unless approved by 

Oregon DEQ. 

Bonded Fiber Matrix – Materials and Application Procedures 
MULCHES – EP-8 

Page 2 of 3 

• Bonded fiber matrix (BFM) is a hydraulically-applied system of fibers and adhesives that upon drying 

forms an erosion-resistant blanket that promotes vegetation, and prevents soil erosion. BFMs are 

typically applied at rates from 3,000 to 4,000 lb/ac (3,400 to 4,500 kg/ha) based on the 

manufacturer’s recommendation. The biodegradable BFM is composed of materials that are 100% 

biodegradable. The binder in the BFM shall also be biodegradable and shall not dissolve or disperse 

upon re-wetting. Typically, biodegradable BFMs should not be applied immediately before, during or 

immediately after rainfall if the soil is saturated. Depending on the product, BFMs require 12 to 24 

hours to dry to become effective. 

• BFM should be selected and used in accordance with local municipality requirements and 

specifications. 

• Apply bonded fiber matrices from multiple directions to adequately cover the soil. Application from 

a single direction can result in shadowing, uneven coverage, and failure of the BFM. 

Straw Mulch - Materials 

• All materials shall conform to Oregon DOT Standard Specifications Sections 01030.15(b) and any 

local municipality requirements. 

• Straw shall be derived from wheat, rice, or barley. The straw mulch contractor shall furnish evidence 

that clearance has been obtained from the County Agricultural Commissioner, as required by law, 

before straw obtained from outside the county in which it is to be used is delivered to the site of the 

work. Straw that has been used for stable bedding shall not be used. 

Straw Mulch – Application Procedures 

• Apply loose straw at a minimum rate of 4,000 lb/ac (3,570 kg/ha), or as indicated in the project’s 

Erosion and Sediment Control Plan, either by machine or by hand distribution. 

• The straw mulch must be evenly distributed on the soil surface. 

• Avoid placing straw onto the traveled way, sidewalks, lined drainage channels, walls, and existing 

vegetation. 

• Anchor the mulch in place by using a tackifier (preferred) or by “punching” it into the soil 

mechanically (incorporating). 

• If using a tackifier to anchor the straw mulch in lieu of incorporation, roughen embankment or fill 

areas by rolling with a crimping or punching-type roller or by track walking before placing the straw 

mulch. Track walking should only be used where rolling is impractical. 

• A tackifier acts to glue the straw fibers together and to the soil surface. The tackifier shall be selected 

based on longevity and ability to hold the fibers in place (see Oregon DOT Standard Specifications 

Section 01030.16). 

• A tackifier is typically applied at a rate of 125 lb/ac (140 kg/ha). In windy conditions, the rate is 

typically 178 lb/ac (200 kg/ha). 

• Straw mulch with tackifier shall not be applied during or immediately before rainfall. 

• Methods for holding the straw mulch in place depend upon the slope steepness, accessibility, soil 

conditions and longevity. If the selected method is incorporation of straw mulch into the soil, then do 

as follows: 

• Applying and incorporating straw shall follow the requirements in Oregon DOT Standard 

Specifications Section 01030.48(b) and any local municipality’s specifications and requirements. 

• On small areas, a spade or shovel can be used. 

• On slopes with soils, which are stable enough and of sufficient gradient to safely support 

construction equipment without contributing to compaction and instability problems, straw may 

be “punched” into the ground using a knife-blade roller or a straight bladed coulter, known 

commercially as a “crimper.” 

• On small areas and/or steep slopes, straw may also be held in place using plastic netting or jute. 

The netting shall be held in place using 11 gauge wire staples, geotextile pins or wooden stakes. 

Refer to EP-10, “Erosion Control Blankets and Mats.” 
MULCHES – EP-8 

Page 3 of 3 

Inspection and Maintenance: 

• Maintain an unbroken, temporary mulched ground cover throughout the period of construction when 

the soils are not being reworked. Inspect before expected rain events and repair any damaged ground 

cover and re-mulch exposed areas of bare soil. 

• The key consideration in maintenance and inspection is that the mulch needs to last long enough to 

achieve erosion control objectives. Mulch is a temporary ground cover and not suitable for long-term 

erosion control. 

• Maintain an unbroken, temporary mulched ground cover while disturbed soil areas are non-active. 

Repair any damaged ground cover and re-mulch exposed areas. 

• Reapplication of mulch and tackifier may be required by Oregon DEQ and local municipalities to 

maintain effective soil stabilization over disturbed areas and slopes. 

• After any rainfall event, maintain all slopes to reduce or prevent erosion.
Oregon DEQ 

OREGON MANUAL-APPENDICES.DOC Erosion and Sediment Control Manual

 April 28, 2005

APPENDIX F 

SEDIMENT CONTROL BMPS 

 SC-1 Sediment Fence 

 SC-2 Sand Bag Barrier 

 SC-3 Gravel Bag Berm 

 SC-4 Straw Bale Dike 

 SC-5 Rock or Brush Filters 

 SC-6 Compost Berms and Socks 

 SC-7 Fiber Rolls or Wattles 

 SC-8 Storm Drain Inlet Protection 

 SC-9 Temporary Sediment Basin 

 SC-10 Entrance/Exit Tracking Controls 

 SC-11 Entrance/Exit Tire Wash 

 SC-12 Undercut Lots
SEDIMENT FENCE – SC-1 

Page 1 of 3 

Construction Specifications: 

Local municipality requirements should be checked to determine if local requirements differ from this 

BMP with respect to specific types of sediment fence allowed and methods of installation. 

Prefabricated Sediment Fence

Prefabricated fence fabric shall consist of material approved by its manufacturer for use in sediment fence 

applications and shall include pre-fabricated pockets for stake installation. Select standard duty or heavy 

duty prefabricated sediment fence based on criteria shown below: 

Standard Duty Sediment Fence 

• Slope of area draining to fence is 4H:1V or less - Use is generally limited to less than five months 

• Area draining to fence produces moderate sediment loads 

• Use prefabricated standard duty sediment fence. 

• Layout in accordance with typical layout - Install in accordance with attached detail. 

Heavy Duty Sediment Fence 

• Slope of area draining to fence is 1H:1V or less 

• Use generally limited to eight months. Longer periods may require fabric replacement 

• Area draining to fence produces moderate sediment loads 

• Use prefabricated heavy duty sediment fence. Heavy duty sediment fences typically have the 

following physical characteristics: 

o Fence fabric has greater tensile strength than other fabric types available from manufacturer 

o Fence fabric has a greater permittivity than other fabric types available from manufacturer 

o Fence fabric may be reinforced with a backing or additional support to increase fabric strength 

o Posts may be spaced closer together than other pre- manufactured sediment fence types available 

from manufacturer. 

• Layout in accordance with attached typical layout. 

• Install in accordance with attached standard details. 

Installation 

• Install sediment fence along a level contour, with the last 6 ft of fence turned up slope. Except for the 

ends, the difference in elevation between the highest and lowest point along the top of the sediment 

fence shall not exceed one-third the fence height. 

• Generally, should be used in conjunction with erosion source controls up slope to provide effective 

control. 

Minimum BMP standards that apply to Prefabricated Sediment Fence are provided on the 

attached details.

Common Reasons/Circumstances for Failure 

• The most common reasons for sediment fence failure are due to improper installation and poor 

maintenance. In particular, the toe must be securely trenched into the slope and accumulated 

sediment should be removed when accumulation reaches 1/3 of the fence height. 

Inspection and Maintenance: 

• Repair undercut sediment fences. 
SEDIMENT FENCE – SC-1 

Page 2 of 3 

• Repair or replace split, torn, slumping, or weathered fabric. 

• Inspect sediment fence before, during, and after storm events. 

• Any required repairs shall be performed as soon as possible. 

• Remove sediment when accumulation reaches 1/3rd the fence height. 

• The removed sediment shall be incorporated in the project, disposed of properly, or appropriately 

stabilized with vegetation. 

• Remove sediment fence when no longer needed and upslope area has been stabilized. Fill and 

compact post holes and anchorage trench, remove sediment accumulation, and grade fence alignment 

to blend with adjacent ground. 
SEDIMENT FENCE – SC-1 

Page 3 of 3 
COMPOST BERMS AND SOCKS SC-6

Page 1 of 6 

Construction Specifications

A compost filter berm is a trapezoidal berm applied by a blower and a compost sock is compost material 

encased in mesh to form a tube/roll. Both techniques intercept sheet flow and pond runoff, allowing 

sediment to fall out of suspension, and often filtering sediment as well. Compost berms and socks 

provide an environmentally-sensitive and cost-effective alternative to sediment fence. 

Advantages

• Compost berms and compost socks made from 

biodegradable mesh sometimes offer a better 

solution than sediment fence and other sediment 

control methods, because compost does not require 

any special trenching, construction, or removal, 

unlike straw bales, sediment fence or coir rolls. This 

makes the technique very cost-effective. 

• Compost is organic, biodegradable, renewable, and 

can be left onsite. This is particularly important 

below embankments near streams, as re-entry to 

remove or maintain the berm can cause additional 

disturbance. Sediment fence has to be disposed of 

in landfills and is often left abandoned on jobsites. 

• Compost does not leach nutrients. Field tests in 

Connecticut have shown that run-off from compost 

treated sites has very low soluble salts, and all 

metals and nutrients are well within pollution 

leaching limits. 

• Compost berms can be easily and quickly fixed should something happen to them in the course of 

construction. Compost socks withstand heavy machinery, but frequent disturbance can decrease 

the effectiveness of the sock. 

• Mechanical compost spreaders for compost berms are commercially available and are widely 

used in the Pacific Northwest. 

• When properly made, compost is full of nutrients and micro-organisms that stimulate turf and 

increase resistance to diseases. Compost binds heavy metals and can break down hydrocarbons 

into carbon, salts and other innocuous compounds.
COMPOST BERMS AND SOCKS SC-6

Page 2 of 6 

Design Considerations 

Compost filter berms and socks should be used at the base of slopes 2:1 or less. There are many types of 

compost, all with different properties, so it is best to determine what application the compost is being 

used for. For compost berms and socks, compost should have the following specifications:

• Compost needs to be stable and mature.

• Particle size: Compost should consist of both large and small pieces for maximum filtration. 

Finer grades (screened through 3/8-1/2”) are better for vegetation establishment, long term plant 

nutrients, and increased infiltration rates. The coarser grades (screened 2-3”) are better for 

increased filtration, and are less likely to be disturbed by rainfall and runoff. For berms, the ratio 

of coarse and fine material should be 1:1. No particle should be greater than 3”. 

• The recommended moisture content ranges from 20-50%. Compost that is too dry is harder to 

apply, while that which is too wet is heavier and harder to transport. In drier areas, use compost 

with a higher moisture content; in wet areas, use the drier compost, as it will absorb water. 

• Organic matter content: The percentage of carbon based materials in finished compost should 

range between 40-70%. However, Texas DOT specifies no less than 70%. 

• The pH should be between 5.0 and 8.5. 

• Nitrogen Content: 0.5-2.0%. 

• Compost should have a minimum of soluble salts, as these can inhibit vegetation establishment. 

These levels should be between 4.0 and 6.0 mmhos/cm. 

• Compost must be weed and pesticide free, with manmade materials comprising less than 1%. 

Construction Specifications 

• For compost berms on slopes of 3:1 or less, 

install a compost berm 1-2 ft high and 2-4 ft 

wide at the base. For maximum filtration 

properties, install berm in a trapezoidal 

shape, with a 4-6 ft base, and a 2-3 ft wide 

top. Larger berms should be used for 

steeper slopes. The basic rule of thumb is 

that the base should be twice the height of 

the berm. 

• Typically, compost socks can handle the 

same water flow or slightly more than sediment fence. However, the installation technique is 

especially important for them to work effectively. For most applications, standard sediment fence 

is replaced with 12” compost socks. 

o When placed on level contours sheet flow of water should be perpendicular to the 

compost sock at impact and un-concentrated. 

o Place compost socks at a 5’ or greater distance away from the toe of slopes to maximize 

space available for sediment deposition. 

o In order to prevent water flowing around the ends of compost socks, point the ends 

upslope to place them at a higher elevation. 
COMPOST BERMS AND SOCKS SC-6

Page 3 of 6 

• Compost Berms and Socks can be placed around the perimeter of affected areas, if the area is flat 

or the perimeter is on contour. Berms and socks should be placed using ‘smiles’ and j-hooks. Do 

not place berms and socks where they cannot pond water. 

• For steeper slopes, an additional berm or sock can be constructed on the top of the slope. 

• Compost berms and socks can be seeded during application. However, field tests indicate that it 

is best to have only a thin layer of compost over the seed in compost berms. Slopes seeded with 

2- 4” of compost over the seed had less vegetation establishment than slopes with less compost 

over the seed. 

• Do not use compost berms and socks in areas of concentrated flow, as they are intended to control 

and filter sheet flow only. 

• Tackifiers may be applied to berms if needed to enhance performance. 

Inspection and Maintenance

• Compost berms and socks shall be inspected after each storm event and reapplied if necessary. 

• Sediment retained by the berm or sock shall be removed when it has reached 1/3 of the exposed 

height of the berm. Alternatively, the sediment and berm or sock can be stabilized with 

vegetation at the end of construction. 

• Berms can be left onsite and seeded, or spread out in place as a soil enhancement. 
COMPOST BERMS AND SOCKS SC-6

Page 4 of 6 
COMPOST BERMS AND SOCKS SC-6

Page 5 of 6 

 
COMPOST BERMS AND SOCKS SC-6

Page 6 of 6 

 
FIBER ROLLS OR WATTLES SC-7 

Page 1 of 3

Construction Specifications 

Fiber rolls are manufactured from biodegradable fibers (such as weed-free rice straw) that are wrapped in 

photo degradable netting. They range from approximately 8 to 20 inches in diameter by 25-30 feet (8-9 

m) long. Rolls are placed and staked along the contour of newly constructed or disturbed slopes, in 

shallow trenches. Fiber rolls reduce slope length, and are intended to capture and keep sediment on the 

slopes. Fiber rolls are useful to temporarily stabilize slopes by reducing soil creep, and sheet and rill 

erosion until permanent vegetation can be established. Fiber rolls can catch soil that is moved down the 

slope by the freeze/thaw processes. Organic matter and seeds are trapped behind the rolls, which provide 

a stable medium for germination. Rolls trap topsoil and retain moisture from rainfall, which aids in 

growth of seedlings planted upslope of the rolls. 

Design Considerations: 

• Sites appropriate for fiber rolls are: 

o Slopes susceptible to sheet and rill erosion. 

o Slopes producing dry ravel. 

o Slopes susceptible to freeze/thaw activity. 

o Slopes difficult to vegetate because of soil movement. 

• Fiber rolls are not intended for use in concentrated flow situations. 

• It is imperative, especially on steeper slopes, that a sufficiently deep trench is constructed in 

which to place the roll. Without the trench, the roll will not function properly, runoff will scour 

underneath it, and trees or shrubs planted behind the roll will not have a stable environment in 

which to become established. 

• Fiber rolls last an average of two years, depending on the fiber and mesh used in manufacturing. 

This is an important factor to consider when planning how long the slope will need to be 

mechanically stabilized. 

• Fiber rolls can be staked with live stakes if site conditions warrant. The moisture retained by the 

fiber roll will encourage cutting establishment. 

Advantages 

• Fiber rolls are a relatively low-cost solution to sheet and rill erosion problems. 

• They can replace sediment fences or straw bales on steep slopes. 

• Rolls are a short-term solution to help establish native vegetation. 

• Rolls store moisture for vegetation planted immediately upslope. 

• Plastic netting will eventually photo-degrade, eliminating the need for retrieval of materials after 

the fiber or straw has broken down. 
FIBER ROLLS OR WATTLES SC-7 

Page 2 of 3

• The fibers become incorporated into the soil with time, adding organic material to the soil and 

retaining moisture for vegetation.

Disadvantages 

• Rolls only function for one or two seasons. 

• Pilot holes through the rolls must be pre-driven with a metal rod. 

• If not installed properly with a sufficient trench, rolls may fail during the first rain event. 

• Fiber rolls may require maintenance to ensure that the stakes are holding and the rolls are still in 

contact with the soil. This is especially true on steep slopes in sandy soil. 

Installation 

• Prepare the slope before the installation procedure is started. 

• Shallow gullies should be smoothed as work progresses. 

• Dig small trenches across the slope on contour, to place rolls in. The trench should be deep 

enough to accommodate half the thickness of the roll. When the soil is loose and uncompacted, 

the trench should be deep enough to bury the roll 1/3 of its thickness because the ground will 

settle. 

• It is critical that rolls are installed perpendicular to water movement, and parallel to the slope 

contour. 

• Start building trenches and installing rolls from the bottom of the slope and work up. 

• Construct trenches at contour intervals 25-30 feet (8-10 m) apart depending on the steepness of 

the slope. The steeper the slope, the closer together the trenches should be. 

• Lay the roll along the trenches fitting it snugly against the soil. Make sure no gaps exist between 

the soil and the straw wattle. 

• Use a straight bar to drive holes through the roll and into the soil for the willow or wooden stakes. 

• Drive the stake through the prepared hole, and into the soil. Leave only 1 or 2 inches (25 or 51 

mm) of the stake exposed above roll. 

• Install stakes at least every 4 feet (1.2 m) apart along the length of the wattle. Additional stakes 

may be driven on the downslope side of the trenches on highly erosive or very steep slopes. 

Inspection and Maintenance 

• Inspect the rolls and the slopes after rain events and at the frequencies required by local 

municipalities. Make sure the rolls are in contact with the soil. 

• Repair any rills or gullies promptly. 

• Reseed or replant vegetation if necessary until the slope is stabilized. 
FIBER ROLLS OR WATTLES SC-7 

Page 3 of 3
TEMPORARY SEDIMENT BASIN –SC-9 

Page 1 of 3 

Construction Specifications: 

A sediment basin is a temporary basin with a controlled release structure, formed by excavating or 

constructing an earthen embankment across a waterway or low drainage area. Sediment basins may be 

placed where sediment laden storm water may enter a storm drain or watercourse, and around and/or upslope from storm drain inlet protection measures. The sediment basin shall follow one of the four design 

options summarized below: 

1. A sediment basin designed pursuant to local ordinance provided that the design efficiency is as 

protective, or more protective of water quality than Option No. 3. 

2. A sediment basin designed with a minimum capacity of 3,600 cubic feet of storage per acre of 

disturbed land in a watershed equivalent to or more efficient than Option No. 3. 

3. A sediment basin designed using the following equation: 

 (V) = 1.2Q/VsED where:

 V = settling zone volume, 

 Q = flow rate based on peak discharge from a specified design storm (where Q = CiA; see Section 

2.4), and 

 VsED = settling velocity of the design soil particle. 

4. A basin designed using an equivalent surface area design equation, equivalent to or more efficient 

than Option No. 3. 

• In accordance with the requirements of the NPDES 1200-C General Permit, all sediment basins must 

be designed by a professional engineer licensed in Oregon. 

• Construct the basin by excavating or building an embankment before any clearing or grading work 

begins. 

• Areas under the embankment and any structural works shall be cleared, grubbed and stripped of any 

vegetation and rootmat as shown on the grading plan. 

• In order to facilitate cleanout and restoration, the basin area shall be cleared, grubbed and stripped of 

any vegetation. 

• A cut-off trench shall be excavated along the centerline of the earth fill embankments. The minimum 

depth shall be 2 feet (0.6 m). The cut-off trench shall extend up both abutments to the spillway 

elevation. 

• Fill material for the embankment shall be clean mineral soil free of roots, woody vegetation, 

oversized stones, rocks or other objectionable material, and sufficiently moist for compaction. 

• Fill material shall be placed in 6 inch (0.2 m) lifts, continuous layers over the entire length of the fill. 

Compaction shall be obtained by routing the hauling equipment over the fill so that the entire surface 

of each layer of the fill is traversed by at least one wheel or tread track of the equipment, or by the use 

of a compactor. 

• The embankment should be constructed to an elevation of 10 percent higher than the design height to 

allow for settlement if compacting is achieved with hauling equipment. If compactors are used for 

compacting, the overbuild may be reduced to not less than 5 percent. The basin shall have means for 

dewatering within 7 days following a storm event. 

• The principal spillway riser shall be securely attached to the discharge pipe by welding all around. 

All connections shall be watertight. A trash rack shall be installed on the top of the riser to prevent 

clogging of the discharge pipe. 
TEMPORARY SEDIMENT BASIN –SC-9 

Page 2 of 3 

• The pipe and riser shall be placed on a firm, smooth soil foundation. The connection between the 

riser and the riser base shall be watertight. Pervious materials such as sand, gravel or crushed stone 

shall not be used as backfill around the pipe or anti-seep collars. 

• The fill material around the pipe spillway shall be placed in 4-inch (101 mm) layers and compacted 

under the shoulders and around the pipe to at least the same density as the adjacent embankment. A 

minimum of 2 feet (0.6 m) of compacted backfill shall be placed over the pipe spillway before 

crossing it with construction equipment. 

• Steel base plates shall have at least 2 1/2 feet (0.8 m) of compacted earth, stone or gravel over them to 

prevent flotation. 

• The emergency spillway shall not be installed in fill. Elevations, design width, and entrance and exit 

channel slopes are critical to the successful operation of the emergency spillway. 

• If used, baffles shall be constructed of 4 inch (101 mm) by 4 inch (101 mm) posts and of 4 foot (1.2 

m) by 8 foot (2.4 m) - 1/2inch (12.7 mm) exterior plywood. The posts shall be set at least 3 feet (0.9 

m) into the ground, no further apart than 8 feet (2.4 m) center to center, and shall reach a height 6 

inches (0.2 m) below the riser crest elevation. Alternatively, earthen berms, metal sheeting, or other 

methods may be used as approved by DEQ or the local agency in the project ESCP. 

• The embankment and emergency spillway shall be stabilized with vegetation immediately following 

construction. The outflow shall be provided with outlet protection to prevent erosion and scour of the 

embankment and channel. 

• Construction operations shall be carried out in such a manner that erosion and water pollution will be 

minimized. 

• Local and state requirements shall be met concerning fencing and signs warning the public of hazards 

of soft sediment and floodwater. 

Minimum BMP standards are provided on the following details. 

Inspection and Maintenance: 

• Inspect before during, and after each rain event. 

• All damages caused by soil erosion or construction equipment shall be repaired before the end of each 

working day. 

• Remove sediment when the sediment storage zone is half full. This sediment shall be placed in such 

a manner that it will not erode from the site. The sediment shall not be deposited downstream from 

the embankment or in or adjacent to a stream or floodplain. 

• When temporary structures have served their intended purpose and the contributing drainage area has 

been properly stabilized, the embankment and resulting sediment deposit shall be leveled or otherwise 

disposed of in accordance with the approved erosion and sediment control plan. 
TEMPORARY SEDIMENT BASIN –SC-9 

Page 3 of 3 
ENTRANCE / EXIT TRACKING CONTROLS – SC-10 

Page 1 of 3 

Tracking controls reduce offsite tracking of sediment and other pollutants by providing a stabilized 

entrance at defined construction site entrances and exits and/or providing methods to clean-up sediment or 

other materials to prevent them from entering a storm drain by sweeping or vacuuming. 

Construction Specifications:

• Stabilize entrances should be implemented on a project-by-project basis in addition to other BMPs. 

• Sweeping or vacuuming should be implemented when sediment is tracked from the project site onto 

public or private paved roads, typically at points of site exit. 

• Use stabilized entrances and/or sweeping at construction sites: 

o Where dirt or mud is tracked onto public roads; 

o Adjacent to water bodies; 

o Where poor soils are encountered, such as soils containing clay; 

o Where dust is a problem during dry weather conditions. 

Stabilized Construction Entrances 

• Limit the points of entrance/exit to the construction site by designating combination or single purpose 

entrances and exits. Require all employees, subcontractors and others to use them. Limit speed of 

vehicles to control dust. Clearly mark entrances and exits with appropriate signage. 

• Locate construction entrances and exits to limit sediment leaving the site and to provide for maximum 

utility by all construction vehicles. Avoid entrances which have steep grades and entrances at curves 

in public roads. 

• Grade each construction entrance/exit to prevent runoff from leaving the construction site. 

• Design stabilized entrance/exit to support heaviest vehicles and equipment that will use it. 

• Select construction access stabilization (aggregate, asphaltic concrete, concrete) based on longevity, 

required performance, and site conditions. 

• Use of constructed or constructed/manufactured steel plates with ribs (e.g., shaker / rumble plates or 

corrugated steel plates) for entrance/exit access is allowable (See below). 

• The aggregate size for construction of the pad shall be 3-6 inch (76-152 mm) stone. Place the gravel 

to the specific grade and dimensions shown on the plans, and smooth it. 

• The thickness of the pad shall not be less than 8 inches (203 mm). Use geotextile fabric, if necessary, 

to improve stability of the foundation in locations subject to seepage or high water table. 

• The width of the pad shall not be less than the full width of all points of ingress or egress and in any 

case shall not be less than 12 feet (3.6 m) wide. 

• The length of the pad is as required, but not less than 50 feet (15.2 m). 

• All sediment spilled, dropped, washed or tracked onto public rights-of-way shall be removed as soon 

as possible by hand sweeping or mechanized sweeper. Washing of sediment from the public right-ofway shall be prohibited. 

• Provide drainage to carry water to a sediment trap or other suitable outlet. 

• When necessary, wheels shall be cleaned to remove sediment prior to entrance onto public rights-ofway (see SC-11, Entrance / Exit Tire Wash). 

• All sediment shall be reduced or prevented from entering any storm drain, ditch or watercourse 

through use of sediment fence, gravel bags, sediment barriers, or other approved methods. 
ENTRANCE / EXIT TRACKING CONTROLS – SC-10 

Page 2 of 3 

Minimum BMP standards are provided on the following detail. 

Entrance with Shaker Plates 

• Incorporate with a stabilized construction entrance/exit. 

• Construct on level ground when possible, on a pad of coarse aggregate, greater than 3 inches (76 mm) 

and smaller than 6 inches (150 mm). A geotextile fabric shall be placed below the aggregate. 

• Install constructed or manufactured steel plates with ribs (e.g., rumble plates or corrugated steel 

plates) at the entrance/exit in addition to the aggregate. 

• Steel shaker plates shall be designed and constructed/manufactured for anticipated traffic loads. 

Street Sweeping and Vacuum Sweeping

• Inspect potential sediment tracking locations daily. 

• Visible sediment tracking should be swept or vacuumed as needed. Manual sweeping is appropriate 

for small jobs. 

• For larger projects, it is preferred to use mechanical broom or vacuum sweepers that collect and 

contain removed sediment and material. 

If not mixed with debris or trash, incorporate the removed sediment back into the project or depose of it at 

an approved disposal site. 

Inspection and Maintenance:

Stabilized Construction Entrance

• Inspect routinely for damage and assess effectiveness. Repair if access is clogged with sediment. 

• Where tracking has occurred on roadways sweeping should be conducted the same day. Preferably 

water should not be used to wash sediment off the streets. If water is used, it should be captured 

preventing sediment-laden water from running off the site. 

• Keep all temporary roadway ditches clear. 

• The entrance shall be maintained in a condition that will reduce or prevent tracking or flowing of 

sediment onto public rights-of-way. This may require periodic top dressing with additional stone as 

conditions demand, and repair and/or maintenance of any measures used to trap sediment. 

• Maintain the gravel pad in a condition to prevent mud or sediment from leaving the construction site. 

Replace gravel material when surface voids are visible. 

• After each rainfall, inspect all gravel construction entrances and clean it out as necessary. 

• As soon as possible remove all objectionable materials spilled, washed, or tracked onto public 

roadways. Remove all sediment deposited on paved roadways immediately. 

Street Sweeping and Vacuuming

• Inspect entrance and exit points daily and sweep tracked sediment as needed. 

• Be careful not to sweep up any unknown substance or any object that may be potentially hazardous. 

• After sweeping is finished, properly dispose of sweeper wastes. 
ENTRANCE / EXIT TRACKING CONTROLS – SC-10 

Page 3 of 3 
ENTRANCE / EXIT TIRE WASH – SC-11 

Page 1 of 3 

Construction Specifications: 

• Incorporate with a stabilized construction entrance/exit. See BMP SC-10, “Entrance / Exit Tracking 

Controls.” 

Manual/Hose Tire Wash

• Construct on level ground when possible, on a pad of coarse aggregate, greater than 3 inches (75 mm) 

and smaller than 6 inches (150 mm). A geotextile fabric shall be placed below the aggregate. 

• Tire wash shall be designed and constructed/manufactured for anticipated traffic loads. 

• Provide a drainage conveyance that will convey the runoff from the wash area to a sediment trapping 

device. The drainage ditch shall be of sufficient grade, width, and depth to carry the wash runoff. 

• Require that all employees, subcontractors, and others that leave the site with mud-caked tires and/or 

under-carriages use the wash facility. 

Temporary Drive-Through Tire Wash

• Minimum dimensions: 40 feet by 12 feet by 1.5 feet (length, width, and sump depth; 12.2 m by 3.7 m 

by 0.46 m). The minimum length includes ingress and egress from the sump. 

• The aggregate size for construction of the pad shall be 4-6 inch (101-152 mm) stone. Place the gravel 

to the specific grade and dimensions shown on the plans, and smooth it. 

• The thickness of the pad shall not be less than 8 inches (203 mm). Use geotextile fabric under the 

gravel to improve stability of the foundation. 

• Alternatively, install a 3 in. asphalt lift over a stable roadway base with the same dimensions 

identified above. 

• The run out pad should extend 50 feet (15.2 m) past the egress ramp and drain back into the sump or 

to a suitable collection and treatment facility. 

• Install fencing, as necessary, to manage vehicle traffic. 

Minimum BMP standards are provided on the following illustrations.

Inspection and Maintenance:

Manual/Hose Tire Wash

• Remove accumulated sediment in tire wash and/or sediment trap to maintain system performance. 

• Inspect routinely for damage and repair as needed. 

Temporary Drive-Through Tire Wash

• Inspect routinely to assess the water levels within the sump, the depth of accumulated sediment, and 

identify any areas that require maintenance. 

• Remove accumulated sediment from the tire wash facility to maintain tire wash sump depth. 

Sediment may be pumped, piped or vacuumed to a suitable collection and treatment facility. 

• Clean or replace rock when clogged with sediment and re-grade as needed. 

• Maintain the run-out pad as necessary to prevent sediment accumulation. 

• Immediately remove any rock that is carried from the pad to the roadway.

• Ensure that wash water drainage, collection and treatment system is functioning.
ENTRANCE / EXIT TIRE WASH – SC-11 

Page 2 of 3 

MANUAL / HOSE TIRE WASH 
ENTRANCE / EXIT TIRE WASH – SC-11 

Page 3 of 3 

TEMPORARY DRIVE THROUGH TIRE WASH 
Oregon DEQ 

OREGON MANUAL-APPENDICES.DOC Erosion and Sediment Control Manual

 April 28, 2005

APPENDIX G 

NON-STORM WATER 

POLLUTION CONTROL BMPS 

 NS-1 Dewatering and Ponded Water Management 

 NS-2 Paving Operations Controls 

 NS-3 Temporary Equipment Bridge 

 NS-4 Illicit Connection / Illegal Discharge 

 NS-5 Vehicle and Equipment Cleaning 

 NS-6 Vehicle and Equipment Fueling, Maintenance, 

 and Storage 

 NS-7 Material Delivery and Storage Controls 

 NS-8 Material Use 

 NS-9 Stockpile Management 

 NS-10 Spill Prevention and Control Procedures 

 NS-11 Solid Waste Management 

 NS-12 Hazardous Materials and Waste Management 

 NS-13 Contaminated Soil Management 

 NS-14 Concrete Management 

 NS-15 Sanitary Waste Management 

 NS-16 Liquid Waste Management 

 NS-17 Training and Signage
DEWATERING AND PONDED WATER MANAGEMENT – NS-1 

 Page 1 of 1 

Dewatering and ponded water management applies to areas where storm water has collected in low spots, 

trenches or other depressions and needs to be removed to proceed with construction activities or for 

vector control. All dewatering discharge activities must be conducted in accordance with local agency 

(i.e., local sewerage agency or other applicable agency) permit requirements. 

Construction Specifications:

• Ponded storm water shall be settled or filtered for sediment removal prior to discharge. 

• Water from trench or excavation dewatering shall be tested if required by applicable permits and 

discharged in accordance with permit provisions. 

• For clean ponded storm water, dewatering discharges (without permit requirements), and authorized 

non-storm water discharges, use one of the following methods for discharge / disposal as allowable 

by local requirements / agencies and approved by the Project Superintendent. Water shall be clean 

and free of significant sediment, surfactants, or other pollutants. 

• Reduce sediment discharge by pumping water from the top of ponded areas using a floating or 

raised hose. 

• Use water where possible for construction activities such as compaction and dust control and 

landscape irrigation. If used for these applications, ensure that the water will infiltrate and not 

run-off from the land to storm drain systems, to creek beds (even if dry) or to receiving waters. 

• Infiltrate to an appropriate landscaped, vegetated or soil area. Note: Infiltration may be 

prohibited in accordance with local requirements. 

• Discharge to an on-site temporary sediment pond. 

• Discharge to the storm drain system. Water from dewatering must not contain significant 

sediments or other pollutants and discharge must be in accordance with local permits. 

• Alternatively, a vacuum truck may be used to remove the water and haul it to an authorized 

discharge location. 

• If a permit is required, provide temporary onsite storage (Baker tanks, etc.) of water removed from 

trenches, excavations, etc., until a permit to discharge is obtained. 

• If a permit is obtained for discharge to a storm drain or sanitary sewer system, conduct all 

dewatering discharge activities in accordance with permit requirements. 

Inspection and Maintenance:

• Inspect pumps, hoses and all equipment before use. Monitor dewatering operations to ensure it does 

not cause offsite discharge or erosion. 

• Inspect routinely, when applicable activities are under way. 
VEHICLE AND EQUIPMENT CLEANING – NS-5 

 Page 1 of 1 

Construction Specifications:

• Vehicles and equipment should be washed off site at a controlled wash facility when at all possible. 

• Use “dry cleaning methods” such as wiping down whenever possible rather than water washing 

vehicles on site. 

• If cleaning must be conducted on-site, it shall be conducted in a dedicated area with the following 

characteristics: 

• Located away from storm drain inlets, drainage facilities, or watercourses. 

• Paved with concrete or asphalt, or stabilized with an aggregate base. 

• Bermed to contain wash waters and to prevent run-on and runoff. 

• Configured wash area with a sump to allow collection and disposal of wash water. 

• Discharges wash water to a sanitary or process waste sewer (where permitted), or to a dead end 

sump. Wash waters shall not be discharged to storm drains or watercourses. 

• Used only when necessary. 

Additionally, when cleaning vehicles or equipment with water. 

• Use as little water as possible. High pressure sprayers may use less water than a hose, and should be 

considered. 

• Use positive shutoff valve to minimize water usage. 

• Do not use solvents or detergents to clean vehicles or equipment on site. 

• Do not permit steam cleaning on site. 

Inspection and Maintenance: 

• Inspect and clean work areas regularly to limit wind blow debris and pollutants transported by storm 

water. 
VEHICLE AND EQUIPMENT FUELING, MAINTENANCE, AND STORAGE – NS-6 

Page 1 of 1 

Vehicles and heavy machinery are a potential source of pollutants such as petroleum products, antifreeze, 

and exhaust and waste oil containing heavy metals. Pollutants may enter storm water runoff by means of 

direct contact with machine ports and by contact with spills on surfaces and the ground. The following 

control measures can help prevent contact of these potential pollutants with storm water and ground 

surfaces. 

Construction Specifications: 

Fueling - On site vehicle and equipment fueling should only be used where it is impractical to send 

vehicles and equipment offsite for fueling. When fueling must occur on site, the contractor shall select 

and designate an area to be used, subject to approval. Vehicle and equipment fueling (including fueling 

of handheld equipment) shall be conducted in accordance with the following: 

 Away from storm drain inlets, drainage facilities, or watercourses. 

 On a paved surface where practical. 

 Within a bermed area to prevent run-on, runoff, and to contain spills. 

 Store portable fuel containers for hand held equipment in a tub or equivalent device to avoid 

spills and leaks. 

 Use secondary containment techniques for fueling of handheld or portable equipment, such as 

drain pans or drop cloths to catch spills or leaks. 

 All fueling shall be conducted with the fueling operator in attendance at all times. 

 Use vapor recovery nozzles to help control drips and reduce air pollution and nozzles equipped 

with automatic shutoff features to prevent overtopping fuel tank. 

 Signage that fuel tanks should not be “topped off.” 

 An adequate supply of spill clean up materials shall be readily accessible to all fueling activities. 

Maintenance - Maintenance of large equipment shall be conducted within designated maintenance yards 

in order to enable careful management. During minor routine maintenance, drip pans shall be placed 

under vehicles and equipment. All on site vehicles shall be monitored for leaks and shall receive 

preventive maintenance to reduce leakage. 

Only necessary maintenance required for the proper functioning of handheld equipment and portable 

generators/compressors is allowed onsite. Drop clothes, trays or an equivalent method shall be used 

underneath handheld and portable equipment to avoid leaking fluids, fuels, oils, or grease onto the 

ground. Do not overspray aerosols to the ground or other rain-exposed surfaces. Clean up spills 

immediately and dispose of waste properly. 

Fuel and Vehicle Storage - Fuel storage shall be conducted in accordance with applicable local, state, 

and federal regulations and in accordance with the BMP for “Hazardous Materials and Waste 

Management.” Vehicles and equipment shall be stored in designated, bermed vehicle storage areas (such as 

dedicated storage areas or fueling and maintenance areas) when possible, or off of paved areas to the extent 

practical. During long periods (typically more than one month) of storage, and when otherwise necessary 

drip pans shall be placed under vehicles and equipment that are prone to leakage. Plastic tarps shall be 

placed over exposed equipment when not in use for long periods (>3 mos.) to prevent contact with storm 

water. All on site vehicles shall be monitored for leaks and shall receive preventive maintenance to reduce 

leakage. 

Inspection and Maintenance: 

 Check to ensure adequate supply of spill cleanup materials is available. 

 Perform routine inspections of designated maintenance, cleaning, and fueling areas. 

 Report all spills immediately to the project Superintendent. 

 Service sumps regularly. 
MATERIAL DELIVERY AND STORAGE CONTROLS – NS-7 

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Many materials used in construction can contribute pollutants to storm water runoff. Examples of such 

materials include soil, vehicle fuels, oils, antifreeze, paints/coatings, pressure treated lumber, dry wall, 

fertilizers, pesticides, and herbicides. 

Construction Specifications: 

• All construction materials shall be delivered to and stored in designated areas or designated staging 

areas at the construction site. 

• Material storage areas shall be placed near construction site entrances to the extent practicable, away 

from storm drain inlets, culverts and surface water bodies. 

• Designated storage areas shall be kept clean, well organized, and litter-free. 

• Any materials being stored that could release pollutants by wind or runoff transport shall be protected 

by overhead cover, secondary containment, tarpaulins, visqueen/plastic sheeting or other appropriate 

method prior to rainfall or periods of high wind. Where feasible, store materials indoors (e.g., 

container storage or garages/buildings under construction, where work is being conducted. 

• Any chemicals, drums or bagged materials not stored in a covered location, shall be stored on pallets, 

and when possible in secondary containment. 

• Secondary containment shall be provided for liquids. 

• Secondary containment areas shall be covered, where feasible, to prevent accumulation of rainwater. 

• Construction materials shall be stored in a manner to prevent or minimize contact with storm water. 

• The main loading, unloading, and access areas shall be located away from storm drain inlets and 

channels. 

• Enclosures or flow barriers (berms) shall be constructed around designated storage areas to prevent 

storm water flows from entering storm drains or receiving waters, and to control the discharge of 

sediments and other pollutants. 

• Deliveries shall be scheduled in a manner that reduces the time for onsite storage of potentially 

polluting materials prior to use and minimize the number of material drop locations. 

• Fuels shall be stored in accordance with the BMP for “Vehicle and Equipment Fueling, Maintenance, 

and Storage.” 

• Hazardous materials shall be stored in accordance with the BMP for “Hazardous Material and Waste 

Management.” 

Inspection and Maintenance: 

 Inspect material storage areas routinely for compliance with the above practices. 
MATERIAL USE – NS-8 

Page 1 of 1 

Apply this BMP when the following materials are used or prepared on site: pesticides and herbicides; 

fertilizers and soil amendments; detergents; petroleum products such as fuel, oil, and grease; asphalt and 

other concrete components; plaster; hazardous chemicals such as acids, lime, glues, adhesives, paints, 

solvents, and curing compounds; mastic, pipe wrap, primers, and paint; concrete compounds; welding 

material; and other materials that may be detrimental if released to the environment. 

Construction Specifications: 

 Materials shall be used in accordance with manufacturer directions and in a manner to reduce or 

eliminate release of pollutants 

 An accurate, up-to-date inventory of materials delivered and stored on-site shall be kept by each 

contractor. 

 Reduce or eliminate use of hazardous materials on site when practical. Use safer, recycled and/or 

less hazardous products when practical. 

 Use materials only where and when needed to complete the construction activity. 

 Recycle residual paints, solvents, non-treated lumber, and other materials. 

 Do not remove the original product label; it contains important safety and disposal information. 

 Use the entire product before disposing of the container. 

 Keep an ample supply of spill clean up material near use areas. Instruct employees in spill clean 

up procedures. 

 Avoid exposing applied materials to rainfall unless sufficient time has been allowed for them to 

dry or cure. 

Inspection and Maintenance: 

 Spot check employees and subcontractors monthly throughout the job to ensure appropriate 

practices are being employed. 
STOCKPILE MANAGEMENT – NS-9 

Page 1 of 1 

Stockpile management procedures and practices are designed to reduce or eliminate air and storm water 

pollution from stockpiles of soil, sand, and paving materials such as Portland cement concrete (PCC) 

rubble, asphalt concrete (AC), asphalt concrete rubble, aggregate base, aggregate sub-base or pre-mixed 

aggregate, asphalt binder (so called “cold mix” asphalt) and pressure treated wood.

Construction Specifications: 

All Stockpiles 

• If feasible, locate stockpiles a minimum of 50 feet away from inlets, drainage courses, or water 

bodies. 

• Keep stockpiles organized and surrounding areas clean. 

• Protect storm drain inlets, drainage courses, and receiving waters from stockpiles, using drain inlet 

protection and perimeter sediment controls as appropriate. 

• Implement dust control practices as appropriate to prevent wind erosion of stockpiled material.

• Temporary stockpiles not removed or used by the end of one workday must be managed in 

accordance with this BMP and in all cases protected prior to rainfall.

Stockpiles of soil, Portland cement, sand, mulch, concrete rubble, asphalt concrete, asphalt concrete 

rubble, aggregate base, or aggregate sub-base 

• Protect stockpiles with a perimeter sediment barrier such as berms, sediment fences, fiber rolls, 

sand/gravel bags, or straw bale barriers year round. 

• Stockpiles should additionally be covered or stabilized as necessary during significant forecasted 

storm events (> 0.25 inches), prolonged periods of rain, and to protect from wind erosion. 

• Soil stockpiles may be returned to the excavation if rain is forecast. 

• Topsoil stockpiles should be low n height (ideally <1 meter) and flat and be used within 6 months to 

promote healthy soil organisms and microbes. Stockpiles not used within 6 months should be 

reseeded with a species that is mycorrhizal dependent to avoid the development of anaerobic 

conditions in the stockpile.. In addition, topsoil stockpiles can be turned periodically to keep 

organisms alive for larger stockpiles and during extremely hot weather. 

Stockpiles of “cold mix” or other pollutants easily transported in storm water (cement, lime, and 

other caustic amendments): 

• Stockpiles shall be placed on plastic or comparable material at all times. 

• Stockpiles shall be covered with plastic or comparable material prior to the onset of significant rain (> 

0.10 inches). 

Bagged Materials 

• Bagged materials shall be placed on pallets at all times and under cover (plastic sheeting, indoors, 

etc.) prior to the onset of significant rain (>0.10 inches). 

Stockpiles/Storage of pressure treated wood with copper, chromium, and arsenic or ammoniacal 

copper, zinc, and arsenate: 

• “Stockpiles” of treated wood shall be covered with plastic or comparable material prior to the onset of 

significant rain (>0.25 inches). 

Inspection and Maintenance:

• Inspect stockpiles regularly and repair and/or replace covers, and perimeter controls as needed.
SPILL PREVENTION AND CONTROL PROCEDURES – NS-10 

Page 1 of 2 

Spills and leaks can be significant sources of storm water pollutants and are, in most cases, avoidable. 

Construction Specifications: 

 The Contractor shall prepare a site/project specific spill response plan that identifies the type and 

location of products or wastes on the site with spill potential, the location of spill cleanup materials, 

storm drains or sensitive areas that require immediate response, personnel responsible for spill 

response and notifications, and spill cleanup procedures. 

 Avoiding spills and leaks is preferable to cleaning them up after they occur. Heavy equipment (e.g., 

bulldozers and other grading equipment) and vehicles should be inspected daily (or as often as 

possible) for leaks and should be repaired as necessary. Use secondary containment and drip pans for 

vehicle fueling, maintenance, and storage (See BMP for “Vehicle and Equipment Fueling, 

Maintenance, and Storage.” 

 Despite precautions, spills may still occur at the site. Spills (of liquid or dry materials) should never 

be cleaned up by hosing off the area. In the event that spills occur they should be controlled as 

follows: 

 Any fuel products, lubricating fluids, grease or other products and/or waste released from vehicles, 

equipment, or operations shall be collected and disposed of in accordance with state, federal and local 

laws. 

 If the spill has occurred during a rain event, the area will be covered as quickly as possible. The spill 

will be cleaned up as soon as possible during or after cessation of rain. 

 Spill cleanup materials will be stored near potential spill areas (e.g., painting, vehicle maintenance 

areas). 

 Minor Spills: Minor spills typically involve small quantities of oil, gasoline, paint, etc. that can be 

controlled by the first responder at the discovery of the spill. Control of minor spills involves: 

1. Contain the spill immediately. 

2. Recover spilled materials (if possible). 

3. Clean the contaminated area and dispose of contaminated materials. 

 Medium-Sized Spills: Medium-sized spills still can be controlled by the first responder, along with 

the aid of other personnel such as laborers, foremen, etc. This response may require the cessation of 

other activities. Spills should be cleaned up immediately, as follows: 

1. Notify the project foreman immediately. The foreman/superintendent is responsible for 

any necessary notifications (fire department etc.). 

2. Contain the spread of the spill (using sand bags or other barriers) immediately. 

3. If the spill has occurred on a paved or impermeable surface, clean it up using dry 

methods (absorbent materials, cat litter, and/or rags). Contain the spill by encircling it 

with absorbent materials. 

4. If the spill has occurred on an unpaved or permeable surface, immediately contain the 

spill by constructing an earthen dike. Dig up and properly dispose of contaminated soil. 

5. If the spill has occurred during a rain event, cover/contain the area if possible. 

 Significant/Hazardous Spills: For large spills or spills involving hazardous materials that cannot be 

controlled by project personnel, the following steps should be taken: 

1. The Foreman should notify the Project Superintendent immediately and follow up with a 

written incident report. 

2. The Project Superintendent will notify local emergency response personnel by dialing 

911. In addition, the Project Superintendent will notify the appropriate County officials. 

It is the Project Superintendent's responsibility to have all of the emergency phone 

numbers at the construction site. 

3. The Project Superintendent will also notify the Oregon DEQ. 
SPILL PREVENTION AND CONTROL PROCEDURES – NS-10 

Page 2 of 2 

4. For spills of federal Reportable Quantity (as established under 40 CFR Parts 110, 117, or 

302), the Project Superintendent will notify the National Response Center by telephone at 

(800) 424-8802 within 24 hours. Within 14 days, the Project Superintendent will submit a 

written description of the release to EPA Region 10, including the date and circumstances 

of the incident and steps taken to prevent another release. 

5. Retain the services of a Spill Cleanup Contractor or HazMat Team immediately. 

Construction personnel should not attempt to clean up the spill until the appropriate and 

qualified staff has arrived at the site. 

6. Other agencies that may need to be contacted include the local fire department, Oregon 

Department of Transportation, etc. 

Inspection and Maintenance: 

 Inspect work and material storage areas routinely for adequate containment to avoid 

uncontrolled releases. 
SOLID WASTE MANAGEMENT – NS-11 

Page 1 of 1 

Construction Specifications: 

 Broom cleaning of paved areas of the site and of paved public areas is preferred. Use of water for 

cleaning is prohibited unless approved on a project specific basis by the owner. If approved, 

wash water shall not be discharged to the storm sewer and shall be collected, contained and 

disposed of appropriate (see bullet below regarding liquid wastes). 

 There shall be designated temporary waste storage areas on the site. 

 Designated waste storage areas shall be contained within earthen berms or provided with other 

perimeter protection to prevent run-on to and run-off from the area. 

 Non-hazardous construction wastes (e.g., vegetation, trash, and construction debris) shall be 

collected from throughout the site once a day and before storm events and deposited at the 

designated waste storage areas. 

 When practical, wastes shall be stored within covered, water-tight dumpsters and/or containers 

that prevent exposure to rain and prevent loss of wastes when it’s windy. 

 Dumpsters shall not be hosed out on the construction site. Any required dumpster cleaning will be 

done off-site by the trash hauling contractor. 

 Any waste containers constructed on-site (not prefabricated) shall be inspected prior to use and 

inspected regularly to verify integrity. 

 Any wastes stored in open containers or waste piles shall be covered prior to significant 

forecasted rain (0.25”). 

 All waste materials shall be removed from the storage areas on a weekly basis or more frequently 

if capacity is reached and disposed or recycled in accordance with all Federal, state, and local 

regulations. 

 Any solid waste that accumulates at erosion and sediment control devices will be removed ASAP. 

 Liquid wastes shall be managed in accordance with the BMP for “Liquid Waste Management.” 
HAZARDOUS MATERIALS AND WASTE MANAGEMENT – NS-12 

Page 1 of 1 

Construction Specifications: 

Hazardous Materials 

 Storage of hazardous materials on site shall be minimized. Any hazardous materials used during 

construction shall be containerized and kept closed during work activities. 

 Hazardous material storage shall conform to all applicable local, state and federal requirements. 

 Hazardous materials shall be stored in sealed containers within an enclosed container or a bermed 

and permanently covered storage area. Lids alone shall not be considered adequate cover. 

 Dedicated areas of the construction site shall be designated for hazardous material delivery and 

storage. Designated storage areas will be placed near construction site entrances, to the extent 

practical, and away from drain inlets, culverts and surface water bodies. 

 Designated storage areas shall be kept clean and well organized. 

 The following types of materials shall be stored in accordance with these provisions: fertilizers, 

herbicides, pesticides, detergents, oil, grease, glues, paints, solvents, curing compounds materials, 

and other similar materials that could be considered potential pollutants in storm water discharge. 

 Fuel shall be stored and managed in accordance with the BMP for “Vehicle and Equipment 

Fueling, Maintenance, and Storage.” 

 Regular inspections of storage areas shall be conducted to monitor inventory and check for 

leaking containers. 

Hazardous Wastes 

 Hazardous wastes and containers shall be placed in a designated hazardous waste storage area 

that is permanently covered and has an impermeable bottom surface surrounded by secondary 

containment to minimize the mixing of wastes with storm water and to prevent the direct release 

of liquid waste to storm water. Temporary storage and removal of hazardous wastes from the site 

shall be in accordance with all applicable state and federal laws. 

 Wastes shall be segregated and recycled where feasible (e.g., paints, solvents, used oil, batteries, 

anti-freeze). Wastes shall not be mixed since this can cause potentially dangerous chemical 

reactions, make recycling impossible and complicate disposal. 

 Covered waste bins shall be designated for the disposal of all empty hazardous waste product 

(e.g., paints, solvents, glues, petroleum products, exterior finishes, pesticides, fertilizers, etc.) 

containers. The original product label shall not be removed as it contains important safety and 

disposal information. 

 Toxic wastes and chemicals shall not be disposed of in dumpsters designated for construction 

debris. 

 If any asbestos is discovered in the demolished materials, asbestos removal and disposal shall be 

performed by a licensed contractor or licensed subcontractor trained in asbestos removal. All 

removal and disposal shall be done in accordance with state and federal regulations. Any asbestos 

wastes stored on-site prior to removal shall be stored within dumpsters (roll-offs) covered with 

tarps or other appropriate method to prevent contact with rain and minimize exposure to wind. 

 Employees and subcontractors shall be trained on proper storage practices. 
SANITARY WASTE MANAGEMENT –NS-15 

Page 1 of 1 

 All sanitary wastes shall be collected and managed through the use of portable toilet facilities. 

 Portable toilets shall be placed on a level surface and to the extent practical, a safe distance away 

from paved areas and away from storm drains. 

 Portable toilets shall be provided with secondary containment. 

 If placed in an area of high winds, portable toilets shall be secured to the ground to prevent 

blowing over. 

 Portable toilets shall be transported to and from the construction site by a licensed contractor. 

 No sanitary wastes shall be disposed of on site (e.g., to on-site storm drains, burial, etc.). 

 Care shall be taken during pump-out to avoid spillage. If spillage occurs it shall be cleaned up 

immediately. 
LIQUID WASTE MANAGEMENT – NS-16 

Page 1 of 1 

Liquid waste management is applicable to construction projects that generate any of the following nonhazardous by products, residuals, or wastes, such as: 

 Drilling slurries and drilling fluids 

 Grease-free and oil-free wastewater and rinse water 

 Dredging spoils 

 Other non-storm water liquid discharges not permitted by separate permits. 

Separate BMPs should also be referenced for the following onsite liquid wastes: 

 Dewatering operations 

 Liquid hazardous wastes, or 

 Concrete slurry residue 

Construction Specifications: 

 Vehicle and equipment cleaning using water is discouraged on site. 

 Drilling residue and drilling fluids should be disposed of in accordance with appropriate 

requirements at an approved disposal site. 

 Wastes generated as part of an operational procedure, such as water-laden dredged material and 

drilling mud, should be contained and not allowed to flow into drainage channels or receiving 

waters. 

 Contain non-hazardous liquid wastes in a controlled area, such as a lined holding pit, lined 

sediment basin, roll-off bin, or portable tank. 

 Containment devices must be of sufficient quantity or volume to completely contain the liquid 

wastes generated and any addition volume based on anticipated rainfall. 

 Do not locate containment areas or devices where accidental release of the contained liquid can 

threaten health or safety, or discharge to watercourses, storm drain system, or to a receiving 

water. 

 Capture all liquid wastes running off a surface that has the potential to affect the storm drainage 

system. Examples are: wash water and rinse water from cleaning walls or pavement. 

 If the liquid waste is sediment laden, use a sediment trap or capture in a containment device and 

allow sediment to settle. 

 Disposal of liquid wastes are subject to specific laws and regulations, or to requirements of other 

permits secured for the construction project. 

Maintenance and Inspection: 

 Remove deposited solids from containment areas and containment systems as needed, and at the 

completion of the project. 

 Inspect containment areas and containment systems routinely for damage, and repair as needed. 
TRAINING AND SIGNAGE – NS-17 

Page 1 of 1 

When properly trained, site personnel are more capable of managing materials properly, preventing spills, 

and implementing control practices efficiently and correctly. Personnel at all levels shall be trained in the 

components and goals of the permit. 

Construction Specifications: 

The following measures shall be followed to ensure the ESCP is effectively implemented, BMP 

inspections are performed, BMP maintenance and repair are performed, and appropriate records are 

prepared and retained: 

 Before beginning construction activities and periodically during construction, appropriate 

personnel shall receive training to implement the ESCP effectively, perform BMP inspections, 

perform BMP maintenance and repair, and keep records. Non-storm water discharges and 

general contractor activity BMPs shall also be covered during training. An appropriate forum for 

training would be "tailgate meetings" or safety meetings that focus generally on the components 

and goals of the ESCP, and specifically on the implementation, inspection, and maintenance of 

the storm water pollution control BMPs. Training shall be documented by the contractor. 

 Individuals responsible for overseeing, revising, and amending the ESCPs shall also document 

their training. 

 All appropriate new employees and contractors shall be trained by staff familiar with the ESCP 

requirements before they shall be permitted to work at the site. Contractors shall be responsible 

for informing their subcontractors about ESCP requirements. 

 BMP drawings, trade water quality guidelines, fact sheets, or other specifications shall be copied 

and distributed to contractors and site personnel engaged in the activity in question and/or 

installation/maintenance of BMPs. 

 Signs shall be placed throughout the job site that convey critical information storm water 

pollution prevention information such as: 

o • Job Site Clean-Up Required Everyday 

o • Directions to and identification of concrete and paint wash outs 

o • Erosion and Sediment Control Plan in Effect 

Attachment 2

Emergency Response Numbers

KEY PROJECT CONTACTS

Oregon LNG’s Project Manager

Name

Phone numbers:

Office

Cell

Lead Environmental Inspector

Name

Phone numbers:

Office

Cell

Contractor Project Supervisor

Name

Phone numbers:

Office

Cell

Emergency Response Contractor

Name

Phone numbers:

Office

Cell

1

APPENDIX F2 

AGRICULTURAL IMPACT MITIGATION PLAN

Oregon LNG Bidirectional Project 

Agricultural Impact Mitigation Plan 

Prepared for 

Oregon Pipeline Company, LLC 

Prepared by CH2M HILL 

May 2013 

Oregon Pipeline Company iii FERC NGA Sections 3a and 7c Application 

Table of Contents 

Section Page 

Definitions ............................................................................................................................................. v

1.0 Introduction ............................................................................................................................. 1

2.0 Limitations of this Plan ........................................................................................................... 1

3.0 Agricultural Specialists and Inspectors ................................................................................. 2

4.0 Landowner Relations .............................................................................................................. 2

5.0 Determining Construction-Related Damages ....................................................................... 4

6.0 Mitigation Measures ................................................................................................................ 4

6.1 Construction Area Access ............................................................................................ 4

6.1.1 Ingress and Egress Routes .......................................................................... 4

6.1.2 Temporary Access Roads and Laydown Areas .......................................... 5

6.1.3 Landowner and Tenant Access ................................................................... 5

6.2 Depth of Pipeline Cover ............................................................................................... 5

6.3 Soil Preservation and Restoration ................................................................................ 6

6.3.1 Segregation of Topsoil ............................................................................... 6

6.3.2 Removal of Excess Rock ............................................................................ 7

6.3.3 Mitigation of Soil Compaction and Rutting ............................................... 7

6.4 Construction in Wet Conditions ................................................................................... 8

6.4.1 Impact Avoidance ....................................................................................... 8

6.4.2 Trench Dewatering ..................................................................................... 8

6.5 Protection and Repair of Irrigation and Drainage Systems .......................................... 9

6.5.1 Irrigation Systems ....................................................................................... 9

6.5.2 Drainage Systems ..................................................................................... 10

6.6 Identification and Repair of Soil Conservation Practices ........................................... 11

6.7 Dust Control ............................................................................................................... 11

6.8 Soil Erosion and Sediment Control ............................................................................ 11

6.9 Weed Control ............................................................................................................. 12

6.10 Post-Construction Monitoring and Follow-Up Mitigation ......................................... 12

6.10.1 Drain Tiles ................................................................................................ 13

6.10.2 Excess Rock ............................................................................................. 13

6.10.3 Trench Settlement ..................................................................................... 13

6.10.4 Irrigation Systems ..................................................................................... 13

6.10.5 Crop Monitoring ....................................................................................... 13

6.10.6 Noxious Weeds ......................................................................................... 14

Exhibits 

Exhibit A. Allowed Crops within Rights-of-Way on Agricultural Land Following Construction ........ 3 

Oregon Pipeline Company v FERC NGA Sections 3a and 7c Application 

Definitions 

Agricultural Land Annually cultivated or rotated cropland; land in perennial field crops, 

orchards, or vineyards; land used for small fruit, nursery crops, greenhouses, 

or Christmas trees; land in short rotation woody crops on exclusive farm use 

zoned land; improved pasture, hayfields, land in the Conservation Reserve 

Program; and previously cultivated land in government sponsored 

environmental or conservation programs, not including land converted to 

wetlands. 

Drain Tile Any buried segmented clay pipe or perforated plastic pipe material used to 

artificially improve subsurface drainage of perched or shallow groundwater 

within an agricultural field. 

FERC Plan The January 17, 2003, version of the Federal Energy Regulatory 

Commissions’ “Upland Erosion Control, Revegetation, and Maintenance 

Plan.” 

Landowner Person(s) holding legal title to property on the Pipeline route from whom the 

Oregon Pipeline Company, LLC, is seeking or has obtained a temporary or 

permanent easement. 

Landowner’s 

Designate 

Any person(s) legally authorized by a landowner or court of law to make 

decisions regarding the mitigation or restoration of agricultural impacts to 

such landowner's property. Any landowner's designate will provide the 

Oregon Pipeline Company, LLC, with a written document signed by the 

landowner or a court with jurisdiction authorizing the designate to discuss, 

negotiate, and reach agreements with the Oregon Pipeline Company, LLC. 

Pipeline Includes the natural gas pipeline(s) and its related appurtenances as 

described in the Oregon Pipeline Company, LLC, application to the Federal 

Energy Regulatory Commission. 

Tenant Any person lawfully residing on or in possession of property, and who is the 

farm operator and has a lease or pays rent on the property that Oregon 

Pipeline Company, LLC, is seeking or has obtained a temporary or 

permanent easement from the landowner. 

Topsoil The uppermost part of the soil including the plow layer (Ap horizon) and 

other A horizons (e.g., A1, A2), but not including transition horizons (e.g., 

A13, AC, BA, E). It is the surface layer of the soil that generally has the 

darkest color and the highest content of organic matter. 

OREGON LNG BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

Oregon Pipeline Company 1 FERC NGA Sections 3a and 7c Application 

1.0 Introduction 

This agricultural impact mitigation plan (Plan) outlines mitigation measures devised to compensate or 

mitigate for agricultural impacts that may occur because of construction of the liquefied natural gas 

(LNG) bidirectional terminal (Terminal) and bidirectional pipeline (Pipeline) (collectively, the 

Project) being developed by LNG Development Company, LLC, and Oregon Pipeline Company, 

LLC (together referred to as Oregon LNG). Since the Terminal does not impact any agricultural land, 

this Plan has been written to address construction of the Pipeline by the Oregon Pipeline Company, 

LLC (Oregon Pipeline Company). 

The purpose of this plan is to provide affected landowners or landowner designates and tenants with a 

basis for discussions about Project impact mitigation. The mitigation measures1 in this plan 

supplement the information provided in the Federal Energy Regulatory Commission (FERC) Natural 

Gas Act (NGA) Sections 3a and 7c Application for the Project. As such, this plan does not establish 

any contractual obligations or representations between Oregon Pipeline Company (the applicant) and 

any party, and does not create any third-party beneficiary rights between Oregon Pipeline Company 

and any party. 

This plan is meant to supplement the FERC Plan and provides an equal or greater level of 

environmental protection than the FERC Plan. Oregon LNG will comply with all requirements 

of this plan and the FERC Plan. In the case of inconsistency between this plan and the FERC 

Plan, the version that provides the highest level of environmental protection shall control. 

2.0 Limitations of this Plan 

A. The mitigation measures and conditions described in this Plan apply only to construction 

activities occurring partially or wholly on privately owned agricultural land. They do not apply to 

construction activities on public right-of-way, railroad right-of-way, publicly owned land, or 

private land that is not agricultural land, except where agricultural structures such as drainage tile 

and irrigation systems that are associated with privately-owned agricultural land pass through or 

extend into these areas. 

B. Oregon Pipeline Company will implement the mitigation measures contained in this Plan to the 

extent that they are consistent with the mitigation measures approved by, or other requirements 

of, the FERC certificate for the Project. This Plan will impose requirements upon Oregon Pipeline 

Company only to the extent that such requirements are imposed as conditions of the FERC 

certificate. 

C. Oregon Pipeline Company will implement the mitigation measures contained in this Plan to the 

extent that they do not conflict with the requirements of any applicable federal, state, and local 

rules and regulations, and other permits and approvals that are obtained by Oregon Pipeline 

Company for the Project. 

 

1 The majority of the conditions and mitigation measures in this plan are adapted from the Agricultural Impact Mitigation Plan 

for the South Mist Pipeline Extension Project prepared by NW Natural (revised and approved March 13, 2003) as a supplement 

to its application to the Energy Facility Siting Council of the Oregon Department of Energy. 
OREGON BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

 

Oregon Pipeline Company 2 FERC NGA Sections 3a and 7c Application 

D. Nothing in this document is intended to grant or suggest FERC jurisdiction over remedies for 

property compensation resolved in accordance with Oregon law. 

E. Unless specifically stated otherwise in an easement agreement between Oregon Pipeline 

Company and a landowner, Oregon Pipeline Company will implement this Plan’s mitigation 

measures according to the conditions described in the Plan. 

3.0 Agricultural Specialists and Inspectors 

Oregon Pipeline Company will retain qualified Agricultural Specialists on each work phase of the 

Project including construction planning, Pipeline construction, restoration, post-construction 

monitoring, and follow-up restoration. Oregon Pipeline Company will designate one or more of the 

Environmental Inspectors to serve as the Agricultural Inspector. The Agricultural Inspector will 

provide technical assistance to Construction Managers, other Project Inspectors, and Oregon Pipeline 

Company Land Representatives to facilitate the effective implementation of agricultural mitigation 

measures from the construction through post-construction and monitoring phases of the Project. 

Independent Agricultural Specialists will also be retained to seek a mutual agreement between the 

Oregon Pipeline Company and landowners concerning post-construction claims for damages or crop 

deficiencies. The qualified Agricultural Specialist will be selected on a claim-by-claim basis by 

agreement of a representative designated by Oregon Pipeline Company and a representative 

designated by the party Farm Bureaus (or the landowner, at the election of the landowner). 

4.0 Landowner Relations 

A. Before construction of the Pipeline, Oregon Pipeline Company will provide to each landowner, 

landowner's designate, and/or tenant the name, telephone number, and mailing address of the 

Oregon Pipeline Company representative or agent responsible for the liaison activities on behalf 

of Oregon Pipeline Company both during construction and subsequent operational-related 

activities. Oregon Pipeline Company will respond promptly to any landowner and/or tenant issues 

or concerns both during the construction and long-term operational activities. 

B. Oregon Pipeline Company will consult with landowners to obtain information on any special 

certifications that the landowners hold (e.g., certified weed-free seed or hay, organic certification) 

and to develop plans that will not jeopardize compliance with these certification programs. 

C. Oregon Pipeline Company may negotiate with landowners or landowner's designates regarding 

implementation of mitigation measures that landowners wish to perform themselves. 

D. Certain provisions of the Plan require that Oregon Pipeline Company consult with and/or obtain 

agreement with the landowner and the tenant of a property. Oregon Pipeline Company will make 

a good faith effort to secure the agreement of both landowner and tenant in such cases. In the 

event of a disagreement between the landowner and tenant, Oregon Pipeline Company will secure 

the landowner's agreement unless the tenant can demonstrate a superior legal right in the matter at 

issue. The standard allowances for crops grown within the 50-foot wide permanent Pipeline 

easement are shown in Exhibit A. 

E. Mitigation measures within the Plan may be modified upon written mutual agreement between 

Oregon Pipeline Company and the landowner. 
OREGON LNG BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

Oregon Pipeline Company 3 FERC NGA Sections 3a and 7c Application 
OREGON BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

 

Oregon Pipeline Company 4 FERC NGA Sections 3a and 7c Application 

5.0 Determining Construction-Related Damages 

A. Before construction, Oregon Pipeline Company or its agent together with the landowner, the 

landowner's designate, and/or the tenant will examine each affected property to inventory crops, 

livestock, fences, irrigation systems, drain tiles, etc. 

B. If construction activities damage crops, Oregon Pipeline Company will compensate the 

landowner and/or tenant for 100 percent of the damages. 

C. Farm improvements such as fences, drain tiles, irrigation systems, and related structures that are 

damaged as a result of construction activities will be replaced or restored to the preconstruction 

condition as nearly as possible, or to better condition. In some cases, where Oregon Pipeline 

Company and the landowner, landowner's designate, and/or tenant agree, Oregon Pipeline 

Company may provide compensation for construction-related damage to farm improvements in 

lieu of repair or restoration. 

D. Agricultural production of all herbaceous (non-woody) crops can resume on the construction 

area, including the permanent Pipeline easement, following construction. Woody and deep rooted 

vegetation including trees, shrubs, cane berries, vines, and any crops requiring trellising that may 

cause damage to the buried Pipeline may be restricted within the 50-foot wide permanent Pipeline 

easement. Oregon Pipeline Company may negotiate with landowners, on an individual basis, to 

allow production of certain specialty crops within its exclusive easement, as long as the proposed 

activities do not interfere with the safe operation of the Pipeline, or Oregon Pipeline Company's 

ability to maintain its exclusive easement. 

E. Oregon Pipeline Company and the landowner will seek a mutual agreement concerning postconstruction claims for damages or crop deficiencies. In the event Oregon Pipeline Company and 

the landowner are unable to reach a mutually satisfactory agreement, such claims will be assessed 

on an individual basis by a qualified agricultural specialist. The qualified agricultural specialist 

will be selected on a claim-by-claim basis by agreement of a representative designated by Oregon 

Pipeline Company and a representative designated by the party Farm Bureaus (or the landowner, 

at the election of the landowner). Oregon Pipeline Company must pay the cost of retaining the 

qualified agricultural specialist. The agricultural specialist will review and evaluate claims of 

damages. If the agricultural specialist approves the claim, Oregon Pipeline Company will pay 

compensation for the claim in the amount determined by the agricultural specialist. Claims will 

be evaluated in a timely manner following notification of such damages or deficiencies from the 

landowner and/or tenant. 

6.0 Mitigation Measures 

6.1 Construction Area Access 

6.1.1 Ingress and Egress Routes 

A. Before Pipeline installation, should access to the construction easement not be practical or 

feasible from adjacent segments of the construction easement or from public rights-of way, 
OREGON LNG BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

Oregon Pipeline Company 5 FERC NGA Sections 3a and 7c Application 

Oregon Pipeline Company will seek a mutually acceptable agreement with the landowner on the 

route that will be used for entering and leaving the construction easement. 

B. Where access ramps or pads are required from a road or highway to the construction area in 

agricultural fields, an underlayer of durable, geotextile fabric will be placed over the soil surface 

before installation of temporary rock access fill material. The geotextile fabric will be sufficiently 

strong to prevent rock from becoming embedded in the soil and to withstand removal of the rock 

without tearing. Rock and geotextile fabric will be completely removed when the Project is 

completed. 

6.1.2 Temporary Access Roads and Laydown Areas 

A. The location of temporary access roads and laydown areas to be used for construction purposes 

will be negotiated with the landowner and tenant. 

B. Oregon Pipeline Company will attempt to identify existing farm lanes as preferred temporary 

access roads for construction. 

C. Temporary access roads and laydown areas will be designed so proper drainage is not impaired 

and will be built to minimize soil erosion on or near these sites. 

D. Oregon Pipeline Company will restore temporary access roads and laydown areas to 

preconstruction conditions or better, unless otherwise specified in the landowner easement 

agreement. 

E. Upon abandonment, temporary access roads may be left intact through mutual agreement of the 

landowner, the tenant, and Oregon Pipeline Company, unless located in flood areas or drainage 

hazard areas, or otherwise restricted by federal, state, or local regulations. 

6.1.3 Landowner and Tenant Access 

A. Where feasible, Oregon Pipeline Company will coordinate with landowners and tenants to 

provide access for farm equipment and livestock to fields isolated by the Pipeline trench or other 

construction activities. 

B. Oregon Pipeline Company will construct temporary fences and gates across the construction area, 

as necessary. 

6.2 Depth of Pipeline Cover 

A. Except for piping facilities such as mainline block valves, tap valves, meter stations, etc., and 

except as otherwise stated in this Plan, the Pipeline will be buried with a minimum of 5 feet of 

cover where it crosses agricultural land. 

B. Oregon Pipeline Company will install the Pipeline under existing and planned drain tiles, unless 

existing or planned drain tiles are located deep enough to allow the Pipeline to be installed above 

the drain tile with at least 5 feet of top cover over the Pipeline and a 12-inch clearance between 

the tile and the Pipeline. 
OREGON BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

 

Oregon Pipeline Company 6 FERC NGA Sections 3a and 7c Application 

C. Where feasible and practicable, Oregon Pipeline Company will install the Pipeline with greater 

than 5 feet of top cover in agricultural land where specifically requested by the landowner to 

allow for certain site-specific conditions or practices. Additional construction space may be 

required for trench spoil storage in these cases. 

D. Oregon Pipeline Company will install plastic warning ribbon approximately 18 to 24 inches 

above the buried Pipeline to provide a greater level of safety for potential excavation activities in 

the area of the Pipeline. 

E. On lands subject to soil erosion, Oregon Pipeline Company will patrol the Pipeline with 

reasonable frequency to detect erosion of top cover. At a minimum, Oregon Pipeline Company 

will need to patrol the Pipeline in accordance with Department of Transportation requirements as 

described in CFR Title 49 Part 192.705, Transmission Lines: Patrolling and the FERC Plan . 

Whenever Oregon Pipeline Company discovers that the loss of cover due to erosion creates a 

safety hazard, Oregon Pipeline Company will take corrective action. 

6.3 Soil Preservation and Restoration 

6.3.1 Segregation of Topsoil 

A. Oregon Pipeline Company will strip and segregate topsoil from over the trench and from the 

trench spoil storage area in agricultural lands. Oregon Pipeline Company will also strip and 

segregate topsoil in agricultural land, over portions of the construction area where grading or cut 

and fill will occur or where excavations are made beyond the typical trench width. 

B. Oregon Pipeline Company will strip and segregate topsoil down to the lower limit of the “A” 

horizon or to 12 inches in depth, whichever is less. 

C. Topsoil will generally not be stripped and segregated on public right-of-way areas, except for the 

portions used for agriculture. 

D. During construction in areas where the topsoil is segregated, the stripped topsoil will be stored 

separately to reduce further disturbance to the stripped topsoil. The stripped topsoil will not be 

allowed to mix with trench spoil, cut-and-fill materials, rock, construction debris, excavated 

materials, or other subsoil. In areas where topsoil is segregated, subsoil will not be stored on 

topsoil and the topsoil will not be used to pad the pipe, for constructing trench breakers, or for 

any other purpose that would result in the loss or degradation of the stripped topsoil. 

E. Topsoil will be stored in a manner that minimizes an increase in water content by leaving gaps in 

topsoil piles where surface drainage and ditches occur. Gaps will be left in topsoil piles where 

livestock and farm machinery crossings are located. 

F. When working in excessively wet soils in agricultural land where the topsoil is not stripped, 

Oregon Pipeline Company will restrict the operation of vehicles and heavy equipment, or will 

take other appropriate action, so that deep rutting does not result in mixing of topsoil and subsoil. 

G. Following backfilling, grading, and subsoil decompaction, the stripped topsoil will be returned to 

its original position. 
OREGON LNG BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

Oregon Pipeline Company 7 FERC NGA Sections 3a and 7c Application 

H. Original soil contours will be restored, with allowance for settling as necessary. Trench crowns 

will be constructed where Oregon Pipeline Company determines that trench crowning is 

necessary to allow for trench settlement. 

6.3.2 Removal of Excess Rock 

A. The introduction of subsoil stones into the topsoil in agricultural lands will be minimized because 

Oregon Pipeline Company will segregate topsoil from the trench spoil. Oregon Pipeline Company 

will replace the segregated topsoil in agricultural lands after the Pipeline is installed and the 

trench spoil is backfilled. 

B. Blasting in agricultural lands is anticipated to be minimal. In agricultural areas over shallow 

bedrock that require blasting, matting, or controlled blasting will he used to limit the dispersion of 

blast rock fragments. Suitable precautions will be taken to minimize the potential for oversize 

rock from blasting or other trenching activities to become interspersed with soil that is placed 

back in the trench in agricultural areas and to prevent the introduction of rock into the topsoil. 

Landowners and/or tenants will be given timely notice before blasting on agricultural land. 

C. Excess rock, including blast rock, may be used to backfill the trench above the level of the pipe 

zone material up to the top of the existing bedrock profile. 

D. In agricultural land, the top 12 inches within the Pipeline trench, bore pits, or other excavations 

will not be backfilled with soil containing rocks of significantly greater concentration or size than 

existed before the Pipeline's construction. 

E. Following backfilling and decompaction in agricultural lands, excess rock will be removed from 

the subsoil surface before the replacement of topsoil. 

F. Following the final soil surface treatment, rocks will be removed as necessary so the size, density, 

and distribution of rock in the construction area will be similar to adjacent areas not disturbed by 

construction. 

G. Where additional soil is necessary to restore the original soil contours as a result of the removal 

of excess rock from the trench backfill, imported soil will be used but will not be allowed within 

the topsoil backfill. Imported soil will be consistent in texture and quality with the existing soil in 

the soil horizon in which it is placed on the affected site. 

6.3.3 Mitigation of Soil Compaction and Rutting 

A. Where topsoil is stripped in agricultural lands, Oregon Pipeline Company will relieve compaction 

of the exposed subsoil before replacing the topsoil. Oregon Pipeline Company will relieve subsoil 

compaction using an agricultural subsoiler or other appropriate implement. After decompaction 

and before topsoil replacement, a disc or harrow will be used, as necessary, to smooth the subsoil 

surface. 

B. Following final grading and topsoil replacement in agricultural lands, Oregon Pipeline Company 

will conduct deep tillage to relieve soil compaction in construction areas or will test soils for 

compaction at regular intervals. Where soil compaction is tested, construction areas will be 
OREGON BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

 

Oregon Pipeline Company 8 FERC NGA Sections 3a and 7c Application 

compared to adjacent areas not disturbed by construction using cone penetrometers or other 

appropriate devices or methods. Compacted agricultural lands will be treated using a 

noninversion, deep-tillage agricultural subsoiler specifically designed for soil decompaction and 

designed to minimize surface disturbance and mixing of subsoil with topsoil. 

C. Weather and soil conditions permitting, Oregon Pipeline Company will conduct soil 

decompaction when soil moisture levels allow for effective soil shattering. Decompaction 

equipment will not be operated on soils that are too wet, such that a greater level of soil 

compaction might result. 

D. Oregon Pipeline Company will use agricultural subsoiling equipment with shank operating depth 

and shank spacing that is adequate to effectively relieve soil compaction. 

E. Oregon Pipeline Company will make multiple passes of decompaction equipment where 

necessary to effectively relieve soil compaction. 

F. Oregon Pipeline Company will restore rutted areas and leave the soil in the proper surface 

condition for planting. 

G. On agricultural land, Oregon Pipeline Company will complete final grading, topsoil replacement, 

and installation of permanent erosion control structures within 20 days after backfilling the trench 

on each parcel, weather and soil conditions permitting. 

6.4 Construction in Wet Conditions 

6.4.1 Impact Avoidance 

A. As feasible, Oregon Pipeline Company will schedule most Pipeline construction activities to 

avoid the months of greatest precipitation 

B. On excessively wet soils, Oregon Pipeline Company will restrict certain construction activities 

such as the operation of heavy equipment, as feasible; or will take other appropriate action, so that 

soil productivity is preserved or so that soil productivity can be restored and to prevent damage to 

buried drain tiles and irrigation pipelines. 

6.4.2 Trench Dewatering 

A. Where it is necessary to pump water from open trenches, Oregon Pipeline Company will pump 

water into a constructed energy-dissipating structure in a manner that will minimize damage to 

adjacent agricultural land, drainage systems, and crops. 

B. If water-related damages occur to agricultural land as a result of pumping water from open 

trenches, Oregon Pipeline Company will reasonably compensate the landowner and/or tenant for 

crop damages, and will either restore the land to the preconstruction conditions or will reasonably 

compensate the landowner and/or tenant for damage to such land. 

C. Pumping of water from open trenches will be conducted so as to comply with Project permits, 

existing drainage laws, local ordinances relating to such activities, and provisions of the Clean 

Water Act.
OREGON LNG BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

Oregon Pipeline Company 9 FERC NGA Sections 3a and 7c Application 

6.5 Protection and Repair of Irrigation and Drainage Systems 

A. Before construction, Oregon Pipeline Company will contact landowners and tenants to identify 

the locations of irrigation systems, wells, and drainage systems. Identified underground irrigation 

water pipes, well systems, and drain tile lines that intersect the construction area will be flagged 

to alert construction crews. 

B. If underground irrigation water pipes, well systems, or drain tile lines in or adjacent to the 

construction area are damaged by construction activities or adversely affected by the Pipeline, 

Oregon Pipeline Company will repair the system to the former condition as nearly as possible in a 

manner that assures the proper operating condition at the point of repair, or restore the function of 

the system to the preconstruction condition or better. Such action may include the relocation, 

reconfiguration, or replacement of the pipe, well, or tile line. 

C. At the election of the landowner, Oregon Pipeline Company may negotiate a fair settlement with 

the affected landowner for the repair, reconfiguration, or replacement of damaged irrigation water 

pipes, well systems, or drain tile lines. Oregon Pipeline Company will not assume liability for the 

proper function of water pipes, wells, or drain tile repaired, reconfigured, or replaced by the 

landowner or the landowner's agent. 

D. Oregon Pipeline Company will conduct the repair, reconfiguration, or replacement of damaged 

water pipes, wells, or drain tiles where the damaged item is part of a system that affects 

neighboring landowners or is shared by neighboring landowners. 

E. Before completing permanent repairs, drain tiles and irrigation pipelines will be examined by 

suitable means on both sides of the trench for the entire length within the work area to check for 

damage by construction equipment. If damaged drain tiles or irrigation pipelines are found, they 

will be repaired to the former condition or better as nearly as possible. 

F. Drain tile and irrigation repairs will be made with materials of the same or better quality as that 

which was damaged. 

G. There will be a minimum of 12 inches clearance between the drain tiles (including any support 

member), irrigation facilities, and the Pipeline. 

H. Where an adjacent irrigation pipeline exists, Oregon Pipeline Company will install the Pipeline in 

agricultural areas with at least the same depth of cover as the existing, adjacent irrigation 

pipeline. 

6.5.1 Irrigation Systems 

A. Oregon Pipeline Company will maintain the flow of irrigation water during construction or will 

coordinate a temporary shut-off with affected parties. 

B. Oregon Pipeline Company will repair disrupted irrigation systems as soon as possible and will 

compensate affected parties for crop losses that result from irrigation system interruptions due to 

the construction of the Pipeline. 
OREGON BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

 

Oregon Pipeline Company 10 FERC NGA Sections 3a and 7c Application 

6.5.2 Drainage Systems 

Oregon Pipeline Company will repair damaged drain tiles in accordance with the following standards: 

A. During construction, any drain tile that is damaged, cut, or removed will be distinctly marked. 

The marker will be maintained until the drain tile has been permanently repaired. 

B. If water is flowing through a damaged tile line, the tile line will be immediately and temporarily 

repaired until permanent repairs are made. The exposed opening of cut or damaged tile lines 

where water is not flowing will be covered with filter material as soon as practically possible to 

prevent the entry of soil or other foreign material. 

C. Permanent drain tile repairs will be made within 60 days following the completion of construction 

on any affected landowners property, weather and soil conditions permitting. Where available, 

local drain tile contractors will be employed to make permanent repairs of affected tile lines. 

D. For permanent repairs where drain tiles are severed by the Pipeline trench: 

i. The damaged section of drain tile line will be replaced by rigid, non-perforated material, 

unless otherwise directed by the Project Inspector. The replacement section will be 

approximately the same internal diameter as the existing tile line or larger. The 

replacement section will be of sufficient strength to withstand typical point loads from 

construction and farming equipment on the soil surface above the repaired drain tile, or 

will be supported by a support member. 

ii. A support member will be used to support the repaired tile line where directed by the 

Project Inspector. The support member will be of sufficient strength to support the drain tile 

and to withstand typical point loads from construction and farming equipment on the soil 

surface above the repaired tile line. Support member materials, where necessary, may 

include plastic half pipe, nonmetallic 90-degree angle support, steel channel iron, steel 

angle iron, or other suitable materials. 

iii. The drain tile replacement section, and the support member, where used, will extend a 

minimum of 2 feet (as measured perpendicular to the trench wall) into previously 

undisturbed soil on both sides of the trench. The drain tile replacement section will extend 

to undamaged tile line, and an appropriate connector will be installed between the 

replacement section and the existing drain tile line. Support members, where used, will be 

installed in a manner that will prevent overturning. 

iv. Where tile repairs involve clay tile, the support member will extend to the first joint 

beyond the minimum 2-foot distance. 

v. The trench will be backfilled under each drain tile replacement section to obtain positive 

support that is not prone to settling. As necessary, clean sand will be used to backfill under 

sections of repaired drain tile. 

vi. The span of the drain tile replacement section over the trench will not exceed 12 feet. If the 

span of the drain tile replacement section over the trench would exceed 12 feet, the 
OREGON LNG BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

Oregon Pipeline Company 11 FERC NGA Sections 3a and 7c Application 

replacement section will be relocated as feasible into undisturbed soil so the subsequent 

span over the trench is less than 12 feet. 

vii. The grade of tile lines will be maintained. 

6.6 Identification and Repair of Soil Conservation Practices 

A. Oregon Pipeline Company will work with the U.S. Department of Agriculture (USDA), the 

agency with regulatory authority over federally enrolled conservation easements (e.g., WRP, 

CREP, CRP, EQIP) to protect sensitive resources and minimize potential adverse impacts. 

B. Soil conservation practices such as grassed waterways and terraces that are damaged by the 

Pipeline construction will be restored to their preconstruction condition as nearly as possible. 

6.7 Dust Control 

A. Oregon Pipeline Company will control excessive dust emissions generated during construction, as 

necessary, by the control of vehicle speed, by wetting the construction area, or by other means. 

B. Oregon Pipeline Company will coordinate with farm operators to provide adequate dust control in 

areas where specialty crops are susceptible to damage from dust contamination. 

6.8 Soil Erosion and Sediment Control 

A. Oregon Pipeline Company will implement erosion prevention and sediment control measures 

during construction in accordance with the Project's Department of Environmental Quality (DEQ) 

Construction Stormwater Permit (1200-C) and the FERC certificate and in consultation with 

agricultural landowners. 

B. Following construction, cultivated cropland will generally be reseeded or replanted by the 

landowner. Oregon Pipeline Company will reseed and mulch non-cultivated agricultural land 

such as pastures and perennial grass hayfields in consultation with landowners, or will make 

arrangements with landowners that prefer to conduct the reseeding of these areas. 

C. Oregon Pipeline Company will apply temporary mulch in the event of a seasonal shutdown, if 

construction or restoration activity is interrupted or delayed for an extended period, or if 

permanent seeding of non-cultivated areas is not completed during the recommended seeding 

period before the winter season. Temporary straw mulch will be applied to bare soil surfaces, 

including topsoil piles, at the rate of 4,000 pounds per acre and will be adequately anchored by 

crimping into the soil or by application of a tackifier. Interim seeding of a cover crop may be used 

in lieu of temporary mulching in some areas. 

D. Following construction, Oregon Pipeline Company will work with landowners and tenants to 

prevent excessive erosion on cultivated agricultural lands disturbed by construction. Where the 

landowner or tenant will not plant the area disturbed by construction before the first winter 

season, Oregon Pipeline Company will plant a temporary cover crop and/or will apply mulch 

following construction area restoration. The cover crop may be an annual grain, other annual 

grass, annual legume, or other appropriate species. 
OREGON BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

 

Oregon Pipeline Company 12 FERC NGA Sections 3a and 7c Application 

E. Permanent erosion control devices such as trench breakers and slope breakers will be installed 

along the Pipeline. Trench breakers are used to slow the flow of subsurface water along the trench 

where slopes are steeper than 5 percent. Slope breakers (also called waterbars or diversion berms) 

are intended to reduce runoff velocity and divert water off the surface of the area affected by 

construction. Slope breakers will typically be installed following construction as feasible on 

slopes steeper than 5 percent on non-cultivated agricultural land including pastures. Installation of 

permanent erosion control devices will be in conformance with the FERC Plan, Sections V.B.1 

and V.B.2. 

6.9 Weed Control 

A. On permanent easement areas where Oregon Pipeline Company has control of the surface use of 

the land such as aboveground valve sites and metering stations, Oregon Pipeline Company will 

provide for weed control in a manner that does not allow the spread of weeds to adjacent lands 

used for agriculture. Herbicide application on such areas will be conducted by an applicator 

licensed by the State of Oregon. 

B. Oregon Pipeline Company will consult with the Oregon Department of Agriculture and other 

appropriate agencies to determine the location of noxious weeds in the Project area prior to 

construction. Oregon Pipeline Company will take appropriate action to minimize the spread of 

noxious weeds in cooperation with the appropriate agency. 

C. To prevent the introduction of weeds from other geographic regions, Oregon Pipeline Company 

will require contractors to thoroughly clean each unit of construction equipment with highpressure washing before the initial move of those units of construction equipment to the general 

Project site and when moving equipment out of working areas with known noxious or nuisance 

weed infestations. 

D. Oregon Pipeline Company will use straw bales for erosion control and straw for mulch that are 

uncontaminated by noxious or nuisance weeds and are certified as weed free. 

E. Oregon Pipeline Company will use Oregon certified seed or equivalent for revegetation. 

F. For lands subject to Organic certification or where landowners specifically request that no 

herbicides be used, Oregon Pipeline Company will coordinate with affected landowners to 

provide alternate methods of weed control. 

6.10 Post-Construction Monitoring and Follow-Up Mitigation 

Oregon Pipeline Company will actively monitor soil restoration, crop production, tile drainage, and 

irrigation systems for 2 years following the completion of initial construction area restoration. During 

the monitoring period, Oregon Pipeline Company will identify remaining soil and agricultural 

impacts associated with construction that require mitigation and will implement follow-up restoration 

or appropriate mitigation measures. Follow-up repairs and restoration of damages that are the result of 

the Pipeline construction will not be limited to the 2-year monitoring period. 
OREGON LNG BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

Oregon Pipeline Company 13 FERC NGA Sections 3a and 7c Application 

6.10.1 Drain Tiles 

Oregon Pipeline Company will correct drain tile line repairs that fail because of Pipeline construction, 

provided those repairs were made by Oregon Pipeline Company. Oregon Pipeline Company will not 

be responsible for tile line repairs that the company, at the election of the landowner, paid the 

landowner or the landowner's agent to perform. 

To properly drain wet areas in agricultural lands caused by construction or the existence of the 

Pipeline, additional drain tile or other drainage measures will be installed on the permanent easement 

and temporary workspace, as necessary, to restore these areas to preconstruction conditions as nearly 

as feasible. 

6.10.2 Excess Rock 

On agricultural land, where cultivation or soil settling results in excess surface rock compared to the 

adjacent area not disturbed by construction, Oregon Pipeline Company will remove and dispose of the 

excess rock from the permanent and temporary easements. 

6.10.3 Trench Settlement 

Oregon Pipeline Company will repair trench settlement, as necessary. In agricultural lands where 

trench settling is excessive and cannot be repaired with minor surface grading; imported topsoil will 

be used. Oregon Pipeline Company will make reasonable efforts to obtain imported topsoil that is free 

of noxious weeds. Imported topsoil will be consistent in texture and quality with the existing topsoil 

on the affected site. 

6.10.4 Irrigation Systems 

Oregon Pipeline Company will correct problems with irrigation systems resulting from Pipeline 

construction. Oregon Pipeline Company will not be responsible for irrigation system repairs that 

Oregon Pipeline Company, at the election of the landowner, paid the landowner or the landowner's 

agent to perform. 

6.10.5 Crop Monitoring 

A. Oregon Pipeline Company will conduct onsite monitoring of growing crops at least two times 

during each growing season during the 2-year monitoring period. 

B. The growth of the crop on the construction area (permanent and temporary easement) will be 

compared with the adjacent area not disturbed by construction or to a comparable area of the field 

outside the construction area. Visual observations of crop plant vigor, density, height, color, and 

uniformity will be made. 

C. Where significant visual crop deficiencies occur on the construction area compared to the 

adjacent or comparable area not disturbed by construction, the Agricultural Specialist will 

determine the need for additional restoration measures. 

D. Oregon Pipeline Company will implement additional restoration or mitigation measures, as 

necessary, in cooperation with affected landowners and tenants. 
OREGON BIDIRECTIONAL PROJECT 

AGRICULTURAL IMPACT MITIGATION PLAN 

 

Oregon Pipeline Company 14 FERC NGA Sections 3a and 7c Application 

E. Oregon Pipeline Company will work with affected landowners and agencies to develop a postconstruction crop monitoring plan, which will detail standardized methods for inspection and 

impact evaluation with standardized field checklists to use on all affected properties. 

6.10.6 Noxious Weeds 

A. Oregon Pipeline Company will monitor the construction areas for noxious weed infestations in 

conjunction with the crop monitoring described above. 

B. Oregon Pipeline Company will take appropriate measures to control new noxious weed 

infestations that were not identified in the construction area before or during construction. 

C. Weed control will be conducted in cooperation with appropriate agencies and with landowners 

and farm operators. 

D. For lands subject to Organic certification or where landowners specifically request that no 

herbicides be used, Oregon Pipeline Company will coordinate with affected landowners to 

provide alternate methods of weed control. 
APPENDIX F3

CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL

AND OREGON PIPELINE PROJECT

Updated Mitigation Plan 

Applicant-Prepared 

Conceptual Mitigation Plan for the 

Oregon LNG Terminal and 

Oregon Pipeline Project 

Prepared for 

Federal Energy Regulatory Commission 

Docket Nos. CP09-6-001 and CP09-7-001

Originally Filed September 15, 2009 

First Revised Filing November 17, 2009 

Second Revised Filing December 19, 2013 

Third Revised Filing April 29, 2015 

Prepared by 

Contents 

Disclaimer ......................................................................................................................................................... vii

Acronyms and Abbreviations .............................................................................................................................. ix

Executive Summary ........................................................................................................................................ ES-1

1 Introduction ......................................................................................................................................... 1-1

1.1 Purpose ............................................................................................................................................ 1-1 

1.2 Scope ............................................................................................................................................... 1-1 

1.2.1 Cross-References to Documents Already Filed with FERC ................................................. 1-1 

1.2.2 History and Focus of the Mitigation Described in This Plan ............................................... 1-1 

1.2.3 Compliance Monitoring and Adaptive Management ......................................................... 1-3 

1.2.4 Regulatory Context and Standards ..................................................................................... 1-4 

1.2.5 Best Management Practices ............................................................................................... 1-5 

1.2.6 Onsite Strategies ................................................................................................................. 1-6 

1.2.7 Compensatory Mitigation ................................................................................................... 1-8 

1.2.8 Physiographic Regions and River Basins ............................................................................. 1-9 

1.3 Organization .................................................................................................................................... 1-9 

2 Preconstruction Surveys and Studies .................................................................................................... 2-1

3 Northern Spotted Owl .......................................................................................................................... 3-1

3.1 Onsite Mitigation ............................................................................................................................. 3-1 

3.2 Compensatory Mitigation ................................................................................................................ 3-3 

3.2.1 Effects ................................................................................................................................. 3-3 

3.2.2 Compensatory Mitigation ................................................................................................... 3-4 

3.2.3 Contingency ........................................................................................................................ 3-8 

3.3 Operational Mitigation, Post-Construction Monitoring, and Adaptive Management .................... 3-8 

4 Marbled Murrelet ................................................................................................................................ 4-1

4.1 Onsite Mitigation ............................................................................................................................. 4-2 

4.2 Effects and Compensatory Mitigation ............................................................................................. 4-3 

5 Fish ...................................................................................................................................................... 5-1

5.1 Onsite Mitigation, Avoidance, and Minimization Measures ........................................................... 5-1 

5.1.1 Pipeline ............................................................................................................................... 5-1 

5.1.2 Terminal ............................................................................................................................ 5-14 

5.2 Compensatory Mitigation .............................................................................................................. 5-18 

5.2.1 Unavoidable Effects .......................................................................................................... 5-19 

5.2.2 Compensatory Strategies and Measures .......................................................................... 5-20 

5.2.3 Rationale for the Extent of Fish-Related Compensatory Mitigation ................................ 5-23 

5.2.4 Mitigation Project Lists ..................................................................................................... 5-28 

5.3 Operational Mitigation, Post-Construction Monitoring, and Adaptive Management .................. 5-29 

5.3.1 Pipeline ............................................................................................................................. 5-29 

5.3.2 Terminal ............................................................................................................................ 5-30 

5.3.3 Adaptive Management Summary ..................................................................................... 5-32 

6 Habitat Types and Vegetation .............................................................................................................. 6-1

6.1 Onsite Mitigation ............................................................................................................................. 6-1 

6.1.1 Habitat Categories—Pipeline Corridor ............................................................................... 6-1 

6.1.2 Threatened and Endangered Plants ................................................................................... 6-2 

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APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

6.1.3 Revegetation ....................................................................................................................... 6-2 

6.1.4 Invasive Vegetation ............................................................................................................ 6-4 

6.2 Compensatory Mitigation ................................................................................................................ 6-4 

6.2.1 Unavoidable Impacts .......................................................................................................... 6-4 

6.2.2 Rare Plants .......................................................................................................................... 6-6 

6.3 Operational Mitigation, Post-Construction Monitoring, and Adaptive Management .................... 6-6 

6.3.1 Framework .......................................................................................................................... 6-6 

6.3.2 Performance Standards ...................................................................................................... 6-7 

6.3.3 Contingencies and Adaptive Management ........................................................................ 6-8 

7 Wetlands ............................................................................................................................................. 7-1

7.1 Onsite Mitigation ............................................................................................................................. 7-1 

7.1.1 Pipeline ............................................................................................................................... 7-1 

7.1.2 Terminal .............................................................................................................................. 7-6 

7.2 Compensatory Mitigation ................................................................................................................ 7-7 

7.2.1 Pipeline ............................................................................................................................... 7-7 

7.2.2 Terminal .............................................................................................................................. 7-8 

7.2.3 Mitigation Banking and In-lieu or Fee-in-lieu Payment Strategy ....................................... 7-9 

7.2.4 Land Acquisition and Conservation Easement Strategy ..................................................... 7-9 

7.3 Operational Mitigation, Post-Construction Monitoring, and Adaptive Management .................. 7-10 

7.3.1 Framework ........................................................................................................................ 7-10 

7.3.2 Performance Standards .................................................................................................... 7-11 

8 Stream Channels and Waterbodies ...................................................................................................... 8-1

8.1 Onsite Mitigation ............................................................................................................................. 8-1 

8.1.1 Stream Channel Crossings .................................................................................................. 8-1 

8.1.2 Applicant and Contractor Responsibilities ......................................................................... 8-5 

8.1.3 Preconstruction Site Characterization and Documentation ............................................... 8-5 

8.1.4 Stream Channel Restoration Measures .............................................................................. 8-6 

8.1.5 Restoration Documentation ............................................................................................... 8-7 

8.1.6 Water Quality ..................................................................................................................... 8-8 

8.2 Compensatory Mitigation ................................................................................................................ 8-9 

8.3 Operational Mitigation, Post-Construction Monitoring, and Adaptive Management .................... 8-9 

8.3.1 Performance Standards .................................................................................................... 8-10 

8.3.2 Reporting .......................................................................................................................... 8-11 

8.3.3 Adaptive Management Summary ..................................................................................... 8-11 

9 Marine Reptiles and Mammals............................................................................................................. 9-1

9.1 Onsite Mitigation ............................................................................................................................. 9-1 

9.1.1 Marine Mammals ............................................................................................................... 9-1 

9.1.2 Marine Reptiles ................................................................................................................... 9-2 

9.2 Compensatory Mitigation ................................................................................................................ 9-2 

9.3 Operational Mitigation, Post-Construction Monitoring, and Adaptive Management .................... 9-3 

10 Migratory Birds .................................................................................................................................. 10-1

10.1 Onsite Mitigation ........................................................................................................................... 10-1 

10.1.1 Preconstruction Monitoring ............................................................................................. 10-2 

10.2 Compensatory Mitigation .............................................................................................................. 10-3 

10.3 Operational Mitigation, Post-Construction Monitoring, and Adaptive Management .................. 10-3 

10.3.1 Construction Monitoring .................................................................................................. 10-3 

10.3.2 Contingency Salvage ......................................................................................................... 10-3 

11 Reptiles and Amphibians .................................................................................................................... 11-1

IV EN0427151027PDX 
CONTENTS 

12 Invertebrates ..................................................................................................................................... 12-1

12.1 Onsite Mitigation ........................................................................................................................... 12-1 

12.1.1 Fender’s Blue Butterfly (Icaricia icarioides fenderi) (Federal Endangered) ...................... 12-1 

12.1.2 Oregon Silverspot Butterfly (Speyeria zerene hippolyta) (Federal Threatened) .............. 12-1 

12.1.3 Taylor’s Checkerspot Butterfly (Euphydryas editha taylori) (Federal Candidate) ............ 12-2 

12.2 Compensatory Mitigation .............................................................................................................. 12-2 

12.3 Operational Mitigation and Post-Construction Monitoring .......................................................... 12-3 

13 Other Birds ........................................................................................................................................ 13-1

13.1 Onsite Mitigation ........................................................................................................................... 13-1 

13.1.1 Streaked Horned Lark (Eremophila alpestris strigata) (Federal Threatened, State 

Sensitive) .......................................................................................................................... 13-1 

13.1.2 Western Yellow-billed Cuckoo (Coccyzus americanus) (Federal Threatened) ................. 13-1 

13.2 Effects and Compensatory Mitigation ........................................................................................... 13-2 

14 Mammals ........................................................................................................................................... 14-1

14.1 Onsite Mitigation ........................................................................................................................... 14-1 

14.1.1 Columbia White Tailed Deer (Odocoileus virginianus leucurus) (Endangered) ................ 14-1 

14.2 Effects and Compensatory Mitigation ................................................................................................ 14-1 

15 References ......................................................................................................................................... 15-1

Appendices 

A Wildlife Habitats by Oregon Fish and Wildlife Department Category with Mitigation Goals 

B Stormwater Pollution Prevention Plan with Erosion Prevention and Sediment Control Plan; Spill 

Prevention, Control, and Countermeasures Plan; and Frac-Out Contingency Plan 

C Characteristics of Streams Crossed by the Pipeline 

D Probabilistic Analysis of ESA-Listed Salmonid Entrainment at Ballast and Cooling Water Intakes 

E Conceptual Wetland Restoration Monitoring Plan and Performance Standards and Review of Wetland 

Avoidance and Mitigation Efforts 

F Channel Response Matrix for Pipeline Crossings of Endangered Species Act Streams 

G Drawings of Typical Non-ESA-Listed Stream Crossings 

H Migratory Bird Avoidance and Monitoring Plan for the Oregon LNG Project 

Tables (located at the end of text, with the exception of the Executive Summary tables) 

ES-1 Summary of Compensatory Mitigation for Effects on Fish and Riparian Areas 

ES-2 Summary of Compensatory Mitigation for Permanent Effects on Wetlands 

ES-3 Summary of Compensatory Mitigation for Effects on Upland Vegetation 

ES-4 Summary of Adjusted Habitat Acquisition (acres) for Removal and Other Indirect Effects to Northern 

Spotted Owl 

ES-5 Summary of Adjusted Habitat Acquisition (acres) for Removal and Other Indirect Effects to Marbled 

Murrelet 

1-1 Oregon Department of Fish and Wildlife Mitigation Goals and Implementation Standards by Habitat 

Category 

3-1 Definitions of Categories of Relative Intensity for Habitat Removal and Other Indirect Effects for the 

Northern Spotted Owl 

3-2 Impacts and Proposed Mitigation for Habitat Removal 

3-3 Impacts and Proposed Mitigation for Other Indirect Effects 

3-4 Summary of Adjusted Habitat Acquisition (acres) for Removal and Other Indirect Effects 

3-5 Theoretical Scaling of Habitat Acquisitions Dependent on Availability in the Marketplace 

EN0427151027PDX V 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

3-6 Silvicultural Treatment Ratios for Northern Spotted Owl Habitat Removal and Other Indirect Impacts to 

Northern Spotted Owl 

4-1 Marbled Murrelet Suitable Habitat Units within the Action Area 

4-2 Definitions of Categories of Relative Intensity for Habitat Removal and Other Indirect Effects for the 

Marbled Murrelet 

4-3 Removal Impacts and Habitat Acquisition for the Marbled Murrelet 

4-4 Other Indirect Impacts and Habitat Acquisition for the Marbled Murrelet 

4-5 Summary of Adjusted Habitat Acquisition (acres) for Removal and Other Indirect Effects 

4-6 Hypothetical Adjustments to Mitigation for Out-of-kind Habitat Acquisitions 

4-7 Mitigation Ratios for Silvicultural Treatments for Indirect Effects on Marbled Murrelet Habitat 

5-1 Rivers and Streams Crossed Using HDD 

5-2 Potential Direct Take of Special-Status Species from Ballast/Cooling Water Withdrawal, Pile-Driving Noise, 

and Fish Salvage 

5-3 Degree to which Species are Affected by Unquantified Sources of Take 

5-4 Duration of Project Impacts 

5-5 Proposed Mitigation by Evolutionarily Significant Unit 

5-6 Estimated Lower Columbia River Coho Affected by Salvage 

5-7 Estimated Oregon Coast Coho Affected by Salvage 

5-8 Fish Barrier Projects Ranked as High Priority in Clatsop, Columbia, and Wallowa Counties 

6-1 Pipeline Construction Impacts by Habitat Category (Oregon) 

6-2 Pipeline Construction Impacts by Habitat Type (Oregon) 

6-3 Ratios for Compensatory Mitigation of Coniferous Forest and Non-Oak Deciduous Forest Habitats 

7-1 Summary of Minimization and Avoidance Measures for High-Value Wetlands 

7-2 Determination of Wetland Impacts Associated with Permanent and Temporary Easements and Planned 

Maintenance Activities 

7-3 10-Year Restoration Monitoring Schedule 

7-4 Summary of Performance Standards 

8-1 In-Water Work Periods Recommended by the Oregon Department of Fish and Wildlife 

10-1 List of Migratory Birds of Concern for the Oregon LNG Project and Associated Ecoregions within the 

Project Action Area 

Figures (located at the end of text, after Tables) 

5-1 Conceptual Riparian and Forested Wetland Mitigation 

5-2 Restoration for Streams with Existing Riparian Cover 

7-1 Typical Wetland Crossing Impacts 

7-2 Proposed Wetland Mitigation Site—Youngs River Mitigation Site 

7-3 Proposed Wetland Mitigation Site—Nehalem River Property 

VI EN0427151027PDX 
Disclaimer 

This conceptual mitigation plan is preliminary and subject to change based on the outcome of ongoing 

negotiations and reviews with regulatory agencies. Every attempt was made to estimate impacts and areas of 

mitigation consistent with the analyses presented in resource reports, the Applicant-Prepared Draft Biological 

Assessment and Essential Fish Habitat Assessment for the Oregon LNG Terminal and Oregon Pipeline Project, and 

the state and federal wetland permit applications (Oregon Removal-Fill, Washington Joint Aquatic Resources 

Application, and United States [U.S.] Army Corps of Engineers/U.S. Environmental Protection Agency Section 

404/10/103 applications). Many state and federal agencies (Federal Energy Regulatory Commission, U.S. Fish and 

Wildlife Service, National Marine Fisheries Service, Oregon Department of Fish and Wildlife, Washington 

Department of Fish and Wildlife, U.S. Environmental Protection Agency, Oregon Department of Land 

Conservation, Oregon Department of State Lands, Washington Department of Ecology, Oregon Water Resources 

Department, and U.S. Coast Guard) have jurisdictional authority over resources assigned by state and federal 

laws. Permit conditions from state and federal agencies will be the final authority on mitigation and conservation 

measures. Furthermore, impact calculations will be reevaluated during final engineering and design of the Oregon 

LNG project, and quantities of impacts and mitigation may change slightly. However, although quantities may be 

modified during final engineering and design, Oregon LNG is committed to the proposed actions and ratios in this 

document. 

EN0427151027PDX VII 

Acronyms and Abbreviations 

AC activity center

ATWS additional temporary workspace

BA Applicant-Prepared Draft Biological Assessment and Essential Fish Habitat Assessment for the 

Oregon LNG Terminal and Oregon Pipeline Project

BMP Best Management Practices 

BP Developed (power line corridors and roads) 

BPA Bonneville Power Administration 

CAS Chemical Abstract Service 

CF Conifer Forest

CFR Code of Federal Regulations 

CHU critical habitat unit 

CRMB Claremont Road Mitigation Bank 

dB decibel(s)

DEIS Draft Environmental Impact Statement

DF Deciduous Forest

DPS Distinct Population Segment 

DSL Oregon Department of State Lands 

Ecology Washington Department of Ecology 

EFH Essential Fish Habitat 

EI environmental inspector

EIR Environmental Information Request 

ESA Endangered Species Act

ESP East Bank Skipanon Peninsula 

ESU Evolutionarily Significant Unit

FBB Fender’s blue butterfly 

FERC Federal Energy Regulatory Commission 

FISRWG Federal Interagency Stream Restoration Working Group 

> greater than

HDD horizontal directional drilling

HUC Hydrologic Unit Code

IHA Incidental Harassment Authorization 

km kilometer(s)

LCR Lower Columbia River 

LCRE Lower Columbia River Estuary 

LNG liquefied natural gas 

LNGC liquefied natural gas carrier

LWD large woody debris

MBTA Migratory Bird Treaty Act 

mg/L milligrams per liter

MMPA Marine Mammal Protection Act 

MP milepost

MSDS Material Safety Data Sheet 

N/A not applicable

EN0427151027PDX IX 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

NGA Natural Gas Act 

NMFS National Marine Fisheries Service 

NOAA National Oceanic and Atmospheric Administration 

NPDES National Pollutant Discharge Elimination System 

NRCS Natural Resources Conservation Service 

OAR Oregon Administrative Rule 

OC coho Oregon Coast coho salmon 

ODA Oregon Department of Agriculture 

ODEQ Oregon Department of Environmental Quality 

ODF Oregon Department of Forestry 

ODFW Oregon Department of Fish and Wildlife 

ODOT Oregon Department of Transportation 

ORNHIC Oregon Natural Heritage Information Center 

OWEB Oregon Watershed Enhancement Board 

PAC polyanionic cellulose 

PCE Primary Constituent Element 

PEM palustrine emergent 

PFO palustrine forest 

Plan FERC’s Upland Erosion Control and Revegetation Plan

Procedures FERC’s Wetland and Waterbody Construction and Mitigation Procedures 

POTW Publicly Owned Treatment Works 

Project Oregon LNG Terminal and Oregon Pipeline Project 

PSS palustrine scrub/shrub 

RCW Revised Code of Washington 

ROW right-of-way 

SHU suitable habitat unit 

SPCC Spill Prevention, Control, and Countermeasures 

SRF Snake River fall-run [Chinook] 

T&E threatened and endangered 

TEC Turnstone Environmental Consultants 

TWS temporary workspace 

U.S. United States 

USACE United States Army Corps of Engineers 

USC United States Code

USCG United States Coast Guard 

USEPA United States Environmental Protection Agency 

USFWS United States Fish and Wildlife Service 

UWR Upper Willamette River 

WAC Washington Administrative Code 

WDFW Washington Department of Fish and Wildlife 

WDNR Washington Department of Natural Resources 

X EN0427151027PDX 
Executive Summary 

This conceptual mitigation plan describes measures that are prescribed to offset temporary and permanent 

effects disclosed in the resource reports, Applicant-Prepared Draft Biological Assessment and Essential Fish 

Habitat Assessment for the Oregon LNG Terminal and Oregon Pipeline Project (Applicant-Draft BA) (CH2M HILL, 

2013a (Sections 2.6, 5.0, 7.0 and Appendix 13 updated March 2015)1, and other supporting documents submitted 

to the Federal Energy Regulatory Commission as part of the Application filed by LNG Development Company, LLC 

(d/b/a Oregon LNG), and Oregon Pipeline Company, LLC (collectively, Oregon LNG) on June 7, 2013 (Oregon LNG, 

2013). Conceptual plans for wetland mitigation and stream crossings are also included. The Application was filed 

under Section 3 of the Natural Gas Act (NGA) for authorization to site, own, and construct a liquefied natural gas 

(LNG) receiving terminal and associated facilities (Terminal), and under Section 7 of the NGA to construct, own, 

and operate a new natural gas pipeline (Pipeline). Additional mitigation planning occurred in collaboration with 

agencies to identify further measures beneficial to assuring regulatory compliance. 

Mitigation Types 

Oregon LNG proposes to implement both onsite and compensatory mitigation measures. Extensive studies were 

conducted to document the presence or absence and location of sensitive species and their habitats. Oregon LNG 

evaluated alternative site layouts at the Terminal and Pipeline route as due diligence to avoid and minimize 

effects on sensitive habitats and species. The width of the construction corridor is the minimum necessary for a 

36-inch Pipeline. The horizontal directional drilling (HDD) construction technique would be employed in 13 

locations to avoid effects on sensitive riparian and stream habitats. Seasonal timing of construction would be an 

important aspect to mitigation. For example, tree clearing is scheduled in the late spring or early summer, before 

Pipeline construction, to avoid effects of erosion on steep ground in the Coast Range during the rainy season. Inwater water windows would be used to minimize potential effects on fish from dredging and stream crossings. 

Additional post-construction monitoring is proposed where needed, as described in the body of this plan. Three 

types of mitigation would be employed to compensate for temporary, long-term, and permanent effects on 

habitats. 

Onsite Mitigation 

Proposed onsite mitigation focuses on effects that occur within the footprint of the Terminal and Pipeline 

facilities. Measures are designed to avoid, minimize, or restore potential effects on natural resources. Strategies 

include site-specific measures where a practice unique to the site is warranted. For example, the HDD crossing 

method is a site-specific mitigation measure proposed to avoid and minimize effects on riparian areas, wetlands, 

migratory bird-nesting habitat, listed species of fish, and other fish-bearing and perennial streams. Most wetland 

effects would be temporary and restored immediately after construction. Riparian and upland habitats would be 

restored within the construction corridor. In agricultural areas and near meandering or scouring streams, the 

Pipeline would be buried with more than the minimum of 3 feet of cover to avoid conflicts with plowing or lateral 

and vertical movement of streams. 

Compensatory Mitigation 

Proposed compensatory mitigation focuses on non-site-specific effects. Effects include unavoidable temporal 

effects on habitats, long-term unavoidable effects, potential “take” of listed threatened and endangered species, 

and Cowardin class changes to wetlands. Oregon LNG initiated interaction with various regulatory agencies to 

collaborate on the development of compensatory strategies and approaches. While general strategic approaches 

1 On March 6, 2015, Oregon LNG submitted to FERC updated Sections 2.6 (Mitigation Strategy), 5.0 (Terrestrial Species), and 7.0 (References), as well as 

additions to Appendix 13 (Northern Spotted Owl and Marbled Murrelet Habitat Assessments and Survey Reports), consisting of the 2014 survey report 

and the 2015 habitat and impact assessment. Oregon LNG revised these portions of the document in close coordination with the U.S. Fish and Wildlife 

Service, which has informed Oregon LNG that it is satisfied with the revisions, and with the efforts made by Oregon LNG to avoid and minimize effects to 

Endangered Species Act-listed species. 

EN0427151027PDX ES-1 

 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

were identified, specificity was a goal to ensure that the ecological functions provided in mitigation projects are 

commensurate with the magnitude and duration of the effects. 

For example, compensatory mitigation for effects on listed species of fish focuses on alleviating limiting factors 

(e.g., access to salmon spawning and rearing habitat), restoring those populations that are most at risk, and 

implementing high-priority restoration activities consistent with recovery objectives. Specifically, one large 

mitigation area is proposed to offset negative effects on fish potentially caused by construction and operation of 

the Terminal. The area consists of 140 acres at the mouth of Youngs River (known as the Youngs River Mitigation 

Site), where modifications to a levee would reconnect historical floodplain to tidal hydrology. Barriers to fish 

passage are proposed for removal to promote increased access to productive spawning and rearing habitat. In 

addition to the Youngs River Mitigation Site, compensatory habitat mitigation in the Coast Range focuses on 

managing and preserving habitat for late-successional forest, limiting factors for the recovery of the northern 

spotted owl and marbled murrelet.

Oregon LNG’s approach to wetland mitigation follows the United States [U.S.] Environmental Protection Agency, 

U.S. Army Corps of Engineers (USACE), Oregon Department of State Lands (DSL), and Washington Department of 

Ecology mitigation sequencing. Where compensation is required, a watershed approach is followed to select 

available resource replacement sites that offer the greatest functional benefits. Permanent Cowardin class 

changes from shrub wetland to herbaceous wetland, and forested wetland to herbaceous or shrub wetland, 

would occur as a result of Pipeline construction and maintenance. Palustrine scrub/shrub wetlands would be 

restored in situ to the greatest extent possible. Oregon LNG is committed to providing mitigation to compensate 

for the temporal loss of wetland function. 

Unavoidable and permanent effects on wetlands in the Lower Columbia River Basin would be mitigated by 

establishing the aforementioned Youngs River Mitigation Site at the mouth of the Youngs River. Wetland effects 

in the Nehalem River basin will be mitigated through restoration, creation, and enhancement of approximately 45 

acres of floodplain adjacent to the Nehalem River. The Nehalem River property contains a large remnant river 

oxbow with an outlet to the river and pastures used for cattle grazing. Functional uplifts would occur by removal 

of cattle grazing; removal of reed canary to enhance salmon habitat; wetland creation and enhancement in the 

floodplain through grading and native plantings; and restoration of native riparian floodplain habitat. 

Proposed mitigation for wetland effects in the Lower Columbia–Clatskanie River basin in Oregon would consist of 

funding to a fee-in-lieu project or the Youngs River Mitigation Site. Out-of-kind mitigation focusing on restoration 

of salmon habitat, a priority in the Columbia River watershed, will be used to compensate for changes in Cowardin 

class in the Lower Columbia-Clatskanie River basin. 

Operational Mitigation, Post-Construction Monitoring, and Adaptive Management 

Operational mitigation and post-construction monitoring measures focus on effects that could occur once 

operations are underway. Restoration within the Pipeline corridor (i.e., upland, riparian, and wetland restoration; 

stream and streambank restoration) and at offsite compensatory mitigation sites would be monitored to ensure 

that sites are on a trajectory to meet management objectives. At the Terminal, the shoreline would be monitored 

quarterly to evaluate shoreline erosion. Bird roosting behavior would be monitored to ensure the Terminal is not 

stimulating roosting behavior and congregations of birds that may prey on juvenile salmon. 

Day-to-day operations are not likely to affect restored habitat or wildlife behavior above the buried Pipeline. 

However, points of access along the Pipeline would be monitored to ensure the blockage of access by off-road 

vehicles. The unlikely need for a Pipeline repair could create the potential for adverse effects on the northern 

spotted owl or marbled murrelet. If unforeseen repairs necessitate activities within 1.5 miles of potential suitable 

or occupied habitat, then the U.S. Fish and Wildlife Service (USFWS) would be notified and plans developed to 

implement necessary conservation measures. 

Oregon LNG proposes the organization of a formal interagency Adaptive Management Team (Team) to be 

operative during preconstruction of the Terminal and Pipeline and to continue several years post-construction. 

The Team would comprise representatives from the USACE, DSL, Oregon Department of Fish and Wildlife (ODFW), 

Oregon Department of Forestry, Oregon Department of Environmental Quality, USFWS, National Marine Fisheries 

ES-2 EN0427151027PDX 
EXECUTIVE SUMMARY 

Service, USEPA, Washington Department of Fish and Wildlife, and U.S. Coast Guard. Each agency would provide a 

primary contact and a backup for involvement. The initial charge of the Team would be to review specific 

mitigation projects and designs for adequacy and compliance with agency design standards. The ongoing role of 

the Team would be to provide consultation and recommendations in the event of a significant Project 

modification, emergency, or unanticipated effect on fish and wildlife, and their habitats. 

Summary of Proposed Mitigation 

Tables ES-1 through ES-5 summarize proposed mitigation for potential effects in each of the following five natural 

resource area categories: 

x Fish and Riparian Areas 

x Wetlands 

x Upland VegetationNorthern Spotted Owl 

x Marbled Murrelet 

Each summary table includes proposed actions, corresponding effects, habitat category, effect quantity and 

duration, and approximate mitigation cost (if known). 

The Pipeline construction corridor amounts to approximately 1,100 acres, about 16 percent of which is Category 5 

and 6 habitat that does not require compensatory mitigation according to the guidelines stated in Oregon 

Administrative Rules 635-415-0000 to 635-415-0010, the ODFW Habitat Mitigation Policy. 

On the basis of currently assessed effects, Oregon LNG proposes approximately 1,220 acres of compensatory 

habitat mitigation for the Pipeline in the Coast Range to comply with the ODFW policy. To comply with the August 

2014 Revised Conservation Framework for the Northern Spotted Owl and Marbled Murrelet: Jordan Cove Energy 

and Pacific Connector Gas Pipeline Project (Conservation Framework) (USFWS, 2014), Oregon LNG proposes 

approximately 346 acres and 820 acres of habitat acquisition for the marbled murrelet and northern spotted owl, 

respectively. Areas of habitat mitigation may be adjusted upward according to Tables 3-2 through 3-5 and 4-3 

through 4-6, depending on quality of habitat available for acquisition. Operationally, habitat acquisitions to 

comply with the ODFW Habitat Mitigation Policy and USFWS Conservation Framework would not be additive. The 

acquisitions would be stacked in such a manner that each agency’s mitigation or conservation requirements are 

met. For example, “X” acres of habitat acquisition for compliance with the Conservation Framework could be the 

same “X” acres for compliance with the Habitat Mitigation Policy. Section 3.2.2 in this conceptual mitigation plan 

describes silviculture and barred owl management options that may be substituted for portions of habitat 

acquisition strategy to satisfy compliance with the USFWS Conservation Framework. 

An additional 140 acres of wetland mitigation would be provided at the Youngs River Mitigation Site for wetland 

fill associated with the Terminal facilities and Pipeline in the Lower Columbia River watershed. About 13 wetland 

mitigation credits will be created at the Nehalem River property to compensate for Cowardin class changes from 

palustrine forest/palustrine scrub/shrub to palustrine emergent within the Nehalem and Lower Willamette 

watersheds. Oregon LNG proposes to provide approximately 4.4 miles of riparian restoration and enhancement 

independent of the 1,220 acres of ODFW habitat acquisitions, and to remove seven barriers to fish passage. 

Removal of the barriers is anticipated to open up at least 7 miles of quality spawning habitat for salmonids. 

Proposed compensatory mitigation includes the following commitments: 

x Target mitigation acquisitions and conservation easements in blocks as large as possible, strategically located 

as possible to benefit Endangered Species Act-listed species, and with a focus on older stands 

x Manage parcels in the Coast Range for late-successional and old-growth habitat 

x Fund long-term management (management planning and implementation, monitoring, and reporting) 

x Form an interagency Adaptive Management Team to oversee individual mitigation projects and to oversee 

accounting that would ensure each agency’s requirements are satisfied. 

EN0427151027PDX ES-3 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

x Commit to develop documents before construction authorization that bind the Project to the mitigation plan 

and long-term mitigation obligations2. 

The body of this plan provides detailed descriptions of proposed mitigation in the natural resource areas 

identified above. 

2 Instruments are in place for use of the Youngs River and Nehalem River properties for wetland mitigation. 

ES-4 EN0427151027PDX 

 
TABLE ES-1Summary of Compensatory Mitigation for Effects on Fish and Riparian Areas 

Action Effect 

Evolutionarily 

Significant Unit/Distinct 

Population Segment 

ODFW 

Habitat 

Category 

Ecoregion or 

HUC of Effect 

Mitigation 

Location Mitigation Type Effect Quantity Units Duration of Effect Mitigation Ratio Mitigation Quantity Mitigation Units 

Approximate 

cost basis fo

fee) 

$$/Unit T

Ship water withdrawals (125 ships annually) 

Potential fish entrainment in cooling water 

Eulachon N/A LCRE None None Several 

thousand 

Individual larvae 

Annually, November to June 

N/A None N/A 

Ship ballast water withdrawals (2 annually) 

Potential fish entrainment in ballast water 

LCR Chinook N/A LCRE Youngs River 

Property 

Reconnect floodplain to estuary 

Less than 3.62 to 13.81 

Individuals, juveniles 

Dec/Jan N/A 140 Acres Actual 

cost 

Acco

Ship ballast water withdrawals (2 annually) 

Potential fish entrainment in ballast water 

Snake River Fall Chinook 

N/A LCRE Within the 

spawning/rearing range of the ESU 

Remove fish barrier 

 0.14 to 0.56 

Individuals, juveniles 

Annual N/A 1 Project Actual 

cost 

Acco

Ship ballast water withdrawals (2 annually) 

Potential fish entrainment in ballast water 

Snake River spring/summer run chinook 

N/A LCRE Youngs River 

Property 

Reconnect floodplain to estuary 

0.01 to 0.07 annually 

Individuals, juveniles 

Annual N/A 140 Acres Actual 

cost 

Acco

Ship ballast water withdrawals (2 annually) 

Potential fish entrainment in ballast water 

LCR Coho N/A LCRE Youngs River 

Property 

Reconnect floodplain to estuary 

Less than 0.22 to 1.19

Individuals, juveniles 

Annual N/A 140 Acres Actual 

cost 

Acco

Ship ballast water withdrawals (2 ships annually) 

Potential fish entrainment in ballast water 

Unlisted species N/A LCRE Youngs River 

Property 

Reconnect floodplain to estuary 

Not quantified 

 Annual N/A 140 Acres 

Pile driving Noise LCR Chinook N/A LCRE Youngs River 

Property 

Reconnect floodplain to estuary 

122 Individuals One-time N/A 140 Acres Actual 

cost 

Acco

Pile driving Noise Snake River Fall-run 

Chinook 

N/A LCRE Youngs River 

Property 

Reconnect floodplain to estuary 

3 Individuals One-time N/A 1 Project Actual 

cost 

Acco

Dredging Entrainment All ESA-listed 

salmonids 

N/A LCRE Youngs River 

Property 

Reconnect floodplain to estuary 

0.3 Percent of 

time/migration habitat 

One-time N/A 140 Acres Actual 

cost 

Acco

Dredging Entrainment Unlisted species N/A Reconnect 

floodplain to estuary 

 None 

proposed 

 

Pipeline construction Loss of LWD 

recruitment potential 

Unlisted species DF4, DF3, 

DF2, F4, anCF3 

155 total streams with riparian cover within at least 100 feet of the stream bank. 

Same as for temporal loss land clearing 

Same as for temporal loss land clearing 

 

Pipeline construction Fish salvage OC Coho N/A Crossings listed 

above 

Upper or Lower Nehalem 5th Field HUC 

Remove fish barrier 

178 Individual 

juveniles 

One-time N/A 2 Project Actual 

cost 

Acco

Pipeline construction Fish salvage LCR coho N/A Crossings listed 

above 

Young Bay 5th Field HUC 

Remove fish barrier 

58 Individual 

juveniles 

One-time N/A 2 Project Actual 

cost 

Acco

EN0427151027PDX 
TABLE ES-1Summary of Compensatory Mitigation for Effects on Fish and Riparian Areas 

Action Effect 

Evolutionarily 

Significant Unit/Distinct 

Population Segment 

ODFW 

Habitat 

Category 

Ecoregion or 

HUC of Effect 

Mitigation 

Location Mitigation Type Effect Quantity Units Duration of Effect Mitigation Ratio Mitigation Quantity Mitigation Units 

Approximate 

cost basis fo

fee) 

$$/Unit T

Clearing riparian vegetation for pipeline construction 

Stream temperature 

N/A 2, 3, 4 Lower 

Columbia, Coast Range, Lower ColumbiaClatskanie, Willamette 

N/A N/A < 1 Degree F per 

crossing 

Modeled for hottest day 

N/A N/A N/A 

Clearing riparian vegetation for pipeline construction 

Temporal loss of habitat, including LWD recruitment; 155 streams with existing riparian vegetation 

N/A 3, 4 Coast Range Primarily 

Nehalem Watershed 

Riparian vegetation restoration, enhancement, protection; invasive species control and placement of LWD may accompany vegetation restoration/ 

enhancement 

projects. 

2.94 Miles 3 to 80 

years 

1.5:1 4.41 Miles $100,000

/ mile 

$4

Notes: ESA = Endangered Species Act 

DF = Deciduous Forest ESU = Evolutionarily Significant Unit F = Fahrenheit HUC = Hydrologic Unit Code LCR = Lower Columbia River LCRE = Lower Columbia River estuary LWD = large woody debris N/A = Not applicable OC = Oregon Coast ODFW = Oregon Department of Fish and Wildlife 

EN0427151027PDX 
TABLE ES-2Summary of Compensatory Mitigation for Permanent Effects on Wetlands 

Action Effect 

Oregon Department 

of Fish and Wildlife 

Habitat Category 

Ecoregion or 

HUC of Effect 

Mitigation Location 

(Site, Ecoregion, or 

HUC) 

Mitigation Type Effect Quantity Units Duration of Effect Mitigation Ratio Mitigation Quantity Mitigation Units $$/Unit 

Land clearing, filling, and development; Terminal and Terminal infrastructure 

Permanent fill of wetlands 

2, 3 Lower Columbia West bank, mouth of 

Youngs River 

Estuarine enhancement; reconnect floodplain to estuary 

33.02 Acres Permanent 3:1 99.06 Acres Actual cost 

Clearing; Terminal Permanent class 

change of PFO to PSS or PEM 

2, 3 Lower Columbia West bank, mouth of 

Youngs River 

Out-of-kind wetland and 

salmon habitat 

1.9 Acres Permanent 1:1 1.9 Credit Actual cost 

Clearing; Pipeline Permanent class 

change of PFO to PSS or PEM 

2, 3 Lower Columbia West bank, mouth of 

Youngs River 

Estuarine enhancement; reconnect floodplain to estuary 

6.91 Acres Permanent 1:1 Acres Actual cost 

Clearing; Pipeline Permanent class 

change of PFO to PSS or PEM 

2, 3 Lower Columbia Lower Columbia In-Lieu 

Fee Bank 

Out-of-kind wetland and 

salmon habitat 

6.9 Acres Permanent 1:1 6.9 Credit 

Clearing; Pipeline Permanent class 

change of PFO to PSS or PEM 

2, 3 Nehalem Floodplain adjacent to 

Nehalem River 

PFO habitat 

enhancement and 

preservation 

9.82 Acres Permanent 3:1/1.5:1 See 

below 

Acres Actual cost 

Clearing; Pipeline Permanent class 

change of PFO to PSS or PEM 

2, 3 Lower Willamette Floodplain adjacent to 

Nehalem River 

PFO habitat enhancement and restoration, salmon habitat restoration, wetland creation 

1.31 Acres Permanent 3:1/1.5:1 33.81 Acres Actual cost 

Clearing; Pipeline Permanent class 

change of PFO to PSS or PEM 

2, 3 Lower ColumbiaClatskanie West bank, mouth of Youngs River Estuarine enhancement; reconnect floodplain to 

estuary 

4.66 Acres Permanent 3:1 13.98 Acres Market rate 

Notes: Credits and effects are not necessarily equal. The number of acres to create a credit is variable and is predetermined as appropriate to compensate for affected functions and acreage. Mitigation banks operate according to an Instrum

Department of State Lands, United States Army Corps of Engineers, United States Fish and Wildlife Service, United States Environmental Protection Agency, and Oregon Department of Fish and Wildlife). For example, 3 acres (3:1 a

banking credit. HUC = Hydrologic Unit Code PEM = palustrine emergent PFO = palustrine forest PSS = palustrine scrub/shrub 

EN0427151027PDX 
TABLE ES-3Summary of Compensatory Mitigation for Effects on Upland Vegetation 

Action Effect ODFW Habitat Category Ecoregion or HUC of Effect Mitigation Location (Site, Ecoregion, or HUC) Mitigation Type Effect Quantity Units Duration of Effect Mitigation Ratio Mitigation Quantity Mitigation Units APPROXIMATE 

cost basis for i

$$/Unit 

Pipeline land clearing 

Temporal loss of habitat to terrestrial wildlife and migratory birds: 50-foot 

permanent easement 

BP, CF, and DF 3, 4 

Coast Range Coast Range Land acquisition for 

management of latesuccessional forest and preservation 

384a Acres 3 to 80 

years 

2:1 768 Acres Market rate M

Pipeline land clearing 

Temporal loss of habitat to terrestrial wildlife and migratory birds: 50-foot TWS and ATWS 

BP, CF, and DF 3, 4 

Coast Range Coast Range Land acquisition for 

management of latesuccessional forest and preservation 

453a Acres 3 to 80 

years 

1:1 453 Acres Market rate M

Pipeline l and clearing 

Primary Constituent Element (PCE) marbled murrelet and northern spotted owl habitat 

CF 3, 4, and 5 Coast Range, 

designated Critical Habitat on state land 

Coast Range Land acquisition for 

management of latesuccessional forest and preservation 

Variable by species and PCE 

Acres 3 to >80 

years 

N/A Approx. 

1,220 

Acres Market rate M

a Includes upland and riparian buffers. 

Notes: ATWS = additional temporary workspace BP = Developed CF = Conifer Forest DF = Deciduous Forest HUC = Hydrologic Unit Code N/A = Not applicable ODFW = Oregon Department of Fish and Wildlife PCE = Primary Constituent Element TWS = temporary workspace 

EN0427151027PDX 
TABLE ES-4 

Summary of Adjusted Habitat Acquisition (acres) for Removal and Other Indirect Effects to Northern Spotted Owl 

Action Effect Mitigation Type Critical Habitat Subunit 

Mitigation Location 

(Site, Ecoregion, or 

Hydrologic Unit Code) 

Habitat Type a

Other 

Indirect 

Effects 

Habitat 

Removal Total 

APPROXIMATE COST (or cost 

basis for in lieu fee) 

$$/Unit Total $$ 

Pipeline land clearing of designated critical habitat and suitable Northern Spotted Owl nesting habitat 

Temporal and permanent loss of habitat to terrestrial wildlife and migratory birds: 50-foot 

permanent easement 

Habitat acquisition for management of latesuccessional forest and preservation/Barred Owl Management Program 

North Coast and Olympic Ranges (NCO04) 

Coast Range NRF 

Dispersal Capable Total

175.35 141.46 1.45 318.26 

148.96 346.23 6.38 501.57 

324.30 487.83 7.83 819.96 

Market rate Market rate 

a Habitat types are defined in Section 3 (Northern Spotted Owl). See Tables 3-2, 3-3, and 3-5 in Section 3 for mitigation ratios. b As discussed in a meeting between the United States Fish and Wildlife Service and CH2M HILL on October 30, 2014. 

Notes: HUC = hydrologic unit code NRF= nesting, roosting, foraging 

EN0427151027PDX 
TABLE ES-5 

Summary of Adjusted Habitat Acquisition (acres) for Removal and Other Indirect Effects to Marbled Murrelet 

Action Effect Mitigation Type Critical Habitat Subunit Mitigation Location (Site, Ecoregion, or HUC) Habitat Type* Other Indirect Effects Habitat Removal Total 

APPROXIMATE COST (or cos

basis for in-lieu fee) 

$$/Unit Total $$ 

Pipeline land clearing of designated critical habitat and suitable marbled murrelets nesting habitat 

Temporal and permanent loss of habitat to terrestrial wildlife and migratory birds: 50-foot 

permanent easement 

 Habitat acquisition for management of latesuccessional forest and preservation 

North Coast and Olympic Ranges (NCO04) 

Coast Range Suitable 

Recruitment Capable Total 

38.34 42.41 15.66 96.41 

14.16 194.13 41.29 249.58 

249.58 236.54 56.95 56.95 

Market rate Market rate 

* Habitat types are defined in Section 4 (Marbled Murrelet). See Tables 4-3, 4-4, and 4-6 in Section 4 for mitigation ratios. Note: HUC = hydrologic unit code EN0427151027PDX 
SECTION 1 

Introduction 

1.1 Purpose 

The purpose of this conceptual mitigation plan (Plan) is to summarize proposed mitigation associated with the 

Oregon LNG Terminal and Oregon Pipeline Project (Project) in a single, comprehensive document. This plan is 

intended to aid the Federal Energy Regulatory Commission (FERC) with the preparation of a Draft Environmental 

Impact Statement (DEIS) and facilitate federal and state regulatory collaboration and review. 

1.2 Scope 

This Plan describes measures that are prescribed to offset temporary and permanent effects disclosed in the 

resource reports, Applicant-Prepared Draft Biological Assessment and Essential Fish Habitat Assessment for the 

Oregon LNG Terminal and Oregon Pipeline Project (Applicant-Draft BA) (CH2M HILL, 2013a) (Sections 2.6, 5.0, 7.0 

and Appendix 13 updated March 2015)3, and other supporting documents submitted to FERC as part of the 

Application filed by LNG Development Company, LLC (d/b/a Oregon LNG), and Oregon Pipeline Company, LLC 

(collectively, Oregon LNG) on June 7, 2013 (Oregon LNG, 2013). Conceptual plans for wetland mitigation and 

stream crossings are also included. The Application was filed under Section 3 of the Natural Gas Act (NGA) for 

authorization to site, own, and construct a liquefied natural gas (LNG) receiving terminal and associated facilities 

(Terminal), and under Section 7 of the NGA to construct, own, and operate a new natural gas pipeline (Pipeline). 

Additional mitigation planning occurred in collaboration with agencies to identify further measures beneficial to 

assuring regulatory compliance. 

The following subsections further expand on the multifaceted scope of this plan. 

1.2.1 Cross-References to Documents Already Filed with FERC 

To minimize redundancy, descriptions of the Project, associated facilities, and related actions are not repeated 

here. Complete descriptions are provided in Resource Reports 1 (General Project Description), 2 (Water Use and 

Quality), 3 (Fish, Wildlife, and Vegetation), and 8 (Land Use, Recreation, and Aesthetics), filed with FERC on June 7, 

2013 (Oregon LNG, 2013), and in the Applicant-Draft BA. Additional references are made to other resource 

reports filed on June 7, 2013, to the Pipeline Supplement filing in April 2014 (Oregon LNG, 2014a), and to the 

Supplement filing in December 2014 (Oregon LNG, 2014b). 

1.2.2 History and Focus of the Mitigation Described in This Plan 

Origins of this conceptual mitigation plan date to 2008, when Oregon LNG initiated discussions with the Oregon 

Department of Fish and Wildlife (ODFW), United States (U.S.) Fish and Wildlife Service (USFWS), and National 

Marine Fisheries Service (NMFS) to vet environmental issues for the proposed Project and to develop strategies 

for mitigating4 potential impacts to fish and wildlife habitat. Oregon LNG voluntarily agreed to comply with the 

ODFW Habitat Mitigation Policy (OAR 935-415-0000 through 0025). Through interagency meetings in 2008 and 

2009, Oregon LNG negotiated a conceptual plan for mitigating impacts to fish and wildlife habitat that became the 

basis for the original submittal of the Plan in September 2009. The original 2009 Plan presented best management 

practices (BMPs), avoidance and minimization strategies, and summary of compensatory mitigation to address 

ODFW’s Habitat Mitigation Policy, state and federal wetland rules, and conservation measures5 for listed species 

3 On March 6, 2015, Oregon LNG submitted to FERC updated Sections 2.6 (Mitigation Strategy), 5.0 (Terrestrial Species), and 7.0 (References), as well as 

additions to Appendix 13 (Northern Spotted Owl and Marbled Murrelet Habitat Assessments and Survey Reports), consisting of the 2014 survey report 

and the 2015 habitat and impact assessment. Oregon LNG revised these portions of the document in close coordination with the U.S. Fish and Wildlife 

Service, which has informed Oregon LNG that it is satisfied with the revisions, and with the efforts made by Oregon LNG to avoid and minimize effects to 

Endangered Species Act-listed species.

4 This conceptual mitigation plan follows the definition of “mitigation” provided in Oregon Administrative Rules 635-415-0005 and 141-085-9514.

5 “Conservation measures” is a term used by USFWS in the context of providing actions to preserve endangered species and promote their recovery.

“Conserve,” “conserving,” and “conservation” are defined in 16 United States Code Chapter 35 § 1532. Unlike “conservation,” “mitigation” specifically 

refers to an orderly sequence of avoidance, minimization, rectifying, and compensatory actions. However, both terms embrace best management 

EN0427151027PDX 1-1 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

of fish and wildlife gathered from resource reports and the Applicant-Draft BA. In 2013, the Plan was revised to 

address the change in the Oregon LNG project description from an import terminal and inbound pipeline to an 

export terminal with a bidirectional pipeline. Discussions with USFWS indicated that potential impacts to northern 

spotted owl and marbled murrelet habitat could be compensated through the mitigation provided in voluntary 

compliance with ODFW’s Habitat Mitigation Policy. 

In 2014, USFWS issued a guidance document for the Jordan Cove-Pacific Connector Project, Revised Conservation 

Framework for the Northern Spotted Owl and Marbled Murrelet: Jordan Cove Energy and Pacific Connector Gas 

Pipeline Project (Conservation Framework) (USFWS, 2014)6. According to USFWS (Young/USFWS, 2014, personal 

communication), the Conservation Framework is appropriate for use by proponents of linear development 

projects, where numerous northern spotted owl and marbled murrelet individuals and habitats may be 

encountered during project construction and operations. Upon the request of USFWS, Oregon LNG analyzed 

potential impacts to the marbled murrelet and northern spotted owl according to the Conservation Framework 

and developed conservation measures consistent with the Conservation Framework. Whereas the Applicant-Draft 

BA originally referred to the Plan for conservation measures pertaining to the marbled murrelet and northern 

spotted owl, USFWS further requested that such measures be incorporated into the text of the Applicant-Draft 

BA. Oregon LNG updated portions of the Applicant-Draft BA (Sections 2.6, 5.0, 7.0 and Appendix 13) in March 

2015 that included conservation measures for the marbled murrelet and northern spotted owl in accordance with 

the Conservation Framework. 

In an Environmental Information Request (EIR) dated April 9, 2015, FERC requested that Oregon LNG update the 

Plan. Thus, this revision of the Plan was prepared in response to FERC’s EIR. The primary updates in this revision of 

the Plan were to incorporate conservation measures for the marbled murrelet and northern spotted owl that 

were submitted with updated sections of the Applicant-Draft BA (Sections 2.6, 5.0, 7.0 and Appendix 13) on 

March 26, 2015. As a result, two habitat mitigation concepts are incorporated in this Plan: one that demonstrates 

voluntary compliance with the state ODFW Habitat Mitigation Policy and one that demonstrates voluntary 

compliance with the federal Conservation Framework. The ODFW Habitat Mitigation Policy and USFWS 

Conservation Framework required two different approaches to analyzing potential impacts to habitats and two 

different concepts with differing ratios for habitat mitigation. Habitat acquisition or enhancement with long-term 

management and conservation easements are the common element to the state and federal approaches to 

habitat mitigation and conservation of threatened or endangered species. 

In this revision to the Plan, the voluntary mitigation and conservation measures that were negotiated with ODFW 

and USFWS are addressed separately to enable accounting of each agencies mitigation frameworks. However, 

operationally, habitat acquisition and enhancement projects would not be additive. They would be stacked in 

such a manner that each agency’s mitigation or conservation requirements are met. For example, “X” acres of 

habitat acquisition for compliance with the USFWS Conservation Framework could be the same “X” acres for 

compliance with the ODFW Habitat Mitigation Policy. Section 1.2.3.2 describes an adaptive management team 

that would be created to review individual mitigation projects and track mitigation compliance for the respective 

agencies represented on the team. 

Mitigation described in this plan pertains only to natural resources affected by the construction of the Terminal 

site, the bidirectional Pipeline, and post-construction operation of those facilities for the life of the Project. The 

mitigation strategies described do not address any future actions because there are no current plans for further 

practices, strategies to avoid and minimize, and habitat acquisition. Strictly speaking, in ODFW Habitat Mitigation Policy, habitat acquisition would be a 

compensatory action whereas in an Endangered Species Act context, habitat acquisition is not viewed as compensatory, but rather as a proactive 

measure to prevent further declines or to promote the recovery to a listed species. While there are nuances to the terms “conservation measure” and 

“mitigation” as used in the context of state and federal policy, operationally the terms are roughly equivalent. Both terms are used in this Plan. 

6 The Conservation Framework “provides direction and methods to quantify and categorize the impacts to [northern spotted owls] (and [marbled 

murrelets]) and their habitat, and a means to offset these impacts” with respect to the Jordan Cove Energy and Pacific Connector Pipeline Projects 

currently pending before FERC in Docket Nos. CP13-483-000 and CP13-492-000 (FERC, 2014). The Conservation Framework is included as Appendix Z-4 

to the February 2015 Biological Assessment and Essential Fish Habitat Assessment prepared for those projects (FERC, 2015). The Conservation 

Framework is not binding on Oregon LNG, but provides relevant guidance in certain instances. Thus, this Plan incorporates certain of its voluntary 

measures. 

1-2 EN0427151027PDX 

 
SECTION 1—INTRODUCTION 

expansions, nor any future plans for abandonment. Any future actions that might occur would be preceded by 

submittals of new and separate applications to FERC. 

This document presents mitigation measures for resources and species determined to be potentially affected by 

the Project. Non-Endangered Species Act (ESA) issues involving wetlands, terrestrial habitats, and migratory birds 

that have been included in any of the previous submittals to FERC are addressed in this Plan, as well. Species that 

have not been addressed in either the resource reports or the Applicant-Draft BA are not specifically addressed 

here. Potential habitats for those species are addressed either in mitigation proposed based on ODFW “Mitigation 

Goals and Standards” (OAR 635-415-0020 through 0025), or by habitats that overlap those included herein. The 

majority of the mitigation measures consist of BMPs, site and route selection, and facility plans incorporated as 

design elements intended to avoid, minimize, and restore effects expected to result from the proposed actions. 

The mitigation and conservation measures are further intended to provide a context for standards of performance 

and establish expectations for preconstruction, construction, and post-construction implementation. Although 

strategies and measures developed in the planning and assessment phase are essentially conceptual, providing 

specificity has been a primary objective. Efforts to develop specific mitigation have been conducted as a goodfaith measure to provide assurances that they would be implemented as intended. The level of specificity varies 

to a degree. Mitigation has been integrated into Project and facility design, route location and site selection, 

construction and operational procedures, and post-construction rehabilitation to the greatest degree practicable. 

These strategies have been planned in detail with the intent of avoiding minimizing, and restoring expected 

effects “onsite.” Mitigation and conservation strategies intended to address compensatory needs, which are 

mostly “offsite” projects, are not as detailed, primarily as a result of additional mandated future access, 

acquisition, partnering, and permitting processes that would subsequently be required once the Project is 

authorized. 

Oregon LNG is in the process of preparing applications for a Section 408 authorization from the USACE and fish 

passage authorization from ODFW. Mitigation measures that may arise from ongoing negotiations for these 

agencies is beyond the scope of this updated Plan. 

1.2.3 Compliance Monitoring and Adaptive Management 

Oregon LNG is committed to constructing and operating the Project in a manner that would minimize 

environmental effects in compliance with applicable permits and approvals. Oregon LNG would adopt the Upland 

Control, Revegetation, and Maintenance Plan (FERC Plan; FERC, 2013a) without changes and the Wetland and 

Waterbody Construction and Mitigation Procedures (FERC, 2013b) with the approved alternative measures 

represented in the FERC Wetland and Waterbody Construction and Mitigation Procedures, Modified by Oregon 

LNG (FERC Procedures) (CH2M HILL, 2013b). Other environmental plans and requirements described in the FERC 

Plan and Procedures and in applicable permits and approvals, would be required for the specifications and 

drawings issued with the construction bid documents. In addition, the construction contractor would keep copies 

of these environmental permits and approvals onsite for compliance and inspection. 

1.2.3.1. Compliance Monitoring 

Oregon LNG would assign environmental inspectors (EIs) (three or more per construction spread) to the Project to 

monitor environmental compliance. The EIs would have peer status with other inspectors and would report 

directly to Oregon LNG’s Environmental Project Manager. The EIs would be present throughout construction of 

Pipeline and aboveground facilities and follow-up restoration activities, and would have the authority to enforce 

permit and FERC Certificate conditions. The EIs’ roles and responsibilities would be in accord with the FERC Plan 

and Procedures and would be further described in Oregon LNG’s Implementation Plan. The EIs would be 

responsible for monitoring and documenting compliance with the FERC Plan and Procedures, as well as 

implementing mitigation measures required by permits, certificates, and other environmental approvals. The 

inspectors would be authorized to issue stop-work orders and to require corrective actions to maintain 

environmental compliance. In addition, the inspectors would act as a liaison between Oregon LNG and field 

representatives of environmental regulatory agencies who may visit the Project during construction. 

EN0427151027PDX 1-3 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

Oregon LNG would be responsible for the implementation of environmental requirements during construction of 

the Project facilities. If, notwithstanding Oregon LNG’s best intentions and efforts, a contractor does not comply 

with environmental requirements during construction, Oregon LNG’s EIs would, upon discovery, direct the 

contractor to comply. If necessary, Oregon LNG’s EI would issue a stop-work order for that activity until the 

noncompliance is corrected. Where applicable, the Commission or other responsible agencies would be notified 

as required and remedial measures would be implemented. 

For a summary of wildlife habitats by ODFW habitat category with proposed mitigation goals, see Appendix A of 

this report. 

1.2.3.2. Adaptive Management 

Oregon LNG proposes the organization of a formal interagency Adaptive Management Team (Team) to be 

operative during preconstruction of the Terminal and Pipeline and to continue several years post-construction. 

The Team would comprise representatives from the U.S. Army Corps of Engineers (USACE), Oregon Department of 

State Lands (DSL), ODFW, Oregon Department of Forestry (ODF), Oregon Department of Environmental Quality 

(ODEQ), USFWS, NMFS, U.S. Environmental Protection Agency (USEPA), Washington Department of Fish and 

Wildlife (WDFW), and U.S. Coast Guard (USCG). Each agency would provide a primary contact and a backup for 

involvement. The initial charge of the Team would be to review specific mitigation projects and designs for 

adequacy and compliance with agency design standards. The ongoing role of the Team would be to provide 

consultation and recommendations in the event of a significant Project modification, emergency, or unanticipated 

effect on fish and wildlife, and their habitats. Section 9 of the Biological Assessment, Columbia River Channel 

Improvement Project (USACE, 2001) provides a model for the Team and process. 

The Team would be charged with establishing protocols for communications, issuing approvals for significant 

Project modifications and emergencies, and tracking and accounting for mitigation projects to ensure compliance 

with each agency’s requirements. Team members would meet annually during the anticipated 4-year construction 

period to review regulatory compliance. Oregon LNG proposes establishing a Web site for updating construction 

progress and tracking issues that may require interagency coordination during construction and for a period of 2 

years following site rehabilitation and restoration. Specific policies would ultimately be the responsibility of the 

regulatory agency charged with the policy’s administration. For example, ODFW would have ultimate authority 

over state Habitat Mitigation Policy and USFWS and NMFS would have ultimate authority over matters pertaining 

to ESA and their trust resources. 

Post-construction involvement would principally entail timely review of onsite monitoring results and 

recommendations of actions to be taken when performance standards or ecological objectives as described 

herein and in federal and state permits have not been sufficiently achieved. The Team would also be expected to 

provide timely input regarding offsite project plans and permitting, review accomplishment reports, evaluate 

conservation management plans, and assess monitoring results. Comment from the Team would serve to 

determine modifications to mitigation applications and strategies that monitoring has revealed need adjustment. 

The Team would integrate economic and ecologic considerations into innovative collaborative solutions as 

circumstances warrant. The process would provide opportunities for participating parties to learn, develop, and 

demonstrate successful methods for achieving joint objectives. 

Additional detail and specificity regarding adaptive management approaches and monitoring expectations is 

provided within each of the individual resource sections in this report. 

1.2.4 Regulatory Context and Standards 

As documented in Table 1.8-1, Federal and State Agency Review and Permitting, in the Pipeline Supplement 

(Oregon LNG, 2014a), the regulatory framework for developing this mitigation plan is provided by applicable 

federal and state law, regulation, and permit requirements. For brevity, the long list of pertinent laws and 

regulations is not repeated here. In addition to regulatory requirements for mitigation, nonregulatory mitigation 

needs and measures are addressed in this document, as well. 

1-4 EN0427151027PDX 
SECTION 1—INTRODUCTION 

Selection of appropriate mitigation for effects has followed guidance provided by ODFW in “Mitigation Goals and 

Standards” (OAR 635-415-0020 through 0025), which specifies general mitigation goals and standards for six 

categories of habitat value. The ODFW mitigation goals and standards are similar to the USFWS’s “Resource 

Categories and Mitigation Goals,” as described in the USFWS Mitigation Policy (USFWS, 1981). The ODFW 

mitigation goals and implementation standards are summarized in Table 1-1.

The habitat categories in the Project action area were qualitatively categorized based on their importance to fish 

and wildlife, in accordance with the guidelines stated in Oregon Administrative Rules (OARs) 635-415-0000 to 635-

415-0010, the ODFW Habitat Mitigation Policy, during multiple interagency meetings. Washington State does not 

have a qualitative habitat ranking system or associated habitat mitigation policy. ODFW standards do not preclude 

mitigation required for compliance with federal and state laws and policies such as the Endangered Species Act 

(ESA) or the Clean Water Act, for example. In the context of the Project, however, they are intended to serve as 

goals for avoiding or minimizing effects on both special and non-special-status species. Descriptions of habitat 

categories are provided in Appendix A. 

1.2.5 Best Management Practices 

BMP are an integral element of the mitigation plan. Specific measures have been developed to avoid and 

minimize a broad spectrum of various effects on natural resources. These measures are addressed at length in the 

individual resource reports (particularly Resource Report 1) and in Appendix B, the Stormwater Pollution 

Prevention Plan for Construction of the Oregon LNG Terminal and Pipeline, Including Erosion Prevention and 

Sediment Control Plan; Spill Prevention, Control, and Countermeasures Plan; and Frac-Out Contingency Plan

(SWPPP; CH2M HILL, 2013c). They include actions and considerations pertaining to the construction, operation, 

and maintenance of the Terminal and Pipeline, such as the following: 

x General Terminal and Pipeline construction procedures, timing, and scheduling 

x Grading and clearing activities 

x Construction and use of additional temporary workspace (ATWS), and contractor and pipe storage yards 

x Trenching procedures 

x Locations and activities associated with pipe stringing, bending, and welding activities 

x Pipeline corrosion protection 

x Pipeline installation and trench backfilling 

x Hydrostatic testing 

x Protection of forest lands from wildfire 

x Restoration and cleanup 

x Specialized Pipeline construction procedures on potentially unstable or landslide-prone terrain, agricultural 

lands, state forest lands 

x Railroad, road, and utility crossings 

x Waterbody and wetland crossings 

x Cleanup and spill prevention 

x Temporary construction facilities for the Terminal 

x Ground improvements and foundations 

x Site access and traffic 

x Drainage of the finished site 

x Sanitary sewer collection and disposal 

EN0427151027PDX 1-5 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

x Dredging and dock facility construction procedures 

1.2.6 Onsite Strategies 

Planning and design considerations, as well as BMPs, are site-level strategies associated with the footprint of the 

Terminal and Pipeline facilities aimed at avoiding, minimizing, mitigating, or restoring potential effects on natural 

resources. Strategies include prescriptive approaches where a standardized method is applied; or site-specific 

approaches where a more detailed practice unique to the site is warranted. 

Onsite strategies are intended to prevent certain permanent effects, reduce the risk of regulatory noncompliance, 

and mitigate temporary effects. Certain measures are to be implemented during or after construction, while 

others are to be actions carried out during operations. Strategies are prescribed as conditions of licensing and 

permitting, or according to easement and lease agreements. 

Onsite mitigation reduces the adverse effects of a proposed project through the following actions (see Resource 

Report 8): 

x Avoiding the effect altogether by not taking a certain action or parts of an action 

x Minimizing effects by limiting the degree or magnitude of the action and its implementation 

x Rectifying the effect by repairing, rehabilitating, or restoring the affected environment 

x Reducing or eliminating the effect over time by preservation and maintenance operations during the life of 

the action by monitoring and taking appropriate corrective measures 

Oregon LNG initiated site-level planning to avoid and minimize unwanted effects on natural resources. The 

principles Oregon LNG used in siting the Terminal facilities included the following: 

1. Selecting a site where deposition of dredged materials would minimize effects on marine, fish, shellfish, and 

benthic macroinvertebrate species and their habitats 

2. Avoiding to the extent possible habitats for aquatic, riparian, and terrestrial threatened and endangered (T&E) 

species through careful routing and site selection efforts to minimize potential “take” 

3. Selecting route and facility locations adjacent to or parallel with existing access and utility corridors to 

minimize the amount of clearing; the Project maximizes the use of existing roads to access the Terminal site 

and Pipeline right-of-way 

4. Emphasizing avoidance of estuarine wetlands over avoidance of freshwater (palustrine) wetlands 

5. Designing methods and procedures for minimizing effects at waterbody and wetland crossings 

6. Developing site-specific mitigation and restoration where possible to address localized concerns, issues, and 

conditions 

7. Identifying post-operation and monitoring needs to further achieve individual resource goals and objectives 

8. Designing structures, facilities, and construction procedures that minimize the temporary and permanent 

disturbance footprint of the Project. 

The Terminal layout was designed to balance the excavation volume with the fill volume such that imported fill 

material would be minimized. The initial conceptual design for the Terminal was a layout in a square that would 

have extended the area of fill into the low marsh, mudflats, and shallow subtidal areas on the east side of the 

northern end of the East Skipanon Peninsula. Subsequent layouts were designed along a north-south axis to avoid 

these high-value habitats. Estuarine wetlands are considered high-quality wetlands because of their importance 

to salmonids. They have greater surface water connectivity and nutrient contribution. Oregon LNG modified the 

original layout of the Terminal to avoid estuarine wetland effects as follows: 

1-6 EN0427151027PDX 
SECTION 1—INTRODUCTION 

x The process area (high-pressure LNG pumps and the BOG compressor building) was moved into an area 

slightly elevated from the surrounding area that separates existing wetlands in the east and west parts of the 

property. 

x Buildings and utility systems were located in the southwest corner of the property to minimize access roads 

and are in areas that are close to the Skipanon River shoreline away from existing wetlands within the 

property. 

Oregon LNG modified the site layout in 2012 and 2013. Modifications included reduction of vaporization 

capability, elimination of one of the LNG storage tanks, and modification of LNG spill containment and collection 

systems, fire protection gas detection and safety systems, stormwater treatment system, ground improvements 

and foundations, piping, pipe racks, electrical systems, control systems, utilities, telecommunications, structures, 

access road, and other supporting systems. 

The route for the Pipeline and its facilities was selected in an effort to avoid and minimize effects on natural 

resources. Specifically, the route was chosen to meet the following objectives: 

1. Avoid designated conservation areas, National Parks, Monuments, and Wilderness Areas. 

2. Avoid critical habitat units for federally listed plants and animals; particularly the northern spotted owl and 

marbled murrelet. 

3. Avoid occupied home ranges and known nest patches of the northern spotted owl and marbled murrelet. 

4. Minimize disturbance to sensitive areas (e.g., reduce the number of waterbody crossings, reducing landowner 

encumbrances by avoiding populated areas, and minimizing disturbance to scenic waterways and /or byways) 

5. Minimize effects on public administered lands; about 95 percent of the proposed route would cross privately 

owned lands. 

6. Maximize routing across intensively managed lands (approximately 80 miles of industrial forest in the Coast 

Range and approximately 5 miles through the Lower Columbia river Basin in Cowlitz County, Washington) to 

minimize effects on highest-quality wildlife habitat. 

7. Maximize co-location with existing utility corridors. 

8. Minimize effects on wetlands, particularly those of high value. 

9. Minimize location on steep hillsides and avoid unstable slopes. 

In addition, Oregon LNG has restricted the size of the proposed temporary work areas to minimize land 

disturbance during Pipeline construction, but to still provide adequate space for safe construction practices. As 

previously mentioned, Oregon LNG’s construction ROW typically would be 100 feet wide, and the permanent 

Pipeline ROW would be 50 feet wide. The construction ROW width would be reduced to 75 feet in nonagricultural 

wetlands. In addition, Oregon LNG proposes to use HDD construction techniques to cross waterbodies that 

provide habitat for federally listed fish species and certain high value wetlands. Riparian zone effects would be 

avoided as much as possible through selective Pipeline routing and the judicious use of HDD methods. Oregon 

LNG has stated that it would retain important specimen trees, significant wildlife snags, and nest trees in riparian 

areas, where possible. Natural habitat features (e.g., logs greater than 12 inches in diameter, downed LWD, and 

rocks) would also be retained. These measures would minimize effects on riparian areas, waterbodies, and 

wetlands important for federally listed species. 

The proposed new access roads would not cross wetlands or waterbodies. Existing drainage patterns and culverts 

would be maintained during construction. Erosion and sedimentation controls would be installed at the limits of 

the access roads where necessary. 

Oregon LNG identified six pipe storage and contractor yards for potential use during the construction of the 

Pipeline. The sites were selected because of their proximity to the Pipeline route, existing land use, existing 

railroad accessibility, and access to the sites during construction activities. 

EN0427151027PDX 1-7 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

In addition to spatial avoidance measures incorporated into the design of the Project, Oregon LNG would 

implement temporal avoidance measures, such as seasonal restrictions for construction, to avoid effects on 

species that may be present. Information about seasonal restrictions (e.g., in-water work windows) is discussed in 

the effect determinations for each species. 

1.2.7 Compensatory Mitigation 

Compensatory mitigation for the Project has been developed to address issues and concerns related to 

unavoidable temporal effects on habitats, long-term unavoidable effects, potential “take” of listed T&E species, 

and regulatory compliance. Oregon LNG initiated interaction with various regulatory agencies to collaborate on 

the development of compensatory strategies and approaches. While general strategic approaches were 

identified, specificity was a goal so that unavoidable effects could be compared to planned beneficial treatments 

for regulatory review. 

Compensatory requirements are expected to address unavoidable effects on the following resources: 

x Fisheries 

x T&E Wildlife Species 

 Marbled murrelet – direct and indirect impacts to habitat 

 Northern spotted owl—direct and indirect impacts to habitat 

x Wetlands 

x Upland and riparian coniferous forest in the Coast Range 

x Special, rare, and unique habitats 

Possible strategies for providing necessary and required compensatory mitigation measures considered in this 

plan include the following: 

1. In-lieu, fee-in-lieu payments, or direct purchase of mitigation bank credits designated for funding existing, 

specified offsite conservation efforts for mitigating unavoidable long-term effects on rare, unique, and 

wetland habitats 

2. Funding of offsite projects to provide like-kind mitigation for unavoidable long-term and temporal effects on 

upland, riparian, and wetland habitats 

3. Land acquisition and conservation easement development to offset unavoidable long-term effects on T&E, 

estuarine, and wetland habitats, and to compensate for potential “take” of T&E species 

4. Funding of experimental projects to control barred owls that are threatening the recovery of the northern 

spotted owl 

5. Contingency strategies in the event preconstruction surveys result in a “detection” of a T&E species in 

previously unoccupied suitable habitat 

The objectives of compensatory mitigation development are to describe the resource type(s) and amount(s) that 

would be provided, the method of compensation (e.g., restoration, establishment, preservation), and how the 

anticipated functions of the mitigation project would address needs. Where possible, compensatory planning 

should also account for the following: 

x Site selection, including a description of the factors considered during the selection process 

x Baseline information such as a description of the site’s characteristics 

x A description of the legal instruments or arrangements that would be pursued to ensure long-term protection 

of the mitigation project site (for example, easement agreements, credit purchases, ownership, management 

requirements) 

1-8 EN0427151027PDX 
SECTION 1—INTRODUCTION 

x Determination of credits or the ratios utilized to estimate the amount of compensatory units needed and a 

brief explanation of the rationale used 

Specific mitigation project plans have not yet been fully developed, and would necessitate continued coordination 

and collaboration with regulatory agencies. Additional planning should consider detailed specifications and work 

descriptions for a mitigation project, including the following: 

x Geographic boundaries of the project 

x Construction methods 

x Timing and sequence 

x Source(s) of materials or water 

x Methods for establishing the desired plant community 

x Plans to control invasive plant species 

x Proposed grading plan or plan geometry and form 

x Maintenance and long-term management plans and schedule to ensure the continued viability of the 

resource 

x Ecologically-based performance standards that would be used to determine whether the mitigation project is 

achieving its objectives 

x Monitoring requirements, scheduling, reporting, and parameters to determine whether the mitigation project 

is on track to meet performance standards and if adaptive management is needed 

x An adaptive management strategy to address unforeseen changes in site conditions or other components of 

the mitigation project 

x A description of financial support that would be provided and how they are sufficient to ensure a high level of 

confidence that the mitigation project would be successfully completed, in accordance with performance 

standards 

x Additional information as necessary to determine the appropriateness, feasibility, and practicability of the 

mitigation project 

The level of detail described above would be provided in conjunction with specific permit applications or in 

advance of specific project implementation. 

1.2.8 Physiographic Regions and River Basins 

Mitigation measures and prescriptions have been formulated with site characteristics and physiographic factors in 

mind. Local and regional variations of the endemic physical and biological environment have been considered 

according to ecoregion and 4th-field hydrologic unit. The two principle ecoregions are the North Oregon Coast 

Range (including the Coastal plains), and Lower Columbia River Basin in Cowlitz County, Washington. The main 

4th-field river basins consist of the Lower Columbia River (LCR) (including the Youngs and Lewis & Clark 

watersheds) the Nehalem River, and Lower Columbia/Clatskanie. 

1.3 Organization 

This document is organized by primary resource topics and issues. Onsite, compensatory, and operational 

mitigation are addressed under individual primary resource headings (for example, Fish), followed by a 

description of post-construction monitoring. Appendices are substantive in supporting discussion and issues 

addressed in the text. 

EN0427151027PDX 1-9 
SECTION 2 

Preconstruction Surveys and Studies 

Preconstruction surveys and studies in the form of field investigations were conducted to facilitate Project 

planning and design, perform effects analyses, address regulatory compliance, develop conservation strategies, 

and determine site-specific needs. The surveys and studies that were conducted greatly benefited identification of 

the onsite and compensatory mitigation needs addressed in this Plan. Detailed methodology, results, and 

discussion can be found in the resource reports and Applicant-Draft BA. 

Summary-level information from preconstruction surveys and studies is included in the individual resource 

sections of this report. Field observations and assessment of wildlife habitat followed Oregon LNG wildlife and T&E 

species protocols (see Resource Report 3, Appendix 3D). 

Preconstruction surveys and studies conducted to date include the following: 

x Habitat categorization development for comprehensive multispecies characterization to address the ODFW 

Oregon Conservation Strategy and Mitigation Policies 

x Oregon Conservation Strategy Habitats and Associated Strategy Species Review, August 2008 

x Oregon LNG Habitat Assessment and Mapping, 2005, 2007, 2011, 2012 

x Wildlife Inventory, Spring/Summer 2005 

x Northern Spotted Owl and Marbled Murrelet Habitat Assessment, 2008, 2012, 2015 

x Marbled Murrelet Surveys 2008, 2009, 2012, 2014 

x Northern Spotted Owl Surveys, 2008, 2009, 2012 

x Review of 2012 Proposed Critical Habitat (for northern spotted owl), August 2012 

x Rare Plant Surveys, spring and fall 2008, Rare Plant Desktop Study, 2013 

x Invasive Vegetation Surveys, Summer and Fall 2007 

x Skipanon Peninsula Wildlife Survey - Skipanon Peninsula, Spring 2007 

x Amphibian and Reptile Survey—Oregon LNG Terminal, June 2008 

x Stream Characteristics Surveys, 2007/2008, 2011/2012 

x Taxonomic Composition and Density of Benthic Macroinvertebrates Surveys at Oregon LNG’s Proposed 

Dredge Site in the Lower Columbia River Estuary, Spring 2008 

EN0427151027PDX 2-1 
SECTION 3 

Northern Spotted Owl 

Proposed Project mitigation measures for the northern spotted owl address Section 7(a)(1) of the Endangered 

Species Act, which directs federal agencies to use their authorities to further the purposes of the Act by carrying 

out conservation programs for the benefit of endangered and threatened species. Conservation 

recommendations are discretionary agency activities to minimize or avoid adverse effects of a proposed action on 

listed species or critical habitat, to help implement recovery plans, or to develop information. Conservation 

measures proposed by Oregon LNG are consistent with the August 2014 Revised Conservation Framework for the 

Northern Spotted Owl and Marbled Murrelet: Jordan Cove Energy and Pacific Connector Gas Pipeline Project

(Conservation Framework) (USFWS, 2014). The package of conservation measures would potentially include a 

suite of activities: BMPs related to conducting surveys, timing of construction, and avoidance of certain activities 

during the breeding season; habitat acquisition; silvicultural treatments with or without habitat acquisition; and 

contributing to programs to control barred owls. 

Potential effects of actions related to the Project are addressed in of the Applicant-Draft BA. The revised recovery 

plan for the northern spotted owl (USFWS, 2011) identifies the most important range-wide threats to the spotted 

owl: competition with barred owls, ongoing loss of spotted owl habitat as a result of timber harvest, habitat loss 

or degradation from stand replacing wildfire and other disturbances, and loss of amount and distribution of 

spotted owl habitat as a result of past activities and disturbances. 

Demographic studies suggest that northern spotted owl numbers continue to decline, with estimates ranging 

from 2.9 percent to 3.7 percent annually (USFWS, 2011). Population numbers are declining throughout the 

species’ range, including the northern portion of Oregon’s Coast Range. Management options outline in the 2011 

revised recovery plan focus on the habitat conservation network of the Northwest Forest Plan, in addition to the 

following recommendations: 

x Target research and management efforts to address the increasing threat from the barred owl 

x Retain more occupied spotted owl sites and unoccupied, high-value spotted owl habitat on all lands. 

Vegetation management actions that may have short-term effects but are potentially beneficial to occupied 

spotted owl sites in the long-term meet the goals of ecosystem conservation. Such actions may include 

silvicultural treatments that promote ecological restoration and are expected to reduce future losses of 

spotted owl habitat and improve overall forest ecosystem resilience to climate change, which should result in 

more habitat retained on the landscape for longer periods of time. 

Habitat recovery is focused on preserving high-quality nesting, roosting, foraging habitat (characterized by large 

trees, high canopy cover, multistoried canopy, and sufficient downed wood to support prey species) for northern 

spotted owls, as well as dispersal habitat and moderate-quality habitats that can be expected to develop into 

nesting, roosting, foraging over time (USFWS, 2011). The northern portion of the Coast Range has been 

extensively logged, particularly on private industrial forests. Industrial forest lands are typically maintained on a 

60-year or less rotation. The northern portion of the Coast Range currently is not a target area for recovery 

because of forest management practices and competition from barred owls (Thomas et al., 1990). 

Designated critical habitat for the northern spotted owl was recently revised (Federal Register, 2012). The Project 

passes through spotted owl critical habitat unit NCO-04 near milepost (MP) 41.3. Approximately 49 acres of 

designated critical habitat containing PCEs identified by USFWS as essential to conservation of northern spotted 

owls, would be affected by the action (Turnstone Environmental Consultants [TEC] and CH2M HILL, 2015). 

3.1 Onsite Mitigation 

When the Project was first conceived, the Pipeline would have crossed five home ranges (CH2M HILL, 2009). As a 

conservation measure, the current Project with a Pipeline route modified from the originally conceived LNG 

import project, has avoided impacts to the northern spotted owl by reducing the number of home ranges that 

EN0427151027PDX 3-1 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

would be crossed. The Pipeline route avoids existing occupied northern spotted owl sites and their core and home 

ranges. The route does not cross through any known occupied habitats. 

Surveys in areas adjacent to the Pipeline (within a 1.5-mile radius) that contained potentially suitable spotted owl 

habitat were conducted in the 2008, 2009, and 2012 nesting season (April to mid-August). A total of 117 calling 

stations covering approximately 17,864 acres of potentially suitable spotted owl habitat were surveyed. 

During the 2008 and 2009 northern spotted owl survey season, Oregon LNG conducted surveys on properties 

owned by Weyerhaeuser Corporation, Stimson Lumber Company, ODF, and assorted smaller private landowners. 

Surveys were conducted in areas adjacent to the Oregon LNG Pipeline (within a 1.5-mile radius) that contained 

potentially suitable northern spotted owl habitat. The survey protocol is described in Appendix 13 (Northern 

Spotted Owl and Marbled Murrelet Habitat Assessments and Survey Reports) of the Applicant-Draft BA. Oregon 

LNG surveyed a total of 101 calling stations in potentially suitable northern spotted owl habitat near the Pipeline 

corridor. In 2012, Oregon LNG surveyed a total of 16 calling stations in areas of the Pipeline on land owned by 

ODF and Weyerhaeuser Corporation. No spotted owl surveys were conducted by Oregon LNG in 2013 or 2014 due 

to landowner restrictions. 

Oregon LNG did not encounter northern spotted owls during the surveys in 2008 and 2009, but surveyors did 

observe 25 barred owls, 2 northern saw-whet owls, 5 western screech owls, and 2 northern pygmy owls. No 

spotted owls were identified during the 2012 surveys conducted by Oregon LNG, but surveyors reported 

observations of barred owls and northern saw-whet owls. 

Oregon LNG analyzed potential impacts to northern spotted owl habitat in accordance with the Conservation 

Framework. Habitat impacts were summarized in Section 5.3.2 of the Applicant-Draft BA. Fieldwork conducted in 

2008, 2009, and 2012 can be summarized as follows: 

x There were no northern spotted owl detections in 2008. 

x There were no northern spotted owl or marbled murrelet detections in 2009. 

x There were no northern spotted owl detections in 2012. 

x Two years of protocol surveys for northern spotted owls were completed on August 18, 2009. 

Oregon LNG would apply measures that minimize effects primarily onsite at the time of Project construction 

through implementation of Best Management Practices. The following mitigation recommendations are intended 

to avoid, minimize, or restore effects and promote the recovery of spotted owls: 

x Survey for northern spotted owls in suitable habitats in the action area to document presence or absence 

(survey completed). 

x Provide survey results of monitoring efforts to USFWS as they become available in order to maintain and 

update baseline information and to facilitate future consultations7

(see Appendix 13 [Northern Spotted Owl 

and Marbled Murrelet Habitat Assessments and Survey Reports] to the Applicant-Draft BA for updated survey 

information). 

x Avoid the removal of suitable northern spotted owl nesting, roosting, and foraging habitat during the 

breeding season (March 1 to September 30). 

x Avoid Pipeline installation and access road construction activities within 35 yards of owl sites during the 

Critical Breeding Period (March 1 to July 7). 

7 A considerable amount of the Project’s action area (miles 1 to 33 and 50 to 89) was not surveyed to protocol by Oregon LNG due to landowner concerns. 

However, Oregon LNG was able to evaluate the availability of suitable northern spotted owl habitat in unsurveyed areas via remote sensing and found 

insufficient suitable habitat to support northern spotted owl. The ODF surveys all areas in the Project’s action area with sufficient habitat to support owls 

(approximately miles 34 to 49). Oregon LNG used the GIS-based Biomapper® software to assess habitat suitability for both marbled murrelets and 

northern spotted owl, which was recommended by USFWS for identifying suitable habitat for both species (Smith, 2007, personal communication). 

When evaluating habitat suitability for northern spotted owl, “forested” and “not dispersal” attributes were selected to identify areas of capable habitat. 

Analyses were conducted in accordance with the Conservation Framework. 

3-2 EN0427151027PDX 

 
SECTION 3—NORTHERN SPOTTED OWL 

x Avoid more than 3 consecutive days of any construction activities within 0.25 mile (greater than 35 yards) of 

owl sites during the Critical Breeding Period. 

x Restrict habitat removal within suitable, dispersal, or capable habitat areas to avoid the Critical Breeding 

Period. 

x Restrict construction use of heavy equipment, chainsaws, and cable yarding within 0.25 mile of occupied sites. 

x Restrict blasting, slash disposal, and burning within 0.25 mile of an occupied site during the breeding season 

(March to September). 

x Restrict helicopter yarding over an occupied site or its associated buffer zone during the breeding season 

(March to September). 

x Minimize clearing and construction for new access roads to reduce removal of potential dispersal or NRF habitat 

and creation of new forest edges. 

x Compensatory conservation measures would be provided commensurate with impacts. Compensatory 

conservation measures would take the form of a combination of habitat acquisition, silviculture treatments, 

and barred owl management as described under Conservation Measures in Section 5.3.2 of the Applicant-Draft 

BA. 

x Acquired habitat and land on which silviculture treatments are applied would be preserved and managed to 

maintain and restore old-growth habitat, as described in Section 5.3.2 of the Applicant-Draft BA. 

x Specific compensatory conservation projects would require approval from USFWS. 

3.2 Compensatory Mitigation 

This section reviews effects and mitigation for the northern spotted owl. Direct effects on the northern spotted 

owl are avoided . 

3.2.1 Effects 

Two documented owl ACs are located within a 1.5-mile range of the Pipeline. A documented owl site is any site 

where there has been a recent or historical observation of a resident single spotted owl or a pair of owls. ODF is 

currently conducting surveys for both of these ACs. The ACs include: 

x McGregor Road. The McGregor Road AC is a historical nonresident single site and is not known to be 

historically occupied by nesting adult spotted owls. 

x Wolf Creek. This AC is a nesting site historically occupied by nesting adult spotted owls. 

The location and activity records for sites were obtained from the Oregon Natural Heritage Information Center 

(ORNHIC), ODF, and Weyerhaeuser Corporation. 

These two known sites are located on public land managed by ODF. The ACs and the nonresident single areas are 

usually surveyed every year by contractors hired by ODF. If a documented spotted owl AC does not contain a 

male/female spotted owl pair for 3 consecutive years, its status may be changed from an active pair site to a 

historical pair site. None of the sites within 1.5 miles of the Pipeline route had any observations or detections of 

spotted owl during the 2008, 2009, or 2012 survey seasons. 

On the basis of the evaluation in the Applicant-Draft BA of the current status of the northern spotted owl, the 

environmental baseline for the action area, and the effects of the Project, the proposed action is not likely to 

jeopardize the continued existence of the northern spotted owl. Adverse action would occur to 49 acres of critical 

habitat. 

The proposed action would not reduce the abundance or distribution of northern spotted owls within the 

Northern Oregon Coast physiographic province, and is not expected to significantly reduce the likelihood of both 

survival and recovery of the species. Spotted owls are not expected to permanently abandon the action area as a 

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result of the noise disturbance that would be generated by the proposed action and a relatively small amount of 

habitat would be altered. 

3.2.2 Compensatory Mitigation 

Direct effects on the northern spotted owl are unlikely to occur as a result of the proposed action, however 

indirect effects are identified in Section 5.3.2 of the Applicant-Draft BA. The Coast Range habitat mitigation 

described in Section 6 and summarized in Table ES-3 would focus management for late-successional and oldgrowth forest, a limiting factor to the survival of the northern spotted owl. 

3.2.2.1. Approach 

Oregon LNG would take a programmatic approach to compensatory mitigation. A system for applying and 

crediting mitigation measures commensurate with impacts is detailed under Conservation Measures in Sections 

5.3.1 and 5.3.2 of the Applicant-Draft BA. Details presented in the context of the assessment of impacts are 

discussed below. 

3.2.2.2. Habitat Acquisition 

Section 3 of the ESA defines “conservation” and includes habitat acquisition as one of the methods that may be 

used. In accordance with the definition of conservation, the Conservation Framework recommended habitat 

acquisition as a conservation measure to offset adverse effects of proposed removal of suitable habitat and other 

indirect effects. Thus, Oregon LNG proposes to provide habitat acquisition as a conservation measure for the 

northern spotted owl. The Conservation Framework devised a scale for categorizing (Low, Moderate, High, and 

Severe, defined in Table 3-1) the significance of impacts according to proximity to the northern spotted owl 

activity center, core, and quantity of NRF habitat subject for removal or other indirect effects. Habitat removal 

and other indirect effects would constitute an adverse effect subject to conservation measures. Mitigation ratios 

for habitat acquisition were established by USFWS in the Conservation Framework, ranging from 6:1 to 1.5:1, the 

former placing a premium on impacts to High NRF habitat in High Impact home ranges and the lower limit 

establishing a minimum no net loss objective for capable habitat in Low Impact home ranges or outside a home 

range. 

The Conservation Framework allows for adjustments to habitat acquisition obligations based on a number of 

considerations, among them occupancy status and spatial elements (distance from nearest northern spotted owl 

home range and clustering patterns of northern spotted owl home ranges or High NRF/NRF patches). For 

example, as stated in Section 5.4.1.3 of the Conservation Framework, “The Service assumes that a Project-related 

activity that produces a High Impact Category disruption would result in the loss of a breeding season for a pair of 

NSO.” However, “loss of a breeding season for a pair of NSO” would depend on the presence of a breeding pair 

and there are none along the Pipeline. Thus, the Service’s assumption that a High Impact disruption would result 

in the loss of a breeding season for a pair of northern spotted owl is not valid for the Project. NRF habitat is 

limited and scattered across the landscape within the Pipeline action area, there are no occupied home ranges 

within the action area, and the land use is primarily industrial forest with limited likelihood of a trajectory for 

establishment of NRF habitat. Current and potential future ecological services that habitat proposed to be crossed 

by the Pipeline provides for the northern spotted owl justifies adjusting the amount of habitat acquisition based 

on the USFWS recommended ratios. Providing habitat acquisition recognizes the adverse effects on northern 

spotted owl habitat, despite their absence. Adjustments to the habitat acquisition obligation acknowledges the 

Project as an additional impact in a landscape where land management surrounding the Project is beyond the 

control of Oregon LNG and has a far greater effect on the recovery of the northern spotted owl than the Project 

itself. 

According to the Conservation Framework, capable habitat in industrial forest would not be subject to mitigation. 

Area of removal during construction of the Pipeline subject to mitigation would amount to about 41.64 acres of 

NRF habitat, and 168.62 acres dispersal habitat (Table 3-2). No high-quality NRF would be affected. Since most of 

northwestern Oregon consists of industrial forest, there is a significant amount of capable habitat. However, the 

Conservation Framework recognizes that in the setting of industrial forestry, capable habitat is not likely to 

regrow to NRF habitat and is thus not be subject to mitigation. To put the magnitude of removal into perspective, 

3-4 EN0427151027PDX 
SECTION 3—NORTHERN SPOTTED OWL 

there is approximately 644,000 acres of forest land in Clatsop (308,000 acres) and Columbia (336,000 acres) 

counties (OSU Extension Service, 2015a, 2015b). Permanent removal of approximately 210 acres of NRF and 

dispersal habitat would amount to 0.03 percent (three hundredths of one percent) of the total forest land in the 

two counties. The 210 acres is within the range of the year-to-year variability of timber harvest. Stated another 

way, 210 acres would be indistinguishable from the year-to-year fluctuations in timber harvest on the basis of 

board feet or area. 

Table 3-2 summarizes the acres of habitat to be removed and resulting acquisition mitigation according to impact 

category and habitat type within critical habitat, spotted owl home ranges, and areas outside of home ranges and 

designated critical habitat. Capable habitat in the “low and outside” impact category is provided only as baseline 

information and, to be consistent with the Conservation Framework, is not included in mitigation calculations. The 

total amount of capable habitat impacted by habitat removal would be 475.21 acres, of which 3.44 acres not 

located on industrial forest land (capable habitat in the high and moderate impact category; see Table 3-2) would 

require mitigation under the Conservation Framework. 

Table 3-3 summarizes the acres of habitat impacts as a result of other indirect effects and resulting acquisition 

mitigation according to impact category and habitat type within critical habitat, spotted owl home ranges, and 

areas outside of home ranges and designated critical habitat. The total capable habitat impacted by other indirect 

effects would be 3.15 acres, all of which would be mitigated under the Conservation Framework. 

Table 3-4 summarizes adjusted mitigation for removal and other indirect effects, rounded to the nearest acre. 

Conservation easements would be placed on land acquisitions to protect timberlands for suitable habitat for 

northern spotted owl and if within 52 miles of the coast, concurrently for the marbled murrelet. Written plans 

would be prepared that describe long-term prescriptions for management. Management plans may include 

prescriptions for planting, thinning, or other selective timber harvest that would place acquired habitat on a 

trajectory to becoming High NRF habitat. 

Habitat acquisition would focus on the following priorities: 

x Existing special and unique habitats, suitable or occupied threatened and endangered habitat, older forest 

structure, aquatic and riparian habitats, and designated critical habitat 

x In-kind functional habitat that can be managed for late-successional habitat and conserved in perpetuity 

x Existing high-quality habitat 

x Sufficient acquisition commensurate with mitigation ratios 

x Larger contiguous parcels adjacent to existing conservation areas 

x Land capable of enhancing adjacent existing high-quality habitat 

x Land capable of providing opportunities to enhance connectivity between existing high-quality habitats 

Oregon LNG is exploring opportunities for acquiring land in the Coast Range. The Coast Range habitat mitigation 

described in Section 6 and summarized in Table ES-3 would focus management for late-successional and oldgrowth forest, a limiting factor to the survival of the northern spotted owl. Land acquisition would be finalized 

once FERC issues NGA Section 7(c) authorization for the Project. 

The Conservation Framework (Section 5.4.1.1) “assumes acquisition of the same Habitat Categories as those that 

are impacted.” However, the ability of the applicant to provide in-kind habitat acquisitions is dependent on the 

marketplace and availability and condition of land. Owners of timberland may be more willing to sell capable 

habitat rather than dispersal or NRF habitat with merchantable timber. As explained in the introductions to 

Sections 2.6 and 5.3, the Conservation Framework was prepared in the context of the proposed Jordan Cove 

Energy and Pacific Connector Gas Pipeline Projects, which cross 90 home ranges, a dozen or more of which are 

occupied (FERC, 2014) where in-kind habitat acquisitions would preserve the existing network of home ranges. 

The need for acquisitions to be in-kind might be more important where there is an immediate need to preserve an 

existing cluster of home ranges that support a viable regional population. In contrast, in Clatsop and Columbia 

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counties, northern spotted owls, independent of the Pipeline, are on a collapsing trajectory as evidenced by few 

occupied home ranges clustered with spacing of ч 15 kilometers (9.3 miles) (Marcot et al., 2013). Furthermore, 

the amount of NRF habitat acquisition for this Project would not necessarily create, enhance, or connect northern 

spotted owl homes ranges, which is a goal of acquisition conservation. While the in-kind acquisition could be 

applied elsewhere in the Coast Range province where spotted owls exist in greater number than the north coast, 

such acquisition would have little benefit to the recovery of northern spotted owls in the subregion of the 

proposed impacts. In the context of the north Coast Range where the population of northern spotted owls is or 

has already collapsed, there could be a beneficial, long-term trade-off to acquiring out-of-kind habitat. 

Capable, dispersal, NRF, and high NRF are not strictly defined by age of the trees. However, in the mostly 

industrial forest areas of the north Coast Range and the Pipeline route, forests are homogenous stands of evenaged trees. For a forest to achieve characteristics of dispersal habitat (minimally defined as 11 inches dbh, ш 40 

percent canopy closure, and open space below the canopy) could take 20 to 30 years, depending on site 

capabilities and stand management. Stands less than 20 years would be capable habitat. Dispersal habitat would 

generally be two to three times older than the median age of capable stands. To achieve the complexity of NRF 

habitat could take 80 years of growth and active management or two to three times the age of a dispersal stand 

or 3 to 5 times the age of a capable stand. The amount of out-of-kind habitat acquisition would be based on the 

approximate ratio in ages between capable, dispersal, and NRF habitat. The rationale for the ratios is that more 

land would need to be acquired to account for temporal loss of habitat functions if higher-quality (older-aged 

stands) had to be replaced with lower-quality habitat (younger-aged stands). The reverse situation would be 

applied in the event that NRF habitat could be acquired to fulfill dispersal or capable habitat obligations. 

Supposing only capable habitat were available for acquisition, then Oregon LNG would acquire capable habitat at 

a 4:1 ratio for NRF habitat. Acquiring capable habitat for dispersal habitat would be done at a 2.5:1 ratio. Under 

this scenario, dispersal habitat would be fulfilled at a ratio of 1:2.5 (NRF:dispersal) and capable habitat would be 

fulfilled with NRF habitat at a ratio of 1:4 (NRF:capable). These scenarios are summarized in Table 3-5. 

The worst-case scenario for out-of-kind land acquisition (i.e., most habitat acquired scenario) would result in the 

purchase of about 2,517 acres of capable habitat (based on the sum of the maximum out-of-kind NRF and 

dispersal acreage; see Table 3-5) or over 11 times the amount of indirect removal impacts of 213 acres. 

Silviculture Treatments 

“In certain circumstances, it may be appropriate to offset NSO habitat removal and other indirect adverse effects 

in Dispersal and Capable Habitat by use of silvicultural treatments in similar habitat to expedite the creation of 

NRF and High NRF Habitat. However, techniques to do so are still being developed and it is uncertain that 

silvicultural treatments can grow NRF or High NRF Habitats substantially faster than natural processes. The 

earliest age for habitat to be considered NRF is 80 years average stand age. Only about 2 percent of 80-year old 

stands have the characteristics of NRF habitat, though, and more typically a stand must be at least 100 years of 

age before it functions as NRF Habitat.” (Conservation Framework, Section 5.4.1.2) 

The Conservation Framework further suggests that “...silviculture is not appropriate mitigation for High NRF and 

NRF habitat impacts, where immediate, functional habitat offsets are necessary.” For this Project, the Pipeline 

crosses only two unoccupied home ranges. Suitable habitat removal would be less than one percent of that 

needed to support a home range and would not significantly alter the current functional capabilities of the home 

ranges. Therefore, functional habitat offsets would not be necessary as an immediate necessity, making 

silvicultural treatments viable alternatives in planning conservation measures. 

With silvicultural treatments, a significant time lag (decades to centuries) still occurs for younger stands (capable 

or young dispersal habitat) to mature and develop into functional suitable habitat. Silviculture is not appropriate 

mitigation for adversely impacted NRF habitat and would only be used to mitigate adverse impacts to capable or 

dispersal habitat. In circumstances where silviculture is an acceptable mitigation action, the mitigation ratios for 

adverse impacts to recruitment habitat using silvicultural treatment are higher than for capable habitat in 

recognition of uncertainties and temporal challenges. 

3-6 EN0427151027PDX 
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For silvicultural treatments, mitigation ratios as shown in Table 3-6 (reprinted from Table 6 in the Conservation 

Framework) would be applied. These ratios would be applied on lands that are not directly acquired by Oregon 

LNG, but made available to the Project for the purpose of fulfilling its mitigation obligations. Oregon LNG would 

be responsible for the costs of silvicultural treatments, including preparation of management plans and costs 

associated with implementing the plan. Dispersement of proceeds or profits, if any, as a result of silvicultural 

treatment would be negotiated between the landowner and Oregon LNG. 

Barred Owl Management 

USFWS recognizes competition from the barred owl as a threat to the recovery of the northern spotted owl. 

Furthermore, USFWS is proposing to conduct experimental removal of barred owls as a method to aid in the 

recovery of the northern spotted owl. The Conservation Framework provides a rule set for financial support of the 

barred owl management program. However, the rule set applies to direct impacts on northern spotted owl home 

ranges and no northern spotted owl direct impacts are anticipated for the Project. Even though there are no 

direct impacts to northern spotted owl that would trigger compensatory mitigation via barred owl management 

funding, USFWS has stressed the importance and conservation priority of this conservation measures 

(Young/USFWS, 2014, personal communication). Therefore, in negotiations with the agency, USFWS proposed to 

develop a mix of compensatory northern spotted owl mitigation actions, including barred owl management 

funding, accepted in-lieu of habitat acquisition for up to 25 percent of the obligation for acquiring dispersal 

habitat8

. The concept would result in the following formula: fee in-lieu = number of acres of dispersal habitat 

acquisition X 0.25 X market price for acquiring dispersal habitat. The obligation for acquiring dispersal habitat 

would then be reduced accordingly. For every $1,000,000 of estimated land acquisition, Oregon LNG could apply 

$250,000 to a fund that USFWS would use to support experimental projects in barred owl management. The 

Conservation Framework estimates a cost of $2,100 per home range per year for barred owl management. Thus, a 

contribution of $250,000 to the barred owl management program could provide treatment to 120 northern 

spotted owl home ranges for a year. 

Other Considerations for Land Acquisition and Silvicultural Treatments 

Additional requirements for conservation measures, particularly regarding habitat acquisition, would include 

preparation of conservation easements that would protect mitigation lands in perpetuity, preparation of 

management plans prescribing how land would be managed to create and maintain High NRF and NRF habitat, 

and creation of an endowment fund to support land management. Oregon LNG would fully fund these northern 

spotted owl habitat management planning and implementation actions, over life of Project’s effects. 

Enhancing the quality of habitat for northern spotted owls may not solely depend on habitat acquisition. Under 

very specific conditions, it may be appropriate to offset northern spotted owl habitat removal and other indirect 

adverse effects in recruitment and capable habitat by applying silvicultural treatments to capable or recruitment 

habitat. The ultimate goal of applying these silvicultural treatments is to expedite the development of and 

increase the amount, quality, and distribution of northern spotted owl dispersal and NRF habitat. While 

silvicultural treatments would likely be required on acquired land, they may also be applied to land owned by 

others (than Oregon LNG), such as a public entity or conservation organization who may not have the financial 

resources to support habitat enhancement. Management plans, to be funded by Oregon LNG, would be prepared 

regardless of land ownership for acquired lands or for lands where silvicultural treatments would be applied. 

Management plans would address the following: 

x If needed, prescriptions for planting (species and density of planting) 

x Thinning that may be applied to enhance forest complexity 

8 As discussed in a meeting between USFWS and CH2M HILL on October 30, 2014. 

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x Disposal of thinned trees (e.g., leaving them in the forest as downed logs; selling merchantable timber to pay 

for the cost of the management; or applying the sale of merchantable timber to an endowment fund for land 

management) 

x Disposition of existing roads (e.g., ripping and replanting or maintaining them to allow access for forest 

management) 

x Discussion of what existing or new roads may be needed for ongoing forest management or access for fire 

control 

x Contingency process to address unforeseen disaster such as a wildfire 

x Discussion of what recreational or hunting activities may be allowed on conserved land 

x Description of conditions that may warrant some limited timber harvest in the future, proceeds of which 

could be used towards ongoing stewardship 

Impacts to northern spotted owl habitat were based on landscape conditions interpreted from 2014 aerial 

photography. Habitat impacts and therefore habitat acquisition obligations are likely to change prior to 

commencement of construction as a result of ongoing timber harvest that is beyond the control of Oregon LNG. 

Final impacts to suitable habitat and resulting requirements for conservation measures would be reevaluated 

using aerial photography that is no more than 2 years older than the onset of construction (the earlier of the 

Terminal or Pipeline). Final impacts and conservation measures would ultimately be subject to review by the 

interagency Adaptive Management Team. The Services would retain their regulatory authorities under the ESA. 

3.2.3 Contingency 

Oregon LNG is not proposing compensatory mitigation for the northern spotted owl given the absence of known 

occupied sites in the action area. However, compensatory mitigation proposed for general habitat effects in the 

Coast Range (Section 6.0, see also Table ES-3) would be managed in consideration of the northern spotted owl, 

with a focus on late-successional and old-growth habitat. If future preconstruction surveys result in a detection 

within 1.5 miles of the Pipeline, a contingency plan would be implemented to prevent adverse effects. The USFWS 

would be immediately notified and consulted on elements necessary for contingency to prevent “take” or 

“harassment” and would consider the following general options:

x Construction deferment 

x Habitat replacement via land acquisition 

x Exploration of micro route change possibilities (as practicable) 

3.3 Operational Mitigation, Post-Construction Monitoring, and 

Adaptive Management 

Oregon LNG does not propose additional post-construction mitigation measures for northern spotted owls as 

operational activities are not expected to result in adverse effects on northern spotted owls. If unforeseen repairs 

necessitate activities within 1.5 miles of occupied habitat, USFWS would be notified and plans developed to 

implement necessary conservation measures. 

Oregon LNG would monitor the results of northern spotted owl surveys on ODF lands, annually, through the time 

of construction. If a northern spotted owl is detected in or near the construction corridor before or during 

construction, then potential adaptive management may include determinations of potential effect significance; 

temporary suspension of construction activities in the immediate area until the end of the nesting season; or a 

minor reroute of the Pipeline. Additional terrestrial compensatory mitigation may need to be provided, depending 

on the severity of realized effects. 

3-8 EN0427151027PDX 
SECTION 4 

Marbled Murrelet 

Proposed mitigation measures for the marbled murrelet address Section 7(a)(1) of the Endangered Species Act, 

which directs federal agencies to use their authorities to further the purposes of the Act by carrying out 

conservation programs for the benefit of T&E species. Conservation recommendations are discretionary agency 

activities designed to minimize or avoid adverse effects of a proposed action on listed species or critical habitat, 

enhance the effectiveness of recovery plans, or provide information on the species. 

The conservation strategy for the marbled murrelet is described in the USFWS Recovery Plan for the Threatened 

Marbled Murrelet (Brachyramphus marmoratus) in Washington, Oregon, and California (Recovery Plan) (USFWS, 

1997). The Recovery Plan recommends that efforts concentrate on maintaining occupied sites, minimizing the loss 

of unoccupied but suitable habitat, and decreasing the time for development of new habitat. The Recovery Plan 

further recommends that efforts be directed at the conservation of suitable and occupied murrelet nesting 

habitat in the Elliott State Forest, Tillamook State Forest, and Siuslaw National Forest to help restore the northsouth distribution of murrelet populations and suitable habitat in Zone 3 (USFWS, 1997). 

Potential effects of actions related to the Project are addressed in Appendix 15 of the Applicant-Draft BA. The 

Recovery Plan lists six Conservation Zones for the marbled murrelet. The Project is located in Zone 3, which spans 

the Oregon Coast from the Columbia River in the north to North Bend, Coos County in the south. The land has 

been actively managed for timber production over the past century. Much of the habitat on nonfederal land is of 

lesser quality because it occurs in smaller, more fragmented blocks. In addition to timber production, forests in 

the Oregon Coast Range have been fragmented by several recurrent catastrophic windstorms and high-severity 

burns, both natural and human caused. The action area for the Pipeline contains little high-quality murrelet 

nesting habitat relative to federal lands in Zone 3. 

The action area of the Pipeline intersects one murrelet critical habitat unit (CHU OR-01-d) in eight distinct areas, 

roughly from MP 34 to MP 42 (TEC and CH2M HILL, 2015; see Appendix 13 [Northern Spotted Owl and Marbled 

Murrelet Habitat Assessments and Survey Reports] to the Applicant-Draft BA). Most of the land in the action area 

and within the CHU is owned by ODF, and a small portion is under private ownership. Most of the forested areas 

within the action area and the CHU have been harvested for timber within the last 60 years, according to 

estimated stand age data provided by ODF. The Project area contains PCEs of marbled murrelet critical habitat 

within the CHU. In 2008, Oregon LNG conducted a habitat assessment to identify potentially suitable habitat for 

the marbled murrelet within 1.5 miles of the Pipeline (see Habitat Assessment—Potential Northern Spotted Owl 

and Marbled Murrelet Habitat on Lands Adjacent to the Oregon LNG Pipeline and Applicant-Draft BA Appendix 13) 

within Clatsop, Columbia, Tillamook, and Washington counties in Oregon. The methods used were the same as 

those described above for northern spotted owl. In 2012, Oregon LNG assessed the availability of suitable 

marbled murrelets habitat within 1.5 miles of the Pipeline in Columbia County, Oregon (see Northern Spotted Owl 

and Marbled Murrelet Habitat Assessment for Oregon LNG Reroute in Applicant-Draft BA Appendix 13). 

Protocol marbled murrelet surveys were conducted from 2008 to 2009 and from 2012 to 2013. Oregon LNG 

completed 69 marbled murrelet surveys during the first 2-year protocol period (2008-2009) survey period (see the 

2009 Final Report for Oregon LNG Northern Spotted Owl and Marbled Murrelet Surveys in Applicant-Draft BA 

Appendix 13) and 50 marbled murrelet surveys during the 2012-2013 protocol surveys (see Oregon LNG Project 

Survey Report 2013 Marbled Murrelet and Northern Spotted Owl in Applicant-Draft BA Appendix 13). The surveys 

were conducted on 17 sites9 at a total of 22 survey stations. During fieldwork conducted in 2008 and 2009, 

Oregon LNG observed a single marbled murrelet high above the forest canopy indicating non-nesting behavior 

within the survey area, but revealing that marbled murrelets use the area to migrate to nesting and foraging 

9 As a result of changes in the Project design, the first 2-year protocol survey period was initiated in 2007 and the second was initiated in 2012. Restricted 

access on private land limited the ability of Oregon LNG to survey some areas with suitable habitat for marbled murrelet. 

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habitat. Otherwise, none of the possible habitat delineated from habitat modeling was occupied in the survey 

area in 2008 and 2009. No murrelets were observed during the 2012 to 2014 surveys.

4.1 Onsite Mitigation 

Oregon LNG identified eight suitable habitat units (SHUs) for marbled murrelets within 0.25 mile of the Oregon 

LNG Project (Table 4-1). Six of the eight SHUs were surveyed to protocol for at least two consecutive years 

between 2009 and 2014 with probable absence (TEC, 2009, 2013, 2014; updated BA Appendix 13). The remaining 

two SHUs were not surveyed due to access restrictions and are assumed occupied. 

Fieldwork conducted in 2008, 2009, 2012, and 2014 can be summarized as follows: 

x Two years of protocol surveys for marbled murrelets were completed in 2009. One visual observation of a 

marbled murrelet well above canopy height in 2008 indicated non-nesting behavior near the Pipeline corridor. 

x Two years of protocol surveys for marbled murrelets were completed in 2014. No marbled murrelets were 

detected during the 2012 to 2014 surveys. Two areas of suitable habitat could not be surveyed due to access 

restrictions and are assumed to be occupied. When access to property is obtained, surveys would be 

conducted for marbled murrelets in suitable habitats within the action area where current survey data are 

deficient. This would aid in documenting marbled murrelet inland ranges and habitat use. 

The Pipeline route avoids areas of suitable marbled murrelet habitat and designated critical habitat to the 

greatest extent practicable. Oregon LNG recommendations are to avoid, minimize, or restore unavoidable 

adverse effects and as well as promote the recovery of marbled murrelets with the following measures: 

x Reduce the width of the construction corridor to 75 feet where PCE1 trees are located in the CHU. 

x Survey for murrelets in suitable habitats within the action area where current survey data are deficient. This 

would aid in documenting murrelet inland ranges and habitat use. 

x Avoid construction activities within 0.25 milesof occupied and assumed occupied sites during the critical 

breeding period (April 1 to August 5), except for the transportation of heavy equipment on high-use roads. 

Construction activities which occur during the late breeding period and within the disturbance distance (0.25 

miles) but greater than 100 yards from occupied sites would adhere to daily dawn-to-dusk timing restrictions, 

where construction activities would begin precisely 2 hours after sunrise and end 2 hours before sunset. 

x Avoid removal of occupied and assumed occupied suitable nesting habitat during the entire nesting period 

(April 1 through September 15). 

x Avoid construction activities within 100 yards of occupied and assumed occupied sites during the entire 

breeding period (April 1 to September 15), except for the transportation of heavy equipment on high-use roads. 

x Avoid construction activities within 0.25 miles of occupied and assumed occupied sites during the critical 

breeding period (April 1 to August 5), except for the transportation of heavy equipment on high-use roads. 

Construction activities which occur during the late breeding period and within the disturbance distance (0.25 

miles) but greater than 100 yards from occupied sites would adhere to daily dawn-to-dusk timing restrictions, 

where construction activities would begin precisely 2 hours after sunrise and end 2 hours before sunset. 

x Minimize clearing and construction for new access roads to reduce removal of potential recruitment or suitable 

habitat and creation of new forest edges. 

x Transport heavy equipment on high-use roads during the critical and late breeding periods with adherence to 

daily timing restrictions (dusk to dawn-2 hours after sunrise and ending 2 hours before sunset). 

x Minimize clearing Douglas-fir, Sitka spruce, western hemlock, or western red-cedar trees that have potential 

nesting platforms within the designated CHU, to the greatest extent possible. Maintaining these structures 

would accelerate the recruitment of suitable habitat within the unit. Oregon LNG would reduce the width of 

the construction corridor to 75 feet where PCE1 trees are located in the CHU. 

4-2 EN0427151027PDX 
SECTION 4—MARBLED MURRELET 

x Restrict the use of heavy equipment, helicopters,10 and chainsaws within 0.25 mile of any known or assumed 

occupied nest site during the daily peak activity periods (from 2 hours before official sunrise to 2 hours before 

official sunset). 

x Implement a lighting plan at the Terminal that incorporates the following elements: (a) directional lighting 

facing onshore to the extent possible, (b) screens or lighting hoods, (c) motion-activated lighting, (d) full-cutoff 

light fixtures, which have no direct uplight, help eliminate glare, and are more efficient by directing all lighting 

down to the intended area only, and (e) strobing lights to the greatest extent practicable. 

x Send results of survey efforts to USFWS on an annual basis, in order to maintain and update baseline 

information. Oregon LNG would provide USFWS with the results of 2 years of protocol surveys as they become 

available. 

x To the greatest practicable extent, maximize use of vibratory hammers and minimize impact hammers for pile 

driving to minimize underwater noise. 

x Use pile caps and bubble curtains to minimize underwater noise from pile driving. 

x Although blasting is not a proposed action, if it were to occur within a mile of suitable habitat, BMPs would 

include avoidance of such action during the critical breeding season (April 1 to August 5); minimizing the 

quantity of charges to the least amount required; and use of blasting mats, sand, or crushed rock to reduce 

sound generation. 

The Recovery Plan (USFWS, 1997) recommended that restoration efforts concentrate on maintaining occupied 

sites, minimizing the loss of unoccupied but suitable habitat, and decreasing the time for development of new 

habitat. Oregon LNG has demonstrated its commitment to these recovery goals by avoiding occupied sites and 

minimizing the loss of unoccupied but suitable habitat. During 2012, Oregon LNG had a multidisciplinary team 

consisting of marbled murrelet biologists and geotechnical engineers redesign the route through Columbia County 

to avoid mature forest stands, including stands with suitable murrelet nesting structure. The Recovery Plan 

further recommended that efforts be directed at the conservation of suitable and occupied marbled murrelet 

nesting habitat in the Elliott State Forest, Tillamook State Forest, and Siuslaw National Forest to help restore the 

north-south distribution of marbled murrelet populations and suitable habitat in Zone 3 (TEC, 2008; USFWS,

1997). Oregon LNG is proposing to provide habitat mitigation in accordance with the Conservation Framework. 

4.2 Effects and Compensatory Mitigation 

There is a low likelihood that direct take of nesting marbled murrelets would occur, because although the species 

was not documented within 0.25 mile of the Project during 4 years of protocol surveys, two areas of suitable 

habitat could not be surveyed due to access restrictions and are assumed to be occupied by the species. 

Compensatory mitigation for effects on CHU habitat would be stacked in association with compensatory 

mitigation for Northern spotted owl and ODFW habitat mitigationhabitat, to the extent that such mitigation 

occurrs within 52 miles of the coast. 

To offset unavoidable adverse effects, and to mitigate for temporal effects from Pipeline clearing in designated 

critical habitat and suitable marbled murrelets nesting habitat, Oregon LNG proposes to acquire land for securing 

conservation easements. This approach is also intended to offset unavoidable and temporal effects related to 

upland and riparian resources in the Coast Range and benefit compensatory objectives. Habitat acquisition would 

be in locations that can be managed and preserved for old-growth habitat. 

The Project actions are not expected to significantly reduce the likelihood of survival and recovery of the species. 

General construction disturbance of marbled murrelets may affect their behavior, but there is a low likelihood of 

‘take’ of any individuals. Construction activities would occur outside the critical nesting period of any known or 

assumed occupied marbled murrelet habitat. Oregon LNG identified eight areas of suitable marbled murrelet 

10 Type 1 helicopter use can affect murrelets for up to 0.5 mile. Type I helicopters seat at least 16 people and have a minimum capacity of 5,000 pounds. 

Both a CH-47 (Chinook) and UH-60 (Blackhawk) are Type I helicopters. All other helicopters have 0.25-mile disturbance. 

EN0427151027PDX 4-3 

 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

habitat within the action area, which are distributed sporadically along approximately half of the Pipeline (Oregon 

LNG Project Survey Report 2013—Marbled Murrelet and Northern Spotted Owl [TEC, 2013; Applicant-Draft BA 

Appendix 13]). Seven of the eight marbled murrelet SHUs within the Pipeline easement are located between MP 

30 and MP 46. 

The proposed action would remove approximately 40 acres of designated critical habitat within the Pipeline 

construction right-of-way, including temporary and ATWS. 

The area of the proposed construction right-of-way located within the CHU contains only one of the PCEs of 

marbled murrelet critical habitat. No trees with potential nesting platforms, the requirement for PCE1, would be 

removed or modified. 

To offset unavoidable adverse effects, and to mitigate for temporal effects from Pipeline clearing in designated 

critical habitat and suitable marbled murrelets nesting habitat, Oregon LNG proposes to provide habitat 

acquisition as a conservation measure for marbled murrelet. The Conservation Framework devised a scale for 

categorizing the significance (Low, Moderate, High, and Severe, defined in Table 4-2) of impacts according to the 

type of habitat that would be affected and its proximity to suitable habitat. Removal and other indirect effects 

would constitute an adverse effect subject to habitat acquisition as a conservation measure. Mitigation ratios for 

habitat acquisition were established by USFWS in the Conservation Framework, ranging from 8:1 to 1.5:1, the 

former placing a premium on impacts to High suitable habitat and the lower limit establishing a minimum no net 

loss objective for capable habitat in Low Impact units or outside SHUs. As a result of the specific importance of 

suitable nesting trees, loss of individual trees suitable for nesting by the species is mitigated at a higher ratio. 

The Conservation Framework allows for adjustments to be made to habitat acquisition obligations based on a 

number of considerations, among them stand occupancy or status, acreage of suitable habitat to be removed, 

critical habitat designation, biological viability of any habitat fragments created, proximity to the marine 

environment, and unique Project attributes per agreement with the Service. As a result of operations on industrial 

forests, current and potential future ecological services that habitat proposed to be crossed by the Pipeline 

provides for the marbled murrelet justifies adjusting the amount of habitat acquisition based on the USFWS 

recommended ratios. Providing habitat acquisition recognizes the potential adverse effects on marbled murrelet, 

despite their absence. Adjustments to the habitat acquisition obligation acknowledge the Project as an additive 

impact in a landscape where land management surrounding the Project is beyond the control of Oregon LNG and 

has a far greater effect on the recovery of the marbled murrelet than the Project itself. 

Table 4-3 summarizes the acres of habitat to be removed and resulting acquisition mitigation according to impact 

category and habitat type within critical habitat and areas outside of critical habitat. 

Table 4-4 summarizes the acres of other indirect impacts and resulting acquisition mitigation according to impact 

category and habitat type within critical habitat and areas outside of critical habitat. 

Table 4-5 summarizes adjusted area of habitat acquisition for removal and other indirect effects. 

The Conservation Framework calls for in-kind (according to stand age) habitat acquisitions. However, the ability of 

the applicant to provide in-kind habitat acquisitions is dependent on the marketplace, availability of willing sellers, 

and condition of land. Owners of timberland may be more willing to sell clear-cut or recently clear-cut or recentlycut land (i.e., capable habitat) than land with merchantable timber in age classes greater than 60 years 

(recruitment or suitable habitat age classes). Supposing only capable habitat were available for acquisition, then 

Oregon LNG would acquire capable habitat at a 5:1 ratio for suitable habitat. Acquiring capable habitat for 

recruitment habitat would be done at a 3.5:1 ratio. These ratios would be applied to the acres in Table 4-5. The 

rationale for the ratios is that more land would need to be acquired to account for temporal loss of habitat 

functions if higher quality (older aged stands) had to be replaced with lower quality habitat (younger aged stands). 

The reverse situation would be applied in the event that suitable habitat could be acquired to fulfill recruitment or 

suitable capable habitat obligations. Under this scenario, recruitment habitat would be fulfilled at a ratio of 1:1.5 

(suitable: recruitment) and capable habitat would be fulfilled with suitable habitat at a ratio of 1:5 

(suitable:capable). These scenarios are summarized in Table 4-6. 

4-4 EN0427151027PDX 
SECTION 4—MARBLED MURRELET 

Forest land acquired for conservation would continue to naturally mature and either gain or maintain the 

characteristics of suitable murrelet habitat over a 100-year period, or the lifetime of the Project. This assumes 

that potential nesting structure would develop within an acquired conservation area roughly 90 years after the 

last stand-replacing event or that western hemlock mistletoe brooms are present to provide nesting structure as 

soon as 60 years. In theory, a young, capable (10-year-old) forest stand would become recruitment habitat about 

50 years after acquisition and develop suitable murrelet nesting platforms about 70 to 80 years after acquisition. 

Likewise, a mature stand (60-year-old) would likely serve as suitable habitat as soon as 20 years after acquisition. 

Out-of-kind habitat acquisition ratios are based on the relationships between estimated years from current stand 

status to future ecological function as suitable murrelet habitat over the next 100 years: 

x Capable = 20 years of suitable habitat function 

x Recruitment = 70 years of suitable habitat function 

x Suitable = 100 years of suitable habitat function 

Conservation easements would be placed on land acquisitions to protect timberlands for suitable habitat for land 

acquired within 52 miles of the coast. Since both the marbled murrelet and northern spotted owl are dependent 

on older forests, habitat acquisition suitable for marbled murrelet would also provide functional mitigation for the 

northern spotted owl. Habitat acquisitions could be used to satisfy conservation meausres for the two species, 

simultaneously. Written plans would be prepared that describe long-term prescriptions for management. 

Management plans would include prescriptions for planting, thinning, or other selective timber harvest that 

would place acquired habitat on a trajectory to becoming suitable habitat: 

x If needed, prescriptions for planting (species and density of planting) 

x Thinning that may be applied to enhance forest complexity 

x Disposal of thinned trees (e.g., leaving them in the forest as downed logs; selling merchantable timber to pay 

for the cost of the management; or applying the sale of merchantable timber to an endowment fund for land 

management) 

x Disposition of existing roads (e.g., ripping and replanting or maintaining them to allow access for forest 

management) 

x Discussion of what existing or new roads may be needed for ongoing forest management or access for fire 

control 

x Contingency process to address unforeseen disaster such as a wildfire 

x Discussion of what recreational or hunting activities may be allowed on conserved land 

x Description of conditions that may warrant some limited timber harvest in the future, proceeds of which 

could be used towards ongoing stewardship 

Habitat acquisition would focus on the following priorities: 

x Existing special and unique habitats, suitable or occupied threatened and endangered habitat, older forest 

structure, aquatic and riparian habitats, and designated critical habitat 

x High-quality functional habitat that can be managed for late-successional habitat and conserved in perpetuity 

x Existing high-quality habitat 

x Sufficient acquisition commensurate with mitigation ratios 

x Larger contiguous parcels adjacent to existing conservation areas, SHUs, and designated critical habitat 

x Land capable of enhancing adjacent existing high-quality habitat 

x Land capable of providing opportunities to enhance connectivity between existing high-quality habitats 

EN0427151027PDX 4-5 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

x Land capable of simultaneously providing functional habitat for the northern spotted owl 

Oregon LNG is exploring opportunities for acquiring land in the Coast Range. Land acquisition would be finalized 

once FERC issues NGA Section 7(c) authorization for the Project. 

Additional requirements for conservation measures, particularly regarding habitat acquisition, would include 

preparation of conservation easements that would protect mitigation lands in perpetuity, preparation of 

management plans prescribing how land would be managed to create and maintain suitable nesting habitat, and 

creation of an endowment fund to support land management. Oregon LNG would fully fund these marbled 

murrelet habitat management planning and implementation actions. Investment in the endowment fund (amount 

to be determined in coordination with the Adaptive Management Team) would occur over the first 10 years of the 

Project. Upon full investment, the endowment fund would support land management over the life of the Project’s 

effects. 

Enhancing the quality of habitat for marbled murrelets may not solely depend on habitat acquisition. Under 

specific conditions, it may be appropriate to offset marbled murrelet habitat removal and other indirect adverse 

effects in recruitment and capable habitat by applying silvicultural treatments to capable or recruitment habitat. 

The ultimate goal of applying these silvicultural treatments is to expedite the development of and increase the 

amount, quality, and distribution of marbled murrelet suitable habitat. While silvicultural treatments would likely 

be required on acquired land, they may also be applied to land owned by others (than Oregon LNG), such as a 

public entity or conservation organization who may not have the financial resources to support habitat 

enhancement. 

With silvicultural treatments, there still is a significant time lag (decades to centuries) for younger stands (capable 

or recruitment habitat) to mature and develop into functional suitable habitat. Therefore, silviculture is not 

appropriate mitigation for adversely impacted suitable habitat and would only be used to mitigate adverse 

impacts to capable or recruitment habitat. In circumstances where silviculture is an acceptable mitigation action, 

the mitigation ratios for adverse impacts to recruitment habitat using silvicultural treatment are higher than for 

capable habitat in recognition of uncertainties and temporal challenges. 

For silvicultural treatments, mitigation ratios and the amount of land on which treatments are applied would 

follow the ratios in Table 4-7 for recruitment habitat types. 

Impacts to marbled murrelet habitat were based on landscape conditions interpreted from 2014 aerial 

photography and ground-truthed during protocol surveys. Habitat impacts and therefore habitat acquisition 

obligations are likely to change prior to commencement of construction as a result of ongoing timber harvest that 

is beyond the control of Oregon LNG. Final impacts to suitable, recruitment, and capable habitat and resulting 

requirements for conservation measures are subject to change and would be reevaluated using aerial 

photography that is no more than 2 years older than the onset of construction (the earlier of the Terminal or 

Pipeline). Final impacts and conservation measures would be subject to review and approval by the interagency 

Adaptive Management Team. The Services would retain their regulatory authorities under the ESA. 

4-6 EN0427151027PDX 
SECTION 5 

Fish 

Fish species and their habitat that would potentially be affected by the Project are addressed in Section 3.1 of 

Resource Report 3 and Sections 3.1 to 3.9 of the Applicant-Draft BA. Effects and measures to mitigate them are 

addressed in Section 3.5.1 and Appendix 3B (Aquatic Survey Reports) of Resource Report 3, and Applicant-Draft 

BA Appendix 15 (Summary of Potential Effects and Mitigation Measures for Protected [ESA, MBTA, MMPA] and 

Sensitive Habitats Associated with the Oregon LNG Bidirectional Project). They are analyzed in greater detail and 

discussed further in Sections 3.4 (Terminal Effects and Conservation Measures) and 3.5 (Pipeline Effects and 

Conservation Measures) of the Applicant-Draft BA. 

Section 5.1 addresses Project effects on fish and describes the onsite mitigation measures (avoidance, 

minimization, and conservation) that would be used to either eliminate or reduce those effects. Section 5.2 

outlines a compensatory mitigation plan that has been designed to more than compensate for both direct and 

indirect effects on fish and their habitat that are unavoidable or cannot be reduced to insignificant levels through 

the avoidance, minimization, and conservation measures described in Section 5.1. The mitigation plan focuses on 

effects on listed species of fish and their habitat, but would also mitigate for effects on nonlisted species and their 

habitat. 

5.1 Onsite Mitigation, Avoidance, and Minimization Measures 

As stated in the section above, Applicant-Draft BA Appendix 15 consists of a table that summarizes measures 

taken to avoid and minimize effects on fish. The table reviews measures associated with the Pipeline and 

Terminal. The sections that follow provides additional details and descriptions. Avoidance and minimization 

measures summarized in Appendix 15 are applicable to actions in Section 8, Stream Channels and Waterbodies, 

later in this report. 

5.1.1 Pipeline 

The onsite avoidance, minimization, and conservation measures for potential Pipeline effects on individual ESAlisted fish, critical habitat, existing conditions, and fish not related to critical habit are based on effects 

summarized in Tables 3.8-4 through 3.8-20 of the Applicant-Draft BA. 

Negative effects on ESA-listed salmonids expected to result as a consequence of Pipeline construction would be 

primarily short term during active construction. The most significant of these negative effects include effects on 

individual salmonids resulting from fish salvage and increased turbidity downstream of flume and open-cut 

stream crossings. To avoid negative effects on ESA-listed salmonids, horizontal directional drilling (HDD) methods 

would be implemented so that construction and installation of the Pipeline would be below the bottom of the 

streambed, preventing disturbance to channel geometry, habitat features, aquatic and riparian species, and water 

quality at 13 locations(Table 5-1). 

There are a limited number of flume crossings where salvage and turbidity increases would affect listed 

Evolutionarily Significant Units (ESUs), and any one ESU is not affected by more than eight such crossings. 

Implementation of the conservation measures described below would minimize the negative effects on individual 

fish and should limit “take” primarily to harassment and short-term behavioral effects. As discussed in Section 5.2, 

a very small number of fish potentially could suffer mortality during the salvage operations. Changes to instream 

habitat are expected to be mitigated by the proposed conservation measures described below. 

Longer-term effects would include a small loss of shade at each crossing for several years post-construction and a 

minor loss of large woody debris (LWD) recruitment potential. The shade lost is not expected to raise stream 

temperatures (CH2MHILL, 2009). Loss of LWD recruitment would be mitigated by placing LWD as appropriate, by 

rehabilitating riparian areas and as would be discussed in Section 5.2 through offsite long-term protection of 

mature, high-quality riparian habitat. Taken as a whole, the Project would have limited negative effects that 

largely would be offset by the proposed conservation measures. 

EN0427151027PDX 5-1 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

5.1.1.1. Fish Salvage 

Fish within the construction zone at each flumed Pipeline crossing would be removed before construction 

following a detailed fish salvage plan. This plan has been developed and was originally presented in Resource 

Report 3, Appendix 3B, as the Oregon LNG Pipeline Waterbody Crossing: Fish Salvage Plan technical 

memorandum, filed with FERC by Oregon LNG in October 2008, and revised and resubmitted as Appendix 3O on 

June 7, 2013 (see Appendix 2C to the Applicant-Draft BA for the 2013 plan). Before fish salvage activities are 

conducted, an ODFW/NMFS Scientific Taking Permit would be obtained for species that may be encountered at 

any of the crossing areas, including species listed under the federal ESA. 

Fish species likely to be encountered during fish salvage activities include salmonids (salmon and trout), cyprinids 

(minnows), cottids (sculpins), gasterosteids (sticklebacks), petromyzontids (lampreys), catostomids (suckers), 

ictalurids (catfish), and centrarchids (sunfish and bass). A detailed list of fish species likely to be encountered at 

Pipeline stream crossings is available in Section 3.1 of Resource Report 3. 

Crossing methods that involve in-water or in-channel work would be constructed during the designated ODFW Inwater Work Window (ODFW, 2008) unless specifically authorized in writing by ODFW. In-water work window 

guidelines minimize potential adverse effects on fish and wildlife and their habitats. They also usually avoid 

sensitive life stages, including spawning, rearing, and migration. 

A qualified fisheries biologist would be onsite to oversee and conduct fish salvage operations. Appropriate fish 

handling permits would be obtained from ODFW and NMFS before fish salvage begins, and collected fish would 

be relocated immediately to an appropriate area within the same stream. Because lampreys may be present at 

waterbody crossings, special salvage procedures have been incorporated into this fish salvage plan to account for 

the capture of lamprey ammocoetes or other larval stages (see 2(i) below). 

Fish would be salvaged using backpack electrofishing equipment, traps, seines, or other approved methods. If 

electrofishing equipment is to be used and potential ESA species may be present, NMFS electrofishing guidelines 

would be followed (NMFS, 2000). Electrofishing is the most appropriate method for capturing lamprey 

ammocoetes (larvae) during salvage activities. Traps can be used, but they typically capture lampreys as they 

migrate upstream or downstream. 

Additionally, any fish that are captured would be handled according to requirements in the Scientific Taking 

Permit and which involve the following standards: 

x Before and intermittently during isolation of the in-water work area, capture fish trapped in the area by using 

a trap, seine, electrofishing, or other methods as are prudent to minimize risk of injury, then release them at a 

safe release site. 

x Do not use electrofishing if water temperatures exceed 18 degrees Celsius (°C) or are expected to rise above 

18°C, unless no other method of capture is available. 

x Take fish by backpack electrofishing, seining, or other approved method. If electrofishing equipment is used to 

capture fish, comply with NMFS electrofishing guidelines (NMFS, 2000). 

x Handle ESA-listed fish with extreme care, keeping fish in water to the maximum extent possible during seining 

and transfer procedures to prevent the added stress of out-of-water handling. 

x Ensure that water quality conditions are adequate in buckets or tanks used to transport fish by providing 

circulation of clean, cold water; using aerators to provide dissolved oxygen; and minimizing holding times. 

x Release fish into a safe release site as quickly as possible, and as near as possible to capture sites. 

x Do not transfer ESA-listed fish to anyone except NMFS personnel, unless otherwise approved in writing by 

NMFS. 

x Allow NMFS or its designated representative to accompany the capture team during the capture and release 

activity, and to inspect the team’s capture and release records and facilities. Submit an electronic copy of the 

Salvage Report Form to NMFS within 10 calendar days of completion of the salvage operation. 

5-2 EN0427151027PDX 
SECTION 5—FISH 

x Rescue/salvage (take) of fish during isolation of in-water work areas at Pipeline waterbody crossings would 

include handling of adults or juveniles. Fish handled must be recorded in the annual report for the Scientific 

Taking Permit. 

x In-water work (fish salvage or construction) may occur between the specific designated in-water work 

windows for each specific waterbody. Exceptions to these in-water work periods must be approved by the 

local ODFW District Fish Biologist or his/her representative and submitted to the ODFW ESA Program 

Specialist, in writing, before work commences outside the approved in-water work windows. 

x Activities must be coordinated with the local ODFW District Fish Biologist before any sampling. 

x Indirect mortality may not exceed 10 percent of the total take, or—for species listed under the federal ESA—

up to a specified number of individuals. In the event that mortality for any species exceeds the specified rate, 

the permittee would contact the ESA Program Specialist, ODFW, before any further activity. 

The ODFW in-water work windows for waterbodies to be crossed by the Pipeline are provided in Attachment 1 of 

the Oregon LNG Pipeline Waterbody Crossing: Fish Salvage Plan technical memorandum originally submitted to 

FERC in 2008, and revised and resubmitted in June 2013 as Resource Report 3, Appendix 3O (see Appendix 2C of 

the Applicant-Draft BA for the June resubmittal version). 

The following general procedures and steps would be conducted during salvage activities at crossing sites: 

1. Set block nets upstream and downstream of the area to be crossed to ensure that fish or lampreys cannot 

enter the construction area. 

2. Conduct the salvage between the block nets by using electrofishing equipment, seine, trap, or other approved 

method. If using electrofishing equipment, a minimum two-pass method would be employed to ensure that 

fish and lampreys are captured. Electrofishing equipment is the most appropriate method for capturing larval 

lamprey during salvage activities at crossing sites. 

a. The first electrofishing pass of the minimum two-pass method would be specifically for capturing larval 

lamprey. The electrofishing unit would be set to deliver three pulses/ second (125 volts direct current [dc]) 

at 25 percent duty cycle, with a 3:1 burst pulse train (three pulses on, one pulse off) to remove larvae 

from the substrate (USFWS, 2002). Once larvae emerge, 30 pulses/second would be applied to stun the 

larvae. 

b. The second and subsequent electrofishing passes would be to capture fish that may be in the area and 

were not captured during the first electrofishing pass. The electrofishing unit would be set accordingly to 

deliver the appropriate pulse rate/ second at the appropriate voltage and duty cycle based in part on fish 

size, streamflow, velocity, depth, temperature, and conductivity. 

3. Captured fish and lampreys would be handled to the minimal extent possible and placed in containers of 

clean, aerated water. Individuals would be held in containers for the minimal time necessary. Captured 

individuals would be enumerated, identified, and noted in a field logbook before being released. Captured 

individuals would be released into a safe site as quickly as possible, and as near as possible to capture sites. 

4. After lampreys and other fish have been captured in the construction area, install the flume or dam-andpump equipment. 

5. Inspect the isolated area for stranded fish and salvage, if necessary. 

6. Construct crossing, restore waterbody channel, and remove flume equipment to restore flow in the 

construction area per the guidelines below: 

a. When downstream siltation must be avoided, flumes are generally not recommended for use where 

waterbodies have a broad unconfined channel, permeable substrate, excessive discharge, or where a 

significant amount of bed or bank alteration is required to install flumes or dams. 

b. Schedule crossing during low-flow period, if possible. 

EN0427151027PDX 5-3 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

c. Complete watercourse activities as expediently as possible. In accordance with FERC procedures, the 

duration of construction would be limited to 24 hours across minor waterbodies (10 feet wide or less) and 

48 hours across intermediate waterbodies (between 10 and 100 feet wide). 

d. Do not refuel mobile equipment within 150 feet of a waterbody. Refuel stationary equipment per the 

SWPPP submitted to FERC in June 2013 (see Appendix B). 

e. Minimize riparian clearing to accommodate stream size, terrain, and existing vegetation conditions, and 

to avoid removal of significant trees, where possible, at the margins of the temporary construction zone. 

Existing LWD would be salvaged for reinstallation, and a sufficient quantity of large-diameter conifer logs 

would be stockpiled for post-construction aquatic habitat enhancement. 

f. Install temporary equipment crossing. 

g. In agricultural land, strip topsoil from spoil storage area. 

h. Instream spoil to be stored on banks a minimum of 150 feet from the top of bank for perennial streams. 

i. Leave hard plugs at the stream bank edge until just before pipe installation. 

j. Size flume to handle 150 percent of the anticipated flows. Install flume in watercourse and maintain 

correct alignment until removed. 

k. Construct upstream dam followed by downstream dam. Install a flange on upstream end of flume and 

seal to substrate with sandbags and polyethylene liner where necessary to ensure a watertight barrier. 

“Key” dams into banks or construct secondary dam, if necessary. 

l. Pump stream channel between dams, if necessary. Discharge water through a dewatering structure and 

onto a stable, well-vegetated area to prevent erosion and sedimentation. No heavily silt-laden water may 

be discharged in the stream. 

m. Construct sediment barriers (straw bales and/or silt fence) to prevent silt-laden water and spoil from 

flowing back into the watercourse. Constructed sediment barriers shall extend along the sides of the 

stockpiles and the ends of dams. Barriers may be temporarily removed to allow construction activities but 

must be replaced by the end of each work day. 

n. Complete prefabrication of instream pipe section and weight pipe as necessary before commencement of 

instream activity. 

o. Trench through watercourse. Install temporary (soft) plugs, if necessary, to control water flow and trench 

sloughing. 

p. Maintain streamflow, if present, through flume throughout crossing construction. 

q. Lower-in pipe, install trench plug, and backfill immediately. 

r. Backfill with native material. 

s. Restore watercourse channel to approximate preconstruction profile and substrate. 

t. Restore stream banks to approximate original condition and stabilize, as required. 

Restoration and cleanup would begin after the trench is backfilled or as soon as weather and site conditions 

permit, and in accordance with landowner requests, the FERC Plan, and as described in Resource Report 2, 

Appendix 2D. These fish salvage procedures would be followed at the Pipeline crossings requiring fish salvage. A 

field log would be kept for each fish salvage operation that documents the number of fish by species and age 

group (adult or juvenile), disposition of released fish noting any injuries or mortalities, date, salvage team 

members, and general observations. After stream crossings and salvages have been completed, a report would be 

compiled that summarizes the number of fish salvaged by species and their disposition. 

Rivers and streams that are known to support anadromous salmonids in the Northern Oregon Coastal and 

Willamette basins, and would be crossed using flume and open-cut crossing methods, are listed in Appendix C 

5-4 EN0427151027PDX 
SECTION 5—FISH 

(Characteristics of Streams Crossed by the Pipeline). Those listed as open-cut crossings are assumed to be dry 

during the in-water work window. Streams that contain water during Pipeline construction would be crossed 

using the flume method.

Many perennial named and unnamed streams that the Pipeline would cross are likely to support resident coastal 

cutthroat trout or nongame fish species such as sculpin. Perennial streams are assumed to support fish and would 

require fish salvage at the crossing site. 

5.1.1.2. Physical Instream Habitat Alteration 

Physical instream habitat alteration would be avoided to the extent possible through conscientious Pipeline siting 

and the judicious use of HDD methods. The techniques discussed below would be employed to restore and 

minimize effects on instream habitat at flumed Pipeline crossings. Stream habitat would be restored, as closely as 

possible, to preconstruction condition by using appropriate available technologies. Native materials (including 

large wood, native vegetation, weed-free topsoil, and native channel materials [gravel, cobble, and boulders]) 

disturbed during site preparation would be conserved onsite for site restoration. The following actions would be 

taken to preserve and replace native materials and to restore the morphology of the stream: 

x Locations of instream habitat features would be photo-documented before construction. 

x If possible, native materials would be undisturbed. Where stream bank areas require clearing, vegetation 

would be clipped at ground level to retain root mass and encourage reestablishment of native vegetation. 

x During removal, streambed material would be segregated according to vertical horizons and backfill would 

occur in reverse order. Native materials that are moved, damaged, or destroyed would be replaced with a 

functional equivalent during site restoration. 

x LWD taken from below the Ordinary High Water Line and within 150 feet of a stream—along with native 

vegetation, weed-free topsoil, and native channel material displaced by construction—would be retained for 

use during site restoration. 

x As part of the site restoration, LWD taken from the riparian zone or stream during construction would be 

returned to those areas and placed in a natural configuration. 

x The waterbody would be restored to its preconstruction contours by using native materials augmented by 

functionally equivalent fill. 

Stream bank erosion would be minimized by clearing the smallest amount of vegetation possible at stream 

crossings and grubbing only over the ditch line. Rootstocks would be left in place for erosion control and rapid 

post-construction vegetative regeneration, in addition to seeding and mulching, planting native vegetation (where 

necessary), and—in some cases—use of biodegradable erosion control fabrics. 

Stream crossings would be conducted in compliance with the FERC Plan and Procedures for Pipeline stream 

crossings. They would be monitored after construction to ensure that bank stabilization methods employed were 

effective in abating increased sedimentation. Immediately after pipe installation and backfilling, and before the 

dams and flumes are removed and flow is returned to the waterbody channel, the stream banks would be 

reestablished to approximate preconstruction contours and stabilized. Erosion and sediment control measures 

would be installed across the construction easement to reduce stream bank and upland erosion and sediment 

transport into the waterbody. 

At stream crossings, the pipe would be buried at a depth to minimize the risk of exposure from vertical erosion or 

lateral migration. In the vertical dimension, the pipe would have a minimum of 3 feet of cover below the scour 

depth. In the lateral dimension, the vertical depth would be maintained for a minimum length of 2.2 times the 

active channel width, plus the channel migration zone. For streams with floodplains less than 2.2 times the active 

channel width, the vertical depth would be maintained across the entire width of the floodplain. Active channel 

migration zones and floodplains are applicable to streams with a gradient of less than 4 percent as streams with a 

gradient of 4 percent or greater do not have functional floodplains (Rosgen, 1996). 

EN0427151027PDX 5-5 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

The specific depth that would be required at such crossings would be determined on a site-specific basis, which 

would require acquisition of additional detailed information on substrate characteristics, expected peak flow 

conditions, local bed slope, and upstream and downstream conditions. These data would be acquired before final 

design of the high-risk crossings. 

Should channel subsidence, bank erosion, channel scour, or other negative long-term effects of Pipeline 

construction become apparent during post-construction monitoring, case-specific responses would be tailored to 

alleviate the specific problems identified. 

After construction, stream banks would be restored according to plans submitted in the Applicant-Draft BA. 

Appendix 6A in Applicant-Draft BA (Stream Restoration Methods) shows the scenario in which various stream 

bank restoration techniques may be employed. Riparian habitat in the upland portions of the construction 

easements would be revegetated and returned to discretionary land use by the landowner, consistent with 

easement restrictions. Typically, FERC recommends a 10-foot-wide mow strip centered over the Pipeline (Figures 

5-1 and 5-2). In addition, FERC recommends that vegetation within 15 feet of the centerline may be maintained at 

a height of 15 feet. The remainder of the 75- to 100-foot-wide construction easements would revert to vegetation 

cover preferences or requirements of the landowner. For streams that currently contain riparian cover the 

following revegetation scenario would be adopted, as illustrated in Figures 5-1 and 5-2: 

x Riparian vegetation (trees and shrubs) would be restored continuously for a distance of that matches the 

width of the current riparian buffer, except for a 10-foot-wide herbaceous strip immediately above the 

Pipeline itself. Oregon LNG would deviate from FERC’s recommendations by planting woody vegetation up to 

the limits of the 10-foot-wide herbaceous strip, allowing the canopy to close over the 10-foot-wide mow strip. 

x Where there is preconstruction continuous riparian cover greater than 25 feet perpendicular from the top of 

the bank, then the riparian restoration would extend out to match the riparian width of existing conditions up 

to the width from the top of the bank required by the Forest Practices Act. 

x Trees adjacent to the 10-foot-wide herbaceous strip may be limbed to a height of 10 feet on the interior 

(direction of Pipeline) side of the tree to permit passage of personnel for purposes of inspecting the Pipeline. 

5.1.1.3. Mass Failures 

Erosion control BMPs and the methods outlined in the FERC Plan and Procedures would be implemented to 

reduce the potential for mass failure. In areas where landslides are a concern but specific landslide features 

cannot be identified, proper construction techniques would be implemented to minimize the potential for slope 

failure, landslides, or erosion resulting from Pipeline installation. In general, the installation of a Pipeline below 

ground (and subsequent backfilling of the trench zone with native material) results in a relatively short window of 

disturbance and minor change in subsurface conditions. The larger changes occur at the ground surface, where 

topography and vegetation are altered. Therefore, the majority of the construction techniques that would be 

implemented are performed to restore or improve the land and drainage features after construction is complete. 

These techniques may include the use of water bars, terracing, diversion ditches, and other methods to control 

runoff and erosion. Backfill operations would be performed to ensure that the trench backfill is adequately 

compacted so mounding is not required. Revegetation procedures would also be implemented to ensure rapid 

establishment of a vegetative cover after completion of construction. 

Where steeply sloped areas or mapped landslide hazard areas cannot reasonably be avoided, an effort has been 

made to align the pipe parallel to the maximum fall of the ground (that is, to run the pipe straight down the slope) 

and avoid placing the pipe parallel to the slope (that is, side-sloping the pipe). The potential for pipe damage 

because of soil deformations associated with rapid landslide movement is much less when the movement occurs 

parallel to the axis of the pipe. In areas where specific landslide hazards are identified, a number of methods are 

available for the mitigation of landslide deformation on pipelines. These include stabilization of the landslide, 

relocation of the Pipeline beyond the landslide, installation of the Pipeline above ground, installation below the 

landslide using directional drilling or deep excavation, or the use of deformable backfill such as polystyrene or 

other suitable material (Bukovansky and Major, 2002). 

5-6 EN0427151027PDX 
SECTION 5—FISH 

When avoidance measures are not practical, another option for mitigating the risks of landslide hazards includes 

maintaining the Pipeline within the landslide zone, which can be accomplished using a program of landslide and 

Pipeline monitoring. This approach is particularly well suited to existing landslide areas where movement is 

occurring relatively slowly, which is the case in much of the landslide topography mapped throughout the Coast 

Range. Installation and monitoring of equipment to monitor the movement of landslides and pipelines (and the 

associated strain imposed on the Pipeline) is a common method of maintaining pipelines in active landslide zones. 

Vibrating wire strain gauges have been used extensively during the last 20 years to monitor longitudinal pipeline 

strain changes caused by the landslide deformations (Bukovansky and Major, 2002). Monitoring of pipeline strains 

enables sensitive measurements of forces in the pipe and timely implementation of strain-relief measures if 

strains reach a critical level. According to Bukovansky and Major (2002), federal, state, and local agencies that 

regulate pipeline construction and operation in the United States generally accept strain monitoring to provide for 

the safety of pipelines located in areas of geologic hazards. This has contributed to the acceptance of strain gauge 

monitoring as a basic system for enhancing pipeline safety. 

To prevent landslides at high-risk crossings, BMPs (including slope breakers, straw bales, silt fences, wattles, and 

subsurface drainage) would be used, as detailed in the technical memorandum titled Landslide and Debris Flow: 

Relative Risk Assessment for the Bidirectional Project Pipeline (CH2M HILL, 2013e) in Applicant-Draft BA Appendix 

6B. Site-specific engineering techniques for minimizing landslide risk and for protecting the Pipeline against 

landslides, should they occur, are shown in drawings for each flumed and open-cut crossing that could affect ESAlisted fish (see site-specific stream crossing drawings submitted with Applicant-Draft BA Appendix 6A). The 

consequences of mass slope failures, landslides, persistent turbidity, and Pipeline fractures on fish and wildlife 

resources would depend on downstream physical and biological conditions and timing should a landslide or mass 

failure occur. 

Because the severity of any given landslide with regard to ESA-listed fish is dependent on a nearly infinite number 

of variables, no generalities can be drawn. The effects could be as minor as a short-term pulse of turbidity that 

would require no corrective action or as severe as complete blockage of upstream migration. Should a landslide 

occur that is due to Pipeline construction and not other natural processes, ODFW, NMFS, and other interested 

parties would be consulted to design a site- and case-specific plan to mitigate any negative effects. 

5.1.1.4. Increased Turbidity and Sediment Loads 

Increased turbidity from construction at many crossings was avoided through the use of HDD methods. Turbidity 

would be further minimized through the use of dry crossing (flume) techniques. Before construction begins, the 

action areas would be surveyed to ensure that no spawning is occurring at the crossing location or within 500 feet 

downstream. If spawning is occurring, construction would be postponed until fry have had adequate time to leave 

the redds. The FERC Procedures would be followed to limit water quality effects on waterbodies during 

construction. BMPs and erosion and sediment control measures also would be implemented, as described in the 

SWPPP submitted to FERC in June 2013 (see Appendix B). In addition, a National Pollutant Discharge Elimination 

System (NPDES) 1200-C construction stormwater discharge permit would be obtained before construction of the 

Project. 

During construction of the Pipeline across perennial streams, measures to avoid construction-related effects 

would include placing spoils at least 150 feet from the water’s edge or in ATWS; using erosion and sediment 

controls to prevent the excessive delivery of sediment to waterbodies; and, where temporary vehicle crossing is 

needed, following the FERC Procedures for temporary equipment bridges. ATWS would be located at least 150 

feet from the top of bank. 

Crossing methods for each stream were determined based on field surveys, agency consultation, and review of 

fisheries data. The following general conservation measures would be employed at flume crossings: 

x Dams would be constructed of sandbags and plastic sheeting or other materials that would not contribute 

sediment to the stream channel. 

x Sandbags would be filled with a nonleachable material such as clean, prewashed sand. 

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APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

x Sandbags would be tied securely before they are installed, and sheets of plastic would be interwoven 

between the layers of sandbags to ensure an effective seal. 

x At the flume outfall, flow would be dissipated as needed to avoid disturbing streambed sediments. 

x Work would be conducted during the summer to early fall (periods of low flow), thus minimizing risks of bank 

failure. 

To prevent sedimentation caused by construction and vehicular traffic crossing perennial waterbodies during 

clearing operations, two stream crossing techniques would be employed. Equipment either would be transported 

around streams or would cross on temporary bridges, as described in Section V of RR2 Appendix 2B. There would 

be little concern for erosion associated with flooding at the bridge crossings. However, some temporary bridges 

may need to be reset to facilitate stream crossings in the fall or winter in support of final stream bank restoration. 

In many cases, it would be possible to access the opposite side of larger streams from alternative access routes 

that would not require bridging the stream. At some of the flumed crossings where the stream/slough bottom is 

too soft to support the trenching equipment, temporary fill material (coarse rock) would be placed within the area 

isolated by the dams to allow a solid crossing foundation. This fill material would be removed before the dams are 

breached and would be transported to an upland location at least 150 feet from the stream channel. 

After completion of construction, a report would be prepared for submittal to NMFS that would include the 

following: 

x Fish monitoring and turbidity data taken during construction 

x Dates and times of activities 

x Description of the construction activities and associated downstream turbidity 

x Any corrective actions taken to reduce turbidity 

x Any reporting requirements of the 401 State Water Quality Certification issued for this Project 

x Amount or extent of incidental take that has occurred, including a description of any dead or distressed 

salmonids, and the total amount of disturbed habitat 

x An assessment of stream habitat conditions within the easement and downstream following construction 

5.1.1.5. Water Temperature 

Streams that are listed in the 1972 Clean Water Act § 303(d) as temperature sensitive along the Pipeline would be 

crossed using HDD, thereby avoiding loss of streamside shade in these temperature-sensitive streams. At flume 

and open-cut crossings, the removal of riparian vegetation would be minimized to the extent possible. However, 

based on the technical memorandum in Applicant-Draft BA Appendix 10, Characterizing Deforestation Impacts on 

Stream Temperature (CH2M HILL, 2009), even in the event that the full 100-foot construction corridor is cleared, it 

is unlikely that the resultant increase in incident solar radiation would be sufficient to cause biologically significant 

increases in downstream water temperatures. Revegetation of the easement over the long term (described 

above) would eliminate any small increases in water temperature that do result. 

5.1.1.6. Large Woody Debris 

In areas where unmerchantable trees or downed LWD greater than 12 inches in diameter at breast height occur 

within the Pipeline construction areas (i.e., permanent easements, temporary workspace [TWS], and ATWS), 

some of the material would be salvaged for retention on wood-deficient soil surfaces, consistent with wildfire 

protection regulations, or in stream channels in accordance with ODF and ODFW wood placement guidelines. 

Some of the unmerchantable LWD resulting from clearing would be stockpiled for redistribution to the site as part 

of post-construction rehabilitation, particularly the portion of the construction corridor outside the 50-foot 

operational/maintenance easement. To compensate for the disruption of LWD recruitment potential and shifting 

of instream LWD, LWD removed during construction would be replaced and the riparian corridor replanted, as 

described previously, to replenish source areas for LWD recruitment over the long term. A monitoring plan for 

5-8 EN0427151027PDX 
SECTION 5—FISH 

evaluating the effectiveness of LWD replacement would be prepared as part of the overall Pipeline monitoring 

plan. This plan would be developed before construction and would require agency approval before 

implementation. In this way, existing conditions with respect to LWD are expected to be maintained. 

5.1.1.7. Frac-outs 

Frac-outs are not anticipated, but their effects (should they occur) would be minimized through the use of the 

following conservation measures. The Spill Prevention, Control, and Countermeasures (SPCC) Plan for the Project 

(see Appendix B) outlines procedures for dealing with a frac-out. Depending on the severity of the release, the 

most common first step for the HDD contractor in reestablishing circulation and sealing fractures is to use a 

thicker, lower-viscosity mixture of sodium bentonite and water. The thicker mix of sodium bentonite and water 

would be more effective in forming a filter cake on the inside wall of the borehole and soil/rock particles around 

the borehole to seal voids and prevent further release of drilling mud. In some cases, unhydrated sodium 

bentonite chips would be pumped through the drill rods. These granules of bentonite would flow in and fill or 

bridge a void or fracture. They would hydrate and swell in the presence of the drilling fluid to seal off leaks or 

fractures. 

If the problem is more severe, standard drill fluid additives would be used. These drill fluid additives commonly 

consist of polyanionic cellulose (PAC), or water–swellable synthetic polymers capable of absorbing many times 

their weight in water. These materials work in a similar manner to the granular bentonite; that is, they are 

pumped through the drilling system and allowed to swell to seal voids and fractures. 

These leak-stopping additives may then be released into aquatic systems, potentially exposing fish and other 

aquatic biota. The toxicity of leak-stopping additives and their ingredients is summarized in Table 3.5-6 of the 

Applicant-Draft BA. Because it is not known which products would be used, ecological toxicity data were reviewed 

for 11 leak-stopping products from four of the largest manufacturers of drill-fluid additives. Key ingredients and 

Chemical Abstract Service (CAS) numbers (if presented) were obtained for each product. Ecological toxicity data 

were also obtained from the manufacturers. If ecological toxicity data were not available, the manufacturers were 

contacted to determine whether data could be obtained. In addition, searches were conducted of the USEPA 

Ecotox database and of published literature to identify whether ecological toxicity data were available. Searches 

were based on the CAS numbers of key ingredients in the products and focused exclusively on aquatic toxicity 

data (i.e., effects on fish and invertebrates). 

Ecological toxicity data were identified for at least one of the key ingredients for 9 of the 11 products considered 

(Applicant-Draft BA Table 3.5-6). Ecological effects data were not reported in the Material Safety Data Sheet 

(MSDS) for Fed Seal (manufactured by Federal) or Cel-U-Seal (manufactured by Alpine), and data for their key 

ingredients could not be identified in published literature. Because the ingredients of these products consist of 

cellulose, paper, and other natural fibers, toxicity is likely to be low. 

Ecological toxicity data were available for key ingredients for the nine remaining products, except for crystalline 

silica quartz and crystalline silica tridymite. Because these ingredients represent 1 percent or less of each product, 

as silica compounds are expected to be comparable to sand, they are considered unlikely to contribute to toxicity. 

Three of the products are composed almost entirely of PAC or carboxymethylcellulose sodium salt (ApplicantDraft BA Table 3.5-6). PAC polymer is virtually nontoxic to fish; 96-hour LC50s (concentrations resulting in 50 

percent mortality) ranged from 17,000 milligrams per liter (mg/L) to greater than 20,000 mg/L. Invertebrates, 

however, are more sensitive; the 48-hour EC50s (concentration producing an effect [immobilization] in 50 percent 

of exposed individuals) for daphnids ranged from 87 to 123 mg/L. 

Two products (Polyswell and Macro-Fill) were composed of acrylamide polymer. Acrylamide polymer may be 

either anionic or cationic. Whereas anionic acrylamide polymer has a 96-hour LD50 for fish greater than 600 mg/L, 

cationic acrylamide polymer is much more toxic with a 96-hour LD50 for fish of 2 mg/L. Polyswell is identified as 

an anionic acrylamide polymer; the MSDS for Macro-Fill is not explicit about its composition. 

The remaining four products are composed of inorganic materials (clays, salts, and silicates). The key ingredients 

are bentonite clay, smectite clay, or gypsum (calcium sulfate). The clays have the lowest toxicity (fish LC50 = 

EN0427151027PDX 5-9 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

19,000 mg/L), followed by gypsum (fish and daphnid LC50s greater than 1,970 mg/L). Toxicity testing conducted 

by the manufacturer for one of these products (Max Gel) indicates that the fish LC50 for the formulated product is 

greater than 10,000 mg/L (Table 3.5-6). 

In conclusion, leak-stopping products formulated from clays, gypsum, and silica have the lowest toxicity to fish 

and invertebrates. Products consisting of PAC or carboxymethylcellulose sodium salt have equally low toxicity to 

fish, but are moderately toxic to invertebrates. Products consisting of acrylamide copolymers may be more toxic 

to fish. However, the available toxicity data are limited (the maximum concentration tested was 600 mg/L; it is 

uncertain whether higher concentrations are toxic). Effects of acrylamide copolymers on invertebrates are 

uncertain. Although toxicity data for products formulated from cellulose, paper, and other natural fibers were 

lacking, toxicity is likely to be low. Even in the event of invertebrate toxicity, the additives likely would be bound 

to the bentonite and be poorly soluble in water. Because of the volume of river flow, the proposed cleanup 

provisions for frac-outs, and the demonstrated low toxicity, the effects of these additives is expected to be 

extremely limited. 

In the most severe cases, standard drill fluid additives may not be sufficient to seal fractures and reestablish 

circulation of drill fluid. In these conditions, coarser bridging agents may be required. These bridging agents may 

take the form of fiber, flake, or granular materials (Canon, 2003). Examples of fiber additives are cellulose fiber, 

cedar (or other wood) fiber, cane fiber, or spun mineral fiber. Mica is one of the most common examples of flake 

additives. Granular additives include nut hulls and granular bentonite (discussed above). Most of these bridging 

agents come in different sizes, from coarse to fine, and many manufacturers of drill fluid additives provide 

specially designed materials that may contain a combination of various bridging agents and polymers. 

Should the above methods prove unsuccessful, and HDD drilling fluid is released to water, appropriate local, state, 

and federal agencies would be notified, and a determination whether to cease operations would be made in 

accordance with the SPCC Plan for the Project (see Appendix B). The extent of the release would be assessed, and 

appropriate corrective actions would be taken. These corrective actions may range from simple monitoring in the 

case of small releases, to active cleanup using specialized pumps and filters, to abandonment of the HDD and 

sealing of the hole. In the event of an HDD drilling fluid release to land, the release and drilling hole entry point 

would be contained with berms, pumps, hay bales, sediment fencing, wood products, or other appropriate 

means, and the fluid would be cleaned up immediately using hand tools or vacuum trucks and transported to an 

approved disposal location. 

5.1.1.8. Fish Passage 

Three potential project actions are triggers for fish passage review and authorization for the Oregon LNG project: 

temporary coffer dams and dewatering work areas at stream crossings where trenching is the construction 

method; exposure of the pipeline as a result of stream erosion, post-construction; and new or replacement 

culverts where road improvements are required. Impediments to fish passage were avoided as much as possible 

through conscientious Pipeline siting and the judicious use of HDD methods. Trench construction would take place 

during summer in-water work windows when intermittent and ephemeral streams are expected to be dry and 

flows in perennial streams are at seasonal lows. In the spring and summer of 2015, Oregon LNG will be conducting 

supplemental field studies to evaluate the potential for scour at stream crossings. The results of 2015 field studies 

will supplement completed preliminary risk analysis and further inform which streams are at risk for vertical sour 

or lateral movement. The degree of risk would inform the depth of pipe burial and other in-stream restoration 

measures that could be applied to ensure that practicable measures have been taken to reduce or eliminate the 

risk of pipe exposure, post-construction. Access roads were examined and culvert replacements are not 

anticipated. Therefore, fish passage as a result of replacing culverts beneath roads is not a fish passage trigger. 

The following conservation methods would minimize negative effects on fish passage. Most stream crossings 

would be completed within 24 to 48 hours of initiation, thereby limiting possible effects on fish passage. With the 

few exceptions noted previously, streams known to support anadromous fish would not be crossed during periods 

of adult upstream migration. Downstream juvenile salmonid migrations would continue during construction 

through the bypass flume. Oregon LNG committed to burying the pipeline below the scour depth. The depth of 

5-10 EN0427151027PDX 
SECTION 5—FISH 

pipe burial would depend on the risk of vertical scour or lateral movement of a stream. The following courses of 

action would be taken: 

1. Submit fish passage applications to ODFW prior to FERC’s issuance of the final Environmental Impact 

Statement 

2. Construct and install upstream passage in conformance with the ODFW passage regulations (ODFW OAR 635-

412-0005). 

3. Restore streambeds and stream flows to baseline conditions in the same in-water window as pipeline 

construction 

4. For streams at a low risk of scour, bury pipeline at a standard depth (minimum three feet of cover between 

the pipeline and streambed) 

5. For streams at moderate to high risk of scour, bury pipeline below the scour depth or at a depth that 

minimizes the likelihood of exposure when other in-stream enhancements are applied 

6. At moderate to high risk streams, apply in-stream enhancements (rock and/or large wood) that would help 

direct and control flows to protect the streambed and reduce the likelihood of scouring; in-stream 

enhancements could be used to reduce the depth of pipe burial 

7. Use bioengeered approaches to restoring streambanks (see Table 6A-1 in Applicant-Draft BA Appendix 6A 

8. Engineer flume sizes to accommodate storm surges that could occur during construction 

During construction, regardless of duration, adequate flow rates would be maintained to protect aquatic life and 

avoid disruption of downstream uses. The area within 1,000 feet downstream of each crossing would be 

monitored for distressed fish and other aquatic biota. NMFS would be notified within 3 working days after a dead, 

injured, or sick individual of an endangered or threatened species is located. Initial notification would be made to 

the NMFS Law Enforcement Office. Notification would include the date, time, precise location of the injured 

animal or carcass, and any other pertinent information. Upstream passage of migratory fish is not likely to be 

impeded given that Pipeline construction would take place within in-water work windows approved by ODFW and 

NMFS, flows will be restored in the same in-water work window as construction, and many streams would be 

crossed using the HDD method. 

5.1.1.9. Water Withdrawals and Discharges 

During Pipeline construction, water withdrawals and discharges cannot be avoided. However, the following 

conservation measures would minimize the negative effects. 

Water withdrawals and discharges would be required for HDD drilling and hydrostatic testing. In addition, leakage 

from the dams, or subsurface flow from below the waterbody bed, may cause water to accumulate in the isolated 

crossing area. As water accumulates, it may be pumped out periodically and discharged into energy 

dissipation/sediment filtration devices, such as a geotextile filter bag or straw bale structure, or into wellvegetated areas away from the water’s edge (see Applicant-Draft BA Figure 2.5-3). 

The amount of water required for HDD drilling operations would be small relative to the available sources, and no 

negative effects are anticipated. Conservation measures would include appropriate screening of water intakes to 

ensure no entrainment or impingement of juvenile salmonids. 

Hydrostatic testing would be conducted in accordance with the requirements of United States Department of 

Transportation Pipeline safety regulations, 49 Code of Federal Regulations (CFR) 192, Oregon LNG testing 

specifications, and applicable permits. Oregon LNG is proposing to use municipal water for a significant portion of 

hydrostatic test water. Use of municipal water would minimize concerns about potential cross-contamination 

between watersheds and quality of water that would be discharged back to streams. Discharge sites would be 

near sources to provide for recharge, but they would be in uplands sufficiently removed from the sources to 

prevent immediate direct surface water return. Environmental effects from the withdrawal and discharge of test 

EN0427151027PDX 5-11 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

water would be minimized by applying the measures indicated in the FERC Procedures and through prudent 

implementation of the following measures: 

x Withdrawals and discharges to water sources would be done in compliance with appropriate agency 

requirements that consider the protection of fishery resources on a case-by-case basis. 

x Compliance would occur with appropriate permits and instream water rights. 

x Intakes would be screened to avoid entrainment of fish and aquatic species in accordance with NMFS fish 

screening criteria. A diagram of a typical fish screen at a water intake is provided in Applicant-Draft BA Figure 

2.5-2 as an example. 

x Adequate flow rates would be maintained during withdrawals to protect aquatic life and provide for 

waterbody uses and downstream withdrawals of water by existing users. 

x The discharge pipe would be anchored for safety. 

x The overall rate of discharge would be controlled to prevent flooding and erosion. 

x Test water would be discharged to straw bale dewatering structures to dissipate energy, reduce velocities, 

and spread water flow to avoid erosion and promote ground penetration. The base of the structure would 

consist of a 24-foot-square, single layer of tightly packed straw or hay bales. A second layer of bales would be 

placed atop the perimeter of the base layer as a rim to contain the discharge water, and the whole would be 

surrounded by silt fence. A final layer of bales would then be placed around the outside of the silt fence and 

staked into place. The dewatering structures would be closely monitored for structural integrity and to ensure 

that the water does not overtop the rim. The dewatering structures would effectively dissipate energy, reduce 

velocities, and spread water flow to avoid erosion and promote ground penetration. 

x Test water would be discharged only in uplands across well-vegetated areas. 

Because of the short residence time of the test water in the Pipeline system, the use of biocides or other 

hydrostatic test water additives would not be required. Water testing before discharge would not be required 

because no contaminants (oil, grease, solvents, etc.) are used in the construction procedures for the Pipeline. Dirt 

and scale from inside the pipe would be filtered out by the straw bale enclosure or other filtering device. 

At the time of testing, the Pipeline would be buried and insulated from solar heating. The water would be 

conveyed to the Pipeline from the source areas through temporary piping. Where fish are present, water would 

be withdrawn through screened intake structures that comply with ODFW and NMFS requirements. The actual 

size and type of screen to be used would be determined through consultation with ODFW during the Limited 

Water Use License application process based on information provided by the Oregon Water Resources 

Department on water availability. This information would be used to determine the most appropriate withdrawal 

rate and screen size. Depending on the outcome of the Limited Water Use License application process, intake 

pipefish screens could range from 2.8 square feet to more than 33 square feet in size. 

Hydrostatic test water would be discharged near the point of diversion to prevent cross-watershed disposal 

whenever possible. Discharge of the water would be performed to prevent spread of organisms and to prevent 

erosion and reduce turbidity by using erosion control structures and energy-dissipating devices (see ApplicantDraft BA Figure 2.5-2). Turbidity levels would be maintained in accordance with those outlined in the NPDES 

permit issued by ODEQ or the 1200-C construction permit issued by Clean Water Services. 

Transfer of water between basins (Northern Oregon Coastal, Lower Columbia, and Willamette) would be avoided, 

except where municipal water is the source. Whenever possible, the water would be discharged within the 

subwatershed from which it was obtained, but it may be transferred from one section of pipe to the other, and 

ultimately discharged in a different subwatershed. In the event of discharge to a subwatershed different from that 

where the water was withdrawn, it would be discharged only to a straw-bale dewatering structure in upland areas 

sufficiently far from waterbodies to ensure complete infiltration. Water withdrawals would be conducted in 

accordance with existing water rights, such that no withdrawal would over-appropriate any given stream. In 

5-12 EN0427151027PDX 
SECTION 5—FISH 

addition, withdrawals would be conducted in consultation with ODFW district fish biologists to ensure that the 

withdrawals avoid particularly sensitive stream reaches. The discharge rate would also be carefully metered to 

ensure infiltration and avoid overland flow. Infiltration of the water in upland areas should effectively preclude 

the cross-watershed transfer of any exotic aquatic species or pathogens that may be present in the water. 

Careful adherence to appropriate regulations and implementation of BMPs would ensure that existing conditions 

are maintained. 

5.1.1.10. Hazardous Materials Release 

During consultation with ODFW, USFWS, and NMFS, it was agreed that unless approved by all three agencies, 

ATWS would be set back 150 feet from streams and wetlands. In addition, overnight parking of vehicles, storage 

of fuels and other hazardous materials, and refueling activities would take place no closer than 150 feet from a 

stream or a wetland, unless full containment of potential contaminants is provided. Under certain clearly defined 

conditions, and subject to agency approval, ATWS may be placed closer to waterbodies or wetlands where the 

ATWS placement would not increase effects on streams or fish habitat. This BMP, combined with observance of 

the conditions of the Sediment and Erosion Control Plan, would ensure that hazardous materials would not be 

released from construction equipment into any Pipeline action areas. 

5.1.1.11. Cross Contamination Among Waterbodies 

Cross contamination from water discharges is discussed above. Cross contamination from dirty construction 

equipment would be avoided through compliance with an equipment decontamination plan. The plan would 

encompass large equipment (such as excavators, earthmovers, and trucks), as well as small hand tools. Oregon 

LNG proposes the following risk minimization and equipment decontamination standards: 

x Vehicular traffic would be kept to the absolute minimum necessary. 

x Before equipment remobilizes to a new crossing location, cross contamination and loose debris (e.g., caked 

mud and dust) would be removed using scrapers or brushes. Solids would be removed from equipment and 

tools to the extent feasible and spread onsite. 

x Hand tools would be immersed in a warm soap-and-water solution and/or a solvent rinse using alcohol 

(methanol or isopropanol). 

x Decontaminate equipment by steam cleaning, pressure washing, or washing in soapy water (e.g., Alconox or 

other phosphate-free detergent), followed by a clean water rinse. 

x Decontamination would take place in designated decontamination areas with the following features, or with 

alternative features that provide an equivalent level of protection: 

 Puncture-resistant geomembrane/plastic sheeting robust enough to resist damage from vehicle traffic 

 Adequate size to accommodate the largest anticipated equipment, plus workspace for decontamination 

technician(s) 

 Adequate water from a stationary tank, water truck, or municipal/private supply 

 Bermed sides or sloped topography permitting the complete collection of spent wash water 

 Sides or curtains to contain splash or overspray 

 A tank or tank truck for storing spent wash water 

x Spent wash water would be hauled offsite and disposed of in a publicly owned treatment works (POTW) 

unless proper discharge permits are obtained for onsite disposal. 

It is anticipated that implementation of the final decontamination plan would be adequate to prevent the spread 

of pathogens and non-native species, and thereby maintain existing conditions. The final decontamination plan 

would be completed and approved by ODFW and NMFS before any work begins. 

EN0427151027PDX 5-13 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

5.1.2 Terminal 

The potential Terminal site effects on individual ESA-listed fish, critical habitat, existing conditions, and on 

individual ESUs not related to critical habitat are summarized in Table 3.5-12 of the Applicant-Draft BA. 

Overall, the Project would have limited negative effects that would be offset by the proposed conservation 

measures. Following successful implementation of conservation measures, the overall result of the Project is 

expected to be neutral to positive. 

5.1.2.1. Dredging 

In-water work associated with dredging would be conducted during a proposed spring to fall extension of the 

work period. This would allow disposal to occur at USEPA permitted disposal sites at the Deep Water disposal site. 

It would also minimize the effect on eulachon, while mirroring channel maintenance dredging activities, which 

have been found to not jeopardize the existence of ESA-listed salmonids. 

Other minimization techniques include use of pipeline, clamshell or hopper dredges, and turbidity monitoring. 

Compensatory mitigation at the Youngs River Mitigation Site (discussed below) is proposed to compensate for the 

small negative effects on the food web and physical habitat of juvenile salmonids, green sturgeon, and eulachon. 

Direct Lethal Take 

The following conservation measures would be implemented: 

x Hopper dredging 

 Maintain dragheads in the substrate no more than 3 feet above the river bottom when the dredge pumps 

are running. 

x Clamshell dredging 

 Clamshell dredging is not expected to cause direct mortality to adult or juvenile listed or proposed fish 

species, because the movement of the bucket is typically slow enough for fish to avoid entrainment. 

x Pipeline dredging 

 Maintain cutterhead in the substrate during dredging, and if cutterhead cleaning is needed, do not raise 

the cutterhead more than 3 feet above the river bottom when the dredge pumps are running. 

x General provisions for dredging 

 The contractor shall not release any trash, garbage, oil, grease, chemicals, or other contaminants into the 

waterway. 

 The contractor, where possible, would use or propose for use materials that may be considered 

environmentally friendly in that waste from such materials is not regulated as a hazardous waste or is not 

considered harmful to the environment. If hazardous wastes are generated, disposal shall be done in 

accordance with 40 CFR parts 260-272 and 49 CFR parts 100-177. 

 Dredging would occur in relatively deep water areas and, therefore, should “avoid” areas where 

subyearling Chinook and chum salmon are present. Dredging may also be performed with a clamshell 

bucket dredge, which is unlikely to entrain salmonids or other ESA-listed or proposed species. 

 If at any time during dredging activities, listed salmonids are observed in distress or a listed salmonid is 

killed, operations would cease and NMFS would be notified. 

Turbidity 

Hopper and pipeline dredges generally do not produce large amounts of turbidity during dredging because of the 

suction action of the dredge pump and the fact that the drag-arm or cutterhead is buried in the sediment. 

Therefore, should they be employed, fewer conservation measures would be required. The following measures 

would be employed: 

5-14 EN0427151027PDX 
SECTION 5—FISH 

x Hopper and pipeline dredging 

 The cutterhead shall remain below the surface of the river bottom at all times while the hydraulic pumps 

for the cutterhead are running. The hydraulic pumps for the cutterhead shall be placed in neutral (idling) 

before raising the cutterhead above the river bottom. Backwashing of the hydraulic-pipeline dredge 

intake line shall only occur in water depths greater than -40 feet mean lower low water. 

x Clamshell Dredging 

 BMPs used to control turbidity include regulating the bucket speed, ensuring the bucket lips are closed 

before lifting the bucket out of the water, filling the bucket to capacity to minimize water in the bucket, 

not overfilling the bucket, and modifying the bucket size and/or type, if necessary. 

x General provisions for dredging 

 Dredging and global positioning system software would be used to model the dredge prism and track 

previously dredged areas to ensure that dredging efficiency is maximized. As an incentive to the dredging 

contractor to dredge only the authorized amount, the contractor would be held accountable should they 

dredge in excess of the authorized depths. Post-dredge bathymetry surveys would be conducted to 

ensure that only the material identified for removal before dredging was removed to the authorized 

depth. 

 If a bottom dump barge is used to transport the sediment to a disposal site, no material shall be allowed 

to leak from the barge or overtop the walls. The barge would be loaded so that enough of the freeboard 

remains to allow for safe movement of the barge and its material on route to the unloading facility. 

 Regardless of the assumptions and predicted levels of increased turbidity because of dredging, dredging 

operations would be monitored while they are being conducted and would be required to meet stringent 

ODEQ regulations designed to be protective of fish and their food resources. Dredging currently occurs in 

similar and nearby environments (that is, maintenance dredging of the shipping channels and Astoria 

harbor) in compliance with these ODEQ standards. Daily monitoring and reporting of turbidity are 

required by ODEQ for dredging operations in the LCRE, and these requirements should prevent any 

detrimental effects on listed or proposed fish species or their food resources from excessive turbidity. As 

demonstrated by previous dredge operations, ODEQ’s regulatory standards can be met using modern 

dredging equipment and containment measures. Any elevation in turbidity would be localized and shortterm, quickly returning to background levels. Existing conditions would be maintained. 

Resuspension of Toxics 

Results of the dredge characterization studies indicated that no contaminants were present that exceeded 

screening levels in the Sediment Quality Guidelines for standard chemicals of concern from the Regional Sediment 

Evaluation Team (USEPA and USACE, 2006). On the basis of these results, it can be expected that existing 

conditions would be maintained as the release of toxic substances from dredged materials is expected to be 

minimal and no adverse effects are anticipated. Therefore, no conservation measures are necessary. 

Food Web Effects 

Negative food web effects were minimized through siting of the Terminal in relatively unproductive deep water. 

Dredging would directly remove some salmonid and green-sturgeon food organisms and cause a long-term shift in 

the species make-up of benthic organisms at the Terminal location. Likewise, periodic maintenance dredging at 

approximately 3-year intervals would temporarily remove benthic organisms from the berth and turning basin for 

the life of the Project. However, because benthic sampling indicated that salmonid food organisms are relatively 

scarce in the dredge prism, and similar food resources are plentiful throughout the estuary, no onsite mitigation is 

proposed. 

EN0427151027PDX 5-15 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

5.1.2.2. Dredge Disposal 

Negative effects of dredge disposal would be minimized by disposing of dredged material in previously approved 

dredged material disposal sites. Disposal at these sites has previously undergone consultation by NMFS, who 

found that operation of the disposal sites was unlikely to affect ESA-listed fish in the LCR on the population level. 

5.1.2.3. Construction of the Pier and Access Trestle 

Lighting 

As stated above, construction would be conducted during daylight hours, so construction lighting would be 

minimal. However, some lighting would be required early and late in the workday and for security during 

nighttime hours. Measures to minimize the potential for lighting effects on fish resources include use of the 

following: 

x Directional lighting facing away from the water to the extent possible 

x Screens or lighting hoods 

x Minimum light possible to safely perform the task 

x Full-cutoff light fixtures, which have no direct up-light, help eliminate glare, and are more efficient by 

directing lighting down to the intended area 

Acoustic Effects 

Avoidance and Minimization measures that are proposed include the following: 

x Observance of the in-water work period unless otherwise approved by ODFW and NMFS 

x Possible curtailment of pile driving in February 

x Vibratory hammers 

x Pile caps/hammer cushions 

x Bubble curtains 

x Noise monitoring during construction 

The in-water work period for the LCRE (November 1 to February 28) would be observed for pile driving, unless 

extended under authorization of ODFW and NMFS. Pile driving may be conducted 7 days per week during daylight 

hours, which average (sunrise to sunset) approximately 9.5 hours from November to February. Pile-driving 

activities require extensive setup, tear-down, and monitoring, which results in a maximum 4 hours per day of 

actual pile driving. Therefore, the duration of sound production would be significantly less than the total in-water 

work period, further minimizing effects on fish. NMFS has previously found that conducting pile driving during inwater work periods in the LCRE minimizes negative effects because juvenile salmon and steelhead abundance is 

low and any fish present would likely relocate away from the affected area (NMFS, 2003b). 

Because 85 percent of the fish present during the work window occur during February, reasonable attempts 

would be made to complete pile driving during the period from November 1 to January 31. As construction 

progresses, the likelihood of completing pile driving during that period would be assessed in early January. If the 

contractor feels that pile driving cannot be completed within one in-water work window, pile driving would cease 

on January 31 and resume during the in-water work period of the following year. If the contractor feels that pile 

driving can be completed by extending into the first week or two of February, pile driving would proceed to 

completion, in order to avoid remobilization to the site. By eliminating or substantially reducing the amount of 

pile driving in February this conservation measure would further reduce effects on LCR subyearling Chinook by 50 

to 85 percent. 

Driving piles with impact hammers is more sound-intensive than with vibratory hammers and would be avoided 

whenever site conditions allow. It has been shown that fish can be startled by the first few strikes of an impact 

hammer, but they may then become acclimated and remain in the area, increasing their exposure to potentially 

harmful sound levels (NMFS, 2003b). Vibratory hammers produce lower intensity sound waves compared with 

impact hammers, and fish exhibit avoidance responses to vibratory hammers without becoming acclimated 

5-16 EN0427151027PDX 
SECTION 5—FISH 

(Dolat, 1997; Knudsen et al., 1997). Therefore, vibratory hammers would be employed whenever possible. 

However, because of the depth to which the piles must be driven and the substrate conditions, it is anticipated 

that an impact hammer would be required for a substantial portion of the pile driving. To reduce the sound 

produced by pile driving, technologies to reduce sound pressure levels by approximately 20 decibels (dB) would 

be employed. These technologies would likely include some combination of bubble curtains, bubble curtains 

confined in an isolation casing, bubble curtain tree, hammer cushions, and possibly dewatered cofferdams or 

sandbag rings in shallow intertidal areas. Comprehensive descriptions of most of these technologies and their 

effectiveness in reducing sound levels are available in Illingworth and Rodkin’s Compendium of Pile-Driving Sound 

Data (2007), and IFC Jones and Stokes et al. (2009). 

The sound produced by driving any particular pile is influenced by multiple site-specific variables, including 

currents, tidal condition, water density differences caused by differing salinities, substrate types, angle of the pile, 

water temperature, bottom topography, and barriers such as shoals. Because no models exist that accurately 

incorporate the multiple variables that can affect sound propagation, the actual risk posed by pile-driving noise 

would be monitored during operations through the use of hydrophones. This is described in detail in ApplicantDraft BA Appendix 8, Oregon LNG Terminal and Oregon Pipeline Project—Underwater Noise, Propagation, 

Monitoring, and Mitigation (CH2M HILL, 2011). Potential negative effects would be minimized by adapting noise 

attenuation techniques based on measured sound pressure levels. Because achieving maximum noise attenuation 

relies on many interconnected and compounding factors, only a contractor with significant experience with pile 

driving in similar tidal systems would be selected. Because of increasing concern with noise effects on aquatic 

biota, contractors are available who are familiar with minimizing the negative effects of in-water construction. 

Adaptive management strategies could include modification of bubble curtain design, change in hammer size and 

type, change in pile cap material, or other techniques as agreed upon during consultation with NMFS, should 

further noise attenuation methods be necessary. 

A written report on hydroacoustic monitoring would be provided to NMFS following completion of the work. 

Conservation measures (creation of new shallow water habitat at the dredged material disposal site and new 

estuarine marsh habitat in Youngs Bay) are also proposed that should more than offset the one-time effects 

associated with pile driving. 

Hazardous Materials Release 

Over-water construction vessels would be fueled at existing commercial marine fuel docks. Such facilities have 

existing spill prevention systems in place that would be adequate to avoid spills or immediately address any 

accidental spills that do occur. The only potential sources of contaminants (lubricating oils and fuel) at the pier, 

mooring dolphin, and access trestle would be the construction equipment itself. 

General BMPs are proposed in Oregon LNG’s SPCC Plan (Appendix B). The SPCC meets state and federal agency 

requirements before commencing work. Proper execution of this plan and consistent implementation of BMPs 

would ensure that existing conditions are maintained. Oregon LNG would include a final SPCC Plan as part of the 

construction plan set package. 

BMPs to be employed during concrete pouring on over-water portions of the pier and access trestle are as 

follows: 

x Watertight forms 

x Watertight “walkway” around each pour that is at least 3 feet wide so that misplaced concrete is intercepted 

before entering the water 

x Preconstruction spill response plan (which is the responsibility of the contractor) 

5.1.2.4. Construction of the Onshore Facilities 

Habitat Loss 

The footprint of the shore-based facilities has been modified several times during conceptual design to avoid and 

minimize effects on important estuarine habitat. Early versions of the site plan extended into the intertidal 

EN0427151027PDX 5-17 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

mudflat habitat and had a substantially larger footprint. The proposed footprint maintains existing intertidal 

mudflat habitat and minimizes degradation (through loss of habitat) of high and low marsh habitats. 

Hydrostatic Testing 

Conservation measures employed to minimize negative effects during hydrostatic testing of the LNG storage units 

are as follows: 

x Screening the intake in accordance with NMFS intake screen criteria for avoidance of entrainment of juvenile 

salmonids. The technical memorandum titled Oregon LNG—Deluge Fire Suppression System Intake Structure

(see Applicant-Draft BA Appendix 3) illustrates the proposed screen for water withdrawals from the Columbia 

River. 

x Maintenance of the intake depth in the middle of the water column to minimize turbidity and prevent 

disturbance of the waterbody substrate 

x Maintenance of adequate stream flow rates to protect aquatic life, provide for waterbody uses, and 

downstream withdrawals of water by existing users 

x Discharging test water to the Warrenton POTW 

Hydrostatic test water withdrawal is a nonconsumptive use of water because the water would be discharged to 

the Columbia River through the Warrenton POTW. The discharge rate would be metered to accommodate the 

system capacity, as specified in applicable permits, and to mitigate any negative effects on the receiving body; 

therefore, the action is expected to maintain existing conditions. Because no significant negative effects are 

anticipated, no mitigation is proposed. 

Surface Runoff and Hazardous Materials Release 

An Erosion and Sediment Control Plan has been developed for implementation during site construction. The plan 

was developed in accordance with ODEQ’s Erosion and Sediment Control Manual (ODEQ, 2005b). This would 

ensure that (1) proper controls are in place to prevent surface water contaminants and sediments from reaching 

the estuary, and (2) current conditions are maintained. 

Concrete would be employed during construction of the onshore LNG storage tanks for soil improvement, but 

runoff would be contained with silt fences, straw bales, and other stormwater control devices. Concrete would 

not be poured during storms or extreme high tides. Concrete equipment wash-out would be conducted on upland 

areas away from drainage features and no concrete or runoff would be allowed to enter the LCRE. 

5.2 Compensatory Mitigation 

This section describes the unavoidable Project effects on federally listed and proposed fish species and critical and 

Essential Fish Habitat (EFH), and addresses the mitigation measures proposed to compensate for these effects, 

along with the rationale for the level of mitigation required for each ESU/Distinct Population Segment (DPS) 

known to occur within the Project action areas. Mitigation for nonlisted fish species is also addressed in this 

section but in somewhat less detail. Avoidance and minimization measures are discussed in Section 5.1. Stream 

bank restoration and the replacement of LWD at Pipeline crossings are considered conservation measures and not 

compensatory mitigation. 

The goal of the mitigation program is no net loss, of either individual ESUs/DPSs or habitat function. In order to 

compensate for individual fish lost to Project activities, mitigation is needed that results in increased survival of 

juveniles spawned in existing areas or the reestablishment of access to currently blocked spawning streams or 

rearing habitats. Such mitigation efforts could include riparian plantings, culvert replacement, diversion dam 

removal, return of water rights to instream use, habitat enhancement (e.g., LWD placement), restoration of tidal 

hydrology to diked estuarine wetlands, or monetary contributions to future restoration efforts. 

5-18 EN0427151027PDX 
SECTION 5—FISH 

5.2.1 Unavoidable Effects 

The primary sources of direct take of listed fish species include noise effects from pile driving and fish salvage at 

Pipeline crossings. Direct take from ballast/cooling water is expected to be insignificant. Take associated with 

salvage at Pipeline crossings would primarily involve “harassment” with a much smaller amount of direct 

mortality (Table 5-2). The methods for estimating take from these activities and the extent of the anticipated take 

are detailed in the Applicant-Draft BA. The initial modeling of take from ballast and cooling water withdrawal 

assumed 125 import ships per year, all of which would require ballast water. With the bi-directional Terminal, 

only an estimated two ships per year would be import ships requiring ballast water. Therefore, although Table 5-2 

lists salmonid take from ballast and cooling water withdrawals, the actual take from those operations is likely to 

be much less, with zero take of listed salmonids more likely than the take reported in Table 5-2. 

Other sources of direct take (including harassment), identified for the Project include dredging and ballast 

entrainment, turbidity (from dredging, dredge disposal and Pipeline construction), passage impediments (during 

Pipeline construction), and artificial light, and shading. Identified sources of indirect take include food web effects 

(due to dredging, dredge disposal, and sediment deposition during Pipeline construction), habitat alteration, and 

loss of riparian vegetation (leading to sediment inputs, increased water temperature, loss of LWD recruitment, 

and increased risk of mass failure). 

It was estimated that 0.3 percent of the area/time is available for salmonid migration. If the dredging was done 

over 1 year and conducted during the late part of the dredge season (July to October), or over two years in 

September and October, it would effectively avoid the smolt migration period entirely, eliminating the potential 

for entrainment. Dredging during the spring to fall time period would also completely avoid adult eulachon and 

would coincide only with the very latest downstream drifting juveniles during the first month of dredging. As 

discussed in the Applicant-Draft BA, neither the hydraulic dredge nor the clamshell dredge is likely to result in take 

of juveniles or adults of listed salmonid species. No species-specific estimates of take were made for any effects 

aside from ballast/cooling water withdrawal, fish salvage and pile-driving noise because there are no reliable 

methods for quantifying such take. Therefore, the amount of take from these other sources was assumed to be 

low but not entirely discountable. 

The degree to which species are susceptible to such effects as habitat loss/alteration, removal of riparian 

vegetation, etc. is dependent on their use of the affected habitats. Several species, including steelhead trout, 

sockeye salmon, and yearling (spring/summer) Chinook salmon move very quickly through the estuary and 

therefore, would be largely unaffected by the minor changes in food resources associated with deepening the 

river at the berth and turning basin. The relative degree to which species could be affected by various 

unquantified sources of take is illustrated in Table 5-3. In Table 5-3, species are rated on each effect from 1 to 3, 

with “1” being low effect and “3” being high. If a species would be unaffected by a given parameter or the effect is 

so small as to be biologically insignificant, it is given an “N/A” (not applicable) ranking. The rankings are based on 

the effects on a given species relative to the effects on other species; not the effects resulting from that 

parameter relative to other parameters. For instance, a species may rank “3” on artificial light and shading 

because it is the ESU/DPS most affected by artificial light and shading, even though the overall negative biological 

effect of artificial light or shading is minor. 

ODFW has expressed concern not only for ESA-listed salmonids, but for other species of fish in the Project action 

areas. Such species occur in the identified Project action areas (which were defined based on the documented 

presence of ESA-listed fishes), and at Pipeline crossings where ESA-listed fishes are not known to occur. Appendix 

C (Characteristics of Streams Crossed by the Pipeline) illustrates the number of Pipeline action areas and the 

number of additional stream crossing locations that are expected to contain nonlisted fish during Project 

construction (listed by 4th field Hydrologic Unit Code). Numerous other crossings are expected to be dry during 

the in-water work window and would be accomplished using open-cut methods. 

With the exception of species of concern, little site-specific information exists on native fishes in Oregon. 

Consequently it was not possible to calculate estimated direct and indirect take of these species. 

EN0427151027PDX 5-19 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

State of Oregon sensitive species that are not ESA-listed or proposed that may occur in the Project areas include 

Coastal spring Chinook salmon ESU (listed as sensitive-critical), western brook lamprey (listed as sensitivevulnerable), Pacific lamprey (listed as sensitive-vulnerable), coastal cutthroat trout (listed as sensitive-vulnerable), 

and Oregon coast winter steelhead (listed as sensitive-vulnerable). Southwest Washington Steelhead DPS occurs 

in the Clatskanie River and Lewis and Clark River systems crossed by the Pipeline, but is not listed by the state of 

Oregon as sensitive. Conservation measures and mitigation proposed for Oregon coast coho would also benefit 

coastal cutthroat trout, Coastal spring Chinook and Oregon Coast winter steelhead. 

Pacific lamprey and western brook lamprey are unlikely to be negatively affected by Terminal construction and 

operation as they do not feed in the estuary, are not present during the in-water work window, and even though 

they are not as strong swimmers as salmonids, would be of large enough size to avoid entrainment by ballast and 

cooling water intake. Therefore, negative effects on species of lamprey would be restricted to non-HDD stream 

crossings. Direct effects from stream crossings primarily would be restricted to fish salvage and temporary 

displacement from the crossing locations. Habitat enhancements designed to be beneficial to ESA-listed 

salmonids should also mitigate negative Project effects on lamprey species. 

The effects on coastal pelagic and west coast groundfish EFH species are discussed in Section 3.8 of the ApplicantDraft BA. Negative effects include larval entrainment, short-term turbidity increases during dredging, possible 

dredging entrainment and food-web effects, primarily to starry flounder and English sole. Detrital inputs from the 

mitigation area at the mouth of the Youngs River following reestablishment of tidal flow would benefit west coast 

groundfish with life history stages that utilize the LCRE. Because the negative effects on other coastal pelagic and 

west coast groundfish EFH species are relatively minor, no compensatory mitigation specific to these species is 

proposed. Measures discussed in the Applicant-Draft BA to avoid and minimize negative effects and the use of 

appropriate conservation measures during construction should be sufficient to ensure no net loss of EFH. 

For reference purposes, other fish species that likely occur in the Project action areas are identified in Tables 5-6 

and 5-7. 

5.2.2 Compensatory Strategies and Measures 

5.2.2.1. Goals and Objectives 

The goal of the mitigation program is no net loss of either individual ESUs/DPSs or habitat function. To 

compensate for unavoidable fish take or habitat loss/degradation, compensatory mitigation is needed. Oregon 

LNG is committed to providing appropriate mitigation and has identified the following six primary actions to 

mitigate for expected effects on listed and proposed fish species and their habitats: 

x Enhance approximately 140 acres of estuarine wetland habitat in Youngs Bay near the mouth of the Youngs 

River, through dike breaching and access to historical sloughs. 

x Complete a minimum of eight fish barrier removal waterbody and riparian mitigation projects and 

executing those projects through a preferred provider, such as The Freshwater Trust or similar nonprofit 

organization. 

x Complete wetland mitigation at the Nehalem River property, which would reconnect an historical oxbow that 

currently traps juvenile Oregon Coast coho (OC coho) after subsidence of high water events. 

x Remove/replace road culverts that represent complete barriers to listed salmonids. 

x Acquire and preserve approximately 1,000 acres (final area to be based on habitat effects determined during 

final engineering) in the Coast Range. Management for old-growth habitat and preservation would provide 

watershed-level ecological uplift to OC coho. 

x Contribute to the long-term protection (through either conservation lease or purchase) of mature riparian 

habitat along one or more reaches of high-quality salmonid stream habitat. 

A legal instrument is in place for Oregon LNG to use the Youngs River property site for mitigation, including an 

agreement for a long-term conservation easement as a condition of a deed restriction. There are provisions for 

5-20 EN0427151027PDX 
SECTION 5—FISH 

supporting long-term maintenance and management including a revolving or endowment fund. Oregon LNG 

would prepare a long-term management plan that would be implemented by a third-party conservator. 

Mitigation goals include the following: 

x Breach an existing levee reconnecting 140 acres of historical floodplain along the Youngs River 

x Restore anadromous fish rearing, migration, and refugia habitat in the lower Youngs Bay watershed; 

x Create a low-maintenance and self-sustaining system. 

x Maintain the safety of landowners behind the dike. 

x Create estuarine wetland habitat for federally listed salmonids and other aquatic and terrestrial species 

x Mitigation objectives include the following: 

Restoring high and low tidal marsh wetland; 

x Enhancing wetland hydrology by by sizing breaches to accommodate natural hydroperiod, tidal regime and 

peak flows; 

x Adding habitat structure by providing woody debris; 

x Reestablishment of self-sustaining native plant communities; 

x Providing access to preferred rearing and refuge habitat; 

x Providing aquatic species support by export of organic matter; and 

x Increasing the quantity and quality of off-channel juvenile salmonid habitat for Youngs River salmonid 

populations by restoring off-channel habitat more than 2.5 miles. 

5.2.2.2. Mitigation Measures 

A description of each mitigation measure is provided below. 

The proposed restoration or enhancement of approximately 140 acres of diked pasture land at the mouth of 

Youngs Bay is discussed in detail in Section 7.0, Wetlands. Salmonid habitat at this strategic site in Youngs Bay 

would be enhanced by opening the extensive area to juvenile salmonid access, restoring meandering historic 

channels within the property, and creating new channel habitat along historic tidal channels. Major access points 

for juvenile salmonids (dike breaches) into the marsh would be located where existing subtidal habitat in Youngs 

Bay is close to the existing dike. Hydrodynamic modeling conducted by Coast and Harbor Engineering determined 

that the property would become inundated twice each day at high tide, with inundation ranging from 40 percent 

to 50 percent of the time. No adverse effects on flow circulation, sediment transport, or morphology are 

expected. The site would be reconnected to tidal exchange (historical condition) and develop its own natural 

equilibrium based upon the actual tidal, riverine, and sediment processes following construction. The proximity of 

subtidal habitat is one of the factors that determine whether juvenile salmonids would utilize marsh habitat 

because they require nearby refuge during low tide conditions. After native freshwater marsh plants have 

recolonized the property, the marsh is expected to provide productive new rearing habitat for juvenile salmon 

that use Youngs Bay. In addition to providing food resources within the mitigation site, substantial quantities of 

macro detritus would be exported annually to enhance the estuarine detrital food web, which provides food 

resources to juvenile salmonids as well as a wide variety of nonlisted fish species. 

Return of previously diked tidal areas in the LCRE has been shown to provide significant benefit to juvenile 

salmonids, and such projects have high restoration priority in the LCRE. Lessons learned from previous projects in 

the LCRE (Bonneville Power Administration [BPA] and USACE, 2013) include the following: 

x Geographically larger projects provide more benefits than smaller ones. 

x Projects closer to the Columbia’s main stem, making them more accessible to fish, are better than those 

farther away. 

x Restoring remnant channels is better than excavating new ones. 

EN0427151027PDX 5-21 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

x Natural processes are preferable to engineered processes. 

The HYoungs River property and the proposed process for its restoration meet these criteria. At 140 acres, the 

Youngs RIver property is large in the context of reconnection sites; the property is close to the Columbia 

Mainstem; it has existing remnant channels that can either be restored by allowing them to reestablish naturally; 

and naturally processes would be allowed to regenerated the marsh following dike breaching. 

In addition, much of the Youngs River property site has been identified as residing in the highest conservation 

score category (meaning it is a highly desirable site for restoration) by the Youngs Bay Bottomlands Conservation 

and Restoration Plan (Lev et al., 2006). 

Tidal wetland restoration has been shown to be very effective in providing habitat for rearing juvenile salmonids. 

A 2009 review of restoration sites in the Lower Columbia River Estuary (LCRE) found that juvenile salmon either 

arrived where they had been absent or greatly increased in number (Johnson and Diefenderfer, 2010). In the 

Grays River, a tributary to the LCRE, Roegner et al. (2010) found that juvenile salmon quickly expanded into newly 

available habitat following the removal of tide gates from diked pastureland. 

Haskell and Tiffan (2011) monitored a habitat project that reestablished about 94 acres of wetland and channel 

habitats at Crims Island and estimated 11,000 to 13,000 subyearling Chinook salmon used the site following 

restoration. 

Several road culverts that represent complete migration barriers for adult salmonids would be removed or 

replaced with fish friendly culverts in selected ESUs/DPSs. Oregon LNG is committed to opening seven culverts 

before Project operation. Funding for three additional culvert removals/replacements would be provided postoperation to compensate for uncertainties in the impact analysis process or for any unanticipated effects that are 

identified through post operational monitoring. The seven culverts to be removed or replaced before construction 

would be located within the following ESUs/DPSs: 

x Coastal Coho ESU – three culverts 

x Snake River Fall-run (SRF) Chinook ESU – one culvert 

x Lower Columbia River Coho – three culverts 

These ESUs/DPSs have been identified through impact analysis as likely to be measurably impacted by 

construction or operation of the Project. The specific locations of the culverts to be removed or replaced have yet 

to be determined. Although specific culverts have not been identified for removal or replacement, the minimum 

criteria for culvert removal/replacement would be opening at least 1 mile of productive rearing and spawning 

habitat for the targeted ESUs/DPSs. Using agency-approved habitat survey methods, rearing and spawning habitat 

conditions upstream of each candidate culvert would be assessed and evaluated before final selection of culverts 

for removal/replacement. An estimation of the number of smolts produced as a result of the culvert replacements 

would be provided. Only sites that have high-quality spawning and rearing habitat for at least one mile upstream 

of the culvert would be selected. Agency agreement on the selected sites would be required. Oregon LNG would 

provide assurance to the resource agencies that it has acquired legal rights to remove or replace the culverts and 

that at least a 1-mile reach above each culvert would be protected from future degradation. 

To mitigate, in part, for the long-term loss of LWD recruitment potential at Pipeline crossings, Oregon LNG would 

purchase conservation easements on riparian conifer stands to prevent selective cutting of mature trees within 

100 feet of the stream edge. Locations would be identified within the range of each affected ESU (LCR Coho and 

Coastal Coho). Easements would be purchased on a 1:1 ratio. Based on the number of streams crossed with 

existing riparian vegetation, it is estimated that three to five miles (final mitigation to be based on habitat final 

habitat effects determined during final engineering) of riparian habitat would be protected in the Coast Range 

Additional mitigation for long-term loss of LWD recruitment and other uncertainties associated with effects at 

Pipeline crossings of perennial streams would be provided through the acquisition of a large tract or tracts in the 

Coast Range. The primary objective of funding such acquisitions is to provide compensation for upland and 

riparian effects along the Pipeline corridor. However, an added benefit could be the acquisition of property that 

contains critical habitat of OC coho. To provide additional mitigation for effects on OC coho from salvage, a relict 

5-22 EN0427151027PDX 
SECTION 5—FISH 

oxbow would be modified at the Nehalem River wetland mitigation site, adjacent to the Nehalem River, 1.7 river 

miles upstream of the HDD crossing at MP 33.5. A channel is choked with reed canary grass at the mitigation site. 

During high water events, the channel is flooded, and OC coho move into the channel. When the water recedes, 

the property owner has observed coho become stranded. Oregon LNG would remove the reed canary grass, 

enhance the current off-channel habitat, plant a mix of native vegetation, and deepen the connection with the 

Nehalem River to allow coho to exit the channel under all flow conditions. Additional detail is provided in 

Section 7.0. 

5.2.2.3. Liquefied Natural Gas Carrier Water Withdrawals 

The technical memorandum titled Oregon LNG: Probabilistic Analysis of ESA-Listed Salmonid Entrainment at 

Ballast and Cooling Water Intakes is provided in Appendix D of this Plan. The typical solution for minimizing the 

effect of water withdrawals is to place screens across the openings. NMFS and ODFW have specific criteria for 

screen mesh openings and approach velocities. Both NMFS and ODFW requested screening of the ballast and 

cooling water taken on by the liquefied natural gas carriers (LNGCs). The grates typically present on the LNGC sea 

chest intakes do not meet agency screening requirements for either mesh size or approach velocities during 

ballast water loading. 

In order to outfit LNGCs with fish screens, approvals would be required from flag states, insurance companies, 

classification societies, vessel owners, vessel managers, technical managers, and ship Captains and Chief 

Engineers before a screening device could be placed on or in close proximity to a vessel’s sea chests. While some 

portions of this approval process may be initiated before a vessel’s charter for a particular voyage, the installation 

of a screening device on a particular vessel would be subjected to a multiagency permitting process immediately 

before the installation. After extensive investigation, there is no practical way to undertake this process for the 

potential of one to two import transits per year of tankers of unknown size or origin. USCG would not permit 

affixing and device to a ship that could impede an emergency exit from port. The absence of a defined regulatory 

process or any semblance of consensus among the various interested federal and state agencies on this issue 

makes it impracticable for Oregon LNG to comply with NMFS and ODFW recommendations to screen ballast and 

cooling water. 

Even though take is expected to be less than that outlined in Appendix D (approaching zero) due to the transition 

from over 100 ships per year taking on ballast water to just two ships per year taking on ballast water, Oregon 

LNG is committed to ongoing coordination with federal and state agencies in developing strategies to minimize 

potential effects of ballast and cooling water intakes on listed species of fish. For example, the one or two import 

vessels per year, the transits that would be taking on ballast water, would mostly likely occur in the winter when 

peak demand for gas could not be met by existing pipeline sources. Winter import of gas would be past the peak 

time of salmon outmigration and therefore minimize the likelihood of entrainment in ballast water. Oregon LNG is 

proposing compensatory mitigation to offset the minimal take of fish in ballast and cooling water. The 140-acre 

Youngs River site at the mouth of the Youngs River, as well as riparian enhancement project, is proposed for 

mitigation of the ESUs most affected by ballast water withdrawals. Removal of barriers to fish passage, discussed 

in Section 5.2.2 above, is also proposed to compensate for potential entrainment of listed species of fish in ballast 

and cooling water. 

5.2.3 Rationale for the Extent of Fish-Related Compensatory Mitigation 

The degree of take resulting from certain effects is expected to be insignificant and restricted to behavioral 

modifications not leading to significantly decreased survival. Consequently, no compensatory mitigation is 

proposed for the following effects: 

x Artificial light and shading 

x Turbidity (from dredging, dredge disposal and Pipeline construction) 

x Passage impediments (during Pipeline construction) 

x Food web effects 

The following effects are dependent on species and would require mitigation: 

EN0427151027PDX 5-23 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

x Pile-driving noise 

x Fish salvage at Pipeline crossings 

x Habitat loss or alteration 

x Loss of riparian vegetation 

x Dredging entrainment (only if a hopper dredge is used) 

The severity of Project effects, and thus the need for compensatory mitigation depends, at least in part, on the 

duration of Project effects. Table 5-4 summarizes the duration of each “mitigatable” Project effect. 

As discussed in Section 3.8 of the Applicant-Draft BA, negative effects on many of the ESUs are minor, and would 

be addressed through minimization, avoidance, and BMPs. This results in the need for mitigation for only a subset 

of the ESA-listed species present in the Project action areas. Table 5-5 illustrates the proposed mitigation by 

ESU/DPS species. Proposed mitigation on a per ESU/DPS basis is discussed in Sections 5.2.3.1 through 5.2.3.11 

below. 

Mitigation efforts for the unavoidable effects are concentrated within the ranges of the specific ESUs/DPSs. 

5.2.3.1. Upper Columbia River Steelhead, Upper Willamette River Steelhead, Lower Columbia 

River Steelhead, Middle Columbia River Steelhead and Snake River Basin Steelhead 

Based on ballast water entrainment modeling, steelhead are minimally susceptible to entrainment, and therefore 

take resulting from entrainment would be essentially zero. Likewise, dredging and disposal are unlikely to entrain 

steelhead. Because steelhead move through the estuary very quickly, their utilization of the affected habitats is 

expected to be minor and the extent of unquantified take would be insignificant. Because the degree of direct and 

indirect take is expected to be so low, no compensatory mitigation is proposed. However, these DPSs could 

benefit from macro detritus production exported from the Youngs River Mitigation Site. 

5.2.3.2. Snake River Sockeye 

As with steelhead, sockeye salmon were shown not to be susceptible to ballast and cooling water entrainment, or 

dredging and disposal entrainment and therefore take due to entrainment would be essentially zero. Because 

Snake River sockeye move through the estuary very quickly, their utilization of the affected habitats is expected to 

be minor and the extent of unquantified take would be insignificant. Because the degree of direct and indirect 

take is expected to be so low, no compensatory mitigation is proposed. 

5.2.3.3. Upper Columbia River Spring-Run Chinook 

Because of their stream-type life history, spring-run Chinook, like steelhead and sockeye, are minimally 

susceptible to dredge and dredge disposal entrainment and entrainment due to ballast and cooling water 

withdrawal was estimated at much less than one juvenile salmonid. Upper Columbia River Spring-run Chinook 

move through the estuary very quickly, their utilization of the affected habitats is expected to be minor, and the 

extent of unquantified take would be insignificant. Because the degree of direct and indirect take is expected to 

be so low, no compensatory mitigation is proposed. However, this ESU could benefit from macro detritus 

production exported from the Youngs River Mitigation Site. 

5.2.3.4. Snake River Spring/Summer Chinook 

It was estimated that 0.01 – 0.07 Snake River Spring/Summer Chinook could be entrained in ballast and cooling 

water annually for an import only Terminal. This number is expected to be at least an order of magnitude lower 

for a bi-directional Terminal. Because Snake River Spring/summer Chinook are stream-type fish that migrate 

rapidly through the estuary, their utilization of the affected habitats is expected to be very minor and the extent 

of take due to habitat alteration would be insignificant. Thus, no compensatory mitigation is proposed. However, 

this ESU could benefit from macro detritus production exported from the Youngs River Mitigation Site. 

5.2.3.5. Lower Columbia River Chinook 

It was estimated that from 3.62 to 13.81 LCR Chinook juveniles could be entrained in ballast and cooling water 

annually for an import only Terminal. This number is expected to be at least an order of magnitude lower for a bidirectional Terminal. A total of 185 could potentially be present in the “harm” zone during pile driving. This is by 

5-24 EN0427151027PDX 
SECTION 5—FISH 

far the greatest effect on any ESU from pile-driving noise. In addition, LCR Chinook may be most susceptible to 

dredging entrainment due to their longer period and estuarine utilization and their small size during estuarine 

residency, but this is mitigated by the fact that they tend to be found in shallow edge habitats, and not at the 

depths to be dredged. As ocean-type fish, LCR Chinook likely utilize the LCRE for rearing more than any of the 

other ESUs and therefore would be most negatively affected by habitat alterations and other unquantified forms 

of take. LCR Chinook are also present in streams crossed by the Pipeline. However, the rivers and streams 

containing LCR Chinook habitat would be crossed using HDD methods and therefore no mitigation is proposed for 

habitat effects at the Pipeline crossing locations. 

Mitigation is proposed to compensate for the one-time loss of 185 juvenile LCR Chinook due to pile-driving noise 

and the annual loss of 4 to 14 juvenile LCR Chinook due to ballast and cooling water withdrawal. 

Proposed Mitigation 

The proposed Youngs River Mitigation Site at the mouth of the Youngs River would provide preferred shallow 

water rearing habitat for far more than 185 juvenile LCR Chinook potentially taken during construction and would 

provide rearing habitat for many more than the 14 juveniles potentially taken annually. This rearing habitat would 

be available daily throughout the year and would export organic material that would benefit ESA-listed salmonids 

that do not directly utilize the shallow water and channel habitat to be reopened at the mitigation site. 

5.2.3.6. Upper Willamette River Chinook 

It was estimated that 0.04 to 0.28 Upper Willamette River (UWR) Chinook could be entrained in ballast and 

cooling water annually for an import only Terminal. This number is expected to be at least an order of magnitude 

lower for a bi-directional Terminal. UWR Chinook have both ocean-type and stream-type life histories and could 

also be affected by habitat changes to the LCRE, although the degree of negative effects is expected to be minor. 

Because the level of annual take is expected to be so low, no mitigation is proposed beyond that provided 

primarily to the ocean-type component of this ESU at the Youngs River Mitigation Site. Enhanced rearing 

opportunities at the proposed mitigation site should more than offset the very small amount of take from ballast 

water withdrawal. 

5.2.3.7. Snake River Fall-run Chinook 

It was estimated that 0.15 to 0.56 SRF Chinook could be entrained in ballast and cooling water annually for an 

import-only Terminal. This number is expected to be at least an order of magnitude lower for a bidirectional 

Terminal. It was also estimated that three SRF Chinook could potentially be in the “harm” zone during pile driving. 

SRF Chinook historically had an ocean-type life history and could also be affected by habitat changes to the LCRE, 

although the degree of negative effects is expected to be minor, and the majority of SRF Chinook currently adopt 

a reservoir-rearing life style. 

Mitigation would be conducted for habitat effects in the LCRE and for the direct losses due to ballast/cooling 

water withdrawal and pile-driving noise. 

There is currently only one population of SRF Chinook: the Lower Snake River Mainstem population. This 

population occupies the Snake River from its confluence with the Columbia River to Hells Canyon Dam, and the 

lower reaches of the Clearwater, Imnaha, Grande Ronde, Salmon, and Tucannon Rivers (NMFS, 2005). Currently, 

natural spawning is limited to the area from the upper end of Lower Granite Reservoir to Hells Canyon Dam, the 

lower reaches of the Imnaha, Grande Ronde, Clearwater, and Tucannon Rivers, and small mainstem sections in 

the tailraces of the lower Snake River hydroelectric dams (Good et al., 2005). Dams and alterations in river flow 

and temperatures from various water uses in the upper Snake River and tributaries are the primary continuing 

threats to fall Chinook salmon range and habitat (NMFS, 2005). 

Proposed Mitigation 

Oregon LNG proposes to complete one culvert removal/replacement project within the range of SRF Chinook. 

Because the Imnaha River contains spawning habitat and is located in Oregon, culvert removal/replacement 

efforts would focus on the Imnaha River unless ODFW or other agencies/ nongovernmental entities identify higher 

priority culverts outside the Imnaha Basin. 

EN0427151027PDX 5-25 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

Redd counts in the Imnaha basin are highly variable and thus determining the likely effect of a culvert 

replacement would be very site specific. However, if suitable habitat is present (a requirement of any culvert 

replacement) and spawning adults are present downstream, it is reasonable to assume that at least one redd 

would be occur in a mile of additional spawning habitat. If egg to smolt survival ratio is assumed to be 0.104 for 

Chinook (Quinn, 2005), an additional five eggs would be required to replace the maximum of 0.56 juveniles lost 

annually. Assuming fecundity of 8,000 eggs per female (Scott and Crossman, 1973), opening up spawning habitat 

to even one additional pair of SRF Chinook would more than replace the juveniles lost to ballast and cooling water 

entrainment. 

There is also an ocean-type component of the SRF Chinook population that would benefit from increased rearing 

opportunities at the Youngs River Mitigation Site. Thus, the proposed mitigation site would compensate for any 

direct take due to ballast and cooling water entrainment or noise effects by providing additional productive 

rearing habitat. 

5.2.3.8. Lower Columbia River Coho 

It was estimated that 0.22 to 1.19 LCR coho could be entrained in ballast and cooling water annually for an import 

only Terminal. This number is expected to be at least an order of magnitude lower for a bi-directional Terminal. 

However, it is unlikely that LCR coho rear extensively in the LCRE, and therefore there would be few, if any, 

negative habitat effects in the estuary. Additionally, LCR coho are present at seven HDD stream crossings, and at 

or immediately downstream from eight flume or open-cut crossings that would use flume methods if they contain 

water at the time of construction. 

Juvenile coho density information is available from the Salmon Recovery Data Tracker website 

(http://odfwrecoverytracker.org/). Of the streams where LCR coho may be present, the Clatskanie River, Little 

Clatskanie River, Merrill Creek Tributary and Milton Creek have all been surveyed by ODFW at least once since 

1998. For these streams, the mean density of all samples was used to estimate the number of LCR coho 

potentially affected. For streams where there has been no sampling by ODFW, the mean density of all sampled 

sites over all years (0.09 juvenile salmon/square meter) was used. For the portion of habitat affected at each 

crossing that was not pool, coho density was assumed to be half that of pool habitat. It was assumed that 60 feet 

of waterbody would be isolated by cofferdams during construction and would require salvage. Stream sizes 

crossed and the number of LCR coho likely affected are provided in Table 5-6. Data on stream size were obtained 

from CH2M HILL habitat surveys. 

Using this method of estimation, 58 LCR Coho are expected within the flumed stream crossing isolation areas. Of 

course, this number could be higher or lower depending on the productivity of the year salvage occurs. Assuming 

3 percent mortality of salvaged fish, one or two would likely die as a result of electrofishing. Therefore, salvage 

would result in the loss of up to two and the harassment of 58 LCR coho. 

Based on the nature of the effects, mitigation would be conducted to offset losses due to fish salvage and reduced 

LWD recruitment potential. 

Proposed Mitigation 

The LCR Coho ESU includes 25 populations that historically existed in the Columbia River basin from the Hood 

River downstream. Eight of these populations are present in Oregon: Youngs Bay, Big Creek, Clatskanie River, 

Scappoose Creek, Clackamas River, Sandy River, Lower Gorge and Hood River/Upper Gorge. Although LCR coho 

can, and in some years do, occur in areas crossed by the Pipeline, previously, NMFS concluded that all natural 

populations outside the Sandy and Clackamas rivers were probably extinct, and since the mid-1970s there has 

been no natural reproduction in the Clatskanie River during most years (PSU, 2001). However, in recent years the 

number of coho in the Clatskanie River system has increased. In 2011, the estimated number of coho spawning in 

the Clatskanie River was 1,553, of which only 3 5 were hatchery origin (Lewis et al., 2012). Mitigation would be 

focused on the local populations in Youngs Bay, the Clatskanie River, and Scappoose Creek, all of which are at high 

risk of extinction based on a number of factors (McElhaney et al., 2007). Spatial structure has likely been reduced 

by habitat degradation, particularly in valley floor habitats of the lower basin. Habitat changes in the Columbia 

mainstem and estuary also likely have a significant effect on coho salmon (ibid). Although coho exhibit a primarily 

5-26 EN0427151027PDX 
SECTION 5—FISH 

stream-type life history, recent research indicates that so called “nomads”͸historically considered excess fry that 

moved downstream either due to disturbance (high flows) or density dependent factors͸can adapt to brackish 

water and may rear in estuarine environments before moving back into freshwater to overwinter (Koski, 2009). 

Therefore, the Youngs River Mitigation Site at the mouth of the Youngs River could provide rearing habitat for LCR 

coho “nomads.” 

To compensate for salvage losses Oregon LNG would conduct three culvert removal/replacement projects. 

Opening up one mile of habitat should more than compensate for the one-time loss from salvage. Culvert 

removal/replacement project selection would be conducted as described in Section 5.2.2. In order to compensate 

for the loss of LWD recruitment potential due to removal of riparian vegetation, Oregon LNG would purchase 

conservation easements (as described in Section 5.2.2) on a 1:1 replacement ratio. Of the flume crossings within 

the range of LCR coho, only Hackard Creek, Milton Creek, Merrill Creek and its Tributary have intact woody 

riparian zones, and therefore, purchase of riparian conservation easements would result in the long-term

protection of 300 feet of riparian vegetation. 

5.2.3.9. Oregon Coast Coho 

OC Coho do not occur in the Terminal location and would therefore only be affected by Pipeline construction and 

operation. OC coho are present at five HDD stream crossings, and at or immediately downstream from five flume 

crossings. 

The population affected is the Northern Oregon Coast, Nehalem River population, which is the fourth largest of 21 

populations. Therefore, mitigation would occur only within the geographic boundaries of the population. As 

reported in the Applicant-Draft BA, limiting factors include stream complexity and water quality. 

Salvage at the flume crossings would negatively affect some OC coho. Juvenile coho density information is 

available from the Salmon Recovery Data Tracker website (http://odfwrecoverytracker.org/). Of the streams 

where OC coho may be present, Alder Creek, Rock Creek, Clear Creek, and Cedar Creek have all been surveyed by 

ODFW at least once since 1998. For these streams, the mean density of all samples was used to estimate the 

number of OC coho potentially affected. For streams where there has been no sampling by ODFW, the mean 

density of all sampled sites over all years (0.37 juvenile salmon/square meter) was used. For the portion of habitat 

affected at each crossing that was not pool, coho density was assumed to be half that of pool habitat. It was 

assumed that 60 feet of waterbody would be isolated by cofferdams during construction and would require 

salvage. Stream sizes crossed and the number of OC coho likely affected (based on their average density) are 

displayed in Table 5-7. 

Using this method of estimation, 178 OC Coho are expected within the flumed stream crossing isolation areas. Of 

course, this number could be higher or lower depending on the productivity of the year salvage occurs. Assuming 

3 percent mortality of salvaged fish, five fish would likely die as a result of electrofishing. Therefore, salvage would 

result in the loss of up to five and the harassment of 178 OC coho.

Proposed Mitigation

In order to compensate for salvage losses, Oregon LNG would conduct three culvert removal/replacement 

projects. Culvert removal/replacement project selection would be conducted as described in Section 5.2.2. 

It is assumed that replacing three culverts would result in at least one redd within the additional mile of spawning 

habitat. If egg to smolt survival ratio is assumed to be 0.018 for coho (Quinn, 2005), an additional 7,055 eggs 

would be required to replace the 127 juveniles potentially affected by salvage. Assuming fecundity of 3,000 eggs 

per female (Scott and Crossman, 1973 – range reported to be 1,440 to 5,700 eggs per female in Washington), 

opening up spawning habitat to even three additional pairs of OC coho would replace the juveniles affected by 

salvage. Opening up spawning habitat to one pair would far exceed the projected lethal take due to salvage. 

To compensate for the loss of LWD recruitment potential due to removal of riparian vegetation, Oregon LNG 

would purchase conservation easements as previously described on a 1:1 replacement ratio. 

EN0427151027PDX 5-27 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

Of the flume and open-cut crossings within the range of OC coho, Alder Creek, Rock Creek, N. Fork Wolf Creek, 

and Clear Creek currently have riparian zones with woody vegetation. The purchase of riparian conservation 

easements to mitigate for the loss of LWD recruitment would result in the long-term protection of 300 feet of 

riparian vegetation. 

To further compensate for habitat loss and unforeseen negative effects, Oregon LNG would acquire upland 

habitat that is managed as industrial timberland with riparian and stream components in the landscape. 

Preserving upland and riparian habitat and eliminating 40- to 60-year harvest regimes on large tracts of land 

would be beneficial to stream and fish habitat. Wetland restoration at the Nehalem River property is designed to 

eliminate entrainment of OC coho in reed canary grass. 

5.2.3.10. Green sturgeon 

Because of their large size, and the timing of their estuarine residency, green sturgeon are expected to be little 

affected by any Project activities. The only potential effect would be removal and burial of a small amount of food 

organisms during dredging and dredge disposal. Green sturgeon populations are unlikely to be limited by food 

availability. No compensatory mitigation is proposed. However, there would likely be some food-web benefit to 

green sturgeon from the Youngs River Mitigation Site. 

5.2.3.11. Eulachon 

Eulachon do not occur in any of the streams to be crossed by the Pipeline, except for the HDD crossing of the 

Columbia River. The proposed spring to fall dredging period restricts the negative effects of dredging entrainment 

to a few late drifting larvae in the spring, rather than having a dredging period that completely overlaps eulachon 

upstream and downstream movements. Because eulachon do not utilize food organisms that would be affected 

by the Project, negative effects would be restricted to ballast and cooling water entrainment during the period 

when larvae are present. Because larval mortality is so high and because ballast and cooling water operations 

would affect only a very small fraction of the water in the LCRE, no effect on eulachon populations is anticipated 

and no compensatory mitigation is proposed. 

5.2.3.12. Nonlisted Species 

Pacific Lamprey 

Direct effects from stream crossings primarily would be restricted to fish salvage and temporary displacement 

from the crossing locations. Pacific lamprey salvage would be conducted using low pulse-rate electrofishing gear 

proven to be effective for lamprey ammocoete collection. Culvert replacement or removal designed to be 

beneficial to ESA-listed salmonids should also mitigate negative Project effects on lamprey species. Pacific 

lamprey are likely to be present downstream from culvert replacement or removal locations, and therefore the 

cumulative benefit to lamprey would be greater than to any listed ESU/DPS. 

Nonlisted species would be negatively affected by direct and indirect effects in the LCRE and at Pipeline crossings. 

Negative effects in the LCRE include larval entrainment, short-term turbidity increases during dredging, possible 

dredging entrainment and food-web effects. These negative effects on the LCRE would be mitigated by detrital 

inputs from the Youngs River Mitigation Site at the mouth of the Youngs River following reestablishment of tidal 

flow and the creation of shallow water habitat at the dredge disposal sites. 

“Mitigatable” effects on nonlisted species at Pipeline crossings would include fish salvage and loss of LWD 

recruitment potential. Fish salvage is difficult to quantify, as the populations of the various nonlisted species is 

effectively unknown. However, based on the relatively large and nonthreatened nature of these populations, 

losses due to salvage are expected to be biologically insignificant. To replace the lost LWD recruitment potential, 

Oregon LNG would purchase conservation easements along 3 to 5 miles (to be based on habitat effects during 

final engineering) of stream in the Coast Range as previously described. 

5.2.4 Mitigation Project Lists 

To create a positive effect on species survival and recovery, mitigation would be directed by knowledgeable local 

agency personnel and would focus on areas where the “most bang for the buck” can be achieved. ODFW issued a 

2013 list of priority passage projects. Those in the Nehalem, Lower Columbia, and Lower Columbia-Clatskanie are 

5-28 EN0427151027PDX 
SECTION 5—FISH 

listed in Table 5-8. ODFW has created a 2013 priority list that identifies priority passage projects throughout the 

state. Priorities would change as projects get completed and therefore it is impossible to identify specific projects 

until Oregon LNG receives all necessary construction authorizations. Nonetheless, Table 5-8 was constructed to 

illustrate the abundance of available projects that could be identified that achieve stated mitigation goals. 

Projects would be executed in a manner consistent with ODFW design criteria and standards. Oregon LNG is 

committed to completing a minimum of eight fish barrier removal projects. Projects would be selected relative to 

direct take of listed fish by ESU. Project selection could be accomplished by focusing on alleviating limiting factors, 

restoring those populations that are most at risk, or implementing high-priority restoration activities. Oregon LNG 

is interested in using The Freshwater Trust or a similar conservation organization in executing stream and riparian 

mitigation projects.11 The Freshwater Trust has a tool, StreamBank, that can be modified for use as the online 

tool to communicate with the Adaptive Management Team, tracking projects from design through performance 

monitoring. 

In addition to the stream projects listed in Table 5-8, one large mitigation area is proposed to mitigate the 

negative effects caused by construction and operation of the Terminal. The Youngs River Mitigation Site would 

return currently diked tidal flat to tidal hydrology on 100 acres at the mouth of the Youngs River, 

5.3 Operational Mitigation, Post-Construction Monitoring, and 

Adaptive Management 

5.3.1 Pipeline 

5.3.1.1. Stream Crossings 

Stream banks would be restored according to plans submitted in the Applicant-Draft BA. Stream bank restoration 

would be monitored after construction to ensure that bank stabilization methods employed were effective. 

Should channel subsidence, bank erosion, channel scour, or other negative long-term effects of Pipeline 

construction become apparent during post-construction monitoring, case-specific responses would be tailored to 

alleviate the specific problems identified. 

Restoration procedures would be monitored to ensure their efficiency and effectiveness. If the monitoring 

identifies any areas of erosion or ineffective revegetation, the easement would be restored in accordance with 

the existing plans unless it is determined that modified plans are needed, in which case NMFS and ODFW would 

be contacted for approval of any such modifications. Sediment barriers would be properly maintained throughout 

construction and reinstalled as necessary (such as after backfilling of the trench) until replaced by permanent 

erosion controls, or until restoration of adjacent upland areas is complete and revegetation has stabilized the 

disturbed areas. 

After initial revegetation, a monitoring plan would be implemented to ensure successful reestablishment over the 

long term. The monitoring plan has not yet been developed, but it would be completed and approved by ODFW 

and DSL before consultation begins. It would provide for a minimum of 5 years of monitoring. 

5.3.1.2. Ongoing Vegetation Removal 

Disturbances due to continued maintenance include the effects of mowing, road maintenance, and herbicide use. 

The proposed long-term revegetation plan is described in Section 3.5.3 of the Applicant-Draft BA. Revegetation 

measures would be implemented following the FERC Plan and Procedures. Maintenance mowing and vegetation 

removal would be kept to the minimum necessary to satisfy Pipeline inspection and maintenance requirements. 

Mowing 

Maintenance of the Pipeline would include periodic vegetation mowing, as necessary and in accordance with the 

FERC Plan and FERC Procedures, to allow for visual Pipeline inspections. At stream crossings, the mowed area 

would be 10 feet. This corridor of permanent maintenance would experience a change in condition. However, the 

11 Identifying The Freshwater Trust as the preferred provider for stream and riparian mitigation does not constitute an endorsement of the Project by this 

conservation organization. 

EN0427151027PDX 5-29 

 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

objective of riparian restoration, as shown in Figure 5-2, is to create a dense canopy so that, over time the effects 

from construction would be insignificant to ESA-listed fish species and their habitat. 

Access Road Maintenance 

Equipment such as “brush-hogs” that may be required for controlling vegetation would access the Pipeline on the 

existing access roads and the new road sections discussed above. The equipment would not cross streams that 

support ESA-listed fish where bridges do not currently exist. If necessary, workers would clear vegetation on foot. 

In the unlikely event that repairs are needed at Pipeline crossings, the repair access approach would be the same 

as that described for the original construction. Pipe installed using HDD methods would not be removed under 

any circumstances. If a pipe at an HDD crossing were to fail, a new pipe would be installed using HDD methods, 

rather than attempting a repair. 

Herbicide Application 

Herbicide application may be required for the control of natural vegetation or invasive species, such as Himalayan 

blackberry, in Pipeline easements. However, to preclude herbicide drift into sensitive streams or waterbodies, no 

herbicides would be applied unless absolutely necessary; and, if application becomes necessary, herbicides would 

not be applied within 100 feet of a wetland or waterbody, unless approved by appropriate federal and state 

agencies. In the event that herbicide application proves necessary, specific usage guidelines would be prepared in 

consultation with regulatory agencies to ensure that existing conditions are maintained. 

5.3.1.3. Human Access 

During regular Pipeline maintenance activities, any evidence that the public is using the corridor to access 

otherwise inaccessible areas would be noted. In the event that maintenance of the Pipeline corridor does lead to 

unintended use by the public, steps would be taken to curtail this use by concealing and blocking any trails that 

develop with logs, rootwads, or boulders; posting “no trespassing” signs; or taking other actions as appropriate. 

Existing conditions are expected to be maintained. The intent is to prevent motorized vehicles from unauthorized 

use that could create rutting that leads to erosion. Landowners may permit access for passive recreation or 

hunting. Terms of human use and use by landowners would be defined in the easements that are obtained by 

Oregon LNG. 

5.3.2 Terminal 

5.3.2.1. Long-Term Effects of Dredging 

Habitat Modification 

Construction would result in the conversion of 0.04 acre of shallow water habitat to deepwater habitat. 

Compensatory mitigation is proposed to replace this lost habitat. The ecological functions would be replaced by 

the functional uplift at the Youngs River property mitigation site. 

Hydrology 

Hydrodynamic modeling conducted by Coast & Harbor Engineering (2009a) indicates that the hydrology of the 

LCRE would not be significantly modified from its current state and therefore no conservation measures are 

necessary. 

Salinity and Temperature 

Hydrodynamic modeling indicates that the temperature and salinity of the dredge prism would not be significantly 

modified from their current state and therefore no conservation measures are necessary. 

5.3.2.2. Artificial Light 

In practice, the available methods for avoiding and minimizing light effects are constrained by the fact that 

minimum light requirements for safety and security are often set by industry standards. The minimum amount of 

light necessary to complete construction and operation tasks would be used, and lighting would be directed to 

5-30 EN0427151027PDX 
SECTION 5—FISH 

work areas in order to minimize stray light. Light sources would also be located as close as possible to critical 

instruments, such as gauges, so that additional general lighting is unnecessary. 

Lighting at the Terminal and onshore facilities would likely include a mixture of low-power fluorescent lighting and 

higher intensity security lighting. Measures to minimize the potential for lighting effects on fish resources include 

(a) the use of directional lighting facing onshore to the extent possible, (b) the use of screens or lighting hoods, (c) 

the use of motion-activated lighting, (d) the use of full-cutoff light fixtures, which have no direct uplight, help 

eliminate glare, and are more efficient by directing lighting down to the intended area only, and (e) the planting of 

vegetation along shorelines to screen open-water areas from operating lights. 

While some lighting would be required at all times on the pier and access trestle, more intense light would be 

required during unloading operations, a maximum of 2 days during those weeks when a LNGC is scheduled to 

arrive. Throughout the planning process for the Terminal, NMFS and USFWS would be consulted for input into 

light minimization and mitigation methods. 

5.3.2.3. Attraction of Avian Predators 

To prevent birds from roosting on the pilings, the tops of the pilings would be capped with cones designed to 

prevent roosting. As part of their training, facility employees would be instructed to report any observations of 

birds habitually using facility structures for roosting. During regular inspections and other activities mandated by 

safety and security requirements, a designated employee would be charged with monitoring to determine 

whether other structural components of the mooring pier or access trestle are being used as roosting sites for 

avian predators. Any signs of persistent avian roosting would be recorded, and during the first year of operations 

a report would be filed with designated ODFW and NMFS offices every 6 months. Thereafter, an annual report 

would be filed. If, after 2 years, no avian predators have been observed, reporting would cease but monitoring 

would continue. 

In the event that predatory birds begin using the platform, Terminal, or access trestle, an adaptive management plan 

would be implemented in consultation with local ODFW biologists to prevent roosting. Potential exclusion methods 

would vary, depending on the bird species involved and the specific roosting locations. Possibilities include wire 

mesh or netting to exclude birds from enclosed spaces; metal prongs, needle strips, or porcupine wires installed on 

horizontal roosting surfaces; sticky bird gel repellents; automated water spray deterrent devices; spaced overhead 

wires (similar to those described in Steuber et al., 1993); or other methods suggested by wildlife biologists. These 

methods may constitute “harassment” under the Migratory Bird Treaty Act (MBTA), and before implementation, any 

management plan would be submitted to USFWS for comment. In the unlikely event of nesting on facility structures, 

nests would be removed immediately upon discovery. If a nest becomes established and it is not discovered until 

young birds are present, the disposition of the nest would be handled in accordance with the provisions of the 

MBTA. The implementation of these preventive measures, long-term monitoring, and adaptive management plans 

are expected to ensure that existing conditions regarding avian predation of listed species are maintained. 

5.3.2.4. Shading 

The effects of shading have been minimized through conscientious siting and design of the pier and access trestle 

(e.g., situating the longest axis of the trestle in an east-west configuration, positioning of the trestle relatively high 

above the water surface) and use of grated steel decking. No additional conservation measures are proposed. 

5.3.2.5. Potential LNG Spills 

The potential for LNG spills is greatly reduced by numerous design and security measures, including multi-walled 

tanks, secondary containment of piping and onshore tanks, and leak detection equipment. If a spill were to occur, 

the effects on fish and fishery resources would be minor, localized, and short term. It is expected that existing 

conditions would be maintained. 

5.3.2.6. Hazardous Materials Release 

The SPCC Plan is found in Appendix B. Careful adherence to this plan and consistent implementation of preventive 

measures would ensure the maintenance of existing conditions. 

EN0427151027PDX 5-31 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

5.3.2.7. Maintenance dredging 

The conservation measures described above for the initial dredging of the berth and turning basin would be 

implemented during periodic maintenance dredging. 

5.3.2.8. Terminal Water Discharges 

Impervious surfaces have been reduced to the maximum degree through conscientious site design, thereby 

avoiding and minimizing the potential effects from surface runoff. Conservation measures for the stormwater and 

fire suppression testing water include the conscientious implementation of the stormwater plan. Stormwater 

would be transported to the City of Warrenton POTW. Fire suppression water would be obtained from the 

Skipanon River and would drain back into the river after each test. 

5.3.2.9. Prop Wash 

The shoreline would be monitored for the first five LNG deliveries and thereafter at least once every 90 days 

(quarterly). Should the monitoring determine that potentially damaging erosion is occurring as a result of 

operations (rather than from significant storms or natural wave action) and that stabilization measures would 

reduce erosion potential, appropriate measures would be implemented pursuant to federal and state removal/fill 

approvals. In the event that monitoring indicates shoreline erosion, then soft armoring techniques, such as 

vegetation and brush layering, would be employed as an adaptive management strategy Period bathymetric 

surveys would be conducted concurrent with surveys to establish the necessity of maintenance dredging. Should 

bathymetric surveys indicate slope erosion, adaptive management would be conducted in consultation with 

USACE. Slope armoring or disposal of dredged material could be employed to arrest any slope erosion that does 

occur. 

5.3.2.10. Introduction of Exotic or Invasive Species 

Like other cargo vessels, LNGCs would be required to follow the ballast water management rules laid out in OAR 

340-143-0001. The Oregon rules are generally congruent with USCG regulations. The ballast water program is 

administered by ODEQ, and under the rules, a vessel may discharge ballast within waters of the state only if: 

x The vessel has conducted an open ocean exchange (at least 200 nautical miles [nm] from shore and in waters 

at least 2,000 meters deep); or 

x A coastal exchange of ballast water has been performed (at least 50 nm from shore and in waters at least 200 

meters deep) for vessels on coastal voyages traveling to Oregon from a North American coastal port south of 

40°N or north of 50°N; or 

x The vessel discharges ballast water that has been treated to remove organisms in a USCG-approved manner; 

or 

x Conditions are such that without performing an exchange, the exchange would be unsafe or infeasible 

because of adverse weather, vessel design limitations, or equipment failure.

Vessels are also required to file ballast water management reports to ODEQ at least 24 hours before entry into 

the state. These measures should greatly reduce the likelihood of exotic species introductions via ballast water. 

5.3.3 Adaptive Management Summary 

As described in Sections 3.5 and 3.6 of Oregon LNG’s Applicant-Draft BA, construction and operation of the 

Project has the potential to affect listed fish through a number of direct and indirect pathways. Where direct 

effects on listed species are anticipated (i.e., mortality, harm or harassment), estimates of potential take have 

been provided in the Applicant-Draft BA. Indirect effects have also been described but are more subjective and 

have been estimated with less precision. These estimates of direct and indirect effects provide the targets 

(expected values or ranges of values) for assessment through monitoring. At the Terminal, monitoring programs 

would be developed for turbidity generated during construction dredging, maintenance dredging and dredged 

material disposal; underwater noise; propwash/bow thruster effects on shoreline structures; and for avian 

predator use of pier and trestle structures. 

5-32 EN0427151027PDX 
SECTION 5—FISH 

Also at the Terminal, monitoring would be conducted to validate modeling results for potential entrainment of 

fish in ballast and cooling water. The validation work would be conducted before commencement of Terminal 

operations. Potential methods of validation under consideration include surveying the density and location of fish 

in the water column, pumping water through a face plate with an opening similar in size as might be expected on 

an LNG tanker; or the use of a surrogate ship with intakes at depths similar to an LNG tanker. The fish survey 

approach would validate two of the main variables affecting the results of the entrainment modeling study. The 

face plate and pump mechanism would be tested by hanging the test apparatus at an appropriate depth from a 

barge. The method and timing of the validation study would be coordinated with the NMFS and ODFW before 

commencement of the study. The quantity of compensatory mitigation for direct take of fish may be adjusted, but 

no less than currently proposed, based on the results of the validation study. 

At stream crossings along the Pipeline route, construction and operation effects primarily involve effects on 

instream, bank and riparian habitat conditions rather than direct mortality, harm or harassment to listed fish 

species. The adaptive management plan for listed fish at stream crossings therefore, is described in Section 8.0, 

Stream Channels and Waterbodies. 

For the Terminal, adaptive management plans would be developed for turbidity, underwater noise, avian 

predation, prop and bow thruster wash and ballast/cooling water entrainment. The following summaries provide 

suggested adaptive management strategies for each of the Terminal effects that require monitoring: 

x Water quality effects associated with turbidity generated during dredging and dredge material disposal. 

 The monitoring requirements and location of monitoring sites downstream from dredging activities can 

vary somewhat from project to project, depending on site conditions. The following is based on typical 

requirements for maintenance dredging in the LCR and may not represent the specific requirements that 

ODEQ would specify for this Project. 

 Clamshell dredging would be used to dredge material from the berth and turning basin. Turbidity 

monitoring would be conducted throughout the hydraulic dredging operation at ODEQ-specified intervals 

(usually 4-hour intervals). A turbidity exceedance occurs when turbidity measured downcurrent (usually 

300 feet downstream) from the dredge cutter head exceeds 10 percent over background. If an 

exceedance is detected, the dredge captain would be notified and modifications to the dredging process 

would be made to reduce the turbidity-causing activity. Modifications could include reducing the rate of 

swing of the cutter head and/or reducing the rate of pumping. A second monitoring event would then 

performed two hours later. If turbidity exceeds 5 NTU over background (when background is less than 50 

NTU) during the second monitoring interval, the turbidity-causing activity would be stopped until turbidity 

levels return to background levels measured during that monitoring event. At that point, sampling would 

be continued at 4-hour intervals during active dredging operations. If continued exceedances occur, the 

dredging may be shut down until a satisfactory solution can be achieved to ensure that turbidity criteria 

are not exceeded. 

 Material dredged by clam shell dredging would be transported by barge to the dredge disposal sites and 

bottom-dumped at the disposal sites. Because of the short-term nature of the turbidity plume generated 

by the dumping process, it is not likely that adaptive management would be required for turbidity 

compliance at the disposal sites. However, bathymetric surveys would be conducted to document that 

the placement of material is located where it is supposed to be. 

x Underwater noise effects 

 Monitoring and the adaptive management strategies for reducing excessive underwater noise are 

described in Applicant-Draft BA Appendix 8, Oregon LNG Terminal and Oregon Pipeline Project—

Underwater Noise, Propagation, Monitoring, and Mitigation. 

x Avian predation 

EN0427151027PDX 5-33 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

 Avian predators such as cormorants often use piers and pilings for perching and roosting. Bird predation 

on juvenile salmonids could increase if the proposed wharf and trestle were used as a preferred perching 

or roosting site. Monitoring would be conducted to determine whether the wharf and trestle are used by 

avian predators. If a problem is identified, adaptive management would be implemented to either make 

the wharf and trestle unattractive for roosting or perching or by employing methods that would scare the 

birds from the site. The scientific literature would be reviewed to determine what techniques have been 

used successfully in the past. One or more of these techniques would be selected and tested through 

continued monitoring. If the first technique is unsuccessful, additional techniques would be tested until a 

satisfactory solution is found. 

x Prop wash and shoreline erosion 

 Hydrodynamic modeling indicated that propwash from tugboats and LNGC main propeller would not 

result in bottom scour even for the most conservative scenarios. However, LNG bow thrusters may 

potentially generate dredged slope scour for extreme docking conditions. Although it is unlikely that such 

scour would result in significant effects on turbidity or physical habitat conditions, bathymetric 

monitoring would be conducted periodically to ensure that the conclusions of the hydrodynamic 

modeling are correct. If excessive erosion is identified, adaptive management would be implemented. 

Possible solutions may include changes in the departing procedures for the LNGCs or hardening the 

substrate (e.g., placement of coarse sand) at the site of erosion. 

x Ballast and cooling water 

 Oregon LNG proposed compensatory mitigation commensurate with take modeled for entrainment in 

ballast and cooling water. As an adaptive management strategy, Oregon LNG is committed to adjusting 

the amount of mitigation that may be performed following analysis of the results of the ballast and 

cooling water study. Mitigation may include opening up additional new spawning and rearing habitat 

through culvert removals or enhancement of degraded spawning and rearing habitat. Any such mitigation 

would be directed toward increasing production of juveniles in affected ESUs and would require 

monitoring to ensure that the expected increases are realized. 

5-34 EN0427151027PDX 
SECTION 6 

Habitat Types and Vegetation 

ODFW evaluates Project effects according to ODFW’s Habitat Mitigation Policy. This policy was written to 

standardize analyses and provide goals for the mitigation of effects resulting from development actions that may 

have an effect on fish and wildlife. The state policy is modeled on USFWS Mitigation Policy (46 Fed. Reg. 7644-

7655, Jan. 23, 1981) established in accordance with the Fish and Wildlife Act of 1956 (16 United States Code [USC] 

742(a)-754), the Fish and Wildlife Coordination Act (16 USC 661-667(e)), the Watershed Protection and Flood 

Prevention Act (16 USC 1001-1009), and the National Environmental Policy Act (42 USC 4321-4347). During 

preliminary consultations with ODFW and USFWS, a verbal agreement was made to follow the guidelines in the 

state policy because compliance with the state policy would provide compliance with the federal policy. 

Washington State does not have a qualitative habitat ranking system or associated habitat mitigation policy. 

To comply with ODFW’s Habitat Mitigation Policy, Oregon LNG held several meetings between 2007 and 2008 

with ODFW, USFWS, and other stakeholders to discuss definitions of habitat types and categories. Habitat types 

and categories were initially described in Resource Report 3. For a summary of habitat type descriptions and 

categories associated with the Project, see Appendix A of this Plan. 

6.1 Onsite Mitigation 

6.1.1 Habitat Categories—Pipeline Corridor 

Wildlife habitats found at the Pipeline include upland coniferous forest, upland deciduous forest (DF), riparian, 

palustrine scrub-shrub wetland, palustrine forested wetland, palustrine emergent (PEM) wetland, stream, 

agriculture/pasture/orchard/tree farm, and developed/buildings/roads. 

Habitat by type, ODFW category, and watershed for the Project are summarized in Resource Report 3, Appendix 

3F, Wildlife Habitat Mapping of the Oregon LNG Terminal and Pipeline, as updated in Appendix C to the Pipeline 

Supplement (Oregon LNG, 2014a). 

Impacts habitat typing is not included for Washington because Washington does not have a corresponding state 

habitat mitigation policy. However, most of the effects in Cowlitz County would be to agricultural lands that would 

be restored following construction. 

Table 6-1 displays the acres estimated to be affected by Pipeline construction activities by ODFW habitat category. 

Table 6-2 displays the acres estimated to be affected by Pipeline construction activities by habitat type in Oregon. 

Route selection avoided Category 1 habitats. In both the Coast Range and Lower Columbia provinces the highest 

quality habitat that would be affected are wetland types. Discrete patches of Category 2 conifer forest were also 

avoided by route selection. Most of the conifer forest in the Coast Range that would be affected is in younger age 

classes in second-growth forest. The greatest extent of habitat (80 percent) that would be affected by Pipeline 

construction is Categories 4 and 5, which are primarily private ownerships dominated by commercial forest and 

agricultural land use. 

Riparian zone effects were avoided as much as possible through conscientious Pipeline routing and the judicious 

use of HDD methods. Where possible, important specimen trees, significant wildlife snags, and nest trees in 

riparian areas would be retained. Natural habitat features—such as logs greater than 12 inches in diameter, 

downed large wood, and rocks—would be retained. Effects on the riparian zone would be minimized by reducing 

the amount of clearing as much as possible, and by revegetating the cleared riparian areas as rapidly as possible 

following construction. 

The entire width of the construction corridor, however, does not represent the permanent effect. For the purpose 

of analysis and disclosure, the 50-foot-wide permanent easement (Zones A, B, and C) is considered to be 

permanent because vegetation may be mowed (Zone A) or maintained at a height of 15 feet (Zones A and B), or 

EN0427151027PDX 6-1 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

cleared in the unlikely event of Pipeline repair (Zone C) (Figure 5-1). The remainder of the corridor where trees 

may grow to their full potential is considered to be a temporary effect (Zone D). 

With the exception of the Compressor Station (less than 1 acre), none of the habitat effects along the Pipeline 

corridor represent a permanent loss of wildlife habitat in that the area is not being developed with impervious 

surfaces. However, there would be temporal effects on habitat cleared in Zone D and habitats in Zones A and B 

may be maintained in an early seral stage. 

6.1.2 Threatened and Endangered Plants 

Potentially suitable habitat was identified in Resource Report 3, Appendix 3G-3. Four plants listed by federal or 

state agencies as threatened or endangered or proposed for listing were identified as potentially occurring in the 

vicinity of the Project area. Of those species, three were determined to potentially occur within the Pipeline 

footprint based on evaluation of habitat requirements, elevation, and records of known occurrence. 

The office review determined that habitat may be present along the Pipeline to support four rare plant species: 

x Nelson’s checker-mallow (Sidalcea nelsoniana) 

x Water howellia (Howellia aquatilis) 

x Bradshaw’s lomatium (Lomatium bradshawii) 

Of the four rare species evaluated, three have potential habitat within the Project area. One species, Golden 

Paintbrush (Castilleja levisecta), which is on the Federal Threatened and State Endangered lists, is considered 

extirpated in Oregon and southwestern Washington. 

Because the proposed action would not likely have an adverse effect on any known individual rare plants or 

populations, and would not impact any designated critical habitat, no species-specific conservation measures are 

proposed. Oregon LNG would do preconstruction rare plant surveys in all areas where potential suitable habitat 

was identified in collaboration with the USFWS using USFWS habitat assessment and mitigation protocols in the 

year before Pipeline construction in order to encompass the complete range of bloom times for the identified 

species. 

6.1.3 Revegetation 

Clearing, grubbing, grading, and ground-disturbing activities resulting from construction of the Pipeline and 

Terminal facilities would necessitate reestablishment of vegetation. Onsite revegetation would serve to restore 

habitats and provide erosion control. Revegetation practices are addressed in the following document submittals 

supporting the preparation of the DEIS: 

x Appendix 1I in Resource Report 1, Typical Wetland and Waterbody Crossing Methods and Preliminary Sitespecific Waterbody Crossing Plans

x Stormwater Pollution Prevention Plan for Construction of the Oregon LNG Terminal and Pipeline, Including 

Erosion Prevention and Sediment Control Plan; Spill Prevention, Control, and Countermeasures Plan; and FracOut Contingency Plan (Appendix B to this Plan) 

x Section 2.3.5 and Appendix 2P of Resource Report 2 (Wetland Mitigation Plan), as updated in the December 

2014 supplemental filing (Oregon LNG, 2014b) 

x Section 3 of the Applicant-Draft BA pertaining to fisheries 

x Section(s) 3.5.1 and 3.5.3 of Resource Report 3, Fish, Wildlife, and Vegetation

x Section 7.3.3 of Resource Report 7, Soils

x Appendix 7G of Resource Report 7, FERC’s Upland Erosion Control, Revegetation, and Maintenance Plan

x Appendix 7H of Resource Report 7, the Natural Resources Conservation Service (NRCS) Oregon & Washington 

Guide for Conservation Seedings and Planting

x Appendix 7F of Resource Report 7, Agricultural Impact Mitigation Plan

6-2 EN0427151027PDX 
SECTION 6—HABITAT TYPES AND VEGETATION 

6.1.3.1. Revegetation Along the Pipeline 

After construction, the construction corridor would be revegetated and returned to the discretionary land use of 

the landowner, consistent with easement restrictions. 

Onsite measures to restore vegetation would follow the standardized methods as defined in FERC’s Upland 

Erosion Control, Revegetation, and Maintenance Plan. Refined methods would be necessary for ensuring 

successful reestablishment given the variation between the physiographic environments that the Project spans. 

For more localized specificity, the NRCS Oregon & Washington Guide for Conservation Seedings and Plantings

(NRCS, 2000) would provide guidance for developing specific revegetation plans. Revegetation in forested habitats 

would consider guidance in Oregon State University’s College of Forestry Guide to Reforestation in Oregon (Haase, 

2000). 

Oregon LNG would develop specific revegetation plans once the Project has been certified by FERC. Revegetation 

would occur in accordance with the following criteria: 

x Site and soil capability or limitations 

x Objectives of planting based on prevailing land use 

x Elevation, precipitation, and seed zone 

x Site-adapted species types and mixes 

x Planting density or seeding rate and methods 

x Amount, availability, quality, and sources of suited stock or seed 

x Timing of planting or seeding 

x Site-preparation and maintenance needs 

x Known disease, insect, or other vegetative health issues 

x Potential for success of planting and seeding application 

Additional consideration would be given to the following criteria: 

x Temporary over-winter cover and erosion control vs. final post-construction revegetation 

x Agricultural land that may be put into immediate production 

x Forest land that may be put back into immediate production 

x Vegetative conditions and land use of the private landowners the easement crosses 

x Lead time needed to produce and acquire available planting or seed stock in quantity 

x Labor force required and the sequencing within the construction and operation schedule to conduct 

revegetation and maintenance 

x Logistical complexities of transporting material onsite 

x Potential opportunities for utilizing biomass resulting from clearing the Pipeline corridor onsite as mulch or 

organic amendments 

After construction, the riparian habitat in the upland portions of the construction easements would be 

revegetated and returned to discretionary land use by the landowner, consistent with easement restrictions. 

Typically FERC recommends a 10-foot-wide mow strip centered over the Pipeline. In addition, FERC recommends 

that vegetation within 15 feet of the centerline may be maintained at a height of 15 feet. The remainder of the 

75- to 100-foot-wide construction easements would revert to vegetation cover preferences or requirements of 

the landowner. For streams that currently contain riparian cover the following revegetation scenario would be 

adopted: 

x Riparian vegetation (trees and shrubs) would be restored continuously for a distance of that matches the 

width of the current riparian buffer, except for a 10-foot-wide herbaceous strip immediately above the 

Pipeline itself. Where there is preconstruction continuous riparian cover greater than 25 feet perpendicular 

EN0427151027PDX 6-3 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

from the top of the bank, then the riparian restoration would extend out to match the riparian width of 

existing conditions up to the width from the top of the bank required by the Forest Practices Act. 

6.1.3.2. Revegetation at the Terminal 

Following construction activities at the Terminal site, pervious soil surfaces would be revegetated. Permanent 

erosion control seeding would be applied to finish grades for stabilization, and vegetation would be selected for 

compatibility with site conditions, complementarity with adjacent natural plant communities, and consistency 

with operations at the Terminal. 

Upland areas would be covered with native nitrogen-fixing seed mixture taken from the list recommended by the 

NRCS for dredge spoil stabilization. Seeded surfaces would receive balanced fertilizer and mulch to promote 

germination. Water quality bio-infiltration facilities would be surfaced with a native herbaceous mix. 

6.1.4 Invasive Vegetation 

The technical memorandum titled Oregon LNG Bidirectional Project—Invasive Vegetation, located in Appendix 3Q 

of Resource Report 3 and submitted to FERC in June 2013 (Oregon LNG, 2013), identifies some of the noxious 

weeds and invasive plant species likely to occur within the Project area. Any invasive weeds encountered in the 

course of rare plants or wetland surveys would be documented. The Oregon Department of Agriculture (ODA) and 

2013 Cowlitz County noxious weed list would be used. 

Oregon LNG would take a multifaceted approach to control the spread of invasive species in the Project action 

area in order to ensure that the 50- foot permanent easement does not serve as a nursery for noxious weeds. It is 

assumed that landowners have a vested interest in controlling the spread of noxious weeds on agricultural 

properties. 

Restoring the construction corridor by sowing native seeds would be the first step taken to reduce the likelihood 

that weeds would invade the corridor. Certified, weed-free seed would be specified in the construction contracts. 

In nonagricultural areas, trees and shrubs planted for restoration must also be native species. Mechanical 

methods such as mowing or grubbing can also be used to minimize the spread of noxious weeds, especially if 

mowing takes place before seed set. FERC procedures allow for a 10-foot-wide strip over the Pipeline to be 

maintained in a herbaceous state. Mowing or grubbing is the preferred method within riparian areas and 

wetlands. 

Herbicides would be applied where it is necessary to control noxious weeds. Only USEPA-approved herbicides 

would be applied. Given the number of streams and wetlands in the Project area, only herbicides considered safe 

for aquatic areas would be used. A list of USEPA-approved herbicides that are also approved for use in and near 

aquatic habitats is attached to this technical memorandum. Each herbicide label includes specifics in terms of how 

many feet from any fresh or estuarine habitats, including wetlands, the product can be applied. Herbicide 

application would be conducted according to the methods outlined on the label and in accordance with federal 

and state regulations. FERC does not allow use of herbicides or pesticides within 100 feet of a wetland or 

waterbody except as allowed by the appropriate state or federal land management agency. 

Additional measures would include the application of weed-free straw to exposed soils to prevent erosion. 

Construction equipment would be washed before it enters construction areas to avoid biological contamination 

from other sites. 

6.2 Compensatory Mitigation 

6.2.1 Unavoidable Impacts 

The proposed strategy for compensating for long-term unavoidable and certain temporary impacts attributable to 

the Pipeline is the acquisition of land that would be managed as a conservation easement of in-kind, in-proximity 

Category 3 and 4 habitats. No Category 1 or 2 CF habitat would be impacted. 

The 50-foot-wide stripe (Zones A, B, and C) is considered to be permanent impact area relative to the Pipeline. 

The remainder of the construction corridor constitutes a temporary loss of habitat. 

6-4 EN0427151027PDX 
SECTION 6—HABITAT TYPES AND VEGETATION 

Determination of the amount to be compensated is based on the following factors: 

x A substantial proportion of the habitats that would be impacted are located on privately owned lands, of 

which commercial forestry and agriculture are the dominant land use. 

x There is no Category 1 or 2 riparian habitat in the Lower Columbia or Coast Range provinces. 

x Category 5 and 6 habitats would not receive compensatory mitigation. 

x BP habitat Category 3 or 4 would not receive compensatory mitigation as these areas are under the 

jurisdictional maintenance of power line easements. 

x Mitigation is not needed for HDD crossings. 

x Riparian areas that require compensatory mitigation are determined as those streams with at least percent 

existing cover of woody vegetation immediately adjacent to a stream. 

x Riparian habitat would be double counted and thus receive multiple mitigation treatments: onsite 

restoration; specific riparian restoration; and inclusion in counting impacts to upland habitat. 

x Most of the forested riparian is typed as Category 3 or 4. 

x Analysis concluded that stream temperatures would not be adversely impacted by clearing, so no 

compensatory mitigation is proposed beyond that specified in riparian mitigation. 

Guidelines for compensatory mitigation are based on ratios created by Oregon LNG in cooperation with the 

agencies that administer state and federal terrestrial mitigation policies; ODFW and USFWS. Table 6-3 shows that 

Oregon LNG is generally proposing to provide compensatory mitigation for permanent impacts to habitat 

Category 3 and 4 CF and nonoak DF impacts at a 2:1 area ratio. CF and DF Category 3 and 4 habitat in temporary 

and ATWS would be provided at a 1:1 ratio. 

A number of factors were considered in establishing habitat mitigation ratios: 

x Pipeline habitat impacts are temporal in nature because the Pipeline would be buried: there would be no 

permanent impervious cover except for the Compressor Station; and wildlife would have unrestricted access 

to the same amount of area before and after construction. 

x For purposes of permitting and mitigation, Oregon LNG would count the entire 50-foot width of the 

permanent easement as a permanent impact, even though trees and shrubs would be restored. FERC allows 

shrubs within 15 feet (30 feet total) of the Pipeline to be maintained at a height of 15 feet, thereby 

maintaining most of the easement in an early seral stage of development. 

x Temporary and ATWS outside the permanent 50-foot Pipeline easement would be restored in-kind. 

Temporary and ATWS would be restored, consistent with the Oregon Forest Practices Act regarding 

reforestation. 

x Mitigation for riparian areas would be provided in the following three ways: (1) riparian shrub areas would be 

restored in all but the 10-foot mow strip of the Pipeline corridor, which exceeds FERC standards; (2) 

compensatory mitigation for riparian impacts would be provided at a 1.5:1 ratio; and (3) calculations of 

upland impacts included riparian buffers and riparian areas would be included in land acquisitions associated 

with upland compensatory mitigation. 

x Onsite restoration of the construction corridor is already an element of mitigation that would occur. 

x Mitigation measures to benefit fish would also contribute to in-kind, in-proximity riparian compensation (i.e., 

instream enhancement, fish passage restoration). 

x Coast Range compensatory mitigation would be managed and preserved for late-successional habitat 

To offset these impacts, and to mitigate for the temporal loss of habitat from Pipeline clearing, Oregon LNG 

proposes to acquire land for securing conservation easements. This approach is also intended to offset 

EN0427151027PDX 6-5 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

unavoidable and temporal impacts related to upland and riparian resources in the Coast Range and would be 

intended to benefit a suite of compensatory objectives. 

Acquisition of land for conservation purposes was identified in the Coast Range and has multiple beneficial 

Attributes that would provide Category 2, 3, and 4 upland and riparian forested habitats, and potentially some 

Category 1 habitat are as follows: 

x Existing special and unique habitats, suitable or occupied threatened and endangered habitat, older forest 

structure, aquatic and riparian habitats, and designated critical habitat; 

x High-quality functional habitat can be managed for late-successional habitat and conserved in perpetuity 

x Existing high-quality habitat 

x provide sufficient replacement commensurate with mitigation ratios 

x Larger contiguous parcels adjacent to existing conservation areas 

x Capable of enhancing adjacent existing high-quality habitat 

x Capable to provide opportunities for enhancing connectivity between existing high-quality habitats 

Oregon LNG is exploring opportunities for acquiring land in the Coast Range. Land acquisition would be finalized 

once FERC issues NGA Section 7(c) authorization for the Project. 

6.2.2 Rare Plants 

Proposed compensatory mitigation for potential impacts to rare plant species and habitats are associated with the 

construction corridor of the Project. Compensatory measures proposed are additional to BMPs, plant salvage, and 

onsite restoration described previously. 

Oregon LNG would do preconstruction rare plant surveys in all areas where potential suitable habitat was

identified in collaboration with the USFWS using USFWS habitat assessment and mitigation protocols in the year 

before Pipeline construction in order to encompass the complete range of bloom times for the identified species. 

If, during preconstruction surveys, rare plants are discovered, then additional compensatory mitigation would be 

provided at a ratio of 2:1 with a 1-acre minimum. The rationale for the 2:1 ratio is associated with the uncertainty 

that salvage and restoration would be successful. 

6.3 Operational Mitigation, Post-Construction Monitoring, and 

Adaptive Management 

6.3.1 Framework 

The framework for operational mitigation originates from Resource Report 1—General Project Description, and 

Resource Report 3, Appendix 3B—Biological Survey Reports – Aquatic Species and Habitat. The framework is 

further supported by the wetland documents contained in Appendix E of this Plan, titled Conceptual Wetland 

Restoration Monitoring Plan and Performance Standards and Review of Wetland Avoidance and Minimization 

Efforts. 

The purpose of the monitoring plan would be to confirm that performance standards are being properly followed 

and that performance standards are achieving the goals of habitat restoration and avoidance or minimization of 

adverse effects on the ecosystem. The scope of the monitoring plan scope would include the following: 

x Monitoring would evaluate the effectiveness of onsite revegetation and the management and conditions of 

acquired conservation easements. Fee-in-lieu benefits would be reported based on accomplishment and 

progress updates from advocacy groups receiving the funding. 

x Monitoring would occur at the Terminal and along the Pipeline alignment. Oregon LNG would conduct onsite 

restoration and ensure the reestablishment of vegetation in the Pipeline corridor. This includes restoring 

6-6 EN0427151027PDX 
SECTION 6—HABITAT TYPES AND VEGETATION 

disturbed areas with salvaged plant material, reseeding with native seed stock, or replanting with native 

plants. Site restoration would include a functional benefit of existing degraded plant communities through 

removal of non-native species. 

x During operations, the 30-foot-wide strip within the 50-foot-wide permanent Pipeline easement may be 

maintained. 

x The 10-foot-wide corridor may be replanted with herbaceous material. The 30-foot-wide area adjacent to the 

mow strip may be restored by replanting with shrubs. 

x Trees would be planted just outside of the 30-foot-wide maintenance corridor Seasonal monitoring would be 

conducted by a qualified biologist for a period of 10 years following final installation using the standards set 

forth in the Performance Standards. Stratified random sampling would be employed to evaluate performance 

of upland habitat. Site reviews for upland habitats would be conducted in years 1, 2, 3, 5, 7, and 10 unless 

substandard performance warrants additional management in specific locations. 

The monitoring report would contain the following information: 

x Identification of sample locations 

x Percent of planted materials surviving, classified by condition (e.g., vigorous, living, stressed) 

x Percent cover for the following four classes: native forbs and grasses; non-native forbs and grasses; shrubs 

and trees; bare ground and rock 

x Report on invasive vegetation, vandalism, dumping, wildlife damage or other conditions actually or potentially 

harmful to the restoration 

x Identification of maintenance concerns (e.g., plants needing to be replaced) 

x Representative color photographs keyed to recorded photo points 

Invasion of noxious weeds is most likely to occur during the first 3 years after construction. Therefore, it would be 

important to inspect the Pipeline and Lateral easement in the Coast Range annually for the presence of noxious 

weeds during the first 3 years after construction or until native vegetation has become established. The best time 

to survey for invasive species is in the late spring or early summer (May to early July timeframe). 

6.3.2 Performance Standards 

Performance standards for the Pipeline corridor would be developed based on the specific revegetation plan. 

Monitoring would be conducted by a qualified biologist using best professional judgment. Performance standards 

would be established based on the following goals: 

x Grass, shrub, and forest habitat diversity must be present to an extent equal to or better than preconstruction 

conditions. 

x Diversity of species is equal to or better than the goals of the revegetation plan. 

x Planting density is within 5 percent of planting plan—typically 60 to 80 percent survivorship (native species 

recruitment on the site may be included). 

x Aerial cover is increased in successive years. 

x Bare substrate represents no more than 20 percent cover after 3 years. 

x No more than 10 percent cover of invasive species. 

x If monitoring shows that performance standards are not achieved, Oregon LNG would recommend corrective 

management actions. Corrective actions may include invasive species control (typically spring/early summer); 

protective sleeves to minimize browsing damage by herbivores (typically applied spring/summer); and 

replanting (typically dormant or rainy season). Biologists would keep a written record to document the date of 

each visit, site conditions, and any corrective actions taken. 

EN0427151027PDX 6-7 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

6.3.3 Contingencies and Adaptive Management 

Quantification of habitat types and classifications was based on aerial photography conducted in 2007 for the 

portion of the Pipeline in Clatsop County and 2012 photography used for Columbia County. Since the earliest 

Pipeline construction would occur is 2015 and since logging activities are ongoing in the Coast Range, then habitat 

mapping would be out-of-date by the time construction begins. Oregon LNG would update habitat mapping 

before construction using photography that is no more than 2 years old at the time of construction. 

The proposed mitigation plan established mitigation ratios for various types and classes of habitat impacts. If the 

results of updated habitat mapping differ from the original filed with FERC, then Oregon LNG would adjust the 

quantity and quality of terrestrial mitigation to be commensurate with impacts at the time of construction. 

Surveys for rare plants were incomplete because some property owners denied access. Oregon LNG is committed 

to completing surveys for rare plants in areas with potentially suitable habitat with USFWS using USFWS habitat 

assessment and mitigation protocols. Oregon LNG would conduct these surveys in the year prior to Pipeline 

construction to encompass the complete range of bloom times for the identified species. Despite completion of 

recommended surveys, it is still possible that individuals or populations of rare plant species may be encountered 

in the course of Pipeline construction. In the event of such a discovery, a qualified botanist would be retained to 

verify identity of the plant(s) and make recommendations for addressing the situation 

Oregon LNG would implement the following adaptive management procedures if Bradshaw’s lomatium or other rare 

plants are observed within the Pipeline corridor during Project construction: 

x Work near the rare plant(s) would cease immediately; 

x A qualified botanist would verify identity and delineate the extent of the plant(s); 

x The USFWS would be notified of the discovery; and 

x All efforts would be made to avoid disturbance to discovered species, including implementation of micrositing 

to relocate the Pipeline where possible to avoid rare plant populations. 

If disturbance to the plant cannot be avoided, Oregon LNG would minimize disturbance to the maximum extent 

practicable. Possible avoidance measures may include the following: 

x Clearly delineate and fence rare plant populations; 

x Retain a qualified botanist to provide monitoring during construction; 

x Salvage plants; and 

x Implement site restoration measures immediately upon completion of any work near rare plants. 

6-8 EN0427151027PDX 
SECTION 7 

Wetlands 

The purpose of the wetland mitigation plan is to present additional information on wetlands that are located 

within the construction and permanent easements (also referred to as TWS and permanent easement) for the 

Oregon LNG Pipeline, Terminal, and related aboveground facilities. For wetland features in the Project area, 

avoidance and minimization efforts have been evaluated in the context of both area and wetland function. The 

approach to mitigation follows the USACE, DSL, Ecology, and USEPA rules and guidance with the goal of no net 

loss of wetland functions and values. The approach follows the USACE, DSL, and Ecology mitigation sequencing 

and, where compensation is required, uses a watershed approach to select available resource replacement sites 

that offer the greatest functional benefits. 

The following definitions from OAR 141-085 0510 provided the framework for developing onsite mitigation 

measures: 

x “Temporary Impacts” are adverse impacts to waters of the state that are rectified within 24 months from the 

date the impact occurred. 

x “Temporal Loss” means the loss of the functions and values of waters of this state that occurs between the 

time of the impact and the time of their replacement through compensatory mitigation. 

7.1 Onsite Mitigation 

Most of the wetlands in the study area would be avoided by the Project, with temporary and permanent impacts 

for the Terminal and Pipeline totaling approximately 174 acres of wetlands identified in the Project study area. 

7.1.1 Pipeline 

7.1.1.1. Avoidance and Minimization 

A variety of methods have been implemented during Project design to avoid and minimize impacts to wetlands. 

Examples of methods are as follows: 

x Revise layout 

x Alter the Pipeline route 

x Co-align with existing easements and rights-of-way 

x Cross wetlands at the narrowest point possible 

x Select appropriate construction techniques 

x Use HDD to avoid wetlands 

Avoidance 

Oregon LNG avoided wetlands to the greatest extent possible while still providing a Project route that is 

constructible yet with minimal impact and is acceptable to the public and regulatory agencies. 

Site visits were conducted with state and federal agency staff to view stream crossings identified as areas of 

concern during preliminary agency reviews. Micrositing adjustments were made to avoid or minimize impacts to 

wetlands or streams. For example, in a location where the Pipeline was proposed to cross a beaver marsh on the 

Clatskanie River, the route was relocated to avoid the wetland and limit impacts to a narrow stream crossing. 

During several design iterations, the Pipeline alignment and TWS were shifted away from wetlands and other 

waters, where possible reducing the acreage of impact. In addition, during construction, wetlands outside of the 

construction corridor would be demarcated in the field and identified on work plans as “no work zones” to avoid 

additional wetland impacts. 

Palustrine forest (PFO) wetlands and wetlands greater than 5.0 acres were evaluated on an individual basis and 

for purposes of analysis considered to be of high value. Further efforts to avoid or minimize permanent impacts to 

EN0427151027PDX 7-1 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

high-value wetlands consist of sorting the wetlands by their size, Cowardin class and reevaluating the potential for 

further avoidance or minimization. Of the 489 wetlands identified within the Terminal and Pipeline study area, 87 

high-value wetlands were identified. With the use of avoidance measures such as route shifts and HDD, Oregon 

LNG has avoided permanent impacts to 31 high-value wetlands and minimized impacts to 28 others. Table 7-1 

identifies high-value wetlands and the specific measures taken to further avoid and minimize permanent and 

temporary impacts. 

Large wetland areas would be avoided using the HDD construction method. More than 24 acres of high-value 

wetlands associated with the Adairs Slough the Lewis and Clark River area would be avoided using the HDD 

drilling method. 

The Pipeline was also aligned so that high-value streams could be crossed at a right angle or crossed using HDD 

techniques and avoided completely. Approximately 1.65 miles (27.5 percent) of the area from MP 0 to MP 6 

would be constructed using the HDD construction method. Most of this area is behind dikes where there is 

potential for floodplain restoration, reconnecting historic floodplain to the tidal estuary. In the HDD areas, the 

Pipeline would be deep and would not preclude surface restoration. For the remaining 4.35 miles, Oregon LNG is 

anticipating shallow groundwater. Before final design, Oregon LNG would consider where weight-coating is 

required between MP 0 and MP 6 to make the Pipeline compatible with high water tables or future restoration 

efforts. Oregon LNG would coordinate with ODFW and other stakeholders to determine whether there are areas 

with a low water table (that is, areas not otherwise requiring weight-coating) and which are priority sites for 

restoration. At this stage in planning, Oregon LNG would consider what reasonable measures could be taken to 

accommodate future wetland restoration in those drier areas identified as priorities for restoration and where 

weight-coating would not otherwise be needed. 

ATWS are associated with HDDs and perennial stream crossings. Most would be located 150 feet away from the 

top of bank of streams which exceeds FERC’s minimum standard by 100 feet. ATWS are sited less than 150 feet 

where the existing zone of forested riparian cover is less than 150 feet or where the risks of erosion are low. 

ATWS in riparian areas could have an indirect effect on streams or wetlands by increasing the risk of erosion near 

the wetland or waterbody as a result of land clearing. Extending the distance between ATWS and a wetland or 

waterbody reduces the risks of sediments eroding into the wetland or waterbody. Additionally, BMPs and erosion 

control applications outlined in the Conceptual Wetland Restoration Monitoring Plan and Performance Standards

(Appendix E) would contribute to reducing risks as well. 

Further avoidance efforts are demonstrated with the type of access road the Project proposes to use. Access to 

the temporary and permanent Pipeline easement and aboveground facilities would be through existing public and 

private roads to the extent practical. Where the Pipeline parallels existing utilities, Oregon LNG would use the 

utility maintenance access roads to the extent practical. Oregon LNG would also use a combination of existing 

paved, existing gravel, modified gravel, pasture roads, and other conveyances as appropriate. 

In general, access roads would lead to the Pipelines approximately every mile along the routes of the Oregon 

Pipeline. Of the access roads to be used for the Project, few existing road need improvements, primarily little 

more than additional gravel. None of the new access roads are proposed in areas that would cross wetlands or 

waterbodies. Existing drainage patterns and culverts would be maintained during construction. Erosion and 

sedimentation controls would be installed at the limits of the access roads where necessary. 

Oregon LNG would not construct any new permanent bridges or culverts along the Pipeline routes at stream 

crossings. During land clearing and construction streams up to about 30 feet wide would be crossed using 

temporary bridges. Equipment would be driven around wider crossings. For post-construction maintenance, 

heavy equipment would not be driven across streambeds. Equipment such as a brush-hog, which may be required 

for controlling vegetation, would access the Pipelines via the predetermined existing access roads stationed 

approximately every mile along each route. Should access by a brush-hog type of machine be impractical, clearing 

as required would be accomplished manually with hand tools. 

 

7-2 EN0427151027PDX 
SECTION 7—WETLANDS 

Minimization 

The steps involved in modifying the Pipeline alignment in order to minimize wetland impacts included the 

following: 

x HDD methods would be used to install the Pipeline many feet below the surface of wetlands and streams. 

x The Pipeline was aligned parallel or with existing road right-of-way (ROW) utility corridors, or previously 

disturbed areas. 

x The Pipeline route was aligned so that wetlands would be crossed at their narrowest point when possible. 

x The Pipeline was aligned so that streams would be crossed at a right angle to their banks in order to minimize 

negative impacts to riparian areas and streambed. 

x The width of the Pipeline ROW would be reduced to 75 feet when crossing nonagricultural wetlands to 

minimize the area of disturbance. 

x TWS would be located in areas outside of wetlands to minimize the number of acres of disturbance. 

Pipeline Routing 

In selecting the proposed route, Oregon LNG sought to minimize impacts to the environment and landowners by 

seeking to parallel other linear features to the greatest extent possible or practical. 

Minimizing impacts to wetlands did have limitations due to rugged topography, high densities of wetland areas, 

and a preference to avoid high-quality wetland areas and streams. In areas where a high density of wetlands 

existed, the Pipeline was aligned in a way that minimized impacts to most wetlands. The Pipeline route was 

sometimes aligned to cross wetlands with low functional assessment values in order to avoid wetlands with 

higher values. If the Pipeline could be microsited to avoid every wetland, this would increase the overall length of 

the Pipeline and period of active construction which could result in more permanent impacts to the landscape and 

longer periods of temporary disturbance and active construction along the Pipeline route. 

Some of the wetlands crossed by the Pipeline route are agricultural wetlands. These wetland areas may have 

wetland hydrology at least seasonally or have altered wetland hydrology (e.g., as a result of drain tiling or 

irrigation ditches), but do not have wetland or native vegetation due to farming activities where native vegetation 

is replaced by crops, and therefore provide low quality or only seasonal natural habitat for most species. 

Approximately 10.86 miles of wetlands are crossed by the Pipeline route and approximately 2.47 miles are 

agricultural wetlands. No long-term impacts to these wetlands are anticipated because, following construction, 

these areas would be restored to their preconstruction topographical and hydrological patterns, and would be 

allowed to return to their preexisting agricultural practices. This process would result in no net loss of wetland 

acreage within the Pipeline corridor. Oregon LNG would follow the construction procedures and mitigation 

measures in the FERC Procedures requiring standard upland protective measures, including workspace and 

topsoiling requirements, as they apply to these agricultural wetlands. The width of the ROW would not be 

reduced to 75 feet in agricultural wetlands. 

Construction 

Efforts would be made before, during, and after Pipeline construction to minimize the extent and duration of 

Project-related disturbances to wetland resources. For example, Oregon LNG would segregate and salvage the top 

1 foot of topsoil from nonsaturated wetland areas to be disturbed by trenching (generally coincident with the 10-

foot mow strip maintained during operation) and replace the topsoil at the finish grade after trench 

reconstruction. The duration of temporary wetland disturbance during Pipeline construction would be minimized. 

The backfilled trench would contain anti-seep plugs at appropriate intervals to prevent a French drain effect. 

Oregon LNG would make every effort to maintain a reduced construction easement width of 75 feet in wetlands, 

in accordance with the FERC Procedures. Agricultural wetlands are not included in this width restriction. During 

construction, vegetation would be manually cleared throughout the entire 75-foot construction easement. There 

EN0427151027PDX 7-3 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

would be no grubbing, and the root systems would be left intact except for an approximately 10-foot-wide area 

directly over the pipe trench. This swath would be grubbed in preparation for trenching and pipe placement. 

Work within the 75-foot construction easement would be conducted on mats where wetland soils are wet at time 

of construction to minimize impacts to vegetation and to minimize soil compaction. When constructing the 

Pipeline through the wetlands, the only soil excavation would occur at the Pipeline trench area, which would be 

about 10 feet wide, depending on the depth of the pipe. Temporary fill would occur next to the trench, where soil 

and plant materials from the trench would be stockpiled. Indirect soil disturbance, resulting in removal/fill, is 

expected to occur throughout the 75-foot-wide construction corridor from aboveground vegetation removal and 

mechanized land clearing, which could result in soil displacement. Following construction, all wetlands would be 

rehabilitated to preconstruction soil and hydrology conditions, and revegetated. 

Four construction procedures would be typically used to minimize impacts associated with construction of the 

Pipeline on water resources, as described below. 

Crossing Method 1 

This method would be used in dry wetlands where soils are stable enough to support equipment without sinking 

(for example, mineral hydric soils), or in wetlands that have already been disturbed to provide sufficient traffic 

ability. A reduced construction easement of 75 feet would be maintained and overland construction techniques 

would be used, unless exceptions are required by site conditions. Topsoil disturbed by trenching would be 

segregated, and no matting would be used if conditions are dry. 

Crossing Method 2 

This method would be used in wetlands where the soils are too wet (for example, permanently or 

semipermanently saturated or histic epipedon is present) to support Pipeline construction equipment. Timber 

mats would be used as necessary to support the construction equipment. A reduced construction easement of 75 

feet would be maintained and overland construction techniques would be used, unless a variance has been 

granted. Topsoil disturbed by trenching would not be segregated. 

Crossing Method 3 

This method is not anticipated for use during the Project. It is used in wetlands with standing water (permanent or 

semipermanently flooded) where it is necessary to use push/pull construction techniques. A construction corridor 

wide enough for only a single tractor to work on timber mats is used. The trench is dug and the pipe pulled into 

place. There are no passing or working lanes, only room for spoil on each side of the trench with the 

digging/pulling tractor in the middle. A reduced construction easement of 75 feet is maintained and overland 

construction techniques are used, unless a variance has been granted. 

Crossing Method 4 

HDD methods would be used for specialized crossings of large wetland areas. In general, directional drilling results 

in fewer adverse impacts and less turbidity than conventional excavation methods. Directional drilling is limited in 

application and dependent on critical wetland characteristics, including subsurface lithology, crossing length, 

burial depth, sediment composition, bank conditions, and access. Adverse environmental impacts that may result 

from drilling operations on waterway crossings would be related to discharge and transportation of drilling fluid; 

however, aside from turbidity effects, drilling fluid is a relatively environmentally benign substance. Mitigation of 

any adverse impact from drilling fluid would be by collection and cleanup of spilled material. 

Buffers would be clearly marked in the field during construction activities. Operation of construction equipment in 

wetlands would be limited to that needed to clear the easement, dig the trench, fabricate the pipe, install the 

pipe, backfill the trench, and restore the easement. A detailed description of other measures to minimize 

construction and post-construction maintenance effects on wetlands is provided in Section VI of the FERC 

Procedures. 

The FERC Procedures require ATWS to be located at least 50 feet outside identified wetland boundaries, except 

where the adjacent uplands consist of actively cultivated or rotated cropland or other disturbed land. 

7-4 EN0427151027PDX 
SECTION 7—WETLANDS 

During discussions with USFWS and NMFS for this Project, it was agreed that (unless approved by USFWS, NMFS, 

and ODFW) ATWS would be set back 150 feet from wetlands and streams. Oregon LNG has made extensive efforts 

to locate the ATWS at least 50 feet from wetlands and other waterbodies. In addition, overnight parking of 

vehicles, storage of fuels and other hazardous materials, and refueling activities would take place no closer than 

150 feet from a wetland or a stream, unless full containment of potential contaminants is provided. Under certain 

clearly defined conditions, and subject to agency approval, ATWS may be placed closer to wetlands or 

waterbodies where the ATWS placement would not increase impacts to streams or fish habitat. BMPs and erosion 

control applications outlined in the Wetland Restoration Plan would be implemented to reduce risk of sediments 

entering the waterbodies. 

7.1.1.2. Best Management Practices and Wetland Rehabilitation 

The construction schedule would consider the recommended ODFW in-water work periods unless an extension of 

those work periods is granted. The start and end dates are variable depending on the region and the stream; start 

dates can begin as early as June 1 and end dates are as late as October 15. 

The construction schedule would also consider biological patterns to minimize potential impacts to species and 

habitats. In accordance with the FERC Procedures, restoration and monitoring of wetland crossings would be 

conducted to help ensure successful wetland revegetation. Oregon LNG would abide by additional wetland 

construction methods, monitoring, and restoration as required by the FERC Procedures. 

The rehabilitation/restoration plan is proposed for temporary wetland impact acreage. Rehabilitation of the 

Pipeline construction corridors to preconstruction wetland conditions would include the following activities: 

x Work in the Lower Columbia River Estuary would be timed to take advantage of seasonal low and high tides. 

x A cover crop (in nonagricultural areas) would be planted and erosion control implemented before the rainy 

season following land clearing. 

x Riparian areas would be cleared the same year in which the Pipelines are constructed. Riparian areas would 

be kept intact when land is cleared a year in advance of construction. 

x Work timing would be coordinated with the biological needs of special-status species. For example, no 

harvesting of trees would occur until migratory bird species have completed nesting activities, after August 15 

and before March 15, unless biological surveys indicate the absence of nesting. 

x Where the Pipeline trench may drain a wetland (steep slopes), clay plugs would be constructed or the trench 

bottom would be sealed as necessary to maintain the original wetland hydrology. 

x Oregon LNG would segregate the topsoil up to 1 foot deep over the area disturbed by trenching in wetlands 

where hydrologic conditions permit this practice, and this topsoil would be placed in the trench at the end of 

backfilling of trench spoils once the trench is backfilled. 

For the trench excavation area, natural revegetation with native species would be encouraged by providing 

suitable soil conditions and applying salvaged topsoil from cleared trench area, except that weed-infested topsoil 

would not be reapplied. Proper topsoil stockpile procedures (aeration, moisture, shading) would ensure that 

viable plant propagation sources (e.g., viable seeds, rhizomes, roots, spores, fungi) are replaced following 

construction in the trench area. Temporary erosion control seeding with sterile wheat grass or other accepted 

seed mixes would be used to stabilize soil until natural revegetation occurs. Revegetation efforts would include 

the following measures: 

x Vegetation clearing would take advantage of the dry season. 

x Revegetation would focus on the cool, rainy season. 

x Permanent erosion control would consist of seeding with native wetland species, and seedbed preparation 

where soils are displaced or compacted by equipment. 

EN0427151027PDX 7-5 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

The wetland areas temporarily impacted by vegetation clearing, equipment traffic, and material storage outside 

the trench area would be rehabilitated by reestablishing wetland vegetation from seedbank germination and 

vegetative propagation via resprouting of live roots and propagules left intact and protected during construction. 

Sterile wheat grass cover would be used to temporarily stabilize soil until natural germination occurs. In some 

instances, a permanent native wetland seed mix would be applied to ensure adequate cover of the site by 

desirable species. The seeding and planting mixtures recommended by NRCS for Oregon would be used as a basis 

for developing a Project-specific seed mixture. Measures would be taken to control the spread of noxious weeds. 

For natural regeneration of temporarily cleared forested wetlands outside the 10-foot-wide maintenance 

corridor, the following actions would be taken: 

x To reduce injury to viable roots and shoots, construction traffic would be managed to reduce areas affected 

by soil compaction and rutting; supported by mats, pallets, or other ground pressure dissipaters in moist or 

wet soils; and characterized by low ground pressure equipment where terrain allows. 

x Woody debris, chipped woody vegetation, and unmerchantable logs greater than 12 inches would be salvaged 

for surface application outside the 10-foot-wide maintenance corridor where existing downed wood is 

insufficient. 

x Various site specific seed mixes would be used for temporary erosion control seeding to avoid conflicts with 

the permanent cover. 

x Where compatible with preconstruction woody species, seeds of native woody wetland species would be 

incorporated into permanent erosion control seed mixes. 

x If annual monitoring during 3 years after construction indicates that disturbed wetland areas are not 

successfully revegetating with desirable woody plants, supplemental planting would be undertaken. 

Restoration and cleanup would begin after the trench is backfilled. The disturbed areas would be graded as closely 

as practical to preconstruction contours. During cleanup, trash that remains in the easement would be removed 

and disposed of in approved areas in accordance with applicable regulations. Organic refuse unsuitable for 

spreading over the easement would be disposed of at an authorized facility. Disturbed areas would be restored as 

closely as practical to their original condition, permanent erosion control measures would be installed as 

appropriate, and revegetation measures would be implemented. In addition, line markers would be installed 

directly above the buried Pipelines in accordance with 49 CFR 192, Transportation of Natural and Other Gas by 

Pipeline: Minimum Federal Safety Standards, Subpart M, “Maintenance,” 192.707. 

7.1.2 Terminal 

The Terminal’s location was selected to minimize the Project’s environmental impacts, including high-value 

wetlands, air emissions, water usage, and potential fisheries resources impacts, by siting the Terminal on land that 

is appropriately zoned for industrial use, is on an existing deep-water channel, and is relatively close to major 

natural gas pipeline networks and markets. 

The initial conceptual design for the Terminal was a layout in a square that would have extended the area of fill 

into the low marsh, mudflats, and shallow subtidal areas on the east side of the northern end of the East Bank 

Skipanon Peninsula (ESP). Subsequent layouts were designed along a north-south axis to avoid these high-value 

habitats. Estuarine wetlands are considered high-quality wetlands because of their importance to salmonids. 

There is greater nutrient contribution to the estuary from high and low marshes than from interior palustrine 

wetlands. Modifications to the site layout were made in the 2012 to accommodate the change in the project 

description from primarily import to primarily export of natural gas. 

Principles used in siting the Terminal facilities included the following: 

x Avoiding impacts to low marsh and shallow subtidal habitats that have high functional value for salmon 

x Maximizing the use of nonwetland area 

x Avoiding estuarine wetlands would be more important than avoiding freshwater wetlands 

7-6 EN0427151027PDX 
SECTION 7—WETLANDS 

x Maximize use of existing roads (Northeast King Avenue) to access the Terminal site 

x Demarcating wetlands outside of the construction corridor in the field and identified on work plans as “no 

work zones” to avoid additional wetland impacts 

The main goal in development of the proposed layout was to minimize wetland impacts to the higher quality 

wetland. The proposed layout was also developed to balance the excavation volume with the fill volume such that 

imported fill material would be minimized. Estuarine wetlands are higher quality in terms of providing functions 

for salmonids because of surface water connectivity. There is greater nutrient contribution from estuarine 

wetlands than from interior palustrine wetlands. The proposed layout has less impact to the estuarine wetland 

type than the palustrine wetland type. 

The proposed layout for the Project has been compressed as much as possible to avoid and minimize wetland 

impact, while at the same time remaining consistent with the Export Project Purpose and Need for providing 

bidirectional capability. 

7.2 Compensatory Mitigation 

Oregon LNG intends to avoid, minimize, and, where necessary, compensate for disturbance to wetlands 

associated with the construction and operation of the Project. For all long-term temporary construction impacts, 

mitigation would occur onsite through restoration of the areas to PEM, PSS, or PFO. For permanent Cowardin 

class changes that would occur to palustrine forest in the 30-foot-wide permanent easement (Areas A and B on 

Figure 7-1) and to PSS in the 10-foot mow strip (Area A on Figure 7-1) and permanent Terminal impacts, Oregon 

LNG intends to provide offsite compensatory mitigation. 

Approximately 391 acres of wetlands were identified in the entire Project area. The Project estimates 

approximately 150 acres of temporary and permanent wetland impacts. Permanent unavoidable impacts consist 

of approximately 57 acres of wetlands, inclusive of the Terminal and associated supporting infrastructure. 

Avoidance of some wetlands was not feasible because of the following Project constraints: 

x Large wetland complexes spanning several acres not entirely avoidable 

x HDD method not feasible for small wetlands due to greater overall environmental impacts 

x Orientation of sensitive stream crossings prevented complete avoidance of adjacent wetlands 

x Preference to use existing utility and road ROW resulted in greater impacts to wetlands 

7.2.1 Pipeline 

Construction of the Pipeline would include ground-disturbing activities for installation of the Pipeline itself, 

associated aboveground facilities, and construction staging/storage areas. Construction of the Pipeline would 

result in short-term disturbances to wetland hydrology, water quality, and, where new permanent easement is 

required, long-term disturbance in the form of functional conversion of forested wetlands to emergent wetlands 

within the 10-foot maintenance corridor. Impacts to wetlands associated with the Pipeline construction and 

operation were quantified based on the proposed activity in temporary construction and permanent operation 

zones. 

Of the approximate 276 acres of wetlands identified within the Pipeline study area, approximately 23 acres of 

permanent and 85 acres of temporary impacts would result from activities associated with construction and 

operation of the Pipeline. 

7.2.1.1. Permanent Impacts 

During operations, a 30-foot-wide area within the 50-foot-wide permanent easement would be routinely 

maintained at a maximum frequency of once every 3 years. This area would be maintained free of trees over 15 

feet tall. Within the 30-foot-wide maintained area and centered over the Pipeline would be a 10-foot-wide mow 

strip. The 10-foot-wide mow strip would be maintained annually in a nonwoody or treed condition to allow lineof-sight for aerial surveys. Figure 7-1 and Table 7-2 show the 75-foot construction and 50-foot permanent 

EN0427151027PDX 7-7 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

easements and the construction and maintenance activities that would occur in each. This table also shows the 

type of impacts to wetlands and the type of wetland class conversion that would occur. 

The acreage extent of permanent impacts to wetlands and the compensatory offset is displayed in Table ES-2. 

Mitigation ratios are based on ODFW Habitat Categories. 

7.2.1.2. Temporary Impacts 

The alignment of the main Pipeline would temporarily impact approximately 85 acres of jurisdictional wetlands. 

When constructing the Pipeline through the wetlands, the only soil excavation would occur at the Pipeline trench 

area, which would be about 10 feet wide, depending on depth of pipe. Temporary fill would occur next to the 

trench where soil and plant materials from the trench would be stockpiled. 

During construction, vegetation would be cleared manually throughout the entire 75-foot construction easement 

and use of heavy equipment would be minimized. There would be no grubbing and the root systems would be left 

intact except for the 10-foot-wide area directly over the pipe trench. This swath would be grubbed in preparation 

for trenching and pipe placement. Work within the 75-foot construction right-of way would be conducted on mats 

to minimize soil compaction and minimize impacts to vegetation. Following construction, wetlands would be 

rehabilitated to preconstruction soil and hydrology conditions, and revegetated. 

As a result, the following assessment of Project construction impacts can be made for the 75-foot-wide 

construction corridor: 

x Impacts to wetlands would be short-term and temporary throughout the construction easement (e.g., 

reestablishment of vegetation beginning within days or weeks of cessation of site work), with the exception of 

the trench excavation area. 

x In the estimated 10-foot-wide trench area, impacts would be longer-term and temporary and herbaceous 

wetlands would recover more slowly as a result of clearing, grubbing, and soil excavation. 

7.2.2 Terminal 

The land-based portion of the Terminal includes the Terminal footprint, Terminal access road, and new water 

supply and wastewater disposal pipelines to connect to City of Warrenton water and wastewater systems.

Construction of the Terminal and pier, would affect estuarine and nontidal wetlands in the area, resulting in both 

temporary and permanent impacts to wetlands. Siting of the proposed Terminal has gone through several 

iterations in an effort to avoid impacts to high-quality wetlands. 

Total wetland impacts from construction of the Terminal and associated facilities would be approximately 38.07 

acres, with 34.92 acres of permanent impacts and 3.15 acres of temporary impacts. 

7.2.2.1. Permanent Impacts 

Impacts to wetlands associated with the Terminal and related facilities were considered permanent if they were in 

the permanent facility or removal/fill footprint. For permanent Terminal impacts, Oregon LNG intends to propose 

offsite compensatory mitigation. 

7.2.2.2. Temporary Impacts 

Impacts to wetlands associated with the Terminal and related facilities were considered temporary if they were 

within the area disturbed by construction but outside the permanent facility and removal/fill footprint. In 

accordance with state and federal regulatory requirements, Oregon LNG would offset temporary loss of wetland 

function and values by restoring functions to the impacted area upon completion. Compensation for temporary 

impacts to wetlands as a result of Terminal construction will be mitigated through onsite wetland rehabilitation. 

To the extent feasible, rehabilitation of the Pipeline construction corridors to preconstruction wetland conditions 

will be undertaken. This will involve topsoil segregation and replacement, topsoil management to maintain 

viability of seedbank and vegetative propagules, reconstruction of grades, permanent erosion control seeding 

with native wetland species, and seedbed preparation where soils are displaced or compacted by equipment. 

7-8 EN0427151027PDX 
SECTION 7—WETLANDS 

7.2.3 Mitigation Banking and In-lieu or Fee-in-lieu Payment Strategy 

Compensation for wetland impacts at the Terminal will include both In-Lieu Fee bank credits and offsite, in- kind 

mitigation. DSL currently has mitigation credits in the Lower Columbia In-Lieu Fee bank. The Project proposes 

utilizing 1.9 credits for Terminal impacts. The remaining 33.02 acres of impacts from the Terminal will be 

compensated through an in-kind, offsite Youngs River mitigation site described in Section 7.2.4 below and in 

Section 5.2.2.2 above. 

For the Lower Columbia–Clatskanie River basin in Washington, wetland mitigation would consist of purchase of 

credits in the Columbia River Wetland Mitigation Bank or another mitigation bank that may be in service prior to 

construction. 

7.2.4 Land Acquisition and Conservation Easement Strategy 

7.2.4.1. Lower Columbia River Basin 

For impacts associated with the Terminal construction and operation, including pile-driving noise effects, ballast 

and cooling water withdrawals, dredging and dredge material disposal, Oregon LNG would enhance 

approximately 140 acres of diked pasture land at the mouth of the Youngs River where historical tidal 

floodplain would be reconnected to the estuary (see Figure 7-2). The riverside parcel is currently used for 

grazing and protected from flooding by a levee. Oregon LNG intends to breach the levee to create estuarine 

wetland habitat and provide access for federally listed salmonids and other aquatic species. Salmonid and 

other fish habitat at this strategic site at the mouth of the Youngs River would be enhanced by restoring 

meandering historic channels within the property. To ensure that juvenile salmonids can utilize newly created 

marsh habitat during low tide conditions, Oregon LNG would create three breaches in areas that facilitate 

connection to existing subtidal habitat in Youngs River. The site would be reconnected to tidal exchange 

(historical condition) and develop its own natural equilibrium based upon the actual tidal, riverine, and sediment 

processes following construction. The proximity of subtidal habitat is one of the factors that determine whether 

juvenile salmonids would utilize marsh habitat because they require nearby refuge during low tide conditions. 

After native freshwater marsh plants have recolonized the property, the marsh is expected to provide productive 

new rearing habitat for juvenile salmon that use Youngs Bay, and possibly for prey items for green sturgeon. 

A legal instrument is in place for Oregon LNG to use the Youngs Riverproperty site for mitigation, including an 

agreement for a long-term conservation easement as a condition of a deed. There are provisions for supporting 

long-term maintenance and management including a revolving or endowment fund. Oregon LNG would prepare 

a long-term management plan that would be implemented by a third-party conservator. 

Mitigation goals include the following: 

x Breaching an existing levee reconnecting 140 acres of historical floodplain along the Youngs River 

x Restorating anadromous fish rearing, migration, and refugia habitat in the lower Youngs Bay watershed 

x Creating a low-maintenance and self-sustaining system 

x Maintaining the safety of landowners behind the dike 

x Creating estuarine wetland habitat for federally listed salmonids and other aquatic and terrestrial 

species 

Mitigation objectives include the following: 

x Restoring high and low tidal marsh wetland 

x Enhancing wetland hydrology by sizing breaches to accommodate natural hydroperiod, tidal regime and peak 

flows 

x Adding habitat structure by providing woody debris 

x Reestablishment of self-sustaining native plant communities 

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APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

x Providing access to preferred rearing and refuge habitat 

x Providing aquatic species support by export of organic matter 

x Increasing the quantity and quality of off-channel juvenile salmonid habitat for Youngs River salmonid 

populations by restoring more than 2.5 miles of off-channels habitat 

7.2.4.2. Nehalem and Lower Willamette River Basin 

To offset unavoidable permanent impacts to approximately 11.26 acres of Habitat Category 2 and 3 associated 

with the Pipeline segments in the Nehalem and Lower Willamette River basin, Oregon LNG is working with a 

private landowner to restore and enhance 45 acres of floodplain adjacent to the Nehalem River (see Figure 7-3). 

The property contains a large remnant river oxbow with an outlet to the Nehalem River. Much of the property 

consists of a monoculture of reed canary grass used for grazing cattle. A ratio of 3:1 for enhancement and 1:5:1 of 

wetland creation is proposed. Mitigation objectives for the site include the following: 

x Salmon restoration and enhancement. Salmon fry access the site via the remnant oxbow tributary during 

annual freshets and become trapped within the reed canary grass. Mitigation objectives include the 

establishment of slow-water salmonid refugia that contains high quality habitat. Site modifications would 

restore necessary contours and reestablish native vegetation. 

x Floodplain enhancement and forest restoration. The floodplain is mowed and grazed annually. Mitigation 

would create additional wetlands within the floodplain. The wetlands would retain floodwater and slow the 

velocity of the water flowing back into the river as floodwaters recede. Floodplain forest would be restored by 

replanting native species. This site has been identified as the western extent of Oregon ash plant assemblage. 

The site currently has small remnant patches of ash. Mitigation goals are to expand and restore the floodplain 

forest and scrub-shrub communities. 

7.3 Operational Mitigation, Post-Construction Monitoring, and 

Adaptive Management 

Oregon LNG was unable to delineate wetlands on properties where access was denied during the planning and 

permitting phase of the Project. Once Oregon LNG gains right-of-entry, then wetland delineations would be 

completed. Federal and state permit applications took a conservative approach in determining the amount of 

permanent impacts to wetlands by counting National Wetland Inventory wetlands and areas with hydric soils as 

jurisdictional wetlands for the purposes of determining the mitigation requirements. 

Oregon LNG would recalculate the area of jurisdictional wetlands that would be impacted and recalculate the 

amount of wetland mitigation that is necessary upon completion of the final field delineated surveys. In the 

unlikely event that additional mitigation is needed, Oregon LNG would provide it, consistent with the conceptual 

plan (e.g., purchasing credits in approved mitigation banks). However, compensatory mitigation sites are 

oversized to accommodate additional unanticipated impacts to wetlands. 

If route changes occur during construction, then biologists would be deployed immediately to determine if 

wetlands are present in the area of the route change. If present, then wetlands would be delineated and reported 

to DSL and USACE within 48 hours of discovery. Impacts would be evaluated to determine if additional mitigation 

would be necessary. 

7.3.1 Framework 

The framework for operational mitigation is documented in the technical memorandums in Appendix E titled 

Conceptual Wetland Restoration Monitoring Plan and Performance Standards and Review of Wetland Avoidance 

and Minimization Efforts. 

Seasonal monitoring of wetland restoration along the Pipeline would be conducted by a qualified wetland 

scientist for a period of ten years following final installation using the standards set forth in the Performance 

Standards. 

7-10 EN0427151027PDX 
SECTION 7—WETLANDS 

The monitoring report would consist of the following: 

x Vegetation transect (or transects depending on size of wetlands) that detail herb, shrub, and tree aerial cover 

at radii of 3 feet, 15 feet, and 30 feet, respectively 

x Percent of planted materials surviving, classified by condition (e.g., vigorous, living, stressed) 

x Percent cover for the following four classes: native forbs and grasses; non-native forbs and grasses; shrubs 

and trees; bare ground and rock 

x Documentation of invasive vegetation, vandalism, dumping, wildlife damage, or other conditions actually or 

potentially harmful to restoration 

x Maintenance concerns (e.g., plants need to be replaced) 

x Color photographs that show the restoration site, taken from a fixed photo point (or points depending on size 

of wetland) drawn on a map of the restoration area, keyed to lines of sight from those photo points 

x Monitoring reports submitted to the permitting agencies (DSL and USACE) 

Table 7-3 summarizes the restoration monitoring schedule. 

7.3.2 Performance Standards 

The proposed performance standards would be evaluated by a qualified biologist using best professional 

judgment. Table 7-4 summarizes the performance standards that would be used to evaluate success of the 

planting according to established landscape standards for wetland vegetation communities in the appropriate 

zones (Franklin and Dyrness, 1973) west of the Cascade Crest. 

If any monitoring report shows that performance standards are not achieved, Oregon LNG would recommend 

corrective management actions. Wetlands with substandard performance would be monitored annually until 

there are two successive years demonstrating successful performance. Corrective actions may include invasive 

species control (typically spring/early summer); protective sleeves to minimize browsing damage by herbivores 

(typically applied spring/summer); and replanting (typically dormant or rainy season). Biologists would keep a 

written record to document the date of each visit, site conditions, and any corrective actions taken. 

EN0427151027PDX 7-11 
SECTION 8 

Stream Channels and Waterbodies 

Mitigation measures for stream channels and waterbodies are derived from Section 3.6 and Appendix D of the 

Applicant-Draft BA, Appendix 2B in Resource Report 2, and Section 3.5.1 in Resource Report 3. Anticipated 

construction-related impacts and specific conservation methods including avoidance, minimization, and 

mitigation efforts are addressed in Resource Report 2; in the SWPPP (Appendix B in this Plan); in the Wetland 

Mitigation Plan (Appendix 2P of Resource Report 2, as revised in the supplemental filing [Oregon LNG, 2014b]); 

and in Resource Reports 1 and 7. 

Because the Pipeline crossings of stream channels and waterbodies would occur in waters owned by the state of 

Oregon, actions are under the jurisdiction of DSL OARs “Governing the Issuance and Enforcement of Removal-Fill 

Authorizations within Waters of Oregon Including Wetlands” (OAR 141-085). Crossings of stream channels and 

waterbodies also occur in the state of Washington. The Revised Code of Washington (RCW) and Washington 

Administrative Code (WAC) are the bodies of law governing the state’s associated water quality regulations. The 

USACE provides Ecology with the jurisdictional authority to regulate the filling and removal of material in the 

waters of the state, including wetlands, under the applicable WAC 173-201A. The WDFW administers hydraulic 

code for the protection of freshwater habitat. 

In general, avoidance, minimization, and mitigation of impacts to waterbodies during Pipeline construction would 

follow the FERC Procedures. Pipeline stream crossings would also require ODFW fish passage approval per Oregon 

Revised Statute 509.580-910, and WDFW Hydraulic Project Approval per RCW Chapter 77.55. Oregon LNG would 

consult with DSL, ODFW, Ecology, and WDFW regarding stream crossing methods and timing. DSL and Ecology 

place the highest priority on avoidance and minimization of impacts. Oregon LNG has avoided stream crossings 

wherever possible through careful Pipeline siting and design that minimizes impacts. 

8.1 Onsite Mitigation 

Onsite mitigation measures for stream channels are derived from the FERC Procedures; and from stream crossing 

drawings, supplemental descriptions, and stream bank restoration plans in Appendix 6A of the Applicant-Draft BA. 

Mitigation measures address potential effects on channel morphology and water quality. 

8.1.1 Stream Channel Crossings 

Stream crossings would be conducted in compliance with the FERC Plan and Procedures for Pipeline stream 

crossings. The crossings would be monitored after construction to ensure that bank stabilization methods 

employed were effective in abating increased sedimentation. A Stream Crossing Restoration and PostConstruction Monitoring Plan would be completed and submitted for agency approval before construction begins. 

Immediately after pipe installation and backfilling, and before the dams and flumes are removed and flow is 

returned to the waterbody channel, the stream banks would be reestablished to approximate preconstruction 

contours and stabilized. Erosion and sediment control measures would be installed across the construction 

easement to reduce stream bank and upland erosion and sediment transport into the waterbody. 

8.1.1.1. Determine Crossing Methods 

Stream crossing locations were carefully considered during Pipeline route selection to minimize impacts from the 

crossing method employed. Three crossing methods would be employed: HDD, open-cut trenching, and open-cut 

dry flume methods. HDD would be used on large streams and rivers; open-cut trenches would be used on streams 

that are dry at the time of construction; and open-cut dry flume methods would be used on smaller rivers and 

streams that contain water at the time of construction. Specific procedures for installing temporary bridges over 

waterbodies as well as construction methods for HDD, flume, and trench crossings are detailed in Resource 

Report 1, General Project Description. 

Construction of the pipeline would cross numerous intermittent and perennial streams and rivers. A total of 120 

streams crossed by the Oregon Pipeline have perennial flow regimes, support ESA-listed salmonids, or have 

EN0427151027PDX 8-1 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

designated critical habitat. Twenty-four of those streams support ESA-listed salmonids or have designated critical 

habitat. Some intermittent and ephemeral drainages not supporting ESA-listed salmonids would require further 

investigation before final engineering design. 

There would be 13 HDD crossings. Site-specific stream crossing drawings for streams with ESA-listed fish are 

provided in Appendix 6A of the Applicant-Draft BA. Oregon LNG used the Washington Department of Natural 

Resources (WDNR) Watershed Analyses (1994) technique to evaluate stream morphologies in the Project area. 

Based on WDNR Standard Watershed Analysis Methodology, six channel types with the potential for either lateral 

(bank erosion causing channel migration) and/or vertical (debris flow) scour potential were identified for streams 

being crossed by the pipeline. Of the 24 perennial/ ESA stream crossings, 11 possess some potential for vertical 

scouring or debris flow events, while 23 have at least some potential for lateral channel migration. 

Preconstruction surveys were conducted at crossing locations on ESA-listed and other select streams to evaluate 

design considerations needed to avoid and minimize impacts to channel morphology. Table 1 in the Technical 

Memorandum titled Channel Response Matrix for Pipeline Crossings of Perennial Waterbodies and Streams 

Supporting ESA-Listed Salmonids (located in Appendix F of this document) provides information important for 

estimating the susceptibility of individual channel types to morphological response, particularly vertical scour and 

lateral migration. These site-specific data were important in determining the type and feasibility of crossing 

methods at each stream crossing. 

At Pipeline crossings containing ESA-listed fish or streams crossed within 0.1 mile of such streams, the Pipeline 

would be buried to a minimum depth of 3 feet (top of pipe). At streams with moderate to high scour potential, 

the Pipeline would be buried 3-feet deeper than the scour depth to ensure against exposure. The specific depth 

that would be required at such crossings would be determined on a site-specific basis, which would require 

acquisition of additional detailed information on substrate characteristics, expected peak flow conditions, local 

bed slope, and upstream and downstream conditions. These data would be acquired before final design of the 

high-risk crossings. 

8.1.1.2. Implement Erosion Control Best Management Practices 

Erosion control BMPs and the methods outlined in the FERC Plan and FERC Procedures would be implemented to 

reduce the potential for mass failure. In areas where landslides are a concern but specific landslide features 

cannot be identified, proper construction techniques would be implemented to minimize the potential for slope 

failure, landslides, or erosion resulting from Pipeline installation. In general, the installation of a Pipeline below 

ground (and subsequent backfilling of the trench zone with native material) results in a relatively short window of 

disturbance and minor change in subsurface conditions. The larger changes occur at the ground surface, where 

topography and vegetation are altered. Therefore, the majority of the construction techniques that would be 

implemented are performed to restore or improve the land and drainage features after construction is complete. 

These techniques may include the use of water bars, terracing, diversion ditches, and other methods to control 

runoff and erosion. Backfill operations would be performed to ensure that the trench backfill is adequately 

compacted so mounding is not required. 

8.1.1.3. Avoid or Minimize Landslide Hazards 

Revegetation procedures would be implemented to ensure rapid establishment of a vegetative cover after 

completion of construction. Where steeply sloped areas or mapped landslide hazard areas cannot reasonably be 

avoided, an effort has been made to align the pipe parallel to the maximum fall of the ground (that is, to run the 

pipe straight down the slope) and avoid placing the pipe parallel to the slope (that is, side-sloping the pipe). The 

potential for pipe damage because of soil deformations associated with rapid landslide movement is much less 

when the movement occurs parallel to the axis of the pipe. In areas where specific landslide hazards are 

identified, a number of methods are available for the mitigation of landslide deformation on pipelines. These 

include stabilization of the landslide, relocation of the Pipeline beyond the landslide, installation of the Pipeline 

above ground, installation below the landslide using directional drilling or deep excavation, or the use of 

deformable backfill such as polystyrene or other suitable material (Bukovansky and Major, 2002). 

8-2 EN0427151027PDX 
ECTION 8—STREAM CHANNELS AND WATERBODIES 

When avoidance measures are not practical, another option for mitigating the risks of landslide hazards includes 

maintaining the Pipeline within the landslide zone, which can be accomplished using a program of landslide and 

pipeline monitoring. This approach is particularly well suited to existing landslide areas where movement is 

occurring relatively slowly, which is the case in much of the landslide topography mapped throughout the Coast 

Range. Installation and monitoring of equipment to monitor the movement of landslides and pipelines (and the 

associated strain imposed on the Pipeline) is a common method of maintaining pipelines in active landslide zones. 

Vibrating wire strain gauges have been used extensively during the last 20 years to monitor longitudinal pipeline 

strain changes caused by the landslide deformations (Bukovansky and Major, 2002). Monitoring of pipeline strains 

enables sensitive measurements of forces in the pipe and timely implementation of strain-relief measures if 

strains reach a critical level. According to Bukovansky and Major (2002), federal, state, and local agencies that 

regulate pipeline construction and operation in the United States generally accept strain monitoring to provide for 

the safety of pipelines located in areas of geologic hazards. This has contributed to the acceptance of strain gauge 

monitoring as a basic system for enhancing pipeline safety. 

The consequences of mass slope failures, landslides, persistent turbidity, and Pipeline fractures on fish and 

wildlife resources would depend on downstream physical and biological conditions and timing should a landslide 

or mass failure occur. 

Because the severity of any given landslide with regard to ESA-listed fish is dependent on a nearly infinite number 

of variables, no generalities can be drawn. The effects could be as minor as a short-term pulse of turbidity that 

would require no corrective action or as severe as complete blockage of upstream migration. Should a landslide 

occur that is due to Pipeline construction and not other natural processes, ODFW, NMFS, and other interested 

parties would be consulted to design a site- and case-specific plan to mitigate any negative effects. By identifying 

potential landslide hazards in advance and developing appropriate engineering solutions to minimize the risk of 

landslides at sensitive sites, there should be minimal risk to listed fish from the effects of landslides at the opencut or flumed stream crossings. 

8.1.1.4. Crossing Methods 

HDD Crossings 

HDD crossing methods are a primary mitigation measure for avoiding and minimizing impacts to ESA or other fishbearing and perennial streams. Locations of HDD crossings are listed in Table 5-1 (Section 5.0 above). 

Site drawings for each of the proposed HDD crossing locations at ESA streams were provided to FERC in the June 

2013 filing. The HDD crossings of ESA streams are typical of HDDs at non-ESA streams. 

Surface-Water Crossings 

Surface-water crossing methods for each stream were determined based on field surveys, review of fisheries data, 

and preconsultation meetings with the Services. Perennial streams would be crossed with the flume method on 

non-HDD streams. Stream flow may be channeled into one or multiple flume pipes to convey water across the 

trench and maintain downstream flow. The trench would be excavated from under the flume pipe, the Pipeline 

would be threaded under the flume, the trench would be backfilled, and the flume pipe would be removed to 

restore natural downstream flow. Figure 6A-26 in Appendix 6A of the Applicant-Draft BA shows the details of a 

typical flume crossing method. Temporary cofferdams would be constructed above and below the entry and 

outfall of the flume pipes. Before dewatering the work area, fish salvage would take place according to the 

Oregon LNG Pipeline Waterbody Crossing: Fish Salvage Plan technical memorandum originally submitted to FERC 

in 2008, and revised and resubmitted in June 2013 as Resource Report 3, Appendix 3O (see Appendix 2C of the 

Applicant-Draft BA for the June resubmittal version). 

At stream crossings, the pipe would be buried at a depth to minimize the risk of exposure from vertical erosion or 

lateral migration. In the vertical dimension, the pipe would have a minimum of 3 feet of cover below the 

maximum scour depth. In the lateral dimension, the vertical depth would be maintained for a minimum length of 

2.2 times the active channel width, plus the channel migration zone. For streams with floodplains less than 2.2 

times the active channel width, the vertical depth would be maintained across the entire width of the floodplain. 

EN0427151027PDX 8-3 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

Active channel migration zones and floodplains are applicable to streams with a gradient of less than 4 percent, 

because streams with a gradient of 4 percent or greater do not have functional floodplains (Rosgen, 1996). To 

prevent landslides at high-risk crossings, BMPs (including slope breakers, straw bales, silt fences, wattles, and 

subsurface drainage) would be used, as detailed in the technical memorandum titled Landslide and Debris Flow: 

Relative Risk Assessment for the Bidirectional Project Pipeline in Applicant-Draft BA Appendix 6B. Site-specific 

engineering techniques for minimizing landslide risk and for protecting the Pipeline against landslides, should they 

occur, are shown in drawings for each flumed and open-cut crossing that could affect ESA-listed fish. Should 

channel subsidence, bank erosion, channel scour, or other negative long-term effects of Pipeline construction 

become apparent during post-construction monitoring, case-specific responses would be tailored to alleviate the 

specific problems identified.

Stream bank erosion would be minimized by clearing the smallest amount of vegetation possible at stream 

crossings and grubbing only over the ditch line. Rootstocks would be left in place for erosion control and rapid 

post-construction vegetative regeneration, in addition to seeding and mulching, planting native vegetation (where 

necessary), and—in some cases—use of biodegradable erosion control fabrics. 

The open-cut trenched method is applicable to intermittent and ephemeral streams that are not fish bearing, and 

to fish-bearing intermittent or ephemeral streams if dry at the time of construction. Applicant-Draft BA Figure 6A27 in Appendix 6A shows the details of a typical open-cut trenched crossing method. This method is allowable for 

the crossing of minor or intermediate waterbodies. The restrictions on instream work, restoration of 

preconstruction contours, limitations on equipment operating in the waterbody, or required bridging identified in 

the FERC Procedures would be practiced as follows: 

x Limit the use of the equipment operating in the waterbody to only the needed equipment. 

x Return the waterbody to its preconstruction contours. 

Other general measures to be applied for surface-water crossings are as follows: 

x Stabilize channel banks and install temporary sediment barriers within 24 hours after completing the crossing. 

x Perform pipe stringing, pipe bending, and welding greater than 25 feet on each side of the stream. 

x Give clearing crews specifications for minimizing riparian clearing to accommodate stream size, terrain, and 

existing vegetation conditions, and to avoid removal of significant trees, where possible, at the margins of the 

temporary construction zone. 

x Occasionally require a wider riparian clearing width to cross streams in steep terrain. To account for larger 

trench backslopes and perform temporary grading for equipment access, limit clearing for steep terrain 

crossings to the minimum clearing width to safely perform access and construction. 

x Salvage existing LWD for reinstallation, and stockpile a sufficient quantity of large-diameter conifer logs for 

post-construction aquatic habitat enhancement. 

x Upon completion, regrade and stabilize stream banks, and restore the riparian area with native vegetation 

(see stream bank restoration plan in Applicant-Draft BA Appendix 6A). 

x Segregate topsoil, nontopsoil substrate, instream spoils, and LWD and maintain it near the crossing locations 

for backfilling and restoration activities. Take care to segregate substrate by grain size so that streambeds can 

be restored with their original substrate following pipe installation. 

x For open-flume crossings, remove temporary “bridges” used for construction following construction. It is 

Oregon LNG’s intention to remove these bridges and maintain access to the Pipeline easement by the listed 

access roads. Temporary bridges would only be in place during the late spring and summer dry season. Only if 

there is a Pipeline concern under a waterbody would post-construction reentry be considered. 

8-4 EN0427151027PDX 
ECTION 8—STREAM CHANNELS AND WATERBODIES 

8.1.2 Applicant and Contractor Responsibilities 

8.1.2.1. Oregon LNG 

Throughout the construction phase, Oregon LNG would ensure that the contractor is following prescribed 

methods and is conducting operations in accordance with the final Construction, Restoration, and Monitoring Plan 

and applicable permits and regulations. Oregon LNG would mark waterbody crossings before construction and 

would ensure that the contractor is aware of procedures related to sensitive wildlife habitats, and has sufficient 

supplies to address any unforeseen complications that arise. Oregon LNG would require that the contractor 

maintain sufficient supplies and equipment to complete construction in accordance with the FERC Plan and 

Procedures and the final Construction, Restoration, and Monitoring plan. These supplies would include spill 

control and cleanup devices (absorbent pads, socks, and “kitty litter” type granules), silt fencing, straw bales, and 

other erosion control devices. Erosion controls would be carefully monitored during construction to ensure that 

excessive sediment discharge to streams is avoided. Oregon LNG may have several representatives at the 

construction site at any one time, but one staff member would be designated as the environmental inspector (EI). 

The EI would be responsible for maintaining compliance with the FERC Plan and Procedures, the final restoration 

and monitoring plan, and any other regulations as specified in OARs. The EI would ensure that in-water work 

periods are observed and that markings and flagging remain in place during construction. The EI would have “stop 

work” authority in the case of any activities by the contractor not allowed under the final Construction, 

Restoration, and Monitoring plan. The EI would supervise construction activities in waterbodies including 

installing dams and flumes, fish salvage, and stockpiling/replacing soils, boulders and LWD. The EI would also be 

responsible for overseeing stream restoration and mitigation activities. The EI would ensure that crossings are 

graded to preconstruction contours, that temporary and permanent erosion control devices are installed, that 

crossings are revegetated in accordance with revegetation plans, and would have final say regarding the 

“completeness” of restoration activities. Oregon LNG would also be responsible for the long-term soil 

stabilization, restoration, and monitoring of stream crossings. 

8.1.2.2. Contractors 

Oregon LNG would engage one or more contractors for construction, reclamation, revegetation, and monitoring. 

The construction contractor would be responsible for all phases of construction. This would include procuring 

sufficient supplies to complete construction on schedule, maintaining equipment in good working order, and 

following procedures in the final Construction, Restoration, and Monitoring plan. Specific to stream crossings, the 

contractor would be responsible for installing erosion control devices (silt fence, straw bales, or other sediment 

barriers), installing temporary equipment crossings, segregating spoils (including topsoil, LWD, and other up-land 

and instream spoils), installing flumes, stringing pipe, backfilling trenches, and restoring banks and streambeds. 

8.1.3 Preconstruction Site Characterization and Documentation 

The purpose of the preconstruction assessment is to establish a baseline sufficient to determine whether postconstruction restoration is effective in returning streams to their preconstruction functional ability. As such, the 

preconstruction assessment is not designed to be a comprehensive characterization of wildlife habitats or 

vegetation present at each stream crossing. The method employed would be largely subjective in nature, relying 

on observations by experienced biologists. A key component of the monitoring program would be “before and 

after” photographs. Procedures for photo documentation would follow Edelen and Crowder, 1997. 

Before construction, each stream crossing location would be assessed and documented using the following 

methods (Rashin, Bell, and Clishe, 1993; Federal Interagency Stream Restoration Working Group [FISRWG], 1998; 

OWEB, 1999; and Oregon Plan for Salmon and Watersheds, 2004): 

1. Stream crossings would be assigned a unique identification number. A whiteboard or similar suitable sign 

would be prepared with the date, time, and crossing identification (ID) number to identify the crossing 

location, and would be placed in photographs. Each crossing location would be photographed from multiple 

angles and care would be taken to document adjacent upstream and downstream channel segments. Efforts 

would be made to photograph significant habitat features such as over-hanging banks, root-wads, LWD, 

boulders, and stream substrate. 

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APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

2. A data sheet would be completed at each stream crossing. Information recorded would include bank 

substrate and condition, streambed substrate, stream morphology, dominant bank vegetation, percent 

bankfull discharge at the time of assessment, LWDs or other instream structures, and a narrative describing 

the crossing location in as much detail as possible. A site sketch would be completed on the data sheet, and 

photographs taken would be described. The site sketch would include features that were photographed and 

an indication of the photographer’s location at the time of each photo (for example, a labeled photo with an 

arrow to indicate the direction of the photograph). 

During preconstruction site characterization, Oregon LNG would identify and mark potential donor plant sites at 

adjacent areas where replacement vegetation may be obtained for use in restoration activities. 

8.1.4 Stream Channel Restoration Measures 

8.1.4.1. Schedule 

The construction schedule would adhere to the recommended ODFW in-water work periods unless an extension 

of those work periods is granted. In-water work periods by Pipeline mile and river/basin are shown in Table 8-1. 

As indicated in the table, the start and end dates are variable depending on the region and the stream; start dates 

are as early as April and end dates are as late as October. 

Oregon LNG would complete flume method stream crossing construction in perennial streams in 3 days or less. In 

accordance with the FERC Procedures, the duration of in -water construction would be limited to 24 hours across 

minor waterbodies (10 feet wide or less) and 48 hours across intermediate waterbodies (between 10 and 100 feet 

wide). Bank restoration would follow as quickly as is technically possible. Final cleanup would include regrading, 

mulching, placing erosion control mats, reseeding or transplanting vegetation. Reseeding and reclamation would 

be accomplished as quickly as possible following pipe installation. In the event that precipitation events or other 

force majeure complications preclude the completion of seeding and reclamation within 10 days, exposed 

erodible substrates would be covered with straw or other suitable mulch until seeding is completed and seedlings 

are established as described below. 

Oregon LNG would follow the FERC Procedures to limit water quality effects on waterbodies during construction. 

Oregon LNG would also implement erosion and sediment control measures as described in Figures 6A-26 through 

6A-31 in Applicant-Draft BA Appendix 6A to control soil erosion and sediment discharge. In addition, Oregon LNG 

would obtain an NPDES 1200-C construction stormwater discharge permit before construction of the Project. 

8.1.4.2. Regrading 

Following Pipeline installation, areas disturbed during construction would be returned to their preconstruction 

contours. Trenches would be backfilled and topsoil would be replaced as close as possible to the location from 

which it was excavated. The original profiles, meanders, and contours would be reconstructed, except for very 

steep bank profiles. Steep banks may be graded to a stable angle of repose to prevent erosion. 

Excess rock that cannot be returned to the trench or used for slope stabilization, and is not utilized as instream 

structure for habitat mitigation/enhancement, may be distributed throughout the right-of-way or be utilized as a 

barrier to block unauthorized vehicular access to the right-of-way. No solid waste or construction debris would be 

allowed to remain in the right-of-way following final regrading. 

8.1.4.3. Erosion Control 

Temporary and permanent erosion control would be deployed during and after the Pipeline installation. The 

specific temporary erosion control methods used would be based on site specific requirements related to bank 

slope and substrate conditions. Individual HDD crossing drawings containing detailed plans for the location and 

type of erosion control structures to be applied at those locations. 

The following potential stream bank stabilization BMPs would be used after construction at stream crossings 

regardless of whether they are flowing or dry at the time of construction: 

x Use clean gravel or native cobbles for the upper 1 foot of trench backfill in waterbodies that contain 

coldwater fisheries. 

8-6 EN0427151027PDX 
ECTION 8—STREAM CHANNELS AND WATERBODIES 

x For open-cut crossings, stabilize waterbody banks and install temporary sediment barriers within 24 hours of 

completing instream construction activities. For flume crossings, complete streambed and bank stabilization 

before returning flow to the waterbody channel. 

x Return waterbody banks to preconstruction contours or to a stable angle of repose, as approved by the EI. 

x Employ primarily bioengineering techniques for bank armoring and protection. Apply site-specific BMPs, such 

as those described by McCullah and Gray (2005). 

x Riprap shall not be used for bank stabilization unless a geotechnical or environmental engineer determines 

that alternative soft armoring methods would be inadequate. If riprap is used, it shall be limited to the 

minimum required stream length. 

x Revegetate disturbed riparian areas with conservation grasses and legumes or native plant species, preferably 

woody species. 

x Install a permanent slope breaker across the construction easement at the base of slopes greater than 

5 percent that are less than 50 feet from the waterbody, or as needed to prevent sediment transport into the 

waterbody. 

x At dam and pump and flume crossings, repair unavoidable streambed scour at pump discharges with clean 

gravel. 

x Remove all non-native materials from the crossing after construction and stabilization are complete. 

8.1.4.4. Revegetation 

Banks would be revegetated according to the plan submitted in the Applicant-Draft BA, Appendix 6A to stabilize 

soils and prevent erosion. 

8.1.4.5. LWD Placement and Other Restoration/Mitigation Activities 

If LWD is removed from the streambed during construction, it would be stockpiled until construction is completed 

and then replaced. The EI would be responsible for ensuring that the LWD is appropriately anchored to prevent it 

from displacing downstream and that post-construction placement would provide similar habitat benefits to 

preconstruction conditions. Large trees removed from the construction right-of-way would also be stockpiled for 

use in post-construction operations. 

8.1.5 Restoration Documentation 

Following the completion of reclamation activities but before post-construction monitoring begins, Oregon LNG 

would perform a final inspection of the crossings to verify that preconstruction commitments have been satisfied. 

When the inspection is complete, Oregon LNG’s construction or restoration contractor would be notified of any 

required remedial actions. During the post-construction site visit, temporary erosion control devices (such as silt 

fences) that are no longer required would be noted and Oregon LNG would contract for their removal. In the 

event that temporary erosion control devices are still required, but are in poor repair, Oregon LNG would repair or 

replace them as necessary. 

A post-construction report demonstrating “as-built” conditions is required under OAR 141-085-0151(2)(a) for 

compensatory mitigation, and Oregon LNG would submit a similar report within 90 calendar days of completing 

grading, reclamation, and revegetation. The report would include details on final grading and a discussion of any 

variation from the approved plan. 

Information would be provided on the date and duration of each stream crossing, an explanation of any crossings 

that exceeded the 24-hour preferred construction duration, a description of reclamation activities (temporary and 

permanent erosion control, excess rock placement, remediation activities, and revegetation), and any deficiencies 

(that is, obvious erosion) noted during the initial post-construction inspection. Appendix G in this Plan contains 

drawings of typical non-ESA-listed stream crossings. 

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APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

8.1.6 Water Quality 

Oregon LNG would follow the FERC Procedures to limit water quality effects on waterbodies during construction. 

Oregon LNG would also implement erosion and sediment control measures as described in Figures 6A-26 through 

6A-31 in Applicant-Draft BA Appendix 6A to control soil erosion and sediment discharge. In addition, Oregon LNG 

would obtain an NPDES 1200-C construction stormwater discharge permit before construction of the Project. 

The SWPPP is provided in Appendix B. The locations of site-specific erosion control and BMPs are identified in 

typical stream crossing drawings. Typical details are listed in the figures. The SPCC Plan includes information 

regarding the containment of drilling mud during HDD wetland and waterbody undercrossings. 

During preconsultation discussions with USFWS and NMFS, it was agreed that unless approved by USFWS, NMFS, 

and ODFW, ATWS would be set back 150 feet from perennial streams and wetlands. In addition, overnight parking 

of vehicles, storage of fuels and other hazardous materials, and refueling activities would take place no closer 

than 150 feet from a stream or a wetland, unless full containment of potential contaminants is provided. Under 

certain clearly defined conditions, and subject to agency approval, ATWS may be placed closer to waterbodies or 

wetlands where the ATWS placement would not increase effects on streams or fish habitat. 

During the construction of the Project across perennial streams, measures to avoid construction-related impacts 

would include placing spoils at least 50 feet from the water’s edge for streams without water or in ATWS 150 feet 

from perennial streams; using erosion and sediment controls to prevent the excessive delivery of sediment to 

waterbodies; and, where temporary vehicle crossing is needed, following the FERC Procedures for temporary 

equipment bridges. 

8.1.6.1. Increased Sediment Inputs 

Within the construction easement, erosion and sediment control measures would be installed to reduce postconstruction stream bank and upland erosion and sediment transport into the waterbody, thus eliminating 

concerns for excessive sediment transport from uplands into the streams. The erosion and sediment control 

methods would be maintained until vegetation is established within the riparian zone. Stream bank restoration 

and monitoring would be conducted in accordance with the Restoration and Monitoring Plan to be completed 

before construction begins. 

The Project would use methods adopted from FERC’s Upland Erosion Control, Revegetation, and Maintenance 

Plan to minimize effects from construction operations on slopes and to prevent soil erosion. The Project would 

also comply with the ODEQ Erosion and Sediment Control Manual (ODEQ, 2013) and the Oregon Department of 

Transportation (ODOT) Erosion Control Manual (ODOT, 2005). The adapted version of the FERC Plan is presented 

in Appendix 7G of Resource Report 7 (Oregon LNG, 2013). 

The FERC Plan, as well as the state of Oregon guidance documents, specifies BMPs to reduce sediment discharge 

from construction sites. These BMPs include the use of terraces, mulch (e.g., hay and straw), mulch anchored with 

a light asphalt tack, or mats in areas where a high erosion potential exists. The FERC Plan also specifies the use of 

seeding mixtures that would ensure rapid revegetation. These consist of species adapted to the various conditions 

encountered along the Pipeline easement, including wet and shady areas and areas with shallow soils. 

Sediment barriers would be installed immediately after initial disturbance of the waterbody or adjacent upland. In 

areas where the Pipeline alignment crosses steep slopes, the need for additional erosion control measures, above 

and beyond those required by state and federal agencies, would be evaluated on a case-by-case basis. 

Construction would be conducted in the late spring to early fall, and revegetation of exposed areas would occur 

immediately to avoid exposure of bare soils during the winter rainy season. 

Restoration procedures would be monitored to ensure their efficiency and effectiveness. If the monitoring 

identifies any areas of erosion or ineffective revegetation, the easement would be restored in accordance with 

the existing plans unless it is determined that modified plans are needed, in which case NMFS and ODFW would 

be contacted for approval of any such modifications. Sediment barriers would be properly maintained throughout 

construction and reinstalled as necessary (such as after backfilling of the trench) until replaced by permanent 

8-8 EN0427151027PDX 
ECTION 8—STREAM CHANNELS AND WATERBODIES 

erosion controls, or until restoration of adjacent upland areas is complete and revegetation has stabilized the 

disturbed areas. 

8.1.6.2. Water Temperature 

The streams that are listed (1972 Clean Water Act § 303(d)) as temperature sensitive along the Pipeline would be 

crossed using HDD, thereby avoiding loss of streamside shade in these temperature-sensitive streams. At flume 

and open-cut crossings, the removal of riparian vegetation would be minimized to the extent possible. However, 

even in the event that the full 100-foot construction corridor is cleared, it is unlikely based on the technical 

memorandum in Appendix 10 of the Applicant-Draft BA, Oregon LNG: Characterizing Deforestation Impacts on Stream 

Temperature (CH2M HILL, 2009), that the resultant increase in incident solar radiation would be sufficient to cause 

biologically significant increases in downstream water temperatures. Revegetation of the easement over the long 

term (described above) would eliminate any small increases in water temperature that do result. 

8.2 Compensatory Mitigation 

A post-construction report demonstrating “as-built” conditions is required under OAR 141-085-0151(2)(a) for 

compensatory mitigation, and Oregon LNG would submit a similar report within 90 calendar days of completing 

grading, reclamation, and revegetation. The report would include details on final grading and a discussion of any 

variation from the approved plan. 

Information would be provided on the date and duration of each stream crossing, an explanation of any crossings 

that exceeded the 24-hour preferred construction duration, a description of reclamation activities (temporary and 

permanent erosion control, excess rock placement, remediation activities, and revegetation), and any deficiencies 

(that is, obvious erosion) noted during the initial post-construction inspection. Appendix G in this Plan contains 

drawings of typical non-ESA-listed stream crossings. 

8.3 Operational Mitigation, Post-Construction Monitoring, and 

Adaptive Management 

Post-construction monitoring would be conducted twice during the first year following construction at 

approximately 6-month intervals and annually thereafter for a total of 5 years or until successful reclamation is 

complete, whichever is longer. 

The objectives of the post-construction monitoring program are twofold: 

1. To ensure that stream crossing locations are able to fulfill their preconstruction functions by documenting and 

correcting problems with bank stabilization and revegetation; and 

2. Document the success of LWD placement or other habitat enhancement activities completed as part of the 

mitigation plan. Further details regarding mitigation would be provided upon final selection of mitigation sites 

and methods. 

Objectives would be accomplished by evaluating the following: 

x Growth of riparian vegetation compared to preconstruction conditions, based on species representation, 

cover, and vegetative structure 

x Vegetative conditions in the 10-foot-wide vegetated zone over the Pipeline and the effects of maintenance 

mowing 

x Height of trees and shrubs; assess whether they have attained a height of at least 15 feet in the 30-foot-wide 

vegetated zone centered over the pipe (except for the 10-foot-wide mow strip) 

x Relative condition and dominance of reestablished native trees and shrubs in the Pipeline corridor and the 

riparian buffers 

x Vegetative conditions in relation to the revegetation plan and FERC requirements 

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APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

x Presence and abundance of noxious weeds and the effectiveness of control measures in the adjacent buffer; 

and the within the Pipeline corridor 

x Effectiveness of erosion control applications to stabilize soil and prevent excessive erosion 

x Retention of important specimen trees, significant wildlife snags, nest trees, downed large wood, and rocks in 

riparian areas and stream bank zones 

Monitoring would be conducted to assess streams at the same time of year as their preconstruction site visit. The 

post-construction monitoring would focus on identifying problems with bank stabilization and revegetation. 

During post-construction monitoring events, Oregon LNG or a contractor would look for trench subsidence and 

erosion indicators such as gullies, undercutting banks, bare ground, bank slumping, and evidence of sheet erosion. 

If initial erosion control features are shown to be inadequate or if erosion control structures fail, Oregon LNG 

would retain a contractor to conduct remedial actions as soon as site conditions allow. 

Repairs or remedial actions could include additional seeding or transplanting, installing more robust erosion/

sediment control materials, maintaining or replacing the initial erosion control features, placing boulders or LWD, 

slope armoring, additional mulching, or matting. If trench subsidence is observed, Oregon LNG would direct the 

contractor to fill and compact the trench to grade with appropriately sized substrate. If trench remediation is 

required below the ordinary high water mark, activities would be conducted within appropriate ODFW in-water 

work periods. 

Revegetation monitoring would include a qualitative assessment of the following parameters in comparison to 

adjacent undisturbed areas: 

x Percent total adjacent herbaceous cover (seeded/transplanted species plus desirable volunteers) 

x New or expanded populations of noxious weeds 

x Species composition 

Post-construction surveys would be conducted by experienced biologists. The assessments would include photo 

documentation and completion of data forms for reporting and documentation. 

8.3.1 Performance Standards 

Criterion for establishing adequate vegetation recruitment would be defined in the final Construction, 

Restoration, and Monitoring Plan following consultation with ODFW and DSL. For example, areas may be 

considered successfully reestablished if, after the first year, disturbed areas contain at least 50 percent of the 

herbaceous cover as adjacent undisturbed areas, with no bare spots greater than 2 feet in any dimension and the 

species composition is a mixture of seeded or replanted species and desirable volunteers. At the end of 5 years, 

success may be defined as at least 80 percent of the herbaceous cover as adjacent undisturbed areas. 

Areas with poor reestablishment or undesirable species mixes would be evaluated to determine, if possible, the 

cause of the problem (that is, poor germination, poor planting technique, herbivory), and corrective measures 

would be undertaken. Potential corrective measures include replanting, planting an alternative species mix, or 

protecting existing seedling from herbivory. 

The reclaimed right-of-way would be considered stable when the surface appears similar to adjacent undisturbed 

land and the following accelerated erosion indicators do not exist: 

x Perceptible soil movement (exceeding preconstruction conditions) 

x Flow pattern development resulting in rills or gullies greater than 3 inches deep 

x Evidence of sheet erosion 

x Evidence of siltation in stream substrates downstream of the crossing 

x Perceptible downstream movement of instream rock or woody debris 

x Trench subsidence or slumping 

8-10 EN0427151027PDX 
ECTION 8—STREAM CHANNELS AND WATERBODIES 

8.3.2 Reporting 

Following each monitoring period, Oregon LNG would prepare a report for submittal to the DSL. The report would 

contain the following: 

x Summary of bank vegetation recruitment and species composition as compared with adjacent undisturbed 

areas 

x Assessment of the condition of transplants in riparian areas 

x Discussion of non-native species and noxious weeds in disturbed areas 

x Description of any deviations from the monitoring plan 

x Discussion of Project performance and an assessment of whether Project goals are being met 

x Any observations not included on monitoring forms that further elucidate the success or potential for failure 

of revegetation and restoration efforts 

x Identification of areas that require remedial action 

x Recommendations and schedule for remedial action(s) 

x Before and After photo pairs for each crossing 

x Monitoring forms 

If success criteria have not been met by the end of year 5, Oregon LNG would consult with agencies to determine 

future actions. Actual contingency measures would be based on monitoring data and site circumstances as they 

occur. 

8.3.3 Adaptive Management Summary 

Adaptive management at stream and river crossings would address both unanticipated emergencies (e.g., 

landslides into the stream channel, exposure of the Pipeline through streambed scouring, and frac-outs during 

HDD drilling operations) and compliance with proposed restoration goals. A comprehensive post-construction 

monitoring plan and SPCC plan for stream crossings is included in Resource Report 2, Attachment 2H. 

8.3.3.1. Frac-outs 

Adaptive management for frac-outs is thoroughly addressed in the SPCC plan and includes steps such as the 

following: 

x Depending on the severity of the release, the most common first step for the HDD contractor in reestablishing 

circulation and sealing fractures is to utilize a thicker, lower-viscosity mixture of sodium bentonite and water. 

The thicker mix of sodium bentonite and water would be more effective in forming a filter cake on the inside 

wall of the borehole and soil/rock particles around the borehole to seal voids and prevent further release of 

drilling mud. In some cases, un-hydrated sodium bentonite chips would be pumped through the drill rods. 

These granules of bentonite would flow in and fill or bridge a void or fracture. They would hydrate and swell 

in the presence of the drilling fluid to seal off leaks or fractures. 

x If the problem is more severe, standard drill fluid additives would be used. These drill fluid additives 

commonly consist of PAC, or water–swellable synthetic polymers capable of absorbing many times their 

weight in water. These materials work in a similar manner as the granular bentonite, that is, they are pumped 

through the drilling system and allowed to swell to seal voids and fractures. 

x In the most severe cases, standard drill fluid additives may not be sufficient to seal fractures and reestablish 

circulation of drill fluid. In these conditions, coarser bridging agents may be required. These bridging agents 

may take the form of fiber, flake, or granular materials (Canon, 2003). Examples of fiber additives are cellulose 

fiber, cedar (or other wood) fiber, cane fiber, or spun mineral fiber. Mica is one of the most common 

examples of flake additives. Granular additives include nut hulls and granular bentonite (discussed above). 

Most of these bridging agents come in different sizes from coarse to fine and many manufacturers of drill fluid 

EN0427151027PDX 8-11 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

additives provide specially designed materials that may contain a combination of various bridging agents and 

polymers. 

Should the above methods prove unsuccessful, and HDD drilling fluid is released to water, appropriate local, state, 

and federal agencies would be notified, and a determination on whether or not to cease operations would be 

made in accordance with the SPCC Plan. The extent of the release would be assessed, and appropriate corrective 

actions would be taken. These corrective actions may range from simple monitoring in the case of small releases, 

to active cleanup using specialized pumps and filters, to abandonment of the HDD and sealing of the hole. In the 

event of an HDD drilling fluid release to land, the release and drilling hole entry point would be contained with 

berms, pumps, hay bales, sediment fencing, wood products, or other appropriate means, and the fluid would be 

cleaned up immediately using hand tools or vacuum trucks and transported to an approved disposal location. 

8.3.3.2. Mass Failures 

The steps to be followed in the event of a mass failure would be outlined in the Post Construction Monitoring 

Plan. Because the severity of any given landslide to ESA-listed fish is dependent on a nearly infinite number of 

variables, no generalities can be drawn. The effects could be as minor as a short-term pulse of turbidity that 

would require no corrective action, to complete blockage of upstream migration. Should a landslide occur, that is 

due to Pipeline construction and not other natural processes, the Interagency Adaptive Management Team would 

be consulted to design a site- and case-specific plan to alleviate the problem and mitigate for any negative 

impacts. 

8.3.3.3. Streambed Scour/Pipeline Exposure 

Should channel subsidence, bank erosion, channel scour, or other negative long-term effects of Pipeline 

construction become apparent during post construction monitoring, case-specific responses would be tailored to 

alleviate the specific problems identified. The post-construction monitoring plan would outline the steps to be 

followed in the event that Pipeline exposure is discovered. The steps would likely include first stabilizing the 

exposed pipe, followed by consultation with the agencies on the most effective course of action. Depending on 

the timing and circumstances, the methods followed may be significantly different. For instance, should the scour 

occur during the in-water work period, the most effective and least destructive course of action may be 

immediate reburial at a greater depth, but should the scour become apparent during sensitive spawning or 

migration periods, different options may be pursued. 

8.3.3.4. Compliance with restoration goals. 

The Post Construction Monitoring plan has yet to be completed. However, adaptive management would be an 

integral component of the overall strategy to meet mitigation goals. The plan would lay out steps to follow should 

any of the mitigation or restoration efforts (e.g., LWD placement, bank revegetation, fish passage improvements) 

prove less effective than anticipated, or should the negative effects be greater than anticipated (for instance, if 

more fish are salvaged than predicted in the Applicant-Draft BA). 

Monitoring would be conducted, and reports would be filed annually with ODFW, DSL, and other interested 

parties, outlining the state of restoration efforts, and discussing any proposed alterations/refinements to the 

overall plan based on any deficiencies identified. 

8-12 EN0427151027PDX 
SECTION 9 

Marine Reptiles and Mammals 

Section 4.0 in the Applicant-Draft BA provides the basis for mitigation measures recommended for marine reptiles 

and mammals. 

9.1 Onsite Mitigation 

Onsite mitigation measures for marine mammals and marine reptiles are proposed in the following sections. 

9.1.1 Marine Mammals 

9.1.1.1. Nonlisted Seals and Sea Lions 

Underwater noise mitigation measures may not reduce noise levels below established thresholds. Since seals and 

sea lions are known to swim past the ESP, there is potential for individuals to be exposed to harming noise. The 

proposed action is likely to harass, but not adversely affect seal and sea lion population numbers. This effect 

would be restricted to, at most, two in-water work periods when pile driving would occur. Oregon LNG would 

apply for an Incidental Harassment Authorization (IHA) for level B harassment on pinnipeds. 

The reduced speed limits proposed as a conservation measure to minimize whale strikes would benefit the seals 

and sea lions. LNG ships would slow to speeds below 15 knots as they approach the mouth of the Columbia River. 

If a spill were to occur, Oregon LNG would immediately report the incident and take recommended actions to 

prevent or minimize effects on marine life. 

Measures would be taken to reduce the potential effects of underwater noise on seals and sea lions. Pile driving 

would occur only during daylight hours. The actual number of hours of pile driving each day is not expected to 

exceed 4 hours because of mobilization time for each pile. Vibratory driving would be used where it is practical. 

Density of substrates would determine the extent to which vibratory driving can be used for each pile. Vibratory 

pile driving cannot be used alone, as impact driving would be required to test each pile. In an effort to reduce 

noise levels during impact driving, the Project anticipates installing mitigation measures to achieve approximately 

a 15 to 20 dB reduction. Proposed sound attenuation measures are bubble curtains, confined bubble curtains, pile 

hammer cushions, dewatering caissons, or cofferdams. CH2M HILL outlined underwater noise monitoring 

protocols in detail in the Oregon LNG Terminal and Oregon Pipeline Project—Underwater Noise Propagation, 

Monitoring, and Mitigation (Applicant-Draft BA Appendix 8). Monitoring protocols call for monitoring underwater 

noise, monitoring for the presence of seals and sea lions, and ceasing pile driving if seals and sea lions are visible 

within the zone where underwater noise exceeds the harassment threshold. 

LNG vessels transiting to or from Asia would follow a Great Circle route and would not be in proximity of 

designated critical habitat. Cargo and tanker vessels typically transit about 50 miles offshore (Cameron, 2008; 

Applicant-Draft BA Tables 4.3-1 -4.3.3). LNG vessels are expected to follow a similar pattern of transit along the 

West Coast. Therefore, LNG vessels are expected to be many miles offshore from rookeries that are designated 

critical habitat, thus adverse effects are unlikely. 

9.1.1.2. Whales 

The technical memorandum in Applicant-Draft BA Appendix 11, Oregon LNG: Estimate of Potential Whale Strikes

(CH2M HILL, 2013) addresses provides the basis for mitigation measures related to potential impacts to whales. 

Ship collisions involving whales are uncommon but possible. Depending on the known occurrence and relative 

abundance of select species in the Project area, the proposed action could adversely affect whales. The proposed 

action is not likely to adversely affect critical habitat, nor would the proposed action adversely affect the 

suitability of any occupied (seasonally or permanently) habitats. The proposed action would not degrade 

unoccupied habitats. Effects on whales analyzed in the Applicant-Draft BA include the following: 

x Sei Whale (Federal, Endangered; State, Endangered) 

x North Pacific Right Whale (Federal, Endangered; State, Endangered) 

EN0427151027PDX 9-1 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

x Blue Whale (Federal, Endangered; State, Endangered) 

x Fin Whale (Federal, Endangered; State, Endangered) 

x Humpback Whale (Federal, Endangered; State, Endangered) 

x Killer Whale (Federal, Endangered; State, Not Listed) 

x Sperm Whale (Federal, Endangered; State, Endangered) 

Oregon LNG would adopt the following vessel strike avoidance measures suggested by the NMFS (NMFS, 2008d) 

and recommended for inclusion in the Terminal Users agreement with LNG vessels: 

x Vessel operators and crews should post watch for the detection of whales to avoid striking sighted animals. 

x When whales are sighted, maintain a distance of 100 yards or greater between the whale and the vessel. 

x Reduce vessel speed to 10 knots or less when whales are observed near the vessel, as safety permits. 

Oregon LNG would also adopt the following NMFS recommend measures for reporting any whale strikes (NMFS, 

2008d). 

x Vessel crews must report sightings of any injured, entangled or dead whales as soon as possible, regardless of 

whether the injury or death is caused by your vessel. 

x Report to the Northwest Mammal Stranding Networks 

x If your vessel is responsible for injury or death of a whale, notify the USCG to report the incident and request 

the information be relayed to NMFS, Northwest Regional Office. 

The report should include the following information: 

x Time, date, and location (latitude/longitude) of the incident 

x Name and type of the vessel involved 

x Vessel’s speed during the incident 

x Description of the incident 

x Water depth 

x Environmental conditions (e.g., wind speed and direction, sea state, cloud cover, and visibility) 

x Species 

As ships approach the Columbia River, they would slow to speeds below 15 knots. At slower speeds, collisions 

with whales would be even less likely to occur. In the event of a ship strike or spill, Oregon LNG would 

immediately report the incident and take actions to mitigate or eliminate effects on whales. 

9.1.2 Marine Reptiles 

The proposed action may affect sea turtles, but is not expected to affect their population or habitat. No effect on 

the suitability of seasonally or permanently occupied or unoccupied habitat, or critical habitat is anticipated. 

Effects on sea turtles analyzed in the Applicant-Draft BA include the following: 

x Green Sea Turtle (Federal, Endangered; State, Endangered) 

x Leatherback Sea Turtle (Federal, Endangered; State, Endangered) 

x Loggerhead Sea Turtle (Federal, Threatened; State, Threatened) 

x Olive Ridley Sea Turtle (Federal, Threatened; State, Threatened) 

Conservation measures proposed for avoiding and minimizing strikes to whales would also minimize effects on 

sea turtles. No additional species-specific conservation measures are prescribed. 

9.2 Compensatory Mitigation 

For the marine mammals analyzed, potential conflicts with shipping could occur, and Steller sea lions could be 

disturbed by construction impacts at the Terminal. Therefore, expected adverse effects on individuals are likely. 

Methods for monitoring and mitigating for underwater noise are discussed in the technical memorandum in 

9-2 EN0427151027PDX 
SECTION 9—MARINE REPTILES AND MAMMALS 

Applicant-Draft BA Appendix 8 titled Oregon LNG Terminal and Oregon Pipeline Project—Underwater Noise, 

Propagation, Monitoring, and Mitigation (CH2M HILL, 2011). 

Effects on seals and sea lions would be restricted to, at most, two in-water work periods when pile driving would 

occur. Oregon LNG would apply for an IHA for level B harassment on pinnipeds. Effects on critical habitat are 

unlikely. Therefore, a not likely to adversely affect determination is warranted for critical habitat. 

Effects on whales and marine reptiles are not expected because no critical habitat would be impacted, and the 

suitability of occupied habitat would not be negatively affected. Therefore, the proposed action is not likely to 

adversely affect whales and marine reptiles, nor is it expected to degrade unoccupied habitats. Thus, no speciesspecific compensatory mitigation is needed for whales and marine reptiles. 

9.3 Operational Mitigation, Post-Construction Monitoring, and 

Adaptive Management 

Unanticipated events could include incidental lethal take of seals and sea lions, incidental take (ship-strike) of a 

sea turtle, and whale strikes over and beyond that which is predicted. Oregon LNG outlined monitoring and 

reporting procedures during pile driving in the technical memorandum titled Oregon LNG Terminal and Oregon 

Pipeline Project—Underwater Noise, Propagation, Monitoring, and Mitigation (Applicant-Draft BA Appendix 8; 

CH2M HILL, 2011) and reporting procedures for whale strikes in the conservation measures section (Section 

9.1.1.2, above).

Appropriate adaptive management would begin with an evaluation of the circumstances surrounding the 

unanticipated events. For example, if whale strikes are higher than predicted, then a number of factors would be 

evaluated including vessel speeds, whale population numbers, locations of strikes, and volumes of ship traffic, and 

LNG whale strikes in proportion to other vessels. Potential adaptive management would be dependent on the 

results of the analysis and could include altering ship speeds or routes. The adaptive management strategy would 

differ depending on the analysis. For example, increased whale strikes as a result of increased whale populations 

and constant ship traffic might be treated differently than increased whale strikes in the context of constant or 

declining whale populations. 

EN0427151027PDX 9-3 
SECTION 10 

Migratory Birds 

Mitigation measures for migratory birds were developed using the Migratory Birds—Regulatory Review and 

Mitigation technical memorandum submitted as Appendix 3P to Resource Report 3 (Oregon LNG, 2013) and 

included as Appendix H in this Plan. 

The MBTA (50 CFR 10.13) prohibits the taking, killing, possession, transportation, and importation of migratory 

birds, their eggs, parts, and nests, except when specifically authorized by the Department of the Interior. 

While the MBTA has no provision for allowing unauthorized take, the USFWS recognizes that some birds may be 

taken during activities such as Pipeline construction even if reasonable measures to avoid take are implemented. 

The USFWS’s Office of Law Enforcement carries out its mission to protect migratory birds not only through 

investigation and enforcement, but also through fostering relationships with individuals and industries that 

proactively seek to eliminate their impacts on migratory birds. Although it is not possible under the MBTA to 

absolve individuals, companies, or agencies from liability (even if they implement avian mortality avoidance or 

similar conservation measures), the Office of Law Enforcement focuses on those individuals, companies, or 

agencies that take migratory birds with disregard for their actions and the law, especially when conservation 

measures have been developed but are not properly implemented. 

Oregon LNG recognizes that construction of the Project and maintenance of the permanent right-of-way for the 

Pipeline may result in direct impacts to migratory birds and impacts to the habitats upon which they depend for 

various life requisites. Oregon LNG also recognizes that because of the size of the Project and the fact that some 

construction and operation would occur during the nesting season for a majority of migratory bird species found 

in the Project area, take of active nests, (i.e., eggs and young) may occur in spite of reasonable efforts to avoid 

such take. 

Oregon LNG is committed to taking reasonable measures to comply with the MBTA and would commit to 

providing preservation of habitats for migratory birds in the vicinity of the area where the Pipeline would be 

constructed, operated, and maintained. Accordingly, Oregon LNG has prepared this summary of efforts to comply 

with the MBTA. 

The list of migratory birds of concern in Table 10-1, adapted from a list provided by the USFWS, includes state and 

federal listed species, Oregon birds of conservation concern, and other migratory birds that are known or 

suspected to occur in the action area. 

10.1 Onsite Mitigation 

Clearing of vegetation before construction would occur in the spring, when many birds are nesting. Clearing 

outside of the breeding season for most migratory birds (that is, April 15 to August 15) poses its own risks and 

limitations. For example, clearing in the early spring or late summer/fall could be challenging for workers who 

need to establish effective erosion control on bare ground during the rainy season. The likelihood of causing 

mortality to nesting birds is moderate to high if felling trees and land-clearing takes place during the bird-nesting 

season. However, there is reduced risk of soil erosion if land is cleared at the end of the rainy season. 

Generally, Pipeline construction would follow FERC’s Plan and Procedures, except where inappropriate, infeasible, 

or where unsuitable conditions prevail. The Plan and Procedures help the Project to avoid, minimize, and mitigate 

potential impacts to wildlife and wildlife habitat by establishing best practices for Pipeline construction. In the 

event that construction activities differ from the approved actions within the Plan or Procedures, Oregon LNG 

would request a variance from FERC before beginning construction. 

Oregon LNG would avoid or minimize overall impacts to migratory bird habitat by constructing the Terminal on 

sandy dredge spoils, much of which is devoid of vegetation, and where vegetated, covered by poor quality nesting 

habitat (Scotch broom and Himalayan blackberry). The Pipeline was sited primarily in industrial forest in Oregon 

EN0427151027PDX 10-1 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

and agricultural land in Washington that does not contain blocks of old-growth forest typically associated with 

interior forest species, northern spotted owls, and marbled murrelets. 

Oregon LNG would perform 13 HDDs for Pipeline installation. Avoidance of habitat impacts, particularly riparian 

areas, would occur over a total of 12.3 miles or about 9 percent of the Pipeline as a result of using the HDD 

construction method. Entry and exit points were sited to be outside forested riparian vegetation. 

At stream crossings using trenching and fluming methods, riparian vegetation clearing typically would be 100 feet 

wide to account for workspace requirements for steeper terrain. Many stream crossings would be reduced to a 

width of 75 feet (see Section 2 of the Applicant-Draft BA). 

Riparian clearing is required for equipment access, temporary equipment bridges, installation and removal of 

fluming materials, trench backslopes, pipe capping (if used), and soil handling. Soil stockpiling, pipe stringing, pipe 

bending, and welding would occur at least 50 feet or more from streams. The minimum distance would vary 

according to susceptibility to impacts from erosion. For example, relatively level farm ground with minimal 

riparian vegetation poses a minimal risk that stockpiled material would erode into a stream during the summer 

construction season. Therefore, stockpiling may take place 50 feet of a stream. However, sensitive salmonid 

streams on steeper terrain pose a different set of risks and would require a setback of 150 feet from a perennial 

stream. Through negotiations during prefiling, Oregon LNG and agencies agreed to a minimum 150-foot setback 

for ATWS in the Coast Range or where greater riparian protection is needed in farmlands. Locating ATWS 150 feet 

from streams would minimize impacts to habitat utilized by riparian species. The width of clearing would be 

reduced by aligning the Pipeline parallel to existing cleared easements, such as transmission lines, roads, and 

railroads. Approximately 1.4 miles of new temporary access roads would be constructed. There would be an 

access point to the Pipeline approximately every mile. Extensive use of existing logging roads in the Coast Range 

minimizes impacts to bird habitat. Pipeline storage yards would be located in developed areas and not require 

impacts to migratory bird habitat. 

Within the 50-foot-wide permanent easement, FERC typically allows 10 feet centered over pipelines to be mowed 

on an annual basis. While this may occur, Oregon LNG does not contemplate mowing on an annual basis. Thus, 

compensatory mitigation would be proposed even though the actual impact is likely to be less severe than that 

allowed by FERC. FERC allows woody vegetation to be maintained at a height of 15 feet over a 30-foot wide strip 

over the Pipeline. Oregon LNG is committed to planting trees and shrubs up to the 10-foot-wide herbaceous strip 

over the Pipeline in forested wetlands and riparian areas. Oregon LNG has committed to not topping trees and 

shrubs at 15 feet within 15 feet of the Pipeline in forested wetlands and riparian areas. Oregon LNG may prune 

branches up to a maximum height of 10 feet on the Pipeline side of the 10-foot-wide herbaceous strip. Otherwise, 

canopies would be managed to allow for full canopy closure in forested wetlands and riparian areas. The 

remaining permanent easement, TWS, and ATWS would be restored on a trajectory to reestablish preconstruction 

habitat conditions. 

Revegetation would occur immediately after construction has been completed. Native tree and shrub species 

would be established outside the 10-foot-wide maintenance corridor centered over the pipe. 

10.1.1 Preconstruction Monitoring 

Oregon LNG first completed 2 years of protocol level surveys for the northern spotted owl and marbled murrelet 

in August 2009 followed by the completion of one additional year of spotted owl surveys in 2012 and an 

additional 2 years of protocol marbled murrelets surveys in July 2013. Oregon LNG’s survey data, combined with 

data from private and public landowners, indicates that there are no nesting pairs of either species within the 

surveyed portions of the construction corridor or within an area subject to noise disturbance during construction. 

However, due to access restrictions, protocol spotted owl surveys could not be completed in 2013 and two areas 

of potentially suitable marbled murrelet habitat could not be surveyed in 2012 and 2013. Oregon LNG is 

committed to additional surveys, if the Pipeline construction schedule is delayed and to protocol surveys in areas 

that were previously unsurveyed. 

Assuming that vegetation clearing cannot be avoided during the nesting and breeding season, Oregon LNG would 

provide biologists to conduct a preconstruction reconnaissance of the Terminal and Pipeline corridor to identify 

10-2 EN0427151027PDX 
SECTION 10—MIGRATORY BIRDS 

any active migratory bird nests. If one or more active nests are identified within the construction corridor, 

biologists would mark the location(s) of the nest(s) in the field and on the construction plans and delay vegetation 

clearing around the active nest(s) until such time as the nest(s) have fledged or failed (due to natural causes). If 

one or more active nests are identified outside the construction corridor but nearby, the biologists would monitor 

the nest(s) during construction for signs of disturbance. If it appears that the monitored nest(s) are exhibiting 

disturbance that could lead to unintentional indirect take pursuant to the MBTA, construction should be halted 

temporarily until such time as the nest has fledged or failed (due to natural causes). Trees with nests may be cut 

during the non-nesting season. 

In the absence of field surveys, no harvest of trees in riparian areas would occur until migratory bird species have 

completed nesting activities, after August 15 and before April 15. Vegetation clearing shall not occur within 500 

feet of any existing eagle or peregrine falcon nest locations or trees used as perches by eagles and falcons unless a 

variance is granted, in writing, by USFWS. Band-tailed pigeon nesting or roosting tree(s), as well as any tree(s) 

near an existing great blue heron rookery, are not to be removed unless approved in writing by USFWS. Removing 

trees in a designated nest patch of a northern spotted owl shall be avoided. Removing trees in a cluster of trees 

known to provide nesting for marbled murrelets shall be avoided. 

Unintentional take, the observation that land clearing has unintentionally killed a migratory bird, shall be reported 

to Oregon LNG’s designated environmental compliance officer within 24 hours of such an incident. The 

environmental compliance officer would be responsible for reporting the unintentional take to USFWS. 

10.2 Compensatory Mitigation 

Oregon LNG is committed to complying with ODFW’s Habitat Mitigation Policy. Compensatory mitigation would 

be provided for impacts to terrestrial habitats, riparian areas. In addition, compensatory mitigation would be 

provided for permanent impacts to wetlands in compliance with state and federal wetland rules. Key elements of 

the habitat mitigation plan include provisions to support habitats that support the special-status species listed in 

Table 10-1. Oregon LNG is committed to supporting the preservation, restoration, and enhancement of upland 

and wetland prairie habitat that would support yellow-breasted chat, Oregon vesper sparrow, streaked horned 

lark, and other raptors. Compensatory mitigation would be provided to preserve, restore, and enhance riparian 

habitat in support of bald eagle, great blue heron, little wouldow flycatcher, purple martin, yellow-breasted chat, 

osprey, acorn woodpecker, and other raptors. For habitat impacts in the Coast Range, Oregon LNG is proposing to 

place conservation easements on large-blocks of land and manage them to create late-successional and oldgrowth habitat suitable for interior forest species such as olive sided flycatcher, other raptors, and for northern 

spotted owls and marbled murrelets. The habitat mitigation plan would be provided as an appendix to a 

Memorandum of Understanding established between Oregon LNG and the USFWS. 

10.3 Operational Mitigation, Post-Construction Monitoring, and 

Adaptive Management 

10.3.1 Construction Monitoring 

If one or more active nests are identified outside of the construction corridor but nearby, then a qualified biologist 

would monitor the nest(s) during construction for signs of disturbance. If it appears that the monitored nest(s) are 

exhibiting disturbance that could lead to unintentional indirect take pursuant to the MBTA, the environmental 

compliance inspector would immediately contact the USFWS to discuss potential actions. Potential actions may 

include a determination of no significant effect, a temporary work stoppage until nesting is completed, measures 

to muffle noise or vehicle traffic, or other measures to reduce disturbance. 

10.3.2 Contingency Salvage 

In the event that chicks or fledglings are found out of a nest during construction then the following actions would 

be taken. The USFWS would be contacted immediately during normal business hours. If eggs or chicks can be 

salvaged, then they would be taken to a wildlife rehabilitation center (such as the Portland Audubon Society) by a 

EN0427151027PDX 10-3 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

person authorized to handle migratory birds. The EI shall maintain a log of unintentional bird mortalities and file a 

report to the USFWS within 24 hours of an occurrence. 

10-4 EN0427151027PDX 
SECTION 11 

Reptiles and Amphibians 

Section 5.0 in the Applicant-Draft BA and Appendix 3D in Resource Report 3 (Oregon LNG, 2013) document 

Project effects on reptiles and amphibians. Federally threatened, endangered, and candidate amphibian and 

reptile species are not documented to occur within the Pipeline construction corridor or Project area. 

Preconstruction surveys and a search of the ORNHIC database of recorded sightings revealed that there have 

been no documented occurrences of federally threatened, endangered, and candidate reptile species in the 

Project area, nor is there any federal or state designated critical habitat. Hence, species-specific conservation 

measures are not recommended. 

Mitigation strategies recommended for aquatic, riparian, wetland, and upland habitats should minimize impacts 

to their habitat. Compensatory measures to acquire conservation easements for Coast Range riparian and upland 

habitats should in effect offset adverse effects on reptiles and amphibians. 

Biologists would be deployed to riparian areas immediately before land-clearing to search for and salvage 

amphibians and reptiles according to a plan approved by ODFW. Biologists would obtain state and federal 

collection and handling and salvage permits before Project construction. If riparian land clearing is not concurrent 

with Pipeline construction, then biologists would be deployed again immediately before construction to search for 

and salvage reptiles and amphibians. No in-stream work is anticipated during land-clearing. Thus, amphibian and 

reptile salvage need not focus in streams during the land-clearing phase. In-stream reptile and amphibian salvage 

would occur concurrently with the conduct of fish salvage before Pipeline construction. The reptile and amphibian 

salvage plan would be prepared concurrently with final engineering design. 

EN0427151027PDX 11-1 
SECTION 12 

Invertebrates 

Mitigation measures for invertebrates are based on findings documented in Section 5.4 of the Applicant-Draft BA. 

Section 5.5 addresses rare plants, several of which are considered host species for butterflies. 

12.1 Onsite Mitigation 

12.1.1 Fender’s Blue Butterfly (Icaricia icarioides fenderi) (Federal Endangered) 

Fender’s blue butterfly (FBB) is not known to occur within 2 miles of the proposed construction corridor. The 

nearest occurrence of suitable habitat within the action area is likely to be where this species’ dominant host 

plant, Kincaid’s lupine, has been documented to occur. Kincaid’s lupine was not observed within the 

portions of the Pipeline corridor surveyed in 2008 (see Applicant-Draft BA Appendix 14). 

Therefore, the Project may affect, but is not likely to adversely affect FBB. There would not be any effects on 

designated critical habitat. The following conservation measures are proposed to avoid or minimize effects on 

FBB: 

x Survey areas of potentially suitable habitat on 

x Properties where access was denied before construction. Target species are FBB, host species in the genus 

Lupinus, and nectar plants as listed in the draft joint recovery plan (USFWS, 2008b). 

x Limit removal of host or nectar plants to the minimum necessary for construction. 

x Restore areas that are cleared to preconstruction condition. Seed mixes and plantings in hedgerows, 

roadsides, or other nonagricultural areas would include nectar plants for FBB. 

x If larval host plants are identified during construction, consider the following avoidance and mitigation 

measures: 

 Implement micrositing: alter the Pipeline route slightly to avoid effects on plants. 

 Remove and conserve plants; replant following construction. However, current research has found that 

replanted adult plants have a low survival rate. Plants should either be relocated immediately or stored 

for later planting. Transplanting of adult plants during the growing season is not advised. Disturbance 

during late fall/winter, when plants are dormant, lowers effects on plants. Disturbing plants during winter 

may result in plants that do not thrive as well during the following growing season. 

 Mitigate by seeding an approved offsite area with the same species. Propagation from seed is more 

successful than transplanting of adult plants. 

 Obtain agency approval of mitigation, as well as monitoring for a defined period of time. 

12.1.2 Oregon Silverspot Butterfly (Speyeria zerene hippolyta) (Federal 

Threatened) 

Because typical suitable habitat for the larval host plant is not found at the Terminal or along the Pipeline 

construction right- of-way, and neither the Oregon silverspot butterfly nor its larval host plant has been 

documented within 2 miles of the proposed action even though dispersal habitat may be present, the Project may 

but is not likely to adversely affect the Oregon silverspot butterfly. No designated critical habitat occurs within the 

Project area. The nearest documented occurrence of the species is located approximately 5 miles south of the 

Terminal in the Clatsop Plains area (ORNHIC, 2009). 

The following conservation measures are proposed to avoid or minimize effects on the Oregon silverspot 

butterfly: 

EN0427151027PDX 12-1 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

x Survey areas of potentially suitable habitat on properties where access was denied before construction. 

Target species are Oregon silverspot butterfly, associated larval host species, and nectar plants as listed 

above. 

x Limit removal of host or nectar plants to the minimum necessary for construction. 

x Restore cleared areas to preconstruction condition. 

x If larval host plants are identified during construction, consider the following avoidance and mitigation 

measures: 

 Implement micrositing: the Pipeline route would be altered slightly to avoid effects on plants. 

 Remove and conserve plants; replant following construction. 

12.1.3 Taylor’s Checkerspot Butterfly (Euphydryas editha taylori) (Federal 

Candidate) 

Because no suitable habitat is present within the action area and neither this butterfly nor its larval host plant has 

been documented within the Project area, the proposed action may affect, but is not likely to adversely affect 

Taylor’s checkerspot butterfly. Critical habitat has not been designated for the species. 

The following conservation measures are proposed to avoid or minimize effects on Taylor’s checkerspot butterfly: 

x Survey areas of potentially suitable habitat on properties where access was denied before construction. 

Target species are Taylor’s checkerspot butterfly, associated larval host species, and nectar plants as listed 

above. 

x Limit removal of host or nectar plants to the minimum necessary for construction. 

x Restore cleared areas to preconstruction condition. 

x If larval host plants are identified during construction, consider the following avoidance and mitigation 

measures: 

 Implement micrositing: the Pipeline route would be altered slightly to avoid effects on plants. 

 Remove and conserve plants; replant following construction. 

12.2 Compensatory Mitigation 

FBB is associated with its primary host plants, Lupinus sulphureus ssp. kincaidii, L. arbustus (longspur lupine), and 

L. albicaulis (sickle-keeled lupine). The majority of adult foraging behavior occurs within 1 kilometer (km) of a host 

plant. Adult nectar sources are typically species that are not listed as threatened or endangered, such as: Allium 

acuminatum (tapertip onion), Allium amplectens (narrow-leaved onion), Calochortus tolmiei, Camassia quamash, 

Cryptantha intermedia (clearwater cryptantha), Eriophyllum lanatum, Geranium oreganum (Oregon geranium), 

Iris tenax (Oregon iris), Linum angustifolium (pale flax), Linum perenne (blue flax), Sidalcea campestris (meadow 

checker-mallow), Sidalcea malviflora ssp. virgata, Vicia cracca (bird vetch), V. sativa (common vetch) and V. 

hirsute (tiny vetch) (USFWS, 2008b). 

For the purposes of modeling potential direct and indirect take the USFWS recommended several steps to 

evaluate potential presence and habitat of FBB. Oregon LNG is committed to following the USFWS’s 

recommendations. 

1) Map potential suitable habitat (this step was completed for Oregon LNG by USFWS). 

a. Identify potential suitable habitat as high (Level 1), medium (Level 2) or low (Level 3) 

i. High-Oak savannah; remnant upland or wet prairie; abandoned pastures or fields (e.g., 

abandoned ryegrass field) 

ii. Medium-degraded wet prairies, fields, and pastures that are not plowed or infrequently plowed 

12-2 EN0427151027PDX 
SECTION 12—INVERTEBRATES 

iii. Low-Roadside ditches, fence rows, edges between fields and forest that are typically not 

cultivated, but often treated with herbicides 

b. Buffer each Level 1 habitat by 1 km 

2) Determine if there is any Level 3 habitat within the 1 km buffer of each Level 1 polygon 

a. Determine the number of Level 3 polygons 

b. Determine the number of acres of Level 3 habitat are present 

Compensatory mitigation for FBB is associated with habitat rare plant mitigation as described in Section 6.2.2. 

12.3 Operational Mitigation and Post-Construction Monitoring 

Invertebrates of concern are closely associated specific habitats and host plants. Operational mitigation, 

construction monitoring, and adaptive management for invertebrates is covered in Section 6.3. 

EN0427151027PDX 12-3 
SECTION 13 

Other Birds 

Mitigation measures for other birds are based on findings documented in Section 5.3 of the Applicant-Draft BA. 

13.1 Onsite Mitigation 

13.1.1 Streaked Horned Lark (Eremophila alpestris strigata) (Federal Threatened, 

State Sensitive) 

Potentially suitable habitat for the streaked horned lark is present in the Project area. Disturbance attributable to 

the proposed action has the potential to disturb this ground-nesting bird. No effects are expected on their 

populations. 

The following conservation measures are incorporated as part of the proposed action to minimize effects on 

streaked horned lark potentially suitable habitat: 

x Preconstruction clearance surveys would be conducted in areas of potential suitable habitat for streaked horn 

larks along the Pipeline between MP 82.7 and MP 86.8 if construction is planned to occur during the nesting 

season (March to July). 

x If nests are located in the construction area, postpone or reschedule construction until the completion or 

natural failure of nesting and fledging. 

x If streaked horned larks are confirmed in the Project area during construction, a speed limit of 15 mph would 

be maintained in areas of known or assumed horned lark occupied habitat to avoid flushing birds into 

oncoming traffic. 

x If streaked horned larks are confirmed in the Project area during construction, areas of affected native 

habitats would be mapped and restored with an ODFW-approved native seed mix. 

Standard nest survey methods would be used to survey suitable habitat within the disturbance areas for the 

potential presence of nesting streaked horned larks. Experienced biologists would conduct the preconstruction 

clearance nest surveys by walking 75-foot-wide transects while sweeping the survey area with binoculars for the 

presence of ground nests associated with the species. If an active nest is identified within the disturbance area 

during preconstruction clearance surveys of suitable habitats (described above), Oregon LNG would take one of 

the following actions: (1) install and maintain an avoidance buffer (defined through consultation with USFWS) 

until the young have fledged or the nesting season ends; (2) modify the Pipeline route (if practicable); or (3) 

provide compensatory mitigation in the form of land acquisition. 

13.1.2 Western Yellow-billed Cuckoo (Coccyzus americanus) (Federal Threatened) 

No riparian cottonwood trees would be removed from the small patches of cottonwood riparian habitat along the 

Pipeline corridor. A few cottonwoods may be removed from mixed deciduous stands within the action area, but 

these areas are not considered suitable habitat for the western yellow-billed cuckoo. Therefore, no habitat loss is 

expected as a result of the proposed action. 

Oregon LNG would implement the following conservation measures to avoid or minimize effects on western 

yellow-billed cuckoos: 

x Preconstruction clearance surveys would be conducted on the west and east banks of the Columbia River 

where the Pipeline crosses the only portion of the action area considered marginally suitable for yellow-billed 

cuckoo nesting habitat. 

x If any protected species are observed during preconstruction clearance surveys, the results would be 

submitted to USFWS prior to initiation of construction. 

EN0427151027PDX 13-1 
APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

13.2 Effects and Compensatory Mitigation 

No permanent effects on suitable or critical habitat are anticipated. These two species are not expected to be 

adversely affected nor require compensatory mitigation. 

If future preconstruction clearance surveys result in a streaked horned lark detection within 325 feet of the 

Pipeline, Oregon LNG would immediately notify and consult with USFWS to identify measures necessary to 

prevent “take” or “harassment.” Possible measures include construction deferment, habitat replacement via 

land acquisition, or route changes (as practicable). 

13-2 EN0427151027PDX 
SECTION 14 

Mammals 

Section 5.2.1 in the Applicant-Draft BA provides the basis for mitigation measures recommended for the 

Columbian White-tailed Deer. Columbian white-tailed deer may be directly affected by temporary habitat loss 

during construction of the Pipeline. This effect would be temporary and of short duration. In addition, habitat 

would not likely be affected in any significant way because the species’ habitat in the Pipeline corridor near the 

species’ current range is limited and of low quality relative to the quality of the surrounding habitat, affected 

habitat (i.e., primarily agricultural fields) would be returned to preconstruction conditions, and only a small 

amount of potentially suitable habitat would be affected. 

14.1 Onsite Mitigation 

14.1.1 Columbia White Tailed Deer (Odocoileus virginianus leucurus) 

(Endangered) 

Oregon LNG would implement the following conservation measures to avoid or minimize effects on Columbian 

white-tailed deer: 

x Preconstruction surveys would be conducted in suitable habitat within the action area to identify any 

Columbian white-tailed deer or signs of the subspecies in the vicinity of the Project. 

x Project personnel would be trained in the identification of Columbian white-tailed deer and instructed to 

reduce vehicle speeds to 15 mph around the Project site in areas of potentially suitable habitat (MP 81.5 to 

MP 84.4) to avoid vehicle-deer collisions. Project personnel would also be instructed not to approach adults or 

fawns at any time. 

x If Columbian white-tailed deer are observed within the action area during preconstruction surveys or during 

construction, Oregon LNG would work with USFWS and ODFW to identify appropriate mitigation. For 

example, construction and restoration activities generating noise and visual activity above local ambient noise 

and visual activity levels in areas that support Columbian white-tailed deer (MP 82.7 to MP 84.4) may be 

avoided during the fawning season from 1 June to 15 July. 

x The permanent ROW and temporarily affected areas would be revegetated with native species that would 

create suitable habitat for Columbian white-tailed deer browsing. 

14.2 Effects and Compensatory Mitigation 

Columbian white-tailed deer are not known to occur in the action area and potentially suitable habitat in the 

action area is very limited and of relatively low quality compared to the general vicinity. However, there is a low 

likelihood that the species could occur in the area during construction, which could result in adverse effects such 

as disturbance of fawning or does or abandonment and predation of fawns. Therefore, a may affect, not likely to 

adversely affect determination is warranted for Columbian white-tailed deer. 

Because no critical habitat has been designated for the species, the proposed action would have no effect on 

designated critical habitat for this species.

EN0427151027PDX 14-1 
SECTION 15 

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Bottom, D.L., K.K. Jones, and M.J. Herring. 1984. Fishes of the Columbia River Estuary. Columbia River Estuary Data 

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49 Code of Federal Regulations (CFR) 192. Transportation of Natural and Other Gas by Pipeline: Minimum Federal 

Safety Standards. Subpart M, “Maintenance,” 192.707. 

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CH2M HILL. 2005. Wildlife Inventory. Provided in Appendix 3A to Resource Report 3, Fish Wildlife, and Vegetation. 

CH2M HILL. 2009. Oregon LNG: Characterizing Deforestation Impacts on Stream Temperature. Originally filed with 

Federal Energy Regulatory Commission on May 13, 2009. 

CH2M HILL. 2011. Oregon LNG Terminal and Oregon Pipeline Project—Underwater Noise, Propagation, 

Monitoring, and Mitigation. Prepared for LNG Development Corporation, LLC, and Oregon Pipeline Company, LLC.

CH2M HILL. 2013a. Applicant-Prepared Draft Biological Assessment and Essential Fish Habitat Assessment for the 

Oregon LNG Terminal and Oregon Pipeline Project. Prepared for LNG Development Corporation, LLC, and Oregon 

Pipeline Company, LLC. Originally Filed with the Federal Energy Regulatory Commission in May 2009. Second 

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LNG. Prepared for LNG Development Company, LLC, and Oregon Pipeline Company, LLC. Appendix 2B to Resource 

Report 2—Water Use and Quality. June 2013. 

CH2M HILL. 2013c. Stormwater Pollution Prevention Plan for Construction of the Oregon LNG Terminal and 

Pipeline, Including Erosion Prevention and Sediment Control Plan; Spill Prevention, Control, and Countermeasures 

Plan; and Frac-Out Contingency Plan. Prepared for LNG Development Corporation, LLC, and Oregon Pipeline 

Company, LLC. May.

CH2M HILL. 2013d. Oregon LNG Pipeline Waterbody Crossing: Fish Salvage Plan. Prepared for LNG Development 

Company, LLC, and Oregon Pipeline Company, LLC. May 21. 

CH2M HILL. 2013e. Landslide and Debris Flow: Relative Risk Assessment for the Bidirectional Project Pipeline. 

Prepared for LNG Development Company, LLC, and Oregon Pipeline Company, LLC. November. 

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Monitoring Findings Report. 

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Cowlitz County. 2013. Cowlitz County Noxious Weed Program. 2013 County Weed List. 

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Resources Conservation Service Technical Bulletin 11. 

Federal Energy Regulatory Commission (FERC). 2013a. Upland Erosion Control, Revegetation, and Maintenance 

Plan. http://www.ferc.gov/industries/gas/enviro/guidelines.asp. May. 

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Procedures. http://www.ferc.gov/industries/gas/enviro/guidelines.asp. May. 

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Good, T.P., R.S. Waples, and P. Adams (eds). 2005. Updated Status of Federally Listed ESUs of West Coast Salmon 

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Gulf Interstate Engineering. 1999. Temporary Right-of-Way Width Requirements for Pipeline Construction. INGAA 

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Haase, Rose R. and D.L. 2000. Guide to Reforestation in Oregon. College of Forestry, Oregon State University Press. 

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Hydroacoustic Effects of Pile Driving on Fish. Prepared for the California Department of Transportation. 

Illingworth and Rodkin. 2007. Compendium of Pile Driving Sound Data. Prepared for the California Department of 

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29, 2009. 

Jepsen, D.B., and K. Leader. 2008. Abundance Monitoring of Juvenile Salmonids in Oregon Coastal and Lower 

Columbia Streams, 2007. Monitoring Program Report Number OPSW-ODFW-2008-1, Oregon Department of Fish 

and Wildlife, Salem. 

Johnson GE, and HL Diefenderfer (eds.). 2008. Evaluating Cumulative Ecosystem Response to Restoration Projects 

in the Columbia River Estuary, Annual Report 2007. PNNL-17437, prepared by Pacific Northwest National 

Laboratory, Richland, Washington, for the United States Army Corps of Engineers, Portland District, Portland, 

Oregon. 

Knudsen, F.R., C.B. Schreck, S.M. Knapp, P.S. Enger, and O. Sand. 1997. “Infrasound Produces Flight and Avoidance 

Responses in Pacific Juvenile Salmonids.” Journal of Fish Biology. 51:824-829. 

Koski, K. V. 2009. “The Fate of Coho Salmon Nomads: The Story of an Estuarine-Rearing Strategy Promoting 

Resilience.” Ecology and Society 14(1). 

McCabe, G.T. Jr., S. A. Hinton, and R. L. Emmett. 1993. “Report P. Distribution, Abundance, and Community 

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(Available from Bonneville Power Administration, Division of Fish and Wildlife-PJ, P.O. Box 3621, Portland, Oregon 

97208.) 

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SECTION 15—REFERENCES 

McCabe, G.T. Jr. and S.A. Hinton. 1996. Benthic Invertebrates and Sediment Characteristics at 10 DredgedMaterial Disposal Areas (Beach Nourishment) in the Lower Columbia River, 1994-1995. Report to the United States 

Army Corps of Engineers, Contract E96940050. 

McCabe, G.T. Jr., S.A. Hinton, and R.L. Emmett. 1998. “Benthic Invertebrates and Sediment Characteristics in a 

Shallow Navigation Channel of the Lower Columbia River, Before and After Dredging.” Northwest Science.

72(2):116–126. 

McCullah, J. and D. Gray. 2005. Environmentally Sensitive Channel and Bank-Protection Measures. National

Cooperative Highway Research Program Report 544. Transportation Research Board. Washington, D.C. 

McElhany, P., M. Chilcote, J. Myers, and R. Beamsderfer. 2007. Viability Status of Oregon Salmon and Steelhead 

Populations in the Willamette and Lower Columbia Basins. Prepared for Oregon Department of Fish and Wildlife 

and National Marine Fisheries Service. 

National Marine Fisheries Service (NMFS). 2000. White Paper: Passage of Juvenile and Adult Salmonids past 

Columbia and Snake River Dams. Northwest Fisheries Science Center, 2725 Montlake Blvd. E., Seattle, 

Washington, 98112-2097. 

National Marine Fisheries Services (NMFS). 2003. Endangered Species Act Section 7 Formal Consultation and 

Magnuson-Stevens Fishery and Conservation Management Act Essential Fish Habitat Consultation, West 

Breakwater Replacement Project at the West Mooring Basin in Astoria, Columbia River Estuary, Clatsop County, 

Oregon. Corps No. 200100353. 

National Marine Fisheries Services (NMFS). 2005. Draft Snake River Salmon and Steelhead Recovery Plan. 

http://idahosalmonrecovery.net/index.html. Accessed on 07/01/2009. 

National Marine Fisheries Service (NMFS). 2008. Vessel Strike Avoidance Measures and Reporting. Provided by 

NOAA Fisheries, Northwest Region, to NorthernStar on August 11, 2008. Re: FERC Condition #38. 

Natural Resources Conservation Service (NRCS). 2000. Oregon & Washington Guide for Conservation Seedings and 

Plantings. United States Department of Agriculture-Natural Resources Conservation Service, Portland, Oregon. 

April 2000. 

Nez Perce Tribe. 2004. Snake Hells Canyon Subbasin Assessment. 

http://www.nwcouncil.org/fw/subbasinplanning/snakehellscanyon/plan/. Accessed on 07/02/2009. 

Oregon Department of Environmental Quality (ODEQ). 2005. Erosion and Sediment Control Manual. April. 

Oregon Department of Fish and Wildlife (ODFW). 2005. Oregon Native Fish Status Report. 

Oregon Department of Fish and Wildlife (ODFW). 2006. The Oregon Conservation Strategy. Oregon Department of 

Fish and Wildlife, Salem, Oregon. February. 

Oregon Department of Fish and Wildlife (ODFW). 2008. Willamette Falls Fish Passage Data. 

http://www.dfw.state.or.us/fish/fish_counts/wouldamette/wouldamette_falls_archive.asp. Accessed November 

2008. 

Oregon Department of Transportation (ODOT). 2005. ODOT Erosion Control Manual, Guidelines for Developing 

and Implementing Erosion and Sediment Controls. Prepared by Harza Engineering Company and ODOT 

Geo/Environmental Section. Oregon Department of Transportation. Salem, Oregon. 

Oregon LNG. 2013. Application of LNG Development Company, LLC (d/b/a Oregon LNG) for Authorization Under 

Section 3(a) of the Natural Gas Act to Site, Construct, and Operate Bidirectional Liquefied Natural Gas Facilities 

and Application of Oregon Pipeline Company, LLC, Under Section 7(c) of the Natural Gas Act to Construct, Own, 

and Operate Interstate Natural Gas Pipeline Facilities, Environmental Report (Exhibit F/F-I), Oregon LNG Terminal 

and Oregon Pipeline Project, Warrenton, Oregon. Resource Reports 1 through 13. Submitted to the Federal Energy 

Regulatory Commission on June 7, 2013. Subsequently assigned Docket Numbers CP09-6-000 and CP09-7-000. 

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APPLICANT-PREPARED CONCEPTUAL MITIGATION PLAN FOR THE OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

Oregon LNG. 2014a. Supplement to June 7, 2013, Amendment to Application Under Section 7(c) of the Natural Gas 

Act to Construct, Own and Operate Natural Gas Pipeline Facilities: Proposed Pipeline Modifications. Prepared for 

Federal Energy Regulatory Commission. Docket No. CP09-7-001. April. 

Oregon LNG. 2014b. LNG Development Company, LLC (d/b/a Oregon LNG) and Oregon Pipeline Company, LLC

Supplemental Information. Docket No. CP09-6-001 and CP09-7-001. Prepared for Federal Energy Regulatory 

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Oregon Watershed Enhancement Board (OWEB). 2009. Coast Priorities Limiting Factors Report Generator. 

www.oregonwatershed.net/coast. Report generated January 15, 2009. 

Pomeroy Conservation District. 2004. Lower Snake Mainstream Subbasin Plan. 

Quinn, T. 2005. The Behavior and Ecology of Pacific Salmon and Trout. American Fisheries Society, Bethesda, 

Maryland, and the University of Washington Press, Seattle, Washington. 378 pages. 

Rashin, E.J. Bell and C. Clishe. 1993. Effectiveness of Forest Road and Timber Harvest Best Management Practices 

with Respect to Sediment-Related Water Quality Practices. Interim Report No. 1. Environmental Investigations and 

Laboratory Services Program, Watershed Assessments Section. June 1993. 

Rosgen, Dave. 1996. Applied River Morphology. Wildland Hydrology, Pagosa Springs, Colorado. 

Salmon Recovery Division (SRD), Northwest Region National Marine Fisheries Service (NMFS). 2007. National 

Marine Fisheries Service Endangered Species Act (ESA) Section 7 Consultation Biological Opinion and MagnusonStevens Act Essential Fish Habitat Consultation USFWS Artificial Propagation Programs in the Lower Columbia and 

Middle Columbia. Consultation Number: 2004/02625. 

Scott, W.B. and E.J. Crossman, 1973. Citation, Scott, W.B. and E.J. Crossman. 1973. “Freshwater Fishes of Canada.” 

Bulletin of the Fisheries Research Board of Canada 184:1-966. 

Thomas, J.W., E.D. Forsman, J.B. Lint, E.C. Meslow, B.R. Noon, and J. Verner. 1990. A Conservation Strategy for the 

Northern Spotted Owl. Rep. of Interagency Scientific Committee to Address the Conservation of the Northern 

Spotted Owl. United States Department of the Interior, United States Department of Agriculture, Portland, 

Oregon. 427 pp. + maps.

Turnstone Environmental Consultants (TEC). 2008. Habitat Assessment—Potential Northern Spotted Owl and 

Marbled Murrelet Habitat on Lands Adjacent to the Oregon LNG Pipeline. Prepared for CH2M HILL. April. 

Turnstone Environmental Consultants (TEC). 2009. Final Report for Oregon LNG—Northern Spotted Owl and 

Marbled Murrelet Surveys. Prepared for CH2M HILL. Filed with Federal Energy Regulatory Commission by Oregon 

LNG on October 13, 2009. 

Turnstone Environmental Consultants (TEC). 2012. Northern Spotted Owl and Marbled Murrelet Habitat 

Assessment for Oregon LNG Reroute. Prepared for CH2M HILL. June 18. 

Turnstone Environmental Consultants (TEC). 2013. Oregon LNG Project Survey Report 2013—Marbled Murrelet 

and Northern Spotted Owl. Prepared for CH2M HILL. October.

Turnstone Environmental Consultants (TEC). 2014. Oregon LNG Project Survey Report 2014 –Marbled Murrelet 

and Northern Spotted Owl. 

Turnstone Environmental Consultants (TEC) and CH2M HILL. 2015. Northern Spotted Owl and Marbled Murrelet 

Habitat and Impact Assessment. February. 

U.S. Army Corps of Engineers (USACE). 2001. Biological Assessment, Columbia River Channel Improvement Project. 

U.S. Army Corps of Engineers, December 28, 2001. 

U.S. Environmental Protection Agency and United States Army Corps of Engineers. 2006. Northwest Regional 

Sediment Evaluation Framework, Interim Final. United States Army Corps of Engineers (USACE). 

15-4 EN0427151027PDX 
SECTION 15—REFERENCES 

http://www.nws.usace.army.mil/ publicmenu/ DOCUMENTS/ DMMO/ RSET_Interim_Final.pdf. Accessed on 

February 18, 2009. 

U.S. Fish and Wildlife Service (USFWS). 1981. U.S. Fish and Wildlife Service Mitigation Policy. Federal Register

46(15):7644-7663 (as corrected in the Federal Register of February 4, 1981). 

U.S. Fish and Wildlife Service (USFWS). 1997. Recovery Plan for the Threatened Marbled Murrelet (Brachyramphus 

marmoratus) in Washington, Oregon, and California. U.S. Fish and Wildlife Service, Portland, Oregon. 203 pp. 

U.S. Fish and Wildlife Service (USFWS). 2002. Endangered Species Act —Section 7 Consultation and MagnusonStevens Act Essential Fish Habitat Consultation, Biological Opinion, Columbia River Federal Navigation Channel 

Improvements Project. 

U.S. Fish and Wildlife Service (USFWS). 2008a. Final Recovery Plan for the Northern Spotted Owl, Strix occidentalis 

caurina. U.S. Fish and Wildlife Service, Portland, Oregon. 

U.S. Fish and Wildlife Service (USFWS). 2008b. Draft Recovery Plan for the Prairie Species of Western Oregon and 

Southwestern Washington. Portland, Oregon. 

U.S. Fish and Wildlife Service (USFWS). 2011. Revised Recovery Plan for the Northern Spotted Owl (Strix 

occidentalis caurina). U.S. Fish and Wildlife Service, Portland, Oregon. xvi + 258 pp. Available online: 

http://www.fws.gov/oregonfwo/Species/Data/NorthernSpottedOwl/Recovery/Library/Documents/RevisedNSORe

cPlan2011.pdf. Accessed on November 11, 2013. 

U.S. Fish and Wildlife Service (USFWS). 2014. Revised Conservation Framework for the Northern Spotted Owl and 

Marbled Murrelet: Jordan Cove Energy and Pacific Connector Gas Pipeline Project. USFWS, Ecological Services, 

Region 1. With support from PC Trask & Associates, Inc. in collaboration with Mason, Bruce & Girard, Inc. Docket 

Nos. CP13-483-000 and CP13-492-000. August. 

Young, Doug/U.S. Fish and Wildlife Service (USFWS). 2014. Personal communication by e-mail with Jay 

Lorenz/CH2M HILL. October 31. 

EN0427151027PDX 15-5 
 

Tables 

 
 

TABLE 1-1 

Oregon Department of Fish and Wildlife Mitigation Goals and Implementation Standards by Habitat Category 

Habitat 

Category Mitigation Goal Achieved by 

Category 1 No loss of habitat quantity or quality Avoidance 

Category 2 No net loss of habitat quantity or quality and to provide 

a net benefit of habitat quantity or quality 

In-kind, in-proximity mitigation 

Category 3 No net loss of habitat quantity or quality In-kind, in-proximity mitigation 

Category 4 No net loss of habitat quantity or quality In-kind or out-of-kind, in-proximity or off-proximity 

mitigation 

Category 5 Net benefit in habitat quantity and quality Actions that improve habitat conditions 

Category 6 Minimize impacts Conscientious Project design 

Source: Oregon Department of Fish and Wildlife (ODFW). 2006. The Oregon Conservation Strategy. Oregon Department of Fish 

and Wildlife, Salem, Oregon. February. 

PAGE 1 OF 1 
 

TABLE 3-1 

Definitions of Categories of Relative Intensity for Habitat Removal and Other Indirect Effects for the Northern Spotted Owl 

Habitat Category Definition 

Severe Removal of a Site/Activity Center, or otherwise cause a northern spotted owl home range to become 

nonfunctional (loss of the home range) 

High Removal of any High NRF acres from any portion of the home range, or Project corridor bisects the home 

range and impacts the Core Area (passes within 0.5 mile of the Site/Activity Center), or removal of > 5 

acres total of NRF from any portion of the home range, or removal of > 2 acres total of NRF within the 

Core Area 

Moderate Project corridor bisects the home range and does not impact the Core Area (passes within 0.5 mile of the 

Site/Activity Center), or removal of 2-5 acres total of NRF from any portion of the home range, or 

removal of < 2 acres total of NRF within the Core Area 

Low Project corridor touches the home range boundary, but does not bisect it, or removal of < 2 acres total of 

NRF within a home range (all outside of the Core Area), or the Habitat is located outside of a northern 

spotted owl home range 

 

PAGE 1 OF 1 
 

TABLE 3-2 

Impacts and Proposed Mitigation for Habitat Removal 

Impact Category Habitat Impacts 

(acres) 

Habitat 

Type 

Mitigation 

Ratio 

Unadjusted 

Mitigation 

(acres) 

Adjustment 

Factor 

Adjusted 

Mitigation 

(acres) 

High 

24 NRF 4.00 98 1.00 98 

18 DISP 2.50 44 1.00 44 

1 CAP 2.00 2 1.00 2 

Mod 

7 NRF 3.00 21 1.00 21 

0 DISP 2.00 1 1.00 1 

4 CAP 1.75 7 1.00 7 

Low and outside 

19 NRF 3.00 58 1.00 58 

197 DISP 2.00 393 1.00 393 

0 CAP 1.50 0 1.00 0 

Total 271 624 624 

 

PAGE 1 OF 1 
 

TABLE 3-3

Impacts and Proposed Mitigation for Other Indirect Effects 

 

Impact Category Habitat Impacts 

(acres) 

Habitat 

Type 

Mitigation 

Ratio 

Unadjusted 

Mitigation 

(acres) 

Adjustment 

Factor 

Adjusted 

Mitigation 

(acres) 

High 

48.93 NRF 4.00 195.72 0.80 156.58 

27.48 Dispersal 2.50 68.70 0.35 24.05 

1.39 Capable 2.00 2.78 0.30 0.83 

Mod 

7.82 NRF 3.00 23.46 0.80 18.77 

0.96 Dispersal 2.00 1.92 0.23 0.44 

1.76 Capable 1.75 3.08 0.20 0.62 

Low and outside 

0 NRF 3.00 0 0.60 0 

449.90 Dispersal 2.00 899.80 0.13 116.97 

0 Capable 1.50 0 0.10 0 

Total 538.24 1195.46 318.26 

PAGE 1 OF 1 
 

TABLE 3-4

Summary of Adjusted Habitat Acquisition (acres) for Removal and Other Indirect Effects 

Habitat Type Other Indirect Effects Removal Total

NRF 175.35 148.96 324.30

Dispersal 141.46 346.23 487.83 

Capable 1.45 6.38 7.83

Total 318.26 501.57 819.96

 

PAGE 1 OF 1 
 

TABLE 3-5 

Theoretical Scaling of Habitat Acquisitions Dependent on Availability in the Marketplace 

Habitat Type to Be 

Mitigated 

Adjusted Mitigation 

Obligation (acres) 

Multiplier (Division) for 

Converting to Same or 

Different Habitat Type 

Out-of-Kind 

Habitat Type 

Out-of-Kind Area 

(acres) to be Acquired 

NRF 324.30 2.5 Dispersal 810.75 

NRF 324.30 4.0 Capable 1,297.20 

Dispersal 487.83 2.5 Capable 1,219.58 

Dispersal 487.83 (2.5) NRF 195.13 

Capable 7.83 (2.5) Dispersal 3.13 

Capable 7.83 (4) NRF 1.96 

PAGE 1 OF 1 
 

TABLE 3-6 

Silvicultural Treatment Ratios for Northern Spotted Owl Habitat Removal and Other Indirect Impacts to Northern Spotted Owl 

Habitat Category Impacted HIGH Impacted Home

Ranges

MODERATE Impacted Home 

Ranges

LOW Impacted Home

Ranges and OUTSIDE Home 

Ranges

High NRF N/A N/A N/A

NRF N/A N/A N/A

Dispersal 5:1 4:1 3:1

Capable 3:1 2.5:1 2:1

N/A = not applicable 

PAGE 1 OF 1 
 

TABLE 4-1 

Marbled Murrelet Suitable Habitat Units within the Action Area 

Site No. Status* Inland Zone Owner NWFP Land Use 

Allocation 

M1901 OSH 1 Private None 

M3001 OSH 1 Private None 

M3901 USH 1 ODOT None 

ALD1 USH 1 ODF None 

ALD2 USH 1 ODF None 

ALD3 USH 1 ODF None 

M4601 USH 1 ODF None 

WOLF USH 1 ODF None 

* OSH = assumed occupied suitable habitat; USH = unoccupied suitable habitat 

PAGE 1 OF 1 
 

TABLE 4-2 

Definitions of Categories of Relative Intensity for Habitat Removal and Other Indirect Effects for the Marbled Murrelet 

Habitat Category Definition 

Severe Removal of a known nest tree in OSH at any time of year, or otherwise cause a marbled murrelet SHU to 

become nonfunctional 

High Removal of any Suitable Habitat, or removal of Recruitment Habitat within the 300-foot buffer around the 

Suitable Habitat (regardless of whether SHU is in Critical Habitat or not) 

Moderate Removal of any Capable Habitat within the 300-foot buffer around the Suitable Habitat (regardless of 

whether SHU is in Critical Habitat or not), or 

removal of any Recruitment Habitat within the 0.5-mile buffer around the Suitable Habitat located within a 

SHU in Critical Habitat 

Low Removal of Recruitment Habitat outside of an SHU, or 

removal of Capable Habitat within the 0.5-mile buffer around the Suitable Habitat located within a SHU in 

Critical Habitat 

PAGE 1 OF 1 
 

TABLE 4-3 

Removal Impacts and Habitat Acquisition for the Marbled Murrelet 

Impact Categorya Habitat Impact 

(acres) 

Habitat 

Type 

Mitigation 

Ratio 

Mitigation 

(acres) 

Adjustment 

Factor 

Adjusted 

Mitigation 

(acres) 

High 

1.77 Suitable 8.00 14.16 1.00 14.16 

12.89 Recruitment 4.00 51.56 1.00 51.56 

16.11 Capable 2.00 32.22 1.00 32.22 

Mod 

0.00 Suitable N/A N/A 1.00 0.00 

2.03 Recruitment 3.00 6.09 1.00 6.09 

5.18 Capable 1.75 9.07 1.00 9.07 

Low and outside 

N/A Suitable N/A N/A 1.00 0.00 

54.59 Recruitment 2.50 136.48 1.00 136.48 

564.60 Capable N/A 564.60 0.00 0.00 

a There are no impacts in the “severe” category. 

PAGE 1 OF 1 
 

TABLE 4-4 

Other Indirect Impacts and Habitat Acquisition for the Marbled Murrelet

Impact 

Categorya 

Habitat Impact 

(acres) 

Habitat 

Type 

Mitigation 

Ratio 

Mitigation 

(acres) 

Adjustment 

Factor 

Adjusted 

Mitigation 

(acres) 

High 

5.99 Suitable 8.00 47.92 0.80 38.34 

22.26 Recruitment 4.00 89.04 0.35 31.16 

26.10 Capable 2.00 52.20 0.30 15.66 

Mod 

0.00 Suitable 0.00 0.00 0.80 0.00 

0.00 Recruitment 3.00 0.00 0.23 0.00 

0.00 Capable 1.75 0.00 0.20 0.00 

Low and outside 

N/A Suitable 0.00 0.60 0.00 

34.60 Recruitment 2.50 86.50 0.13 11.25 

0.00 Capable 0.00 0.00 0.10 0.00 

a There are no impacts in the “severe” category. 

PAGE 1 OF 1 
 

TABLE 4-5 

Summary of Adjusted Habitat Acquisition (acres) for Removal and Other Indirect Effects 

Habitat Type Other Indirect Effects Removal Total 

Suitable 38.34 14.16 52.50

Recruitment 42.41 194.13 236.54

Capable 15.66 41.29 56.95

Total 96.41 249.58 345.99

PAGE 1 OF 1 
 

TABLE 4-6 

Hypothetical Adjustments to Mitigation for Out-of-kind Habitat Acquisitions 

Habitat Type to 

be Mitigated 

Adjusted Mitigation 

Obligation (acres) 

Multiplier (Division) for 

Converting to Different 

Habitat Type 

Out-of-Kind 

Habitat Type 

Out-of-Kind Area 

(acres) to be 

Acquired 

Suitable 52.50 1.5 Recruitment 78.75 

Suitable 52.50 5 Capable 262.50 

Recruitment 236.54 3.5 Capable 827.89 

Recruitment 236.54 (1.5) Suitable 157.69 

Capable 56.95 (3.5) Recruitment 16.27 

Capable 56.95 (4.0) Suitable 14.06 

PAGE 1 OF 1 
 

TABLE 4-7 

Mitigation Ratios for Silvicultural Treatments for Indirect Effects on Marbled Murrelet Habitat 

Habitat Category Impacted HIGH-Impacted Suitable 

Habitat Units 

MODERATE Impacted 

Suitable Habitat Units 

LOW Impacted Suitable 

Habitat Units and OUTSIDE 

Suitable Habitat Units

Recruitment N/A N/A 4:11

Capable 5:1 4:1 3:1

PAGE 1 OF 1 
TABLE 5-1

Rivers and Streams Crossed Using HDD

Pipeline 

Milepost River or Stream Crossed Length (feet) 

Milepost 

Begin End 

Columbia River and Estuaries 

Terminal Skipanon River 1,950 NA NA 

0.4 Levee/Columbia Rivera 1,450 0.3 0.6 

1.0 Adair Slough 1,480 0.9 1.2 

3.0 Lewis and Clark River 2,950 2.8 3.4 

5.2 Lewis and Clark River 2,450 5.0 5.5 

5.0 Unnamed Waterway Included in HDD listed above 

5.2 Tributary of Lewis and Clark River Included in HDD listed above 

5.4 Tributary of Lewis and Clark River Included in HDD listed above 

5.7 Lewis and Clark River 2,100 5.6 6.0 

5.8 Tributary of Lewis and Clark River Included in HDD listed above

11 Lewis and Clark River 1,320 10.9 11.2 

Northern Oregon Coastal Basin Rivers 

33.5 Nehalem River 2,010 33.3 33.7 

41.0 Rock Creek 1,910 40.9 41.3 

43.1 South Fork Rock Creek 2,920 43.1 43.6 

43.4 Bear Creek Included in HDD listed above 

43.5 Tributary of Bear Creek 

57.7 Rock Creek 3,000 57.5 58.1 

57.7 Tributary of Rock Creek Included in HDD listed above 

57.7 Braided Channel to Rock Creek Included in HDD listed above 

63.8 Nehalem River 3,370 63.6 64.3 

Columbia Basin 

82.3 Columbia River 5,030 81.9 82.8 

82.0 Dyna Nobel Channel Included in HDD listed above 

a Horizontal directional drill (HDD) is tangential to the Columbia River in this location and the HDD is proposed 

to minimize impacts to an existing levee and tidal wetlands. 
PAGE 1 OIF 1 

TABLE 5-2 

Potential Direct Take of Special-Status Species from Ballast/Cooling Water Withdrawal, Pile-Driving Noise, and Fish Salvage 

Species 

Annual Take of Juveniles 

Resulting from Ballast 

Water Withdrawal 

Take Resulting from 

Pile-Driving Noise 

Take of Juveniles 

Resulting from Fish Salvage 

Endangered Species 

Upper Columbia River Steelhead 

Trout (O. mykiss) 

0 0 0 

Snake River Sockeye Salmon 

(O. nerka) 

0 0 0 

Upper Columbia River Spring-run 

Chinook Salmon (O. tshawytscha) 

0 0 0 

Threatened species 

Lower Columbia River Steelhead 

Trout (O mykiss) 

0 Harassment of adults 0 

Middle Columbia River Steelhead 

Trout (O. mykiss) 

0 Harassment of adults 0 

Upper Willamette River Steelhead 

Trout (O. mykiss) 

0 Harassment of adults 0 

Snake River Basin Steelhead Trout 

(O. mykiss) 

0 0 0 

Lower Columbia River Chinook 

Salmon (O. tshawytscha) 

3.62 122 0 

Upper Willamette River Chinook 

Salmon (O. tshawytscha) 

0.04 0 0 

Snake River Fall Chinook Salmon 

(O. tshawytscha) 

0.15 3 0 

Snake River Spring/Summer-run 

Chinook Salmon (O. tshawytscha) 

0.01 0 0 

Lower Columbia River Coho Salmon 

(O. kisutch) 

0.22 Harassment of adults 58 

Oregon Coast Coho Salmon 

(O. kisutch) 

0 0 178 

North American Green Sturgeon 

(A. medirostris) 

0 0 0 

Columbia River Chum Salmon 

(O. keta) 

0 Harassment of adults 

and juveniles 

0 

Eulachon (T. pacificus) Several thousand larvae (up to 

0.005% of the estuarine 

population) 

0 0 
TABLE 5-3 Degree to which Species are Affected by Unquantified Sources of Take

Species 

Terminal Pipeline 

Artificial 

Light and 

Shading 

Food 

Web 

Effects 

Dredge 

Entrainment 

Turbidity 

(dredging and 

disposal) 

Habitat 

Loss/

Alteration 

Fish 

Salvage 

Passage 

Impediments 

Habitat 

Loss/

Alteration 

Endangered Species Upper Columbia River Steelhead Trout (O. mykiss) NA NA NA NA NA NA NA NA Snake River Sockeye Salmon (O. nerka) NA NA NA NA NA NA NA NA Upper Columbia River Spring-run Chinook Salmon (O. tshawytscha) 

NA NA NA NA NA NA NA NA 

Threatened Species Lower Columbia River Steelhead Trout (O. mykiss) NA NA NA NA NA NA NA NA Middle Columbia River Steelhead Trout (O. mykiss) NA NA NA NA NA NA NA NA Upper Willamette River Steelhead Trout (O. mykiss) NA NA NA NA NA NA NA NA Snake River Basin Steelhead Trout (O. mykiss) NA NA NA NA NA NA NA NA Lower Columbia River Chinook Salmon (O. tshawytscha) 3 3 3 3 3 NA NA NA Upper Willamette River Chinook Salmon (O. tshawytscha) 2 1 1 1 1 NA NA NA Snake River Fall Chinook Salmon (O. tshawytscha) 1 2 1 1 1 NA NA NA Snake River Spring/Summer-run Chinook Salmon (O. tshawytscha) 

NA NA NA NA NA NA NA NA 

Lower Columbia River Coho Salmon (O. kisutch) 1 2 NA NA NA 2 2 2 Oregon Coast Coho Salmon (O. kisutch) NA NA NA NA NA 3 3 3 North American Green Sturgeon (A. medirostris) NA 1 NA NA NA NA NA NA 
PAGE 2 OF 2 

TABLE 5-3 Degree to which Species are Affected by Unquantified Sources of Take

Species 

Terminal Pipeline 

Artificial 

Light and 

Shading 

Food 

Web 

Effects 

Dredge 

Entrainment 

Turbidity 

(dredging and 

disposal) 

Habitat 

Loss/

Alteration 

Fish 

Salvage 

Passage 

Impediments 

Habitat 

Loss/

Alteration 

Columbia River Chum Salmon (O. keta) 2 NA NA NA 1 NA NA NA Eulachon (T. pacificus) NA NA 1 1 NA NA NA NA Notes: NA = Not applicable. 1 = Low effect. 2 = Moderate effect. 3 = High effect. 
 

PAGE 1 OF 1 

TABLE 5-4 

Duration of Project Impacts 

Impact Duration Notes 

Ballast and Cooling Water 

Entrainment 

Life of the Project Number of entrained fish estimated to be low. 

Pile-Driving Noise One in-water work period One-time effect, salmonid numbers low during in water 

work window. 

Dredging Entrainment Initial one-time effect, periodic 

maintenance dredging at approximately 

3-year intervals 

Salmonid numbers low during in-water work window; 

salmonids and other special-status species not especially 

susceptible. 

Fish Salvage One-time effect during Pipeline 

construction 

Approximately 236 listed fish (Lower Columbia River and 

Oregon Coast coho) will be harassed and approximately 

seven fish will suffer mortality during the removal process. 

Habitat Loss/Alteration Months to years Terminal habitat alteration of minor concern. Habitats will 

be returned to preconstruction conditions. 

Loss of Riparian Vegetation Years to life of the Project Loss of riparian vegetation will be significant only at a 

subset of crossings. 
TABLE 5-5 Proposed Mitigation by Evolutionarily Significant Unit 

Species Present During In-water Work Use of Terminal Action Area, Pipeline Action Area, or Both Number of non-HDD Pipeline Crossings Total Estimated T

(lethal and nonlet

Endangered Species Upper Columbia River Steelhead Trout (O. mykiss) No Terminal NA 0 Snake River Sockeye Salmon (O. nerka) No Terminal NA 0 Upper Columbia River Spring-run Chinook Salmon (O. tshawytscha) No Terminal NA 0 Threatened Species Lower Columbia River Steelhead Trout (O. mykiss) Yes (few adults) Terminal NA 0 Middle Columbia River Steelhead Trout (O. mykiss) Yes (few adults) Terminal NA 0 Upper Willamette River Steelhead Trout (O. mykiss) Yes (few adults) Both N/A 0 Snake River Basin Steelhead Trout (O. mykiss) No Terminal NA 0 Lower Columbia River Chinook Salmon (O. tshawytscha) Yes (juveniles) Both 0 

3.62 – 13.81 (annu

and 122 (one-time 

driving loss) 

Upper Willamette River Chinook Salmon (O. tshawytscha) Yes (few juveniles) Both 0 0 Snake River Fall Chinook Salmon (O. tshawytscha) Yes (few juveniles) Terminal NA 

0.15 – 0.56 (annua

and 3 (one-time p

driving loss) 

Snake River Spring/ Summer-run Chinook Salmon (O. tshawytscha) No Terminal NA 0.01 to 0.07 annuLower Columbia River Coho Salmon (O. kisutch) Yes (few adults) Both 9 

0.22 – 1.19 (annua

and 2 (one-time sa

loss), with 58 hara

by fish salvage

Oregon Coast Coho Salmon (O. kisutch) Yes (juveniles) Pipeline 5 

5 (one-time salva

loss), with 178 hara

by fish salvage 

North American Green Sturgeon (A. medirostris) No Terminal NA 0 
PAGE 2 OF 2 

TABLE 5-5 Proposed Mitigation by Evolutionarily Significant Unit 

Species Present During In-water Work Use of Terminal Action Area, Pipeline Action Area, or Both Number of non-HDD Pipeline Crossings Total Estimated T

(lethal and nonlet

Columbia River Chum Salmon (O. keta) Yes (juveniles and few adults) Terminal NA 0 Eulachon (T. pacificus) No Terminal NA Several thousand la

annually 

HDD = horizontal directional drilling NA = not applicable 
PAGE 1 OF 1 

TABLE 5-6 

Estimated Lower Columbia River Coho Affected by Salvage

Stream Width (ft.) 

Area (ft2), 

Assuming 60 ft. 

of Salvage Area 

% Pool Area (m2) Assumed 

Density 

Oregon Coast 

Coho Potentially 

Affected 

Barret Slougha 12 720 0% 66.888 0.09 3.0 

Heckarda Creek 10 600 60% 55.74 0.09 4.0 

Clatskanie Riverb 18.5 1110 100% 103.119 0.19 19.6 

Little Clatskanie 

River 2 120 0% 11.148 0.01 0.1 

Merrill Creeka,b 10 600 100% 55.74 0.09 5.0 

Tributary to 

Merrill Creekb 1 60 100% 5.574 0.06 0.3 

Milton Creek 10 600 5% 55.74 0.17 5.0 

Milton Creekb 22 1320 100% 122.628 0.17 20.8 

a Not surveyed by Oregon Department of Fish and Wildlife, and thus the average coho density from all streams in all years 

surveyed (0.37 fish/m2) was used. b

 Not surveyed by Applicant, and thus are assumed to be 100 percent pool. 

ft = foot/feet 

ft2

 = square foot 

m2

 = metric foot
PAGE 1 OF 1 

TABLE 5-7 

Estimated Oregon Coast Coho Affected by Salvage 

Stream Width (ft.) 

Area (ft2), 

Assuming 60 ft. 

of Salvage Area

% Pool Area (m2) Assumed 

Density 

Oregon Coast 

Coho Potentially 

Affected

Alder Creek 13 780 100% 72.462 0.28 20.3 

Rock Creek 20 1200 0% 111.48 0.3 16.7 

South Fork Rock 

Creeka 15 900 100% 83.61 0.37 30.9 

North Fork Wolf 

Creeka,b 30 1800 100% 167.22 0.37 61.9 

Clear Creek 10 600 15% 55.74 0.23 7.4 

a Not surveyed by the Oregon Department of Fish and Wildlife, and thus the average coho density from all streams in all years 

surveyed (0.37 fish/m2) was used. b

 Not surveyed by the Applicant, and thus are assumed to be 100 percent pool.

ft = foot/feet 

ft2

 = square foot 

m2

 = metric foot 
PAGE 1 OF 2 

TABLE 5-8 Fish Barrier Projects Ranked as High Priority in Clatsopa , Columbiaa ,and Wallowa Countiesb

Basin Subbasin Stream 

Culvert Stream 

Mile 

Habitat 

Quality Comm

Length Diam. Drop 

Columbia R Blind Sl Anderson Cr 60 48 0 2.5 Fair Two pipes, both very rusty; meet fPacific Ocean Necanicum R Bergsvik Cr 120 72 48 0.5 Good Water falls 4’ onto fill. Culvert bowColumbia R Gnat Cr Big Noise Cr 98 96 8 3.2 Good Culvert is a velocity barrier to all f

passable at higher flows in some i

Pacific Ocean Necanicum R Circle Cr 130 72 6 2.1 Good Steel pipe inside concrete box. Ma

barrier at low water. Velocity probl

Pacific Ocean Necanicum R Circle Cr 230 72 1.6 Good No pool below, water falls onto fillColumbia R Youngs R Crosel Cr 65 48 0 1.3 Poor Upstream of pipe is unused pasturNecanicum R Bergsvik Cr Joe Cr 54 96 12 2.1 Fair Culvert is a low water barrier due 

high water due to slope. 

Columbia R Youngs R Moosmoos Cr 60 36 20 1.1 Ukn Culvert is a juvenile barrier; probaColumbia R Gnat Cr Rock Cr 120 120 12 12.9 Good Water cascades 12” onto bedrock. 

is impassable at most flows. Lengvelocity water. There are several mabove this culvert. 

Nehalem Bay Nehalem R Rock Cr 162 90 0 6.6 Good High water velocity inhibits fish paNehalem R N fork Soapstone Cr 80 60 0 0.6 Fair Could not access downstream endColumbia R Gnat Cr Supply Cr 40 78 12 5.4 Good Upper end of culvert is full of rock Klaskanine R N fork Un Cr 60 36 2 1 Fair No comments. Necanicum R Circle Cr Un Cr 38 0 24 0.2 Good This culvert is located just west of 

excellent habitat. 

Necanicum R Circle Cr Un Cr 150 24 4 0.2 Good Good habitat for cutthroat. Culvert Nehalem Bay Nehalem R Un Cr 75 60 6 0.8 Fair High-velocity water and drop impeNehalem Bay Nehalem R Un Cr 75 60 6 1.5 Fair High-velocity water through culvert Pacific Ocean Necanicum R Un Cr 75 24 0 0.6 Good 0.1 mi. east of Necanicum Jct. Cre

appears to be too small and will g

Pacific Ocean Necanicum R Un Cr 0 48 0 2 Excellent Juvenile passage is primary conceRock Cr S fork Un Cr 163 72 0 1.4 Good Upper 140’ of pipe is steep. BottoSnake R Imnaha Imnaha -- -- -- -- Good Gumboot weir retrofit. Scappoose Bay Milton Cr Dart Cr 80 60 16 4.5 Fair Juvenile step barrier. Velocity impe
TABLE 5-8 Fish Barrier Projects Ranked as High Priority in Clatsopa , Columbiaa ,and Wallowa Countiesb

Basin Subbasin Stream 

Culvert Stream 

Mile 

Habitat 

Quality Comm

Length Diam. Drop 

Scappoose Cr N Scappoose 

CR 

Alder Cr 45 60 4 0.2 Good Middle section buckles up. Most o

Barrier. 

Scappose Bay Milton Cr Cox Cr 60 96 0 1.6 Good Juvenile barrier at low water, poss

flows. 

Columbia R Clatskanie R Merrill Cr 60 36 12 0.8 Fair Impassable at most flows. Columbia R Clatskanie R Keysone Cr 60 60 24 1 Fair Beaver ponds above. Culvert is to

Impassable. 

Nehalem Bay Nehalem R Un Cr 60 36 48 0.7 Fair District Priority Rating H6—High-ve

fish passage. 

Nehalem Bay Nehalem R Messing Cr 38 69 0 5 Good District Priority Rating H3—High-veNehalem Bay Nehalem R Messing Cr 72 117 0 4.3 Fair Culvert completely rusted through 

throughout. Road is painted-may b

Nehalem Bay Nehalem R E fork 65 96 2 5.4 Good Newly placed pipe with high-veloc

2/3 of pipe. Pipe sits on fill which pipe, then there is a 1' drop to a 3fish barrier at low flows and problaflows. 

Nehalem Bay Nehalem R Oak Ranch Cr 160 72 1.5 Good Water velocity is high due to slope 

silt and gravel in level sections. 

Nehalem Bay Nehalem R Cedar Cr 50 60 0 5.6 Good District Priority Rating H4--Not on 

24" onto bedrock. Couldn't assess are blocked w/ debris. Creek is cintact riparian area. 

Nehalem Bay Nehalem R Un Cr 75 36 24 1.1 Fair Boulders have recently been place

aid fish passage. This end may be no aid low water passage. Water v

Nehalem R Beaver Cr Un Cr 60 60 12 1 Ukn Velocity and drop inhibit fish passaNehalem R E fork Elk Cr 80 96 12 5.5 Fair 2 pipes. Very high-velocity water. Nehalem R Rock Cr Selder Cr 40 60 0 5.4 Good Juvenile step barrier. Velocity impe

a Source: Oregon Department of Fish and Wildlife 2006 Culvert Inventory. http://www.dfw.state.or.us/fish/passage/inventories.aspb Source: Nez Perce Tribal Fisheries Program. 
TABLE 6-1

Pipeline Construction Impacts by Habitat Category (Oregon) 

Habitat Category 

Total Acres 

(temporary and permanent) 

1 0 

2 12.61 

3 267.17 

4 603.00 

5 166.51 

6 3.27 

Total 1,052.56 

Precision loss may occur because of rounding. Area 

between HDD entry and exit points excluded in 

calculations of habitat impacts. 
TABLE 6-2

Pipeline Construction Impacts by Habitat Type (Oregon) 

Habitat Type 

Total Acres 

(temporary and permanent) 

AW 34.54 

BP 29.96 

CF 840.03 

DF 65.36 

E2USN 5.06 

NO 16.00 

PEM 26.57 

PEM/PFO 0.14 

PFO 12.50 

PSS 11.06 

PSS/PFO 6.41 

ST 4.94 

Total 1,052.56

Precision loss may occur because of rounding. Area 

between HDD entry and exit points excluded in 

calculations of habitat impacts. 
PAGE 1 OF 1 

TABLE 6-3 

Ratios for Compensatory Mitigation of Coniferous Forest and Non-Oak Deciduous Forest Habitats 

Habitat Category 

Affected 

Category of Conservation Easement to be Acquired 

Category 5 Category 4 Category 3 Category 2 Category 1 

Category 5 * NA NA NA NA NA 

Category 4 2:1 2:1 2:1 2:1 2:1 

Category 3 2:1 2:1 2:1 2:1 2:1 

Category 2 3:1 3:1 2:1 2:1 2:1 

Category 1 3:1 3:1 2:1 2:1 2:1 

* Compensatory mitigation is not required for Category 5 habitat as this habitat will be restored onsite within the construction 

corridor and permanent easements 

NA = not applicable. 
TABLE 7-1 Summary of Minimization and Avoidance Measures for High-Value Wetlands

Wetland ID 

4th Hydrological 

Unit Code (HUC) 

Subbasin 

Milepost High-Quality Determination Minimization and Avoidance Measures 

Terminal W4BCL05 Lower Columbia Terminal Greater than 5 acres in size, overall 

functioning score greater than 1.5 

Unavoidable portion of the footprint Terminal. vaporizer moved for avoidance. Spill containmimpacts. 

W4BCL06 Lower Columbia Terminal Greater than 5 acres in size Design of Terminal created to avoid low marsW4BCL07 Lower Columbia Terminal Greater than 5 acres in size, overall 

functioning score greater than 1.5 

Pier modified to minimize impacts. 

W5BCL084 Lower Columbia Terminal Palustrine Forested Wetland Existing road used to minimize impacts. W5BCL085 Lower Columbia Terminal Palustrine Forested Wetland Existing road used to minimize impacts. W99CL0001 Lower Columbia Terminal Palustrine Forested Wetland 10-inch potable water supply line with temporW99CL0002 Lower Columbia Terminal Palustrine Forested Wetland 10-inch potable water supply line with temporW99CL0006 Lower Columbia Terminal Palustrine Forested Wetland Horizontal directional drill (HDD) staging areaW99CL0007 Lower Columbia Terminal Palustrine Forested Wetland HDD staging areaunavoidable impacts. W99CL0009 Lower Columbia Terminal Palustrine Forested Wetland HDD staging areaunavoidable impacts. W99CL00026 Lower Columbia Terminal Greater Than 5.0 Acres in size No impactswetland avoided. Pipeline W99CL0021 Lower Columbia 0.8 Greater than 5 acres in size Temporary impacts unavoidable. W40CL001 Lower Columbia 2.7 Greater than 5 acres in size Temporary impacts unavoidable. W40CL002 Lower Columbia 2.9 Palustrine Forested Wetland HDD will be used to avoid permanent impacts W40CL003 Lower Columbia 3.0 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland W40CL005 Lower Columbia 3.0 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland W99CL033 Lower Columbia 3.7 Palustrine Forested Wetland Route aligned so that associated stream, wetl

crossed in a perpendicular orientation to minim

W99CL077A Lower Columbia 3.7 Greater Than 5.0 Acres in size Numerous route realignments to minimize wet

least temporary impacts associated with const

W5BCL042F Lower Columbia 4.2 Greater Than 5.0 Acres in size Numerous route realignments to minimize wet

least temporary impacts associated with const
PAGE 2 OF 5 

TABLE 7-1 Summary of Minimization and Avoidance Measures for High-Value Wetlands

Wetland ID 

4th Hydrological 

Unit Code (HUC) 

Subbasin 

Milepost High-Quality Determination Minimization and Avoidance Measures 

W42CL001 Lower Columbia 4.5 Greater Than 5.0 Acres in size Additional temporary workspace aligned to avo

riparian area. 

W5BCL073 Lower Columbia 4.5 Palustrine Forested Wetland Permanent impacts to wetland avoided througW40CL017 Lower Columbia 4.9 Palustrine Forested Wetland HDD will be used to avoid permanent impacts W40CL018 Lower Columbia 5.0 Palustrine Forested Wetland HDD will be used to avoid permanent impacts W39CL009 Lower Columbia 5.1 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland 

down to 75 feet. 

W1BCL001 Lower Columbia 7.9 Palustrine Forested Wetland Wetland is crossed at narrower end to minimiW39CL005 Lower Columbia 11.0 Palustrine Forested Wetland HDD will be used to avoid permanent impacts 

waterbody. 

W39CL007 Lower Columbia 11.0 Palustrine Forested Wetland HDD will be used to avoid permanent impacts 

waterbody. 

W39CL007 Lower Columbia 11.0 Palustrine Forested Wetland HDD will be used to avoid permanent impacts 

waterbody. 

W39CL012 Lower Columbia 11.0 Palustrine Forested Wetland HDD will be used to avoid permanent impacts 

waterbody. 

W39CL012 Lower Columbia 11.1 Palustrine Forested Wetland HDD will be used to avoid permanent impacts 

waterbody. 

W1BCL024 Lower Columbia 12.6 Palustrine Forested Wetland No impacts to wetland. W1BCL038 Lower Columbia 18.5 Palustrine Forested Wetland Route aligned to avoid impacts to wetland and 

way. 

W1BCL012 Lower Columbia 18.6 Palustrine Forested Wetland Impacts minimized by necking down constructW1BCL014 Lower Columbia 18.6 Palustrine Forested Wetland Route alignment parallels existing road and w

of the Project, making complete avoidance un

W1BCL015 Lower Columbia 18.9 Palustrine Forested Wetland Permanent impacts to wetland minimized by c

narrow. Construction corridor necked down to impacts. 

W1BCL016 Lower Columbia 19.0 Palustrine Forested Wetland Additional temporary workspaces moved to avW1BCL018 Lower Columbia 19.0 Palustrine Forested Wetland Riparian wetland, unavoidable, necking down W1BCL021 Lower Columbia 19.3 Palustrine Forested Wetland Permanent impacts to wetland will be avoided 
TABLE 7-1 Summary of Minimization and Avoidance Measures for High-Value Wetlands

Wetland ID 

4th Hydrological 

Unit Code (HUC) 

Subbasin 

Milepost High-Quality Determination Minimization and Avoidance Measures 

W2BCL008 Lower Columbia 19.6 Palustrine Forested Wetland, overall 

functioning score greater than 1.5 

Gnarly topography limits micrositing of Pipelinwetland. 

W7BCL006 Lower Columbia 22.4 Palustrine Forested Wetland Permanent impacts to wetland minimized by c

narrow. 

W6BCL003 Lower Columbia 22.5 Palustrine Forested Wetland, overall 

functioning score greater than 1.5 

Permanent impacts to wetland have been minwhere it is narrow. 

W3BCL101 Nehalem 36.3 Palustrine Forested Wetland Unavoidable impacts. Construction area necke

impacts. 

W3BCL100 Nehalem 36.5 Palustrine Forested Wetland Unavoidable impacts. Construction area necke

impacts. 

W3BCL101b Nehalem 36.7 Palustrine Forested Wetland; Wetland 

Greater Than 5.0 Acres 

Unavoidable impacts. Construction area neckeimpacts. 

W3BCL003 Nehalem 37.1 Palustrine Forested Wetland Route alignment parallels existing road to minW3BCL002 Nehalem 37.2 Palustrine Forested Wetland Route alignment parallels existing road to minW1BCL050A Nehalem 39.6 Palustrine Forested Wetland, overall 

functioning score greater than 1.5 

Route alignment parallels Highway 26 minimizto north and south, making it unavoidable. 

W8BCL007B Nehalem 41.0 Palustrine Forested Wetland HDD will be used to avoid impacts to wetlandW8BCL011A Nehalem 41.4 Palustrine Forested Wetland Permanent impacts avoided through route alig

minimized by narrowing the width of temporar

W8BCL011B Nehalem 41.5 Palustrine Forested Wetland Route alignment parallels Highway 26 and cro

narrow to minimize permanent impacts. 

W8BCL012 Nehalem 41.6 Palustrine Forested Wetland Route aligned to parallel Highway 26 and cro

minimize permanent impacts. 

W8BCL013 Nehalem 41.7 Palustrine Forested Wetland Route alignment parallels Highway 26 and cro

narrow to minimize permanent impacts. 

W8BCL018 Nehalem 42.3 Palustrine Forested Wetland Unavoidable impacts. Construction area necke

impacts. 

W1BCL043 Nehalem 43.2 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland W1BCL044 Nehalem 43.4 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland W1BTI001 Nehalem 44.2 Palustrine Forested Wetland, overall 

functioning score greater than 1.5 

Wetland and associated stream S1BTI001 are orientation to minimize impacts. 
PAGE 4 OF 5 

TABLE 7-1 Summary of Minimization and Avoidance Measures for High-Value Wetlands

Wetland ID 

4th Hydrological 

Unit Code (HUC) 

Subbasin 

Milepost High-Quality Determination Minimization and Avoidance Measures 

W6BCO003 Nehalem 47.6 Palustrine Forested Wetland Unavoidable impacts. Construction area necke

impacts. 

W6BCO004 Nehalem 47.6 Palustrine Forested Wetland Unavoidable impacts. Construction area necke

impacts. 

W3BCO111 Nehalem 50.6 Palustrine Forested Wetland Unavoidable impacts. Construction area necke

impacts. 

W3BCO112 Nehalem 50.8 Palustrine Forested Wetland Unavoidable impacts. Construction area necke

impacts. 

W3BCO100 Nehalem 57.7 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland W5BCO002 Nehalem 63.3 Palustrine Forested Wetland Wetland avoided, no impacts. W3BCO102 Nehalem 63.5 Palustrine Forested Wetland Unavoidable impacts. Construction area necke

impacts. 

W3BCO010 Nehalem 63.7 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland W6BCO005 Nehalem 69.1 Palustrine Forested Wetland Unavoidable impacts. Construction area necke

impacts. 

W3BCO007 Lower Willamette 72.9 Palustrine Forested Wetland Unavoidable temporary impacts. W1BCO023 Lower Willamette 73.5 Palustrine Forested Wetland Riparian wetland, unavoidable, necking down W5BCO010 Lower Willamette 74.5 Palustrine Forested Wetland Wetland avoided, no impacts. W6BCO002 Lower Willamette 74.6 Palustrine Forested Wetland Alignment placed to avoid majority of wetlandW6BCO001 Lower Willamette 74.9 Palustrine Forested Wetland Riparian wetland, unavoidable, necking down W3BCO013 Lower Columbia - 

Clatskanie 

76.4 Palustrine Forested Wetland Riparian wetland, unavoidable, necking down 

W3BCO117 Lower Columbia - 

Clatskanie 

79.1 Palustrine Forested Wetland Unavoidable temporary impacts. 

W5BCO013 Lower Columbia - 

Clatskanie 

81.5 Palustrine Forested Wetland Unavoidable temporary impacts. 

W99CO003 Lower ColumbiaClatskanie 81.6 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland W99CO005 Lower Columbia - 

Clatskanie 

81.7 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland 
TABLE 7-1 Summary of Minimization and Avoidance Measures for High-Value Wetlands

Wetland ID 

4th Hydrological 

Unit Code (HUC) 

Subbasin 

Milepost High-Quality Determination Minimization and Avoidance Measures 

W99CO006 Lower Columbia - 

Clatskanie 

81.8 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland 

W99CO007 Lower Columbia - 

Clatskanie 

81.8 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland 

W99CO020 Lower ColumbiaClatskanie 81.9 Palustrine Forested Wetland HDD will be used to avoid impacts to wetland W99CW001 Lower Columbia - 

Clatskanie 

82.7 Wetland Greater Than 5.0 Acres HDD will be used to avoid impacts to wetland 

W99CW002 Lower Columbia - 

Clatskanie 

83 Palustrine Forested Wetland; Wetland 

Greater Than 5.0 Acres 

HDD will be used to avoid impacts to wetland 

W6BCW001 Lower Columbia - 

Clatskanie 

84.2 Wetland Greater Than 5.0 Acres Temporary impacts to agricultural wetlands. 

W99CW007 Lower Columbia - 

Clatskanie 

84.9 Palustrine Forested Wetland; Wetland 

Greater Than 5.0 Acres 

Unavoidable wetland impacts. Wetland is loca

W99CW005 Lower Columbia - 

Clatskanie 

83.0 (HDD Pullback) 

Palustrine Forested Wetland Unavoidable impacts. Construction area necke

impacts. 
PAGE 1 OF 1 

TABLE 7-2 

Determination of Wetland Impacts Associated with Permanent and Temporary Easements and Planned Maintenance Activities

75-foot Wetland Crossing Width 

50-foot-wide Permanent Easement 25-foot-wide 

Construction Easement 

A B C D 

 Ten-foot mow strip 

centered over Pipeline 

Additional 20-foot area 

(10 feet on each side of 

the mow strip) 

Twenty-foot-wide area 

on outside boundary of 

easement (outer 10 feet 

of 50-foot permanent 

easement) 

25-foot-wide additional area needed 

for construction; 5 feet on one side 

and 20 feet on the other side of the 

50-foot permanent easement 

Frequency of 

Maintenance 

Activities 

Annual mowing Every 3 years, routine 

maintenance to cut 

trees over 15 feet tall 

No maintenance activity No maintenance activity 

Wetland type Type of Wetland 

Impact 

Type of Wetland 

Impact 

Type of Wetland 

Impact Type of Wetland Impact 

PEM Temporary during 

construction 

Temporary during 

construction 

Temporary during 

construction 

Temporary during construction 

PSS Temporary wetland 

impacts during 

construction; permanent 

conversion of wetland 

type to PEM 

Temporary Temporary Temporary 

PFO Temporary wetland 

impact during 

construction; permanent 

conversion of wetland 

type to PEM 

Temporary wetland 

impact during 

construction; permanent 

conversion of wetland 

type to PEM or PSS 

Temporary impact 

during construction 

Temporary impact during 

construction 
PAGE 1 OF 1 

TABLE 7-3 

10-Year Restoration Monitoring Schedule 

Year 

Monitoring and Restoration Activities 

Season 

Winter Spring Summer Fall 

1 Monitor Restoration Sites 

Noxious Weed Control (As 

Needed) 

Monitor Restoration Sites 

Noxious Weed Control (As 

Needed) 

Monitor Restoration Sites 

Replant (As Needed) 

2 Submit Results of Year 1 

Monitoring 

Monitor Restoration Sites 

Noxious Weed Control (As 

Needed) 

Monitor Restoration Sites 

Noxious Weed Control (As 

Needed) 

Monitor Restoration Sites 

Replant (As Needed) 

3 Submit Results of Year 2 

Monitoring 

Monitor Sites Deficient 

During Year 1 and 2 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient 

During Year 1 and 2 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient 

During Year 1 and 2 

Replant (As Needed) 

4 Submit Results of Year 3 

Monitoring 

Monitor Sites Deficient 

During Year 1 and 2 and 

Monitor 50% of Sites* 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient 

During Year 1 and 2 and 

Monitor 50% of Sites* 

Noxious Weed Control (As 

Needed)* 

Monitor Sites Deficient 

During Year 1 and 2 and 

Monitor 50% of Sites* 

Replant (As Needed) 

5 Submit Results of Year 4 

Monitoring 

Monitor Sites Deficient 

During Year 1 and 2 and 

Monitor 50% of Sites* Not 

Monitored Year 4 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient 

During Year 1 and 2 and 

Monitor 50% of Sites* Not 

Monitored Year 4 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient 

During Year 1 and 2 

Monitor 50% of Sites Not 

Monitored Year 4 

Replant (As Needed) 

6 Submit Results of Year 5 

Monitoring 

Monitor Sites Deficient in 

Previous Year 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient in 

Previous Year 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient in 

Previous Year 

Replant (As Needed) 

7 Submit Results of Year 6 

Monitoring 

Monitor Sites Deficient in 

Previous Year 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient in 

Previous Year 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient in 

Previous Year 

Replant (As Needed) 

8 Submit Results of Year 7 

Monitoring 

Monitor Sites Deficient in 

Previous Year 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient in 

Previous Year 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient in 

Previous Year 

Replant (As Needed) 

9 Submit Results of Year 8 

Monitoring 

Monitor Sites Deficient in 

Previous Year 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient in 

Previous Year 

Noxious Weed Control (As 

Needed) 

Monitor Sites Deficient in 

Previous Year 

Replant (As Needed) 

10 Submit Results of Year 9 

Monitoring 

Monitor Restoration Sites 

Noxious Weed Control (As 

Needed) 

Monitor Restoration Sites 

Noxious Weed Control (As 

Needed) 

Monitor Restoration Sites 

Noxious Weed Control (As 

Needed) 

11 Submit Final Reports 

*Choose sites using a stratified random approach across watersheds. 
PAGE 1 OF 1 

TABLE 7-4 

Summary of Performance Standards

Objective Performance Standard 

Ensure that areas of wetland 

have hydrology through April 

15 

Hydrology present in accordance with U.S. Army Corps of Engineers Wetland Delineation Manual 

(1987) 

2 years with normal or below normal precipitation 

Maintain structural diversity Grass, shrub, and forest habitat diversity present to an extent equal or better than preconstruction 

conditions 

Maintain species diversity Plant a diverse assemblage of species native to the project area or region to an extent equal or 

better than preconstruction conditions 

Ensure survivorship of trees 

and shrubs 

Planting density within 5 percent of planting plan—typically 60 to 80 percent survivorship (native 

species recruitment on the site may be included) 

Increase aerial cover in successive years; 15 percent aerial cover of trees 3 years after planting; 40 

to 60 percent aerial cover of shrubs after 3 years 

Ensure survivorship of 

ground cover 

30 to 50 percent ground after 1 year 

60 to 80 percent ground cover 2 years after installation in emergent zones 

50 percent ground cover within 2 years in shrub and forest habitat 

Bare substrate represents no more than 20 percent cover after 3 years 

Make cover of noxious 

weeds and non-native 

species minimal 

No more than 10 percent cover of invasive species such as reed canarygrass, Himalayan 

blackberry, Evergreen blackberry, purple loosestrife, kudzu, Japanese knotweed, thistles, and poison 

hemlock 3 years after installation 
PAGE 1 OF 1 

TABLE 8-1 

In-Water Work Periods Recommended by the Oregon Department of Fish and Wildlife

Pipeline Mile River 

In-Water Work Period 

Start Date End Date 

Terminal 

Not applicable Columbia River Estuarya November 1 February 28 

Oregon Portion of the Pipeline 

Columbia Estuary Tributaries 

0 – 13.80 Youngs Bay tributaries—tidal areasa July 1 September 15 

13.80 – 24.25 Youngs River and tributaries July 15 September 30 

Northern Oregon Coastal Basin Rivers 

24.25 – 69.3 Upper Nehalem and tributaries July 1 August 31 

Clatskanie River 

69.3 – 71.8 Clatskanie River and tributaries July 15 September 15 

Columbia River Tributaries 

71.8 – 75.7 Columbia River tributaries (St. Helens to Sandy River) July 15 August 31 

75.7 – 81.9 Columbia River tributaries (Hunt Creek to St. Helens) July 15 September 15 

Columbia River 

81.9 – 82.5 Columbia River (Tongue Point to Bonneville Dam) November 1 February 28 

Washington Portion of the Pipeline 

Columbia River Tributaries 

82.5 – 85.9 Columbia River tributaries TBDb TBDb

a The Oregon Department of Fish and Wildlife (ODFW) normally treats the in-water work window for tidal areas as the same 

dates as the Columbia River Estuary. ODFW is willing to work with the applicant to approve Pipeline construction during the 

published in-water work window. (Stream Subgroup Meeting Notes, August 14, 2008, copy provided in Appendix 1K of 

Resource Report 1—General Project Description [Oregon LNG, 2013]). 

b To be determined: Washington Department of Fish and Wildlife does not publish approved in-water periods. Oregon LNG will 

contact Washington Department of Fish and Wildlife to determine the preferred work period for Washington streams. 
PAGE 1 OF 1 

TABLE 10-1 

List of Migratory Birds of Concern for the Oregon LNG Project and Associated Ecoregions within the Project Action Area 

Species Ecoregion 

Harlequin Duck (Histrionicus histrionicus) Coast Range 

Peregrine falcon (Falco mexicanus) Lower Columbia, Coast Range, 

Osprey (Pandion haliaetus) Lower Columbia, Coast Range 

Bald Eagle (Haliaeetus leucocephalus) Lower Columbia, Coast Range 

Other raptors Lower Columbia, Coast Range 

Marbled Murrelet (Brachyramphus marmoratus) Marine, Coast Range 

Great Blue Heron (Ardea Herodias) Lower Columbia, Coast Range 

Band-tailed Pigeon (Patagioenas fasciata) Coast Range 

Northern Spotted Owl (Strix occidentalis caurina) Coast Range 

Rufous Hummingbird (Selasphorus rufus) Lower Columbia, Coast Range 

Olive-sided Flycatcher (Contopus cooperi) Coast Range 

Little Willow Flycatcher (Empidonax trailii brewsteri) Coast Range 

Streaked Horned Lark (Eremophila alpestris strigata) Coast Range 

Purple Martin (Progne subis) Coast Range 

Yellow-breasted Chat (Icteria virens) Lower Columbia, Coast Range 

Oregon Vesper Sparrow (Pooecetes gramineus affinis) Coast Range 

Acorn woodpecker (Melanerpes formicivorus) Coast Range 
 

Figures 

 

ES042009005PDX 355036.PP.07 08-31-09 amh

NOT TO SCALE

Conceptual Riparian and Forested Wet

OREGON LN

OREGON P

36-inchgas pipeline

5-15 ft 10 ft 10 ft 5 ft 5 ft 10 ft 10 ft 20-35 ft

No Maintenance

Construction Only

 15-25 ft

No Maintenance

Construction Only

 30-45 ft

Temporary Impact to 

Riparian and Wetlands

Temporary Impact to 

Riparian and Wetlands

30-ft Easement

Temporary

Impact

Permanent

Class Change

of PFO/PSS 

to PEM

10 ft

75- to 100-ft Construction Easement

50-ft Permanent Easement

May be 

maintained in 

herbaceous

cover

D D C C B B A
25-100 feet

ES042009005PDX 355036.PP.07 08-31-09 amh

FIGURE 5-2

Restoration for Streams with 

Existing Riparian Cover

OREGON LNG TERMINAL AND

OREGON PIPELINE PROJECT

25-100 feet

2

1

1

2

Mowing on 

1- to 3-year cycle.

Trees exceeding 

15 feet may be cut.

Trees free to grow.

Width to match the greater of existing conditions 

or Oregon Forest Practices Act requirements.

Reforested only if trees removed during clearing, 

and with landowner permission.

Workspace

Temporary

5 feet

Workspace

Temporary

45 feet

Zone of Potential Riparian Influence

Riparian Area Rehabilitation for Pipeline Operation

Zone of Potential Riparian Influence

Riparian Buffers

Vegetation Clearing for Pipeline Construction

Pipeline

Pipeline

75-100 feet

50 feet

Clearing Limits

Easement

Permanent

30 feet

Small Trees & Shrubs

10 feet

Herbaceous Strip

Riparian Forest Rehabilitation

75-100 feet
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140 Mitigation Acres

Youngs River

Breach

Breach

Breach

OLNG Terminal

Youngs River

Youngs Bay

LEGEND

Youngs River Wetland

Mitigation Site (193 acres)

Existing Dike

Parcel Boundary

Figure 7-2

Youngs River Wetland

Mitigation Site

0 500 1,000 250

Feet

Area of Interest

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Appendix A 

Wildlife Habitats by Oregon Fish and Wildlife 

Department Category with Mitigation Goals 

ES111813044445PDX 

OREGON LNG A-1  APPENDIX AWildlife Habitats by Oregon Fish and Wildlife Department Category with Mitigation Goals 

Habitat 

ODFW

Category Explanation 

Terminal and PipelineUpland Coniferous

Forest

CF

1 Irreplaceable, essential habitat; limited on a physiographic or siteͲspecific basis. OldͲgrowth forests as

defined by the Regional Ecosystem Office (REO), age class 180+ years. Category 1 also includes nest patches

(100Ͳacre area around nest for northern spotted owl [NSO]), patches of trees where MAMU are nesting or

potentially nesting, and nests for state and federally listed and sensitive/critical species (for example, bald

eagles). Category 1 includes habitat for other state and federally listed and sensitive/critical species.

Avoidance. No loss o

2 Essential and limited habitat. LateͲsuccessional forests as defined by the REO, 80Ͳto 179Ͳyear age class, with

important habitat elements. Category 2 includes suitable habitat for NSO within an active NSO activity center

(area within 1.5Ͳmile radius of a nest patch).

No net loss of eithe

a net benefit of hab

3 Essential habitat or important and limited habitat. This includes midͲseral forests, 40Ͳto 79Ͳyear age class.

Category 3 includes Ponderosa pine woodlands, 3Ͳto 39Ͳyear age class, as they are an Oregon Strategy

Habitat.

No net loss of eithe

4 Important habitat. Early seral stage forests, age class 3 to 39 years (excluding Ponderosa pine). In the context

of this Project, these are typically managed timberlands. Contributor to sustaining populations of some

common wildlife species over time.

No net loss of eithe

5 Habitat having a high potential to become either essential or important habitat. Degraded habitats, clearͲ

cuts (0Ͳto 3Ͳyear age class), and habitats lacking soil to support plants. Plant cover is minimal and may be

composed of weedy and invasive species. It includes sandy dredge spoils, sand dunes, or other soils that are

devoid of vegetation.

Provide a net benef

Upland DeciduousForestDF

1 Irreplaceable, essential habitat; limited on a physiographic or siteͲspecific basis. Mature oak woodlands and

oak savannah (1 to 2 oak trees per acre) with native grassland component. Category 1 includes oldͲgrowth

legacy oak trees. Category 1 includes habitat for state and federally listed and sensitive/critical species.

Avoidance. No loss o

2 Essential and limited habitat. Nonmature oak woodland (1 to 2 oak trees per acre). No net loss of eithe

a net benefit of hab

3 Essential habitat or important and limited habitat. Category 3 includes forests other than oak, such as maple,

alder, and cottonwood.

No net loss of eithe

4 Important habitat. Contributor to sustaining populations of some common wildlife species over time.

Category 4 includes early seral stages such as scrubͲshrub habitat (for example, shrub hedgerows between

farm fields).

No net loss of eithe

5 Habitat having a high potential to become either essential or important habitat. Degraded habitats and

habitats lacking soil to support plants. Plant cover is minimal and may be composed of weedy and invasive

species. It includes sandy dredge spoils, sand dunes, or other soils that are devoid of vegetation.

Provide a net benef
ES111813044445PDX 

OREGON LNG A-2  APPENDIX AWildlife Habitats by Oregon Fish and Wildlife Department Category with Mitigation Goals 

Habitat 

ODFW

Category Explanation 

Riparian HabitatRH 1 Irreplaceable, essential habitat; limited on a physiographic or siteͲspecific basis. Patches of large trees with nest sites for marbled murrelets, eagles, and northern spotted owls. Category 1 habitat includes oldͲgrowth

conifers and equivalent gallery forests of cottonwoods and other deciduous species. Category 1 includes

habitat for state and federally listed and sensitive/critical species. See also CF and DF Category 1.

Avoidance. No loss o

2 Irreplaceable, essential habitat; limited on a physiographic or siteͲspecific basis. Habitats composed of

woody vegetation adjacent to perennial streams. In the Coast Range, the width of the riparian habitat is

defined by rules in the Oregon Forest Practices Act (ORS 527, and its attendant rules, OAR Chapter 629,

divisions 605 through 665) for private lands or in the Forest Management Plan for state forests.

No net loss of eithe

a net benefit of hab

3 Essential habitat or important and limited habitat. Young, or early seral stage habitats, such as scrubͲshrub,

that are either somewhat degraded or provide limited shading and minimal contributions to woody debris

and nutrients (detritus). See Category 2 for riparian widths.

No net loss of eithe

4 Important habitat. Degraded habitats dominated by weeds or nonͲnative plants. Vegetation does not

overhang stream banks and shading is very minimal. Contributions of woody debris and nutrients are low.

This habitat type and category are equivalent to CF and DF Category 4.

No net loss of eithe

5 Habitat having a high potential to become either essential or important habitat. This includes nonpaved trails

and easements adjacent to streams. Presence of woody vegetation, shrubs, or trees, is absent. Where

adjacent to streams, this habitat type is equivalent to CF and DF Category 5.

Provide a net benef

Palustrine ScrubͲshrubPSS

1 Irreplaceable, essential habitat; limited on a physiographic or siteͲspecific basis. This includes scrubͲshrub

wetlands associated with bogs. PSS with state and federally listed and sensitive/critical species.

Avoidance. No loss o

2 Essential and limited habitat. Larger patches of PSS or interspersed with PFO, PEM, or open water. No net loss of eithe

a net benefit of hab

3 Essential habitat or important and limited habitat. Smaller patches of PSS and those not interspersed with

PEM, PFO, or open water.

No net loss of eithe

Palustrine ForestedWetlandPFO

1 Irreplaceable, essential habitat; limited on a physiographic or siteͲspecific basis. OldͲgrowth wetland forests

dominated by native species. These include PFO with mature stands of Oregon ash or cottonwood with

characteristic native plants in the understory. PFO with state and federally listed and sensitive/critical

species.

Avoidance. No loss o

2 Essential and limited habitat. Young stands or larger patches of PFO or interspersed with PEM, PSS, or open

water.

No net loss of eithe

a net benefit of hab

3 Essential habitat or important and limited habitat. Early seral stage PFO of lower quality than Category 2

such as small areas of PFO or areas not interspersed with PEM, PSS, or open water.

No net loss of eithe
ES111813044445PDX 

OREGON LNG A-3  APPENDIX AWildlife Habitats by Oregon Fish and Wildlife Department Category with Mitigation Goals 

Habitat 

ODFW

Category Explanation 

Palustrine EmergentWetlandPEM

1 Irreplaceable, essential habitat; limited on a physiographic or siteͲspecific basis. True wet prairie with native

plants, vernal pools, or bogs. These are remnant patches representing historical conditions of this habitat

type. Category 1 includes mineral seeps and mineral springs in the Coast Range. PEM with state and federally

listed and sensitive/critical species.

Avoidance. No loss o

2 Essential and limited. Large areas of PEM and those interspersed with PFO, PSS, or open water. No net loss of eithe

a net benefit of hab

3 Essential habitat or important and limited habitat. PEM habitat is disturbed, small in area, composed of nonͲ

native vegetation, or not interspersed with PSS, PFO, or OW habitats.

No net loss of eithe

4 Important habitat. There are no Category 4 PEMs. No net loss of eithe5 Habitat having a high potential to become either essential or important habitat. Farmed wetlands that are

plowed on a regular basis. They have hydric soils and may be partially drained. These areas generally support

ryegrass or other row crops.

Provide a net benef

Estuarine andEstuarine Emergent

Wetland

ES

1 Irreplaceable, essential, and limited. This includes rocky tidepools and forested intertidal zones. Avoidance. No loss o

2 Essential and limited habitat. Potentially suitable habitat for listed salmonids. Includes estuarine emergent

wetlands that provide dendritic channel access to juvenile salmonids and other fish species and contribute

nutrients to the estuarine system; and intertidal and shallow subtidal flats habitat toͲ6 feet MLLW.

No net loss of eithe

a net benefit of hab

3 Essential habitat, or important and limited habitat. High marsh habitat above the mean high water line,

other emergent estuarine wetlands that do not allow access to juvenile salmonids (that is, lack dendritic

channels), and deep subtidal/open water habitat beyond theͲ6 feet MLLW contour.

No net loss of eithe

StreamST

1 Irreplaceable, essential, and limited habitat. In northwest Oregon, Category 1 for the ST habitat type includes

Oregon chub habitat.

Avoidance. No loss o

2 Essential and limited habitat. Critical or essential fish habitat for federally or state listed fish species. NonfishͲ

bearing streams with state or federally listed species and sensitive/critical species of reptiles or amphibians.

No net loss of eithe

a net benefit of hab

3 Essential habitat, or important and limited habitat. Category 3 includes nonfishͲbearing streams that do not

provide habitat for sensitive/critical species of reptiles and amphibians.

No net loss of eithe

Agriculture/Pasture/Orchard/Tree FarmNO

4 Important habitat. Noncultivated areas provide some habitat for wildlife. This may include hedgerows,

perennial crops, orchards, vineyards, and tree farms (for example, Christmas trees). See also CF and DF

Category 4.

No net loss of eithe

5 Habitat having a high potential to become either essential or important habitat. Degraded by human actions

or natural phenomena. Annually cultivated with limited wildlife habitat value, such as ryegrass fields and row

crops. See also CF, DF, and PEM Category 5.

Provide a net benef
ES111813044445PDX 

OREGON LNG A-4  APPENDIX AWildlife Habitats by Oregon Fish and Wildlife Department Category with Mitigation Goals 

Habitat 

ODFW

Category Explanation 

Developed/Buildings/

Roads

BP

4 Important habitat. Category 4 includes utility easements and similar areas where maintenance and

management are required at frequent (less than [<] 5Ͳyear) intervals. These areas are typically maintained in

an early seral stage of succession (scrubͲshrub) by frequent mowing or application of herbicides. NonͲnative

and weedy species may be mixed with native species. See also CF, DF, PSS, and NO Category 4.

Provide a net benef

5 Habitat having a high potential to become either essential or important habitat. Degraded by human actions

or natural phenomena. These areas (for example, unpaved roads and logging landings) are typically devoid of

plants. They may be used as travel corridors for some species of wildlife, but they generally do not provide

food or cover.

Provide a net benef

6 Low habitat value and low restoration potential. Not important in sustaining populations of wildlife species.

Category 6 includes developed areas such as structures, roads, parking lots, and other impervious surfaces.

Minimize effects.

Rare PlantsRP

1 Irreplaceable, essential, and limited habitat. The intent of this habitat is to ensure that locations of federally

or state listed are captured as Category 1 habitats, regardless of patch size and surrounding habitat type.

This is a default category for rare plants.

Avoidance. No loss o

Source: OARs 635Ͳ415Ͳ0000 to 635Ͳ415Ͳ0025, the ODFW Habitat Mitigation Policy.
Appendix B 

StormwaterPollution Prevention Plan with 

Erosion Prevention and Sediment Control Plan; 

Spill Prevention, Control, and Countermeasures 

Plan; and Frac-Out Contingency Plan 

127(7KLVSODQLVSURYHGDV$SSHQGL[)RIRXU(,6

 

Appendix C 

Characteristics of Streams Crossed by the Pipeline

 

APPENDIX C

Characteristics of Streams Crossed by the Pipeline

Milepost Stream ID

Stream

Typea Water Bodyb

Hydrologic Unit Code

(4th Order) Crossing Method

Water Body

Typec

Bedrock

Percentage

Boulder

Percentage

Cobble

Percentage

Rubble

Percentage

Gravel

Percentage

Fines

Percentage

Gradient

Percent

Embeddedness

Bankfull

Width

(ft)

Bankfull

Depth

(ft)

Channel

Type

(Rosgen) Fish Speciesd

Sub

Sc

1 S99CL001 Perennial Adairs Slough Lower Columbia Method 2 - HDD Minor 0 00 Co 

1.5 S5BCL074 Perennial Vera Creek Lower Columbia Method 2 - HDD Minor 0 00 Co 

3.1 S99CL067 Perennial Lewis and Clark River Lower Columbia Method 2 - HDD Minor 0 00 Co,FaCh 4.1 S5BCL059 Perennial Tributary of Barrett Slough Lower Columbia Method 1 - Flume Minor 0 00 Co 

4.2 S5BCL062 Intermittent Tributary of Barrett Slough Lower Columbia Method 3 - Open cut Minor 0 00 Co 

4.3 S5BCL063 Intermittent Tributary of Barrett Slough Lower Columbia Method 3 - Open cut Minor 0 00 Co 

4.5 S5BCL064 Perennial Barrett Slough Lower Columbia Method 1 - Flume Minor 0 00 Co 

4.6 S5BCL066 Intermittent Tributary of Barrett Slough Lower Columbia Method 3 - Open cut Minor 0 00 Co 

4.8 S5BCL068 Intermittent Tributary of Green Slough Lower Columbia Method 3 - Open cut Minor 0 00 Co 

4.8 S5BCL069 Intermittent Tributary of Green Slough Lower Columbia Method 3 - Open cut Minor 0 00 Co 

4.9 S5BCL070 Intermittent Unnamed Lower Columbia Method 3 - Open cut Minor 2 

5 S5BCL071 Intermittent Tributary of Lewis and Clark Lower Columbia Method 2 - HDD Minor 0 00 FaCh 

5.2 S5BCL072 Perennial Tributary of Lewis and Clark Lower Columbia Method 2 - HDD Minor 0 00 Co,FaCh 

5.7 S99CL064 Perennial Lewis and Clark River Lower Columbia Method 2 - HDD Major 0 00 Co,FaCh 5.8 S38CL003 Intermittent Tributary of Lewis and Clark Lower Columbia Method 2 - HDD Minor 0 00 Co 

7.9 S1BCL001 Perennial Heckard Creek Lower Columbia Method 1 - Flume Intermediate 0 00 Co 

8.1 S1BCL050 Intermittent Unnamed Lower Columbia Method 3 - Open cut Intermediate 10 

8.6 S1BCL002 Intermittent Tributary of Lewis and Clark Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

8.8 S1BCL018 Perennial Tributary of Lewis and Clark Lower Columbia Method 1 - Flume Intermediate 0-5 0-5 0-5 0-5 0-5 95-100 1 5 25 1 C6 Co,FaCh 

9.1 S1BCL003 Intermittent Tributary of Lewis and Clark Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

9.3 S1BCL004 Intermittent Tributary of Lewis and Clark Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

9.7 S1BCL005 Intermittent Tributary of Lewis and Clark Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

9.7 S1BCL006 Ephemeral Tributary of Lewis and Clark Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

9.9 S1BCL007 Intermittent Tributary of Lewis and Clark Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

10 S1BCL008 Perennial Tributary of Lewis and Clark Lower Columbia Method 1 - Flume Intermediate 0 00 Co,FaCh 

11 S99CL018 Perennial Lewis and Clark River Lower Columbia Method 2 - HDD Minor 0 00 Co,FaCh 

12.8 S1BCL016 Perennial Tributary of Speelyai Creek Lower Columbia Method 1 - Flume Minor 0-5 40-45 40-45 15-20 0-5 0-5 14 1 10 1 A2a+ Co 

13.8 S5BCL040 Perennial Tributary of Youngs River Lower Columbia Method 1 - Flume Minor 0 0.8 0 Co,FaCh 

13.8 S5BCL041 Perennial Tributary of Youngs River Lower Columbia Method 1 - Flume Minor 0 20 Co,FaCh 

13.9 S5BCL042 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

13.9 S5BCL043 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

14.1 S5BCL045 Perennial Tributary of Youngs River Lower Columbia Method 1 - Flume Minor 0 00 Co,FaCh 

14.2 S5BCL044 Perennial Tributary of Youngs River Lower Columbia Method 1 - Flume Minor 0 00 Co,FaCh 

14.8 S5BCL038 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

15.3 S5BCL035 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

15.6 S5BCL030 Perennial Tributary of Youngs River Lower Columbia Method 1 - Flume Minor 0-5 0-5 5-10 5-10 5-10 85-90 4 3 4 1.2 A5 Co,FaCh 

15.6 S5BCL034 Perennial Tributary of Youngs River Lower Columbia Method 1 - Flume Minor 0-5 0-5 0-5 0-5 55-60 40-45 4 2 4 2 A4 Co,FaCh 

15.8 S5BCL031 Perennial Tributary of Youngs River Lower Columbia Method 1 - Flume Minor 15-20 5-10 5-10 10-15 20-25 45-50 5 4 5 5 A5 Co,FaCh 

16.1 S99CL016 Perennial Bayney Creek Lower Columbia Method 1 - Flume Minor 9.1 0 0 

16.6 S5BCL032 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0 0.4 0 Co,FaCh 

17.3 S5BCL077 Perennial Tributary of Youngs River Lower Columbia Method 1 - Flume Minor 0 00 Co,FaCh 

17.8 S5BCL079 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0-5 5-10 10-15 10-15 25-30 40-45 4 3 5 0 Co,FaCh 

17.8 S5BCL078 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0-5 5-10 15-20 20-25 35-40 25-30 2 3 6 1 Co,FaCh 

17.9 S5BCL080 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

18.4 S5BCL076 Perennial Tributary of Rock Creek Lower Columbia Method 1 - Flume Minor 0-5 0-5 0-5 0-5 40-45 60-65 2 3 4 2 B4 Co,FaCh 18.5 S1BCL009 Perennial Rock Creek Lower Columbia Method 1 - Flume Intermediate 0-5 0-5 20-25 25-30 40-45 15-20 1.5 1 17 2.4 C4 Co,FaCh 18.8 S1BCL010 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

19 S1BCL011 Perennial Tributary of Youngs River Lower Columbia Method 1 - Flume Minor 0-5 0-5 15-20 15-20 15-20 55-60 4 4 6 1 Co,FaCh 

19.1 S1BCL012 Intermittent Unnamed Lower Columbia Method 3 - Open cut Minor 0 00 

19.3 S1BCL014 Perennial Osgood Creek Lower Columbia Method 1 - Flume Minor 0-5 55-60 40-45 1 1 20 3 C4 Co,FaCh 

19.6 S2BCL013A Perennial Tributary of Osgood Creek Lower Columbia Method 1 - Flume Minor 0-5 0-5 0-5 0-5 0-5 90-95 0 2 7 3 Co,FaCh 

20.1 S2BCL013B Perennial Fox Creek Lower Columbia Method 1 - Flume Intermediate 0-5 0-5 25-30 35-40 25-30 5-10 3 1 35 2 B3a Co,FaCh 21.4 S38CL013 Perennial South Fork Youngs River Lower Columbia Method 1 - Flume Minor 0 00 Co,FaCh 

21.6 S42CL003 Intermittent Unnamed lower Columbia Method 3 - Open cut Minor 

21.8 S5BCL058 Perennial Tributary of Youngs River Lower Columbia Method 1 - Flume Intermediate 10-15 10-15 15-20 40-45 20-25 0-5 4 1 15 3 B3a Co,FaCh 

22.1 S5BCL049 Perennial Tributary of Youngs River Lower Columbia Method 1 - Flume Minor 0-5 0-5 0-5 5-10 40-45 50-55 10 2 2.5 1.5 A5 Co,FaCh 

22.2 S5BCL048 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

22.5 S6BCL016 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

22.6 S6BCL014 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 4 Co,FaCh 

22.6 S6BCL013 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 1 Co,FaCh 22.6 S6BCL015 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

22.8 S6BCL017 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

22.8 S6BCL010 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 2 Co,FaCh 22.8 S6BCL011 Intermittent Tributary of Youngs River Lower Columbia Method 3 - Open cut Minor 2 Co,FaCh 22.9 S6BCL018 Intermittent Tributary of Fall Creek Lower Columbia Method 3 - Open cut Minor 25-30 5-10 5-10 20-25 30-35 10-15 7 4 20 3 Co,FaCh 

23 S6BCL019 Perennial Tributary of Fall Creek Lower Columbia Method 1 - Flume Intermediate 0 00 Co,FaCh 

23.1 S6BCL020 Intermittent Tributary of Fall Creek Lower Columbia Method 3 - Open cut Minor 0 00 Co,FaCh 

23.4 S38CL014 Perennial Fall Creek Lower Columbia Method 1 - Flume Minor 0 00 Co,FaCh 

24.3 S5BCL016 Intermittent Tributary of Fishhawk Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 10-15 90-95 11 3.5 0.1 Co,FaCh 

PDX/121670001ES032312232445PDX 
APPENDIX C

Characteristics of Streams Crossed by the Pipeline

Milepost Stream ID

Stream

Typea Water Bodyb

Hydrologic Unit Code

(4th Order) Crossing Method

Water Body

Typec

Bedrock

Percentage

Boulder

Percentage

Cobble

Percentage

Rubble

Percentage

Gravel

Percentage

Fines

Percentage

Gradient

Percent

Embeddedness

Bankfull

Width

(ft)

Bankfull

Depth

(ft)

Channel

Type

(Rosgen) Fish Speciesd

Sub

Sc

24.4 S5BCL018 Perennial Tributary of Fishhawk Creek Nehalem Method 1 - Flume Minor 0-5 5-10 10-15 15-20 30-35 40-45 9 3.5 0.1 Co,FaCh 

24.4 S5BCL017 Intermittent Tributary of Fishhawk Creek Nehalem Method 3 - Open cut Minor 0-5 5-10 10-15 25-30 35-40 25-30 12 5 6 1 A5a+ Co,FaCh 

24.8 S2BCL001 Intermittent Tributary of Fishhawk Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 20-25 35-40 15-20 5-10 7 7 0 Co,FaCh 

24.8 S2BCL002 Intermittent Tributary of Fishhawk Creek Nehalem Method 3 - Open cut Intermediate 50-55 0-5 0-5 0-5 15-20 15-20 7 25 0 Co,FaCh 

25.1 S2BCL003 Ephemeral Tributary of Fishhawk Creek Nehalem Method 3 - Open cut Minor 34 0 0 Co,FaCh 

25.2 S2BCL005 Perennial Tributary of Fishhawk Creek Nehalem Method 1 - Flume Intermediate 0 00 Co,FaCh 

25.2 S2BCL004 Intermittent Tributary of Fishhawk Creek Nehalem Method 3 - Open cut Minor 0-5 5-10 50-55 20-25 15-20 10-15 34 10 0 Co,FaCh 25.3 S2BCL007 Perennial Tributary of Fishhawk Creek Nehalem Method 1 - Flume Minor 0-5 0-5 15-20 25-30 40-45 15-20 13 1 3 0.1 A4a+ Co,FaCh 

25.4 S2BCL008A Perennial Tributary of Fishhawk Creek Nehalem Method 1 - Flume Intermediate 0 00 Co,FaCh 

25.7 S2BCL009 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 - Flume Intermediate 20-25 0-5 15-20 25-30 15-20 20-25 4 2 10 0.1 B1a Co 

25.7 S2BCL010 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 - Open cut Minor 0 0 0 Co 

25.9 S2BCL012 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 - Open cut Minor 0 0 0 Co 

26.3 S5BCL019 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 0-5 15-20 85-90 9 5 1.2 0.2 A5 Co 

26.5 S5BCL029 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 0-5 15-20 85-90 18 1.5 0.2 A5+ Co 

26.6 S5BCL027 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 0-5 0-5 95-100 6 1 0.2 A5 Co 

26.6 S5BCL028 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 - Open cut Minor 0 30 Co 

26.8 S5BCL023 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 0-5 0-5 95-100 23 1.3 0.2 A5 Co 26.8 S5BCL025 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 - Flume Minor 17 1.4 0.7 A5a+ Co 

27 S5BCL022 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 0-5 95-100 23 0 0 Co 

27.2 S5BCL021 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 0-5 0-5 95-100 2 6 0.2 B4 Co 

27.3 S5BCL020 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 0-5 0-5 95-100 4 1.8 0.2 A4 Co 

27.4 S5BCL015 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 0-5 5-10 95-100 13 4 0.2 A5a+ Co 

27.6 S5BCL014 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 0-5 95-100 6 2.4 0.2 Co 

27.8 S5BCL012 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 0-5 95-100 10 2 0.1 Co 

27.8 S5BCL013 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 0-5 95-100 16 2 4 Co 

27.9 S5BCL011 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 - Open cut Minor 0-5 5-10 5-10 10-15 30-35 45-50 10 4 3 1 A5 Co 

28.1 S5BCL010 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 0-5 30-35 55-60 6 3.5 0.5 Co 

28.4 S5BCL007 Intermittent Tributary of East Humbug Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 0-5 95-100 0 6 6 Co 

28.5 S5BCL004 Intermittent Tributary of East Humbug Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 0-5 95-100 7 7 2.5 Co 

28.5 S5BCL005 Intermittent Tributary of East Humbug Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 0-5 95-100 5 4 0.1 Co 

29 S5BCL001 Intermittent Tributary of East Humbug Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 0-5 95-100 0 3 3.5 Co 29 S5BCL002 Intermittent Tributary of East Humbug Creek Nehalem Method 3 - Open cut Minor 0 00 Co 

29.4 S6BCL007 Intermittent Tributary of East Humbug Creek Nehalem Method 3 - Open cut Minor 0 0 0 Co, FaCh 

29.4 S6BCL008 Intermittent Tributary of East Humbug Creek Nehalem Method 3 - Open cut Minor 0 00 Co, FaCh 

29.5 S6BCL006 Perennial Tributary of East Humbug Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 5-10 20-25 65-70 7 2 7 1 A5 Co 

29.5 S6BCL005 Perennial Tributary of East Humbug Creek Nehalem Method 1 - Flume Minor 

29.9 S6BCL004 Intermittent Tributary of East Humbug Creek Nehalem Method 3 - Open cut Minor 

30.9 S2BCL021 Intermittent Tributary of East Humbug Creek Nehalem Method 3 - Open cut Minor 0 0 0 Co 

31.4 S2BCL008B Perennial Alder Creek Nehalem Method 1 - Flume Intermediate 0 0 0 Co 

31.6 S6BCL001 Intermittent Tributary of Alder Creek Nehalem Method 3 - Open cut Minor 0-5 5-10 20-25 5-10 20-25 30-35 10 3 6 1.5 A3 Co 

32 S3BCL001 Intermittent Tributary of Nehalem River Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 10-15 75-80 25 6 1 Co,SpCh,FaCh 32 S3BCL002 Intermittent Tributary of Nehalem River Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 10-15 75-80 13 6 1 Co,SpCh,FaCh 

32.1 S3BCL003 Intermittent Tributary of Nehalem River Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 10-15 75-80 15 4 1 Co,SpCh,FaCh 

32.1 S3BCL004 Intermittent Tributary of Nehalem River Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 10-15 75-80 11 6 1 Co,SpCh,FaCh 

32.3 S3BCL005 Intermittent Tributary of Nehalem River Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 10-15 90-95 7 8 0 Co,SpCh,FaCh 

32.3 S3BCL006 Intermittent Tributary of Nehalem River Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 10-15 90-95 7 6 0 Co,SpCh,FaCh 

32.4 S3BCL007 Intermittent Tributary of Nehalem River Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 10-15 90-95 12 8 5 Co,SpCh,FaCh 

33.5 S99CL108 Perennial Nehalem River Nehalem Method 2 - HDD Major 0 00 Co,SpCh,FaCh 

34.4 S5BCL046 Perennial Tributary of Nehalem River Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 0-5 0-5 95-100 14 2 0.5 A6a+ Co,SpCh,FaCh 

36.2 S3BCL101 Perennial Unnamed Nehalem Method 1 - Flume 36.3 S3BCL102 Perennial Unnamed Nehalem Method 1 - Flume 37.5 S8BCL004 Perennial Tributary of North Fork Quartz Nehalem Method 1 - Flume 37.7 S8BCL003 Intermittent Tributary of North Fork Quartz Nehalem Method 3 - Open cut 

38.5 S8BCL001 Perennial Tributary of South Fork Quartz Nehalem Method 1 - Flume 

39.6 S1BCL029 Intermittent Tributary of Military Creek Nehalem Method 3 - Open cut Minor 0 00 Co 

39.8 S1BCL027 Intermittent Tributary of Military Creek Nehalem Method 3 - Open cut Minor 0 00 Co 

39.8 S1BCL028 Intermittent Tributary of Military Creek Nehalem Method 3 - Open cut Minor 0 00 Co 

41 S8BCL005 Perennial Rock Creek Nehalem Method 2 - HDD Intermediate 15-20 0-5 5-10 20-25 15-20 55-60 2 3 20 0.3 F5b Co 

42.3 S8BCL009 Perennial Tributary of South Fork Rock Nehalem Method 1 - Flume Intermediate 0 11 0 Co 

42.7 S1BCL020 Perennial Tributary of South Fork Rock Nehalem Method 1 - Flume Minor 0-5 25-30 20-25 15-20 0-5 50-55 8 5 6 3 A2a+ Co 

43.1 S1BCL021 Perennial South Fork Rock Creek Nehalem Method 2 - HDD Intermediate 0-5 0-5 10-15 35-40 40-45 15-20 1 2 15 1 C4 Co 

43.4 S1BCL022 Perennial Bear Creek Nehalem Method 2 - HDD Intermediate 0-5 0-5 0-5 0-5 50-55 50-55 1 3 12 1 Co 

43.5 S1BCL023 Intermittent Tributary of Bear Creek Nehalem Method 2 - HDD Minor 0 00 Co 

43.7 S1BCL024 Perennial Tributary of Bear Creek Nehalem Method 1 - Flume Minor 0 00 Co 43.9 S1BCL025 Intermittent Tributary of Bear Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 0-5 95-100 2 5 4 1 Co 

44 S1BCL026 Intermittent Tributary of Bear Creek Nehalem Method 3 - Open cut Minor 0-5 0-5 0-5 0-5 0-5 95-100 4 5 3 1 Co 

44.2 S1BTI001 Perennial Bear Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 0-5 0-5 95-100 1 5 6 2 Co 44.3 S1BTI002 Intermittent Tributary of Bear Creek Nehalem Method 3 - Open cut Minor 0 00 Co 

44.8 S5BTI001 Perennial Tributary of Wolf Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 0-5 25-30 65-70 6 3 5 0.1 A4a+ Co 

PDX/121670001ES032312232445PDX 
APPENDIX C

Characteristics of Streams Crossed by the Pipeline

Milepost Stream ID

Stream

Typea Water Bodyb

Hydrologic Unit Code

(4th Order) Crossing Method

Water Body

Typec

Bedrock

Percentage

Boulder

Percentage

Cobble

Percentage

Rubble

Percentage

Gravel

Percentage

Fines

Percentage

Gradient

Percent

Embeddedness

Bankfull

Width

(ft)

Bankfull

Depth

(ft)

Channel

Type

(Rosgen) Fish Speciesd

Sub

Sc

45.1 S1BTI003 Intermittent Tributary of Wolf Creek Nehalem Method 3 - Open cut Minor 0 00 Co,SpCh 

47.6 S6BCO002 Perennial North Fork Wolf Creek Nehalem Method 1 - Flume Intermediate Co, SpCh, St 

48.3 S1BCO000 Perennial Tributary of North Fork Wolf CreekNehalem Method 1 - Flume Minor not confirmed 

50.5 S3BCO012 Perennial Clear Creek Nehalem Method 1 - Flume Intermediate 0 00 Co 

53.6 S3BCO002 Perennial Fall Creek Nehalem Method 1 - Flume Minor not confirmed 

55.7 S3BCO107 Perennial Cedar Creek Nehalem Method 1 - Flume Intermediate 0-5 0-5 0-5 10-15 35-40 55-60 2 4 10 3 Co 

55.8 S3BCO106 Perennial Tributary of Cedar Creek Nehalem Method 1 - Flume Minor 0-5 0-5 0-5 10-15 55-60 35-40 4 3 4 4 not confirmed 

57.7 S3BCO101B Perennial Braided Channel to Rock Creek Nehalem Method 2 - HDD Intermediate 0-5 0-5 0-5 0-5 0-5 95-100 2 30 30 Co, SpCh, St 

57.7 S3BCO100 Perennial Tributary of Rock Creek Nehalem Method 2 - HDD Intermediate 

57.7 S3BCO101 Perennial Rock Creek Nehalem Method 2 - HDD Intermediate 

63.8 S3BCO014 Perennial Nehalem River Nehalem Method 2 - HDD Intermediate 0-5 0-5 0-5 0-5 0-5 95-100 2 3 30 10 Co, SpCh, St 

66.3 S3BCO103 Intermittent Tributary of Oak Ranch Creek Nehalem Method 3 - Open cut Minor not confirmed 

67.7 S6BCO004 Intermittent Unnamed Nehalem Method 3 - Open cut Minor 

68.0 S6BCO003 Perennial Unnamed Nehalem Method 1 - Flume Minor 

70.2 S3BCO003 Intermittent Tributary of Clatskanie River Lower Columbia-Clatskanie Method 3 - Open cut Intermediate not confirmed 70.7 S99CO020 Perennial Clatskanie River Lower Columbia-Clatskanie Method 1 - Flume Intermediate 

71.0 S99CO021 Perennial Unnamed Lower Columbia-Clatskanie Method 1 - Flume Minor 

71.8 S5BCO001 Perennial Little Clatskanie River Lower Columbia-Clatskanie Method 1 - Flume Minor Co 

72.7 S3BCO008 Perennial/Intermittent Tributary of Milton Creek Lower Willamette Method 1 - Flume Minor not confirmed 

73.0 S3BCO010 Perennial Milton Creek Lower Willamette Method 1 - Flume Intermediate Co, St 

73.5 S1BCO004 Intermittent Apilton Creek Lower Willamette Method 3 - Open cut Minor not confirmed 

73.6 S1BCO005 Intermittent Tributary of Apilton Creek Lower Willamette Method 3 - Open cut Minor not confirmed 

74.5 S5BCO011 Perennial Unnamed Lower Willamette Method 1 - Flume Minor 

74.6 S5BCO010 Perennial Unnamed Lower Willamette Method 1 - Flume Intermediate 

74.9 S6BCO001 Perennial Milton Creek Lower Willamette Method 1 - Flume Intermediate 

76.3 S3BCO110 Intermittent Tributary of Merrill Creek Lower Columbia-Clatskanie Method 3 Minor 0-5 0-5 0-5 0-5 30-35 70-75 12 4 2 1 A5a+ not confirmed 76.4 S3BCO017 Perennial Merrill Creek Lower Columbia-Clatskanie Method 1 - Flume Intermediate 

78.2 S2BCO009 Intermittent Tributary of Merrill Creek Lower Columbia-Clatskanie Method 3 Minor not confirmed 

78.4 S3BCO122 Perennial Tributary of Merrill Creek Lower Columbia-Clatskanie Method 1 - Flume Intermediate 0-5 0-5 10-15 10-15 30-35 50-55 4 3 12 2 Co 79.0 S3BCO120 Intermittent Tributary of Merrill Creek Lower Columbia-Clatskanie Method 3 Minor not confirmed 

79.0 S3BCO119 Intermittent Tributary of Merrill Creek Lower Columbia-Clatskanie Method 3 Minor 0-5 0-5 0-5 0-5 5-10 95-100 4 4 1 1 A6 not confirmed 

79.9 S3BCO115 Perennial Tributary of Merrill Creek Lower Columbia-Clatskanie Method 1 - Flume Minor 0-5 0-5 0-5 0-5 5-10 95-100 17 4 2 2 A5a+ not confirmed 81.6 S99CO011 Perennial Deer Island Slough Lower Columbia-Clatskanie Method 1 - Flume Intermediate 38 not confirmed 

82.0 S3BCO123 Perennial Dyna Nobel Channel Lower Columbia-Clatskanie Method 2 - HDD Intermediate 20 not confirmed 

82.3 S99CO014 Perennial Columbia River Lower Columbia-Clatskanie Method 2 - HDD Major 3300 not confirmed 83.3 S99CW020 Perennial Burris Creek Lewis Method 1 - Flume Intermediate 10 not confirmed 

85.8 S99CW021 Perennial Unnamed Lewis Method 1 - Flume Minor 2 not confirmed 

86 S99CW022 Perennial Unnamed Lewis Method 1 - Flume Minor 2 not confirmed 

86.5 S99CW023 Intermittent Unnamed Lewis Method 1 - Flume Proxy 3 not confirmed 86.7 S99CW025 Intermittent Unnamed Lewis Method 1 - Flume Proxy 3 not confirmed 

86.8 S99CW026 Perennial Unnamed Lewis Method 1 - Flume Proxy 3 not confirmed 

Co = Coho SalmonE = Ephemeral

FaCh = Fall Chinook SalmonI = IntermittentMP = MilepostNA = Not availableNDA = No data availableP = PerennialSpCh = Spring Chinook SalmonSt = Winter SteelheadAdditional Notes:Widths in feet are stream ordinary high water mark (OHWM).Stream ID numbers beginning in S99 are for areas with no field access and are based on aerial photo and Pacific Northwest Hydrography Network database.Remaining data are from field surveys.Duplicate milepost numbers occur because of rounding of mileposts to nearest tenth of a mile.Precision loss may occur because of rounding.a As determined by field observation or the U.S. Geological Survey (USGS) 7.5-minute topographic maps. Intermittent: has surface flow for at least 3 months out of the year and has a connection to 

b Waterbody names are as depicted on USGS 7.5-minute topographic maps.

g Scour Potential (Ave. of substrate and bankfull width scores) column: The scour potential is the average of the substrate and bankfull width scores and represents the potential for vertical and/or horizontal scour. Scour potential is on a scale of 1-5 with 1 representing low scour potential typically because the stream is sm

energy flows. A 5 represents larger channels with higher energy flows and a high percentage of fines and/or gravel.Proxy Data = These data were provided by the National Wetlands Inventory (NWI) database, the Warrington Local Wetland Inventory (LWI) database, the Pacific Northwest (PNW) Hydrography Framework, and the Natural Resources Conservation Service (NRCS) Soil Survey Geographic (SSURGO) database.

The data do not include certain information, such as stream type, stream width, or wetland type. Once the final pipeline route is approved and access to these areas is secured, these data will be collected.

f Bankfull Score column: The bankfull width score is based on the bankfull width of the channel. Scores are on a scale of 1-5 with 1 representing the narrowest channels and 5 representing the widest channels.

c Stream designation includes minor, intermediate, and major waterbodies crossed by the Project. Minor waterbodies include all waterbodies less than or equal to 10 feet wide at the water's edge at the time of crossing; intermediate waterbodies include all waterbodies greater than 10 feet wide but less than or equal to 10

include all waterbodies greater than 100 feet wide at the water's edge at the time of crossing.

d Fisheries classifications within the state of Oregon are considered to be coldwater fisheries (see Resource Report 3 for more information).

e Substrate Score column: The substrate score is based on percent fines, embeddedness, and professional judgment for salmonid spawning substrate. Scores are on a scale of 1-5 with 1 being the best salmonid spawning habitat and 5 being the worst.

Abbreviations:

PDX/121670001ES032312232445PDX 

 

Appendix D 

Probabilistic Analysis of ESA-Listed Salmonid 

Entrainment at Ballast and Cooling Water Intakes 

 

1

TECHNICAL MEMORANDUM

Oregon LNG: Probabilistic Analysis of ESA-Listed 

Salmonid Entrainment at Ballast and Cooling Water 

Intakes 

TO: Mark Bricker/SEA 

Jay Lorenz/PDX 

FROM: Dan Pitzler/SEA 

Aaron Hallerman/SEA 

Bob Ellis, Ellis Ecological Services, Inc. 

Dave DeKrey, Ellis Ecological Services, Inc. 

DATE: August 27, 2009 

Introduction

Oregon LNG is proposing to construct a liquefied natural gas (LNG) Terminal near 

Warrenton, Oregon. While unloading, LNG carriers (LNGCs) take on ballast and cooling 

water, which is accomplished through openings in the hull known as “seachests.” These 

seachests are not screened to exclude juvenile fish and, as such, there is the potential for fish 

listed under the Endangered Species Act (ESA) in the Lower Columbia River Estuary 

(LCRE) to be entrained or impinged. Oregon LNG is currently pursuing methods to screen 

or otherwise exclude juvenile salmonids from ballast and cooling water intakes. However, 

because of numerous technical and operational challenges, development of a screening or 

exclusion system has proven challenging. The purpose of this technical memorandum is to 

estimate the potential number of individual fish that could be entrained from each 

Evolutionarily Significant Unit (ESU) or Distinct Population Segment (DPS) of ESA-listed 

salmonids if screens are not used or if screens fail during use. 

It is assumed that because of their relatively large size and good swimming ability during 

estuarine residency, adult eulachon (proposed for threatened status), adult salmon, and 

adult and subadult green sturgeon will not be susceptible to entrainment. Larval eulachon 

will be susceptible to entrainment but—because of their small size—would not be excluded 

from ballast tanks even if screens were employed. There is also concern for the entrainment 

of juvenile Pacific lamprey, an unlisted species that is potentially in decline and is culturally 

important to Native American tribes. Unfortunately, there are no data on lamprey 

abundance, distribution, or behavior in the LCRE, making estimates on their entrainment 

impossible. Juvenile lamprey have been shown to be relatively poor swimmers, and 

therefore are likely susceptible to entrainment. 

Throughout this technical memorandum, the word “entrainment” will be used as a 

surrogate for both entrainment and impingement since both have the same effect—mortality 

of the entrained or impinged fish. This modeling addresses only juvenile salmonids, as 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

2

adults of those species are strong swimmers and are able to avoid entrainment. Therefore, 

any reference to “fish” is in regard to juvenile salmonids. The only other listed or proposed 

species in the LCRE is green sturgeon. Green sturgeon subadults are at least 1.5 years old 

upon entry into the Columbia River estuary, and large enough to avoid entrainment. 

Although some unlisted species present in the LCRE may be susceptible to entrainment, 

population density and distribution data for those species (perhaps with the exception of 

white sturgeon) are so limited that they preclude reasonably accurate prediction of those 

species’ entrainment potential. Nonetheless, impacts to unlisted species will be addressed in 

subsequent documents outlining proposed mitigation activities. 

This technical memorandum provides an update to a previously published technical 

memorandum on this topic1 (the “May 22 memo”). 

In the analysis conducted and reported in the May 22 memo, many assumptions were made 

about uncertain variables that assumed the conservative “worst case.” Thus, the resulting 

entrainment estimates were similarly conservative. Throughout this updated memorandum, 

the assumptions of the May 22 memo are included and briefly discussed for comparison 

purposes. After reviewing earlier versions of the May 22 memo, regulatory agencies 

requested a sensitivity analysis that could be used to establish confidence limits around the 

entrainment estimates. This updated memorandum discusses a revised entrainment 

estimate methodology in which published research and expert opinion were used to assign 

probability distributions and outcomes to a series of key uncertain variables. Probabilistic 

fish entrainment estimates were then developed using Monte Carlo simulation. 

Monte Carlo Simulation Methods 

Monte Carlo simulation calculates fish entrainment by taking a random sample of each 

specified distribution. This result is saved and the simulation is run again, and the result is 

saved. This process continues for 10,000 simulations. The final result is a probability 

distribution for fish entrainment that encapsulates the accumulated knowledge of all the 

uncertain variables. 

Ideally, the selection of probability distributions for key variables should be based on 

consideration of the underlying physical processes or mechanisms thought to drive the 

observed variability. For example, if a key variable is the result of the product of a large 

number of other random variables, it would make sense to select a lognormal distribution 

for testing. As another example, the exponential distribution would be a reasonable 

candidate if the stochastic variable represented a process akin to inter-arrival times of events 

that occur at a constant rate. As a final example, a gamma distribution would be a 

reasonable candidate if the random variable of interest were the sum of independent 

exponential random variables. 

However, in most risk assessment projects, the uncertainties are not the result of underlying 

physical processes or mechanisms, or there are inadequate data available to use as a basis 

 

1 Technical Memorandum from Bob Ellis, Ellis Ecological Services, Inc., to Jay Lorenz, CH2M HILL. May 22, 2009. Oregon 

LNG: Analysis of ESA-Listed Salmonid Entrainment at Ballast and Cooling Water Intakes. Distributed to subgroup members 

May 22, 2009. 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

3

for selection of a particular distribution. In such cases, there are a few types of distributions 

that are used frequently because their parameters are easy to elicit from subject matter 

experts. For this analysis, all probabilistic variables were assigned one of two distributions: 

the triangle distribution and the uniform distribution. A brief discussion of each distribution 

follows. 

Triangle Distribution 

The triangle distribution specifies a triangular distribution using a midpoint (statistically, 

the mode, or the “base” estimate) and the upper and lower limits (endpoints) of the 

distribution. This distribution allows for skewness, where the upper bound is farther, 

typically, from the most likely outcome than the lower bound (that is, +50/-20). The 

following parameters have been specified for all triangle distributions: 

x Lowest possible outcome 

x Most likely outcome 

x Highest possible outcome 

In this analysis, triangle distributions are used to characterize the following variables: 

1. Percentage of vessels annually that will be 148,000 cubic meters (m3) capacity 

2. Percentage of time slack water occurs 

3. Percentage of fish south of Desdemona Sands 

4. Percentage of fish in the top 20 feet (ft) of water 

5. Percentage of fish that react to an entrainment threat at cruising speed (versus burst 

speed or sustained speed) 

6. Fish lengths by species

Uniform Distribution 

The continuous uniform distribution is such that all intervals of the same length between its 

endpoints are equally probable. The distribution is defined by a minimum and maximum 

value. In this analysis, the uniform distribution is used to characterize intake velocities at 

seachests in each of four potential capture zones. 

Methodology Overview 

Estimated fish entrainment by species is a function of a series of relationships between 

relevant variables, some of which are modeled as deterministic (single point estimates), and 

some of which are modeled as uncertain with a probability distribution. A flow diagram 

that shows the relationships between variables is shown in Figure 1. In the diagram, 

deterministic variables are shown as yellow squares, probabilistic variables are shown as 

green ovals, and calculated values are shown as blue, rounded squares. 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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Terminal Variables 

The Terminal variables refer to data regarding the ships that will dock at the proposed 

Terminal. They include the number of annual deliveries, vessel size, hours of intake, intake 

velocities, and potential capture zones. 

Terminal Operation 

During the unloading process, the LNGCs will take on ballast water in order to offset the 

tonnage lost due to the LNG unloading process and to correct for any trim, list, or structural 

considerations. The intake of ballast water is necessary to maintain safe operations and to 

provide a constant freeboard between the vessel and the marine Terminal. Cooling water is 

also required to cool ship engines. Ballast and cooling water systems and requirements vary 

among vessels, including vessels of similar size and capacity. 

Pertinent characteristics of LNGCs and LNG operations were gathered through contacts 

within the shipping industry and engine manufacturers, and from design data and 

photographs of the largest expected LNGC’s seachests at the Daewoo Shipbuilding & 

Marine Engineering (DSME) Shipyard. Such data are often proprietary or closely held and 

are not typically shared outside the industry. Therefore, it was challenging to obtain 

accurate information on seachest design and configuration. 

A single seachest is a recess or cavity in the ship’s hull through which water is drawn for 

onboard uses (Figure 2). Different ship water systems (e.g., ballast water, cooling water, and 

fire suppression water) do not have individual seachests but, rather, the various water 

supplies obtain their water via intakes within shared seachests. Each seachest has one or 

several openings. A typical opening is 0.8 meter (m) (2.6 ft wide and 1.5 m (4.9 ft) high. It 

was assumed that each seachest is equipped with four of these openings, as was the case for 

the observed ship at the DSME Shipyard. Each opening is equipped with a grate or trash 

rack. Figure 1 illustrates a typical seachest with four grated openings. A typical grate 

consists of 2.5- to 5.0-millimeter (mm) (0.1- to 0.2-inch [in.])-wide bars, 25 mm (one in.) on 

center. Most LNGCs have a filter inboard of the seachest intake, consisting of a mesh with 

5-mm (0.2-in.) openings. This mesh size is larger than the screening criterion of 2.38 mm 

(3/32 in.) recommended by the National Marine Fisheries Service (NMFS) and the Oregon 

Department of Fish and Wildlife (ODFW) for intakes where salmonid fry are present, and is 

less than the 6.35-mm (1/4-in.) screening criterion where fry are never present. 

A typical ship will have four seachests—two “high” and two “low.” The low seachests are 

located on either side of the keel, and it is assumed they will not be used when the LNGCs 

are docked in the Columbia River. This is because the seachests would be located so near the 

bottom of the river that there would be risk of entraining sediment. The high seachests are 

located on the lower part of the hull on either side (port and starboard), typically near the 

stern. The depth of the seachests relative to the water surface can vary, but because the ship 

must maintain a constant draft, the seachest depth is expected to remain relatively constant 

while the vessel is at dock. On the basis of industry sources, this depth is expected to be 

27 to 35 ft below the water line, and for the purposes of this modeling, it was assumed to be 

30 ft (9 m) deep. Water can be pumped through any of the seachests, as the various water 

systems have connections to each. 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BA

FIGURE 1 Methodology Flow Diagram 

Hours

per Year 

at Terminal

Capture Zone

Areas for

4 Intake 

Velocity Ranges

Fish in

Area of

Interest

Fish in 

Potential

Capture

Zones

Fish

Entrained

by Species

# of Ships

 by Size

Intake Velocity

in Potential

Capture Zones

% of Time

Slack Water

% of Fish

on Oregon

Side

% of Fish

in Top

20 Feet

FishSize Time at Terminal (Cooling;

Cooling and Ballast)

Capture Zone Areas

for Intake Velocities,

No. of Tanks,

and Tidal Conditions

% of Time

One Tank 

Is Open

Annual

Fish

Passage

Area of

Interest

% of Fish

Captured

% of Time

Typical

Cross Flow

Fish Swim

Speeds

(body length

per second)

Fish Swim 

Speeds

(Feet per 

Second)

Rou

B

Sq

Gre

Ov

Ye

Squ

Rou

B

Sq

Gre

Ov

Ye

Squ

Rou

B

Sq

Gre

Ov

Ye

Squ

Leg

No. of

Ships by

Size

OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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FIGURE 2 

Typical Seachest, Photographed at the DSME Shipyard 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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The DSME Shipyard data indicate that although there is variability in the seachest 

configuration and flow rates, the operational principles are similar for most LNGCs. The 

DSME Shipyard provided typical ballast water requirements, seachest locations and 

opening sizes, operating parameters of ballast and cooling water intake, and cooling water 

requirements for three types of LNGCs: a common carrier of 148,000 m3 capacity, a carrier of 

213,000 m3 capacity (Q-Flex Class), and a carrier of 266,000 m3 capacity (Q-Max Class). 

In general, most LNGCs under 150,000 m3 are steam powered while many of the newer 

ships with capacities greater than 150,000 m3 are diesel powered. Currently, most vessels in 

service throughout the world have capacities of 150,000 m3 or less and are powered by 

steam. Diesel- and steam-powered vessels differ in the amount of cooling water required. A 

steam-powered vessel requires a large quantity of water to cool the condensers, even while 

the vessel is docked. Cooling water is also required for the ship’s equipment (for example, 

generators), but at a much lower flow rate. A diesel-powered ship requires cooling water 

primarily for the ship’s equipment; diesel-powered ships do not use condensers. Therefore, 

the quantity of water required is substantially less for larger diesel-powered ships. 

Hours of Water Intake 

LNGC vessels require cooling water at a constant rate for the entire time they are at port. 

The amount of time the vessels spend in port is dictated by two things: the unloading 

capacity of the Terminal, and unpredictable variables such as the amount of time it takes to 

complete paperwork or other administrative tasks. The amount of ballast water required 

depends on the size of the vessel; larger vessels require more ballast water to offset their 

cargo, and because the on-loading rate is constant, they must therefore spend more time 

unloading. 

A typical steam-powered vessel will use a large pump rated at 10,000 m3 per hour for the 

main condenser cooling water, and a smaller pump rated at 3,000 m3 per hour for the ship’s 

equipment. The total flow that is actually used is normally less than the maximum capacity 

of the pumps; total use is 1,090 m3 per hour for main condenser cooling and 1,300 m3 per 

hour for auxiliary equipment, or a total cooling-water flow rate of approximately 2,390 m3

per hour. In comparison, the typical cooling-water requirements for the new diesel-powered 

vessels are expected to be approximately 2,040 m3 per hour (i.e., 1,300 m3 per hour for main 

condenser cooling and 740 m3 per hour for auxiliary equipment). 

For the purposes of modeling, it was assumed that each vessel would be in port for 

21 hours. This was based on industry sources, including data obtained from Lone Star R.S. 

Platou Inc., a shipping company, which reported time at port for several vessels at several 

LNG terminals; and data for the Cove Point and Elba LNG terminals in Maryland and 

Georgia, respectively. Times at port for Lone Star R.S. Platou ships ranged from 4 hours, 

14 minutes to 23 hours 15 minutes, with an average of 20 hours, 57 minutes. Time spent at 

port for ships at the Elba and Cove Point facilities ranged from 17 hours 40 minutes to 

33 hours 32 minutes, with an average of 23 hours, 38 minutes and a median of 21 hours 

57 minutes. 

Of the 21 hours spent in port, the amount of time spent unloading is based on the unloading 

capacity of the Terminal. During this time, both ballast water and cooling water are 

required. For the remainder of the 21 hours, only cooling water will be withdrawn from the 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

9

estuary. Table 1 shows the total water requirements for different vessel classes. Annual 

hours of water intake will then be calculated as follows: 

Annual hours of water intake = (number of ships by class) * (hours at 

Terminal for each ship) 

TABLE 1 

LNGC Water Flow and Time at Terminal 

 Water Flow (m3 per hour) 

Maximum Intake 

Rate (ft3

/sec) Time at Terminal (hr) 

LNGC Class 

(cm) Ballast Cooling 

Ballast and 

Cooling Ballast and Cooling 

Cooling 

Only 

Ballast and 

Cooling 

148,000 6,200 2,478 8,678 85.1 9 12 

213,000 6,600 2,040 8,640 84.7 7 14 

266,000 6,600 2,040 8,640 84.7 5 16 

Note: Time at Terminal estimated for cooling water only and for ballast and cooling water combined. 

Abbreviations: 

m3 = cubic millimeters. 

ft3/sec = cubic feet per second. 

hr = hours. 

The maximum intake rate was calculated for the “typical” seachest, with four openings 

0.8 m (2.6 ft) wide and 1.5 m (4.9 ft) high. In the initial modeling (discussed in the May 22 

memo), it was assumed that each of the 100 vessels per year would be withdrawing water at 

the maximum flow rate (85 cubic feet per second [ft3/sec]) for 20 hours. In the updated 

modeling, intake velocities around the seachests were calculated for each condition (cooling 

and ballast plus cooling), and incorporated the expected proportion of different ship types 

and the amount of time each ship type spends withdrawing water. 

Annual Deliveries 

In order to determine the amount of water withdrawn annually, it is necessary to estimate 

how many of each vessel class will call at the Terminal each year (because the different 

vessel classes have different water requirements). When the Terminal is operating at design 

capacity, it is assumed that 100 vessels will arrive at the Terminal annually. This reflects the 

annual capacity of the Terminal. In initial years, fewer vessels are anticipated; therefore, the 

amount of salmonid entrainment estimated in this memorandum is the maximum expected 

during full Terminal operation. 

According to Oregon LNG representatives, most ships delivering LNG to the Terminal, at 

least initially, will be the smaller, steam-powered vessels, with fewer Q-Flex and fewer still 

Q-Max class vessels. Oregon LNG representatives believe that the most likely proportion of 

ship sizes that will call at the Terminal is as follows: 

x 148,000 m3—45 ships per year 

x 213,000 m3—35 ships per year 

x 266,000 m3—20 ships per year 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

10

Because the number of ships in each class will vary from year to year, and because the 

number of each class that will call at the Terminal is unknown, this variable was modeled 

using a triangle distribution. Oregon LNG representatives estimate that the 148,000-m3

vessels will be the most common, and that the proportion of this vessel size will vary 

according to a triangle distribution, as shown in Table 2. 

TABLE 2 

Likelihood That Vessels Will Be 148,000 m3 in Size 

Lowest Possible Most Likely Highest Possible 

0% 45% 100% 

During the Monte Carlo simulation process, the ratio of vessels arriving in each class in the 

most likely scenario is used to determine the number of vessels in each class under all other 

scenarios. In other words, in each simulation the number of 148,000-m3 vessels is selected 

from the triangle distribution, and 100 minus that number of vessels (the remainder) is 

allocated as follows: the number of 213,000-m3 vessels is 35/55 (64 percent) of the remainder, 

and the number of 266,000-m3 vessels is 20/55 (36 percent) of the remainder. An example of 

this method is shown in Table 3. 

TABLE 3 

Ship Size Distribution in Four Example Model Iterations

148,000-m3

Vessels Remainder 

213,000-m3

Vessels 

266,000-m3

Vessels 

Most likely 45 55 35 20 

Iteration 2 52 48 31 17 

Iteration 3 41 59 38 21 

Iteration n 68 32 20 12 

In the initial modeling (discussed in the May 22 memo), the variability in ship sizes and 

water needs was not captured. Instead, 100 vessels per year were assumed to withdraw 

water at the maximum rate (85 ft3/sec) for 20 hours. 

Intake Velocities 

To estimate the potential for entrainment, it is necessary to know the shape and size of the 

area around the seachest where intake velocities exceed the swimming abilities of various 

fish. A velocity of 0.4 foot per second (ft/sec) was set as the lower limit for the area of 

potential entrainment because 0.4 ft/sec is the approach velocity set by NMFS as safe for 

salmonid fry at screens with automated cleaning. 

Coast and Harbor Engineering completed hydrodynamic modeling to determine intake 

velocities around the seachests during both cooling water withdrawal and ballast + cooling 

water withdrawal. 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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Modeling was conducted with nonhydrostatic, three-dimensional (3-D), hydrodynamic 

modeling code. The model is based on the 3D Reynolds Averaged Navier-Stokes (RANS) 

equations and the Boussinesq approximation (Kanarska and Maderich, 2003). The model 

equations are integrated with mode-splitting technique and decomposition of pressure and 

velocity fields on hydrostatic and nonhydrostatic components. The model has been tested 

with experimental data and proved to be a reasonable tool for engineering analysis of flow 

hydrodynamics at intakes and jets. 

The modeling domain was set up to be large enough that the flows on the far ends of the 

domain were not affected by the intake velocities. Ambient flows were included in the 

model as constant initial- and boundary-condition velocities with speed 1.64 ft/sec 

(0.5 meter per second [m/sec]). Figure 3 illustrates the expected intake velocities at the 

seachest and at varying distances from the ship’s hull under slackwater conditions, looking 

from the stern toward the bow, with the riverbed illustrated in red at the bottom of the 

figure. Figure 4 is a plan view, looking down, with the four seachest openings illustrated 

from bow to stern.

FIGURE 3 

Intake Velocities at the Seachest 

Ship keel 

(ft/sec)

Seachest 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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FIGURE 4 

Intake Velocities at the Seachest, Plan View 

As can be seen, the zone of influence, where intake velocities exceed 0.4 ft/sec, extends 

approximately 5 ft out from the ship’s hull, and the maximum intake velocity at the face of 

the seachest will be 2.2 ft/sec. Modeling indicated that under tidal or riverine cross-flow 

conditions of 1.64 ft/sec (which would be average cross flow), the zone of influence was 

smaller and maximum velocities at the face of the seachest were less (Figure 5). 

Because Terminal unloading capacity dictates the rate at which water is required, the 

velocity at the seachests is the same, regardless of ship size (provided that the seachests 

have the same dimensions). Only the time of water withdrawal differs among vessel types. 

Potential Capture Zones 

In order to calculate entrainment, it is necessary to know the total area around the seachest 

through which a fish could potentially swim that has velocities above its swimming ability 

(discussed below in the section titled Fish Variables). For modeling purposes, four potential 

“capture zones” were defined around the seachests. These zones were established 

somewhat arbitrarily, with the zone of highest velocity (zone 1) containing a range of 

0.6 ft/sec, while the remaining zones each contain a range of 0.4 ft/sec. Table 4 illustrates 

the range of velocities within each of the capture zones. Velocities within each zone were 

assumed to be a uniform distribution within the ranges. 

Stern

Bow

(ft/sec)

Seachest 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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FIGURE 5 

Change in Intake Velocities at the Seachest under Cross-flow Conditions of 1.64 ft/sec 

TABLE 4 

Intake Velocities in Each Capture Zone 

Velocity in Feet per Second 

Zone 1 Zone 2 Zone 3 Zone 4 

Low 1.6 1.2 0.8 0.4 

High 2.2 1.6 1.2 0.8 

 

In the initial modeling (reported in the May 22 memo), only two capture zones were used. 

Zone A had velocities from 0.66 to 2.2 ft/sec, and Zone B had velocities from 0.4 to 

0.66 ft/sec. The probabilistic modeling (discussed herein) further differs from the initial 

modeling in two important ways: the number of seachests assumed to be in operation, and 

the influence of tidal cross flow. These factors were not captured in the initial modeling; 

instead, cross flow was considered to be nonexistent and only one seachest was assumed to 

be in operation at all times. Neither of these scenarios represents typical conditions; in fact, 

Oregon LNG has stated that it will require LNGCs to use two seachests (both of the high 

seachests, one on either side of the ship) unless there is a compelling reason to do otherwise. 

To address these issues, Coast and Harbor Engineering completed multiple modeling runs 

and calculated the area within each capture zone under each scenario. Capture zone areas 

are the two-dimensional areas corresponding to the velocities of each zone as defined in 

Table 4, above, and are reported in Table 5. 

(ft/sec)

Seachest
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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TABLE 5 

Potential Capture Zone Areas Under Eight Different Modeled Scenarios 

Capture Zone (square feet) 

Zone 1 Zone 2 Zone 3 Zone 4 

Capture Zone Area – Cooling and Ballast 

Slack Water

One seachest open 4.2 4.4 7.4 23.0 

Two seachests open 0.0 0.0 4.2 11.7 

Typical cross flow of 1.64 

feet per second (ft/sec) 

One seachest open 0.0 0.0 1.4 5.6 

Two seachests open 0.0 0.0 0.0 0.1 

Capture Zone Area – Cooling Water Only 

Slack Water

One seachest open 0.0 0.0 0.0 6.5 

Two seachests open 0.0 0.0 0.0 0.0 

Typical cross flow of 

1.64 ft/sec 

One seachest open 0.0 0.0 0.0 0.0 

Two seachests open 0.0 0.0 0.0 0.0 

NOTE: Based on modeling by Coast and Harbor Engineering. 

Additional assumptions included in the model were as follows: 

x Two seachests will operate 90 percent of the time. According to Oregon LNG, it is 

standard industry practice to use both seachests for cooling and ballast water intake. The 

only time that a single seachest is open is when some type of malfunction or other 

unusual event occurs. 

x The percentage of time with slack water vs. typical cross flow was defined as a triangle 

distribution (discussed below in the section titled River Variables). 

As can be seen in Table 5, during cooling-water-only withdrawal, only the lowest velocity 

zone is present, and then only when one seachest is in operation under slackwater 

conditions. At all other times, velocities in excess of 0.4 ft/sec do not occur, even at the face 

of the seachest. Therefore, except under very rare conditions involving slack water, atypical 

seachest operation, and very small fish, no entrainment will occur during cooling-wateronly withdrawal. 

River Variables 

There are several uncertain variables related to the river that affect the potential for fish 

entrainment. The river variables considered in the model include the size of the “Area of 

Interest” and tidal or riverine cross-flow conditions. 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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Area of Interest 

Each fish in the LCRE was assumed to pass once through a two-dimensional plane 

extending from the water surface to the riverbed (top to bottom) and from the Oregon to the 

Washington shore (north to south). The total area of this plane in the LCRE is 51,422 square 

meters (m2) (553,500 square feet [ft2]) at an average tidal stage (Mean Tide Level). Fish are 

likely to be entrained only within a small portion of this plane in the immediate vicinity of 

the seachests. The area where fish are susceptible to entrainment is termed the “Area of 

Interest.” In the initial modeling, fish were assumed to be uniformly distributed in both the 

horizontal and vertical planes. 

For the purposes of probabilistic modeling, fish were distributed horizontally on either side 

of Desdemona Sands and vertically within the water column, as discussed below. On the 

basis of available data, it was assumed that most fish occur in water less than 20 ft deep, and 

any fish that do occur below the 20-ft depth would be uniformly distributed. Therefore, the 

Area of Interest is that portion of the LCRE greater than 20 ft in depth, between the Oregon 

shore and Desdemona Sands. The size of the Area of Interest is approximately 114,125 ft2 

(10,602 m2) (Figure 6). Any fish occurring above this depth or on the north side of 

Desdemona Sands would not be susceptible to entrainment. 

FIGURE 6 

”Area of Interest” in the LCRE 

The area of the four capture zones under each of the eight modeled scenarios (Table 5) was 

divided by the total Area of Interest to determine the percentage of the total area occupied 

by each of the four zones under each scenario. This percentage was used in later 

calculations. 

River Flow Conditions 

River cross flow influences the size of the capture zones, as discussed above. Therefore, it is 

necessary to estimate the amount of time that there is slack water versus the amount of time 

with cross flow. Slack water occurs only as the tide switches from flood to ebb (four times 

Area of Interest

Desdemona Sands
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

16

each day for brief periods), or when the river flow equals the incoming tidal flow. Because 

tidal and river outflow conditions vary, the amount of time with slack water annually was 

assumed to follow a triangle distribution, shown in Table 6. 

TABLE 6 

Percent of Time Slack Water Occurs 

Lowest 

Possible 

Most Likely 

Condition 

Highest 

Possible 

10% 20% 30% 

While cross-flow velocities are highly variable, for the purposes of this analysis typical 

cross-flow conditions are assumed to be 1.64 ft/sec and to vary probabilistically along with 

slack water. In other words, the amount of time that typical cross-flow conditions occur is 

calculated as 1—the percentage of time that slack water occurs (as calculated by the triangle 

distribution). 

Fish Variables 

Fish variables considered in the analysis include salmonid abundance, seasonal occurrence, 

horizontal and vertical distribution, size/swimming speed, and behavioral responses to the 

threat of entrainment. 

Salmonid Abundance 

Salmonid abundance estimates were obtained from Ferguson (2006, 2007, and 2009). These 

documents provide abundance data under two scenarios: “transportation with spill,” where 

some juvenile salmonids are transported around the dams and some pass through, and “full 

transportation,” where all juvenile salmonids are assumed to be transported around the 

dams. Population numbers for the “transportation with spill” scenario are slightly lower 

(for example, 2 percent lower for subyearling Chinook) because of mortality of fish passing 

over the dams. However, according to Mr. Randy Absolon of NMFS, the most appropriate 

data to use are the transportation with spill data, because that is the typical scenario 

experienced by fish in the Columbia River (Absolon, 2009). 

The population data obtained from Ferguson (2006, 2007, and 2009) are for juvenile fish at 

Tongue Point. These estimates do not include fish from populations downstream of Tongue 

Point that could potentially be affected by the proposed Project, and there are no reliable 

data on the numbers of fish this may include. The primary population of fish downstream of 

Tongue Point is present in the Youngs Bay drainage, including Youngs River and its 

tributaries (primarily the Klaskanine River and its branches) and the Lewis and Clark River. 

Significant hatchery releases occur in Youngs Bay and in the Youngs and Klaskanine rivers; 

for example, in 2008, 1.3 million coho, 1.25 million fall Chinook, 543,000 spring Chinook, 

and 41,000 winter steelhead were released (ODFW, 2009). However, winter steelhead in 

Youngs Bay belong to the Southwest (SW) Washington ESU, which is not ESA listed; and 

the spring and fall Chinook that are released into the system include fall Chinook stock 52 

(also called the “Rogue” stock) and spring Chinook stocks 22 and 24, none of which are part 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

17

of any ESA-listed ESU (ODFW and CEDC, 2005a and b). Most of the hatchery Chinook are 

raised in the Youngs Bay net pens for the Select Area Fishery, with smaller numbers 

released into the Klaskanine River and tidewater sections of Youngs River. Any entrainment 

of these unlisted salmonid juveniles could potentially have an impact on recreational and 

commercial fisheries. 

Coho released into the system belong to hatchery stocks 14 and 11, both of which are 

included in the listing for Lower Columbia River [LCR] coho (ODFW and CEDC, 2005c). 

However, the vast majority of the releases occur from the Youngs Bay net pens for the Select 

Area Commercial and Recreational Fisheries (those not released to the net pens include 

small numbers distributed to area high schools for educational purposes). This stock is 

heavily harvested upon its return (with a 98 percent harvest rate for the 1993 to 1997 broods) 

and the goal is for no spawning escapement, as any hatchery strays that spawn successfully 

would compete with the few native fish that may be present (ODFW and CEDC, 2005c). 

Therefore, although there is a small chance that listed LCR coho hatchery releases could be 

entrained, any entrainment would not reduce the future reproductive potential of the 

population (because all listed hatchery releases are targeted for harvest) and, therefore, 

would have no effect on species recovery. Because the population is small, and smolt-toadult survival is likewise small, entrainment of juveniles from the Youngs Bay population 

would not affect recreational or commercial harvest (for comparative purposes, entrainment 

losses from the entire population of more than 13 million LCR coho would result in the 

estimated loss of only three fish to the fishery). 

Further, natural reproduction in the Youngs Bay drainage is effectively nonexistent for both 

coho and Chinook, except for hatchery-origin strays. ODFW and CEDC (2005c) state that no 

wild LCR fall Chinook spawners were observed in LCR tributaries (which include the 

Youngs and Lewis and Clark rivers) from 1998 to 2005, and that all of the spawning that did 

occur was from unlisted hatchery stocks. Therefore, the number of listed LCR Chinook 

produced below Tongue Point that could be potentially affected by the proposed Project is 

very small to nonexistent. 

ODFW has expressed concern about the impact in the future if populations were to increase. 

According to the Lower Columbia River Salmon Recovery and Fish and Wildlife Subbasin Plan, 

the population of fall Chinook in Youngs Bay is considered to be a “stabilizing” population 

(LCRFRB, 2004), meaning that it is likely to be maintained at its current low level in the 

future rather than increased significantly. This is because of the multiple challenges faced by 

the population, which make its recovery of low priority. This plan was completed by 

Washington state agencies and does not necessarily represent the final opinions of ODFW, 

but it was completed in consultation with ODFW. Because ODFW population recovery 

plans have not been completed, this estimate of future reproductive potential is the only 

estimate available. Because the population is effectively zero and is not expected to increase, 

the entrainment potential of this population is also effectively zero now and in the future. 

In regard to Youngs Bay coho, McElhaney et al. (2007) state that “the [Youngs Bay] 

population [of coho] is dominated by hatchery fish, with on average at least 80 percent of 

the coho of hatchery origin...these data indicate little, if any natural productivity of coho in 

the Youngs Bay population and we consider the population most likely in the “extirpated or 

nearly so” or “high risk” category.” The 2005 Native Fish Status Report (ODFW, 2005) states 

that “it is likely that a large portion of [LCR coho] returns over the past 30 years have been 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

18

hatchery origin...Hatchery fractions since 1999 have ranged from 49 to 99 percent.” 

Spawner density per mile of spawning habitat in the Youngs Bay basin from 2000 to 2003 

ranged from 17 to 231 (ODFW, 2005). Combining the spawning density and the percent 

hatchery origin numbers from ODFW (2005) yields from 0.17 to 71.4 natural-origin 

spawners per mile, with a mean over the 4 years of 29.1. Suring et al. (2006) state that from 

2002 to 2004, the estimated wild-origin spawning population ranged from 142 to 281 with a 

mean of 213 for the entire Astoria population, which includes the Youngs and Lewis and 

Clark rivers and numerous tributaries upstream of Tongue Point (which would have been 

included in the NMFS population estimates). This suggests that the total number of 

spawners contributing ESA-listed coho smolts that were not included in the NMFS 

population estimates used for the modeling is something less than 200 adult fish. Assuming 

200 spawners (half of which are female), fecundity of 2,878 eggs per spawner, and egg-smolt 

survival of 0.018 (Quinn, 2005) yields 5,180 smolts. As with fall Chinook, coho in the Youngs 

Bay basin are considered to be a “stabilizing” population in the Lower Columbia River Salmon 

Recovery and Fish and Wildlife Subbasin Plan (LCRFRB, 2004), and the population is therefore 

unlikely to increase in the future. Thus, the Youngs Bay population was assumed to consist 

of 5,180 smolts annually in the subsequent modeling. 

Tables 7 and 8 contain total fish populations used in the modeling, and the percentage of 

each population that is ESA listed. The 3-year population means were used in subsequent 

calculations. 

TABLE 7 

Total Juvenile Salmonid Population at Tongue Point 

Total 2006 2007 2008 3-year Mean 

Chinook yearling 38,832,655 28,719,701 29,538,756 32,363,704 

Chinook subyearling 89,791,172 90,003,337 81,742,198 87,178,902 

Sockeye 1,368,440 1,663,764 1,650,027 1,560,744 

Coho 18,360,241 16,883,265 18,579,800 17,941,102 

Chum 1,607,982 1,452,982 1,342,982 1,467,982 

Steelhead 14,278,819 13,922,277 14,046,231 14,082,442 

TABLE 8 

Percentage of the Total Juvenile Population at Tongue Point That Is ESA Listed 

Species Status 2006 2007 2008 3-year Mean 

Spring/Summer

Chinook

yearling 

Wild 26.55 11.28 13.91 17.25 

Ad-clip* 6.04 6.85 6.26 6.38 

No ad-clip* 0.76 2.43 1.98 1.72 

Fall Chinook yearling Ad-clip*

 1.27 1.14 1.09 1.17 

No ad-clip* 0.43 1.41 1.20 1.01 

Chinook subyearling Wild 26.59 26.20 30.18 27.66 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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TABLE 8 

Percentage of the Total Juvenile Population at Tongue Point That Is ESA Listed 

Species Status 2006 2007 2008 3-year Mean 

Ad-clip* 26.01 41.38 46.33 37.91 

No ad-clip* 18.91 1.11 0.86 6.96 

Sockeye Wild and hatchery 2.73 4.58 6.60 4.64 

Coho Wild 6.53 7.10 6.40 6.68 

Ad-clip* 54.85 52.98 55.86 54.56 

No ad-clip*

 7.93 22.71 8.05 12.90 

Chum 100 100 100 100.00 

Steelhead Wild 19.5 18.86 15.77 18.04 

Ad-clip* 22.98 19.77 21.87 21.54 

No ad-clip*

 4.7 5.35 5.47 5.17 

Note:

*

Ad-clip = adipose-fin-clipped hatchery fish; no-ad-clip = non-adipose-fin-clipped hatchery fish. 

Ferguson (2006, 2007, and 2009) also provides percentages of the ESA-listed fish that belong 

to each ESU/DPS. Table 9 provides the 3-year mean for the percentage of the total listed fish 

that belong to each ESU. 

TABLE 9 

Percentage of the Total ESA-listed Juvenile Salmonids That Belong to Each ESU/DPS 

Evolutionarily Significant 

Unit/Distinct Population 

Segment (ESU/DPS) 

% of the Listed 

Wild Fish in 

Each ESU 

% of the Listed 

Ad-clipped Fish in 

Each ESU 

% of the Listed Nonad-clipped Fish in 

Each ESU 

Yearling Chinook 

Snake River spring/summer 13.21 16.63 14.39 

Snake River fall 0.00 3.59 24.27 

Upper Columbia River 5.34 2.83 26.97 

Lower Columbia River Spring 24.89 22.10 25.01 

Upper Willamette River 56.56 54.87 9.37 

Subyearling Chinook 

Snake River fall 0.66 2.25 25.41 

Lower Columbia River tule 77.28 97.75 74.59 

Lower Columbia River late run 22.06 0.00 0.00 

Steelhead 

Snake River 29.03 61.88 60.03 

Upper Columbia River 4.98 7.61 21.09 

Middle Columbia River summer 25.90 7.26 5.28 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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TABLE 9 

Percentage of the Total ESA-listed Juvenile Salmonids That Belong to Each ESU/DPS 

Evolutionarily Significant 

Unit/Distinct Population 

Segment (ESU/DPS) 

% of the Listed 

Wild Fish in 

Each ESU 

% of the Listed 

Ad-clipped Fish in 

Each ESU 

% of the Listed Nonad-clipped Fish in 

Each ESU 

Middle Columbia River winter 3.44 0.00 0.00 

Lower Columbia River summer 2.88 0.00 0.00 

Lower Columbia River winter 23.49 23.24 13.60 

Upper Willamette River 10.96 0.00 0.00 

Sockeye 

Snake River sockeye 100 

Coho 

Lower Columbia River coho 100 100 100 

Seasonal Abundance 

In the initial modeling effort, the number of fish passing the Terminal each hour was 

calculated for each species. With the exception of subyearling Chinook, this estimate was 

based on the 3-year mean population and the 5-year mean of daily passage at Bonneville 

Dam. In the case of subyearling Chinook, the population was divided into an upriver 

component (which is produced above Bonneville Dam) and a lower river component. 

Hourly passage rates were calculated for the upriver population based on Bonneville Dam 

daily passage data. For the lower river population, hourly passage was based on a seasonal 

abundance curve constructed from data in Bottom et al. (2008). 

Once the hourly passage rate was calculated, it was then necessary to determine the number 

of fish passing through the LCRE during those hours when ships are at berth. It was 

assumed that ships would be withdrawing water for 20 hours and that two ships would 

arrive per week. A matrix was developed that multiplied the hourly fish passage through 

the LCRE on any given day by the number of hours that a ship was at port during that day. 

Ship arrivals were staggered throughout the year at 3- to 4-day intervals, and numerous 

runs were completed such that a ship was present during each calendar day. The simulation 

was run only for those periods of the year when fish of each species would be expected in 

the LCRE. The runs were then averaged to obtain the mean number of fish passing through 

the LCRE while the ships were at port in an average year. The number of fish passing 

through the LCRE was then multiplied by the percentage of the LCRE cross-section 

occupied by the capture zone, to obtain the total “entrainable” population of each species 

(this number was then further reduced by subtracting out unlisted salmonids and those fish 

that could escape, based on swimming ability). 

A much simpler calculation for the number of fish potentially entrained, which ignores 

seasonality, is to simply take the total annual population of any given species multiplied by 

the percentage of time (in a given year) that ships are withdrawing water (22.8 percent of 

the year, assuming 100 ships withdrawing water for 20 hours), times the percentage of the 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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LCRE cross-section occupied by each capture zone (as defined in the initial model). This 

simplified method ignores the influence of daily fluctuations in fish populations, but it 

yields estimates that are, in all cases, within one percent of those obtained by the more 

complicated seasonal curve calculation method. Therefore, the simpler method was used for 

the probabilistic model. 

Fish Distribution 

Both horizontal distribution and vertical distribution are important in estimating 

susceptibility to entrainment. In the initial model, fish were assumed to be evenly 

distributed both horizontally and vertically, except for chum (which were assumed to be 

more prevalent on the Washington side and to reside only in the top 20 ft of the water 

column) and subyearling Chinook (95 percent of which were assumed to be in the top 20 ft 

of the water column, above seachest depths). Although data are limited, the assumption of 

equal horizontal and vertical distribution is overly conservative. 

Horizontal

Unlike the initial modeling effort, the LCRE was divided at approximately the midpoint of 

Desdemona Sands, which are exposed at low tide, and the fish were distributed either to 

their north or south. McComas et al. (2007 and 2008) studied acoustic-tagged yearling and 

subyearling Chinook at the mouth of the Columbia River, and found significantly more fish 

on the Washington side of the navigation channel than on the Oregon side, and very few 

fish within and immediately adjacent to the navigation channel itself. These distribution 

results may not be the same as fish distribution at the Terminal location, in that the tracking 

array was located more than 5 miles downstream of the Terminal at river mile (RM) 5.6; but 

2 years of data did not illustrate any concentrations of fish near the Oregon shore. 

Truelove (2005) also tracked salmonids in the LCRE by releasing more than 2,600 radiotagged, barged and run-of-river steelhead, yearling, and subyearling Chinook. Of these, 62 

were actively tracked for 2 to 26 hours through the LCRE, from approximately RM 27 

downstream to approximately RM 8 (no individual fish was tracked over the entire 

distance). The author found that all tracked salmon spent a portion of their migration in the 

main navigation channel, while a majority moved from the navigation channel through 

numerous shallow side channels, and into the deep northern channel, near the Washington 

shore. Some steelhead and one spring/summer (yearling) Chinook used the shipping 

channel adjacent to the Terminal, but the majority of the fall (subyearling) Chinook were 

distributed nearer the Washington shore, and none were tracked past the Terminal. 

A recently published study (Carter et al., 2009) found that at RM 5.2 (East Sand Island), most 

acoustic-tagged yearling and subyearling Chinook salmon migrated on the north 

(Washington) side of the navigation channel. This was especially pronounced for 

subyearling Chinook salmon. No data from nearer the Terminal location were available, but 

the acoustic array at RM 5.2 is only 5.8 river miles downstream. With only 2 years of data 

(2005 and 2008), no clear pattern in cross-channel distribution was observed for acoustictagged steelhead on the array near East Sand Island. 

Migration distribution across the array on the Columbia River Bar (RM 1.75) tended to be 

nearer, or in, the navigation channel than it was at RM 5.2 for yearling and subyearling 

Chinook salmon and steelhead. 
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In the case of chum salmon, except for some spawning on the Oregon side of the Columbia 

mainstem near McCord Creek (Multnomah Falls), all Lower Columbia chum are spawned 

on the north side of the Columbia mainstem and in Washington tributaries. On the basis of 

their spawning locations and their propensity to hug the shoreline, chum salmon likely 

migrate and rear primarily along the Washington shore. This is supported by the findings of 

Roegner et al. (2004a and 2004b). In 2003, the authors collected 284 chum salmon by beach 

seine, but only 39 of these were collected at Point Adams Beach (on the Oregon shore); the 

majority (166) were collected at West Sand Island on the Washington side of the estuary 

near the mouth, despite similar seining effort on each side of the river. In 2002, the authors 

collected 590 total chum salmon, but only four of these were collected on the Oregon side. 

Thus, it appears that the majority of chum salmon fry would be nearer the Washington 

shore. 

On the basis of the findings discussed above, the occurrence of juvenile salmonids across the 

estuary was represented by a triangle distribution, with between 20 and 50 percent of the 

juvenile salmonids migrating through the LCRE between Desdemona Sands and the Oregon 

shore; 40 percent occurrence on the Oregon side is considered most probable. 

Vertical

The available evidence indicates that juvenile salmonids tend to migrate in shallow surface 

waters. This assumption is supported, in part, by the significant predation of juvenile 

salmonids by Caspian terns, suggesting that many (if not most) juvenile salmonids are very 

near the surface because Caspian terns cannot dive deeper than 2.5 ft (Collis et al., 2001). 

Ocean-type Salmonids (Subyearling Chinook and Chum). Chum salmon collected during 

beach seining at Point Adams Beach in 2002 and 2003—located at RM 8 downstream from 

the Terminal site—ranged in length from 30 to 75 mm, with the largest of those captured 

later in the year (May versus February) (Roegner et al., 2004a and 2004b). Because of their 

small size, chum likely avoid deep water; in fact, chum fry have been found to follow the 

shoreline in shallow-water areas until they reach 55 to 60 mm fork length or longer (Bax et 

al., 1980; Salo, 1981). The shallow-water orientation of juvenile chum is supported by 

numerous studies identifying chum salmon in shallow-water habitats (Levy and Northcote, 

1981; Myers and Horton, 1982; Simenstad et al., 1982; Levings et al., 1986; Pearcy et al., 

1989). It was recently reinforced by Toft et al. (2004), who found that juvenile salmonids 

(chum, Chinook, and coho) in Puget Sound were never observed in the lower part of the 

water column during 442 snorkel surveys, except for one observation of a larger Chinook or 

coho. 

In deeper water habitats (up to 4.4 m deep), Toft et al. (2004) found that juvenile salmonids 

occupied the middle (40 percent of observed fish) to the surface (60 percent of observed fish) 

of the water column. Juvenile Chinook and coho were located more at the surface of the 

water column at deep-riprap sites, perhaps because of the underlying riprap structure and 

associated predators that can hide in the interstitial spaces. At other studied habitat types 

(cobble beach, sand beach, and shallow riprap), juvenile salmonids were more distributed 

between the middle and the surface of the water column. Chum were always observed at 

the surface except adjacent to overwater structures, where they were occasionally observed 

in the middle of the water column (up to 1.5 m [5 ft] deep). However, the study was 

conducted in Puget Sound and its applicability to the LCRE is unknown. 
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Chum salmon are also known to school (Simenstad et al., 1999), leading to a clumped 

distribution that further complicates attempts to estimate their entrainment risk. 

Nonetheless, there is no reason to believe that schooling would occur at the depth and in the 

location of the seachests. Therefore, it was assumed that because of their strong association 

with shallow shoreline habitats and distribution primarily along the Washington shore, 

chum fry would not be susceptible to entrainment/impingement at the Terminal site, which 

is located in deep water 2,100 ft offshore on the Oregon side of the Columbia River. 

Like chum, subyearling Chinook prefer peripheral shoreline areas, wetlands/marshes, and 

shallow, protected sand flats or mud flats (Nightingale and Simenstad, 2001; NMFS, 2002; 

Fresh et al., 2003). Bottom et al. (2005) assumed (when conducting habitat opportunity 

simulations) that subyearlings were primarily located near shore in water ranging from 

10 centimeters (cm) to about 2 m (4 in. to 6.5 ft) deep. As subyearlings grow, they move into 

other habitats and can be found in open-water areas. However, in open water they appear to 

still use the upper portion of the water column, with very few occurring below 20 ft in depth 

(Dawley et al., 1986; NMFS, 2006). 

If subyearling Chinook move offshore, at least 95 percent of fry and fingerlings occur in the 

upper 3 m of the water column. This is illustrated by Dawley et al. (1986), who sampled fish 

at three depths in the Columbia River estuary (see Table 10). Ten trawls were conducted at 

each of three sites at each of three depths (or thirty trawls at each site) between June 1 and 

July 31, 1966. Although the data are more than 40 years old, there is no reason to believe that 

salmonids have altered their migration depths in that interval. No more than 4.8 percent of 

subyearling Chinook were collected below 3 m (9.84 ft—well above the depth of the 

seachests) (Table 10). And, more significantly, no more than 0.3 percent of subyearling 

Chinook were found below 19.68 ft in depth. On the basis of these results, it is assumed that 

5 percent of the subyearling Chinook are present at seachest depths and therefore 

susceptible to entrainment. This is a conservative assumption given that no more than 

0.3 percent of subyearling Chinook were collected by Dawley et al. (1986) at seachest depths. 

TABLE 10 

Number and Percentage of Subyearling Chinook Collected at Three Sites and Three Depths by Dawley et al. (1986) 

Fishing Depth 

Jones Beach Tongue Point Clatsop Spit 

No. of Fish % No. of Fish % No. of Fish % 

0 to 9.84 ft 1,510 96.3 662 95.2 321 97.9 

9.84 to 19.68 ft 57 3.6 33 4.8 6 1.8 

Below 19.68 ft 1 0.1 0 0.0 1 0.3 

Juvenile salmonids are distributed along a habitat continuum, with larger juveniles 

inhabiting deeper water (Bottom et al., 2005). Even among subyearlings, the larger 

individuals are found in relatively deeper water (Bottom et al., 1984). Dawley et al. (1986) 

found that subyearling Chinook captured in the water column with purse seines were 

generally 10 to 20 mm longer than those captured in nearshore habitats with beach seines. 

Therefore, smaller subyearlings originating below Bonneville Dam would likely be found 

only in the shallows, while larger subyearlings would be among the small percentage at 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

24

seachest depths, further reducing their susceptibility to entrainment (because of greater 

swimming ability). 

Recent data in Carter et al. (2009) indicate that migration depth may be more variable than 

previously assumed, and some subyearling salmonids were tracked migrating at depths of 

up to 90 ft. However, the data reported are preliminary, the study methods were not 

discussed, and—most critical to this modeling effort—the proportion of fish migrating at 

different depths was not provided. 

Stream-type Salmonids (Yearling Chinook, Coho, Sockeye, and Steelhead). Information is 

generally lacking on vertical distribution of stream-type salmonids in the Columbia River 

estuary. Most of the available evidence indicates that the majority of stream-type juveniles 

move rapidly downstream through the estuary and are located in the upper portion of the 

water column (Johnson et al., 2003; Emmett et al., 2004; Truelove, 2005; Dauble et al., 1989; 

Beeman and Maule, 2006). Beeman et al. (2003) determined a median rearing/migration 

depth for juvenile Chinook salmon in 1999 in the McNary Reservoir of 8 ft, with a range of 

water column depths from the water surface to about 33 ft. Steelhead had a slightly deeper 

median rearing/migration depth of 9 ft, as well as a greater range of depths, from the water 

surface to about 39 ft. Unfortunately, this study (as well as Dauble et al. [1989], which was 

conducted in the Hanford Reach) was not conducted in the LCRE. In both studies, the 

median migration depth was well above seachest depths, indicating that most fish would be 

located in shallower water. However, because fish behavior may be significantly different 

between the estuary and the freshwater mainstem sites, the applicability of these studies is 

suspect. 

Carlson et al. (2001) sampled fish between Puget Island and Welch Island in the freshwater 

portion of the estuary. The study has been described by NMFS (2005) as finding “juvenile 

salmonids using water column depths ranging from 22 to 37 ft.” However, the authors used 

a method (hydroacoustics) that could not sample the upper 2.75 m (9 ft) of the water column 

and could identify only undifferentiated “fish,” not just juvenile salmonids. In actuality, 

what the authors found during sampling in 1998 was that, “most fish in the inshore habitat 

were detected within 2 m of the bottom...At the channel margin, the highest densities of the 

fish were detected between 3 and 10 m from the bottom...In the channel, the highest 

densities of the fish were detected between 5 and 15 m from the bottom.” The navigation 

channel was characterized as the deepwater region, usually greater than 15 m, with a rather 

uniform bottom. The channel margin was a sloping region with a noticeable gradient 

leading from the channel up to the inshore area. The inshore region was characterized as a 

shallow area near the bank where the water was normally less than 7 m deep. 

The seachests will be located approximately 5 m above the riverbed, in channel-type habitat. 

This depth is at the deeper extreme of where “most” fish were found in the Carlson et al. 

(2001) study. And again, it must be stressed that the upper water column could not be 

sampled by Carlson et al. (2001), and the observed fish were not necessarily salmonids. 

Sampling was done from July 14 to 16, after peak salmonid outmigration. This period 

coincides with the latter part of the shad migration, when many other fish species are also 

present. 

Because there is no information to suggest that juvenile ESA-listed salmonids are 

concentrated in the 25- to 37-ft-depth range where the seachests are located, data from 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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Dawley et al. (1986) were assumed to be the most reliable. Therefore, the occurrence of 

juvenile salmonids within the water column was represented by a triangle distribution, with 

between 60 and 99 percent of the juvenile salmonids migrating through the LCRE in water 

less than 20 ft deep, with 95 percent occurrence above seachest depth being most probable. 

Summary

With the exception of chum (which were assumed to be unsusceptible to entrainment based 

on their horizontal and vertical distribution), fish distribution is assumed to be the same 

regardless of species. The number of fish in the Area of Interest is calculated as follows: 

Fish in Area of Interest = (percent of fish on Oregon side * [1 percent of fish in top 

20 ft of water]) 

This was modeled as a triangle distribution, as shown in Table 11. 

TABLE 11 

Fish Distribution Model Input Variables 

Lowest 

Possible 

Most

Likely 

Highest 

Possible 

Percent of total fish on the Oregon side 20% 40% 50% 

Percent of fish in top 20 feet of water 60% 95% 99% 

The area of the capture zones, and thus the percentage of the Area of Interest they occupy, 

varies based on the water withdrawal scenarios, as illustrated in Table 5. For each scenario, 

the number of annual fish passing through the potential capture zones is calculated as 

follows: 

Annual number of fish passing through a capture zone = 

Annual fish in Area of Interest* area of potential capture zone/Area of Interest 

The result is then summed for all four zones (Zones 1 through 4). 

Behavioral Response 

Many aspects of salmonid behavior could potentially affect their susceptibility to 

entrainment, such as the following: 

x How salmonids react upon encountering an in-water obstacle such as an LNGC and the 

LNGC dock, which will be outfitted with lights (attraction/avoidance behavior) 

x How salmonids perceive and avoid intake velocities such as those at the seachests 

(response to intake velocities) 

x Diel migratory behavior 

x Tidal cycle migratory behavior 

An overarching assumption in the model, which has been questioned by ODFW reviewers, 

is that each juvenile salmonid moves past the Terminal only once on its downstream 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

26

migration. There is significant support (discussed below) that at least for stream-type fish, 

this is likely the case. However, because some subyearling salmonids may be rearing in the 

vicinity of the Terminal, they could theoretically pass through a capture zone multiple 

times. Multiple passes through a capture zone have the effect of increasing the population of 

“entrainable” fish. In other words, the final results assume one pass through the LCRE per 

fish; if additional passes through the LCRE are assumed, the final results can simply be 

multiplied by the number of assumed passes. 

Attraction and Avoidance

Very little is known about salmonid behavior in response to in-water obstacles and artificial 

light. Simenstad et al. (1999) reviewed the available literature and found that fish response 

to overwater and in-water structures was highly variable and appeared to reflect variable 

conditions (e.g., adjacent shorelines, dock dimensions and material, artificial lighting) that 

affected observations. Toft et al. (2004) studied juvenile salmonid responses to shoreline 

habitats by using snorkel surveys and enclosure nets. The authors found that most juvenile 

salmonids were either schooling or swimming away from overwater structures and deep 

water with riprap substrate (overwater structures were large apartment or business 

complexes constructed on a pier, where average water depth was 3.0 m [9.78 ft; while deep 

riprap had a mean depth of 2.4 m [7.9 ft]). The authors concluded, in part, that, “it seems 

that when juvenile salmonids are migrating along the shoreline and encounter a modified 

habitat with the shallow water zone truncated, they may be forced to inhabit deeper water 

and also school more, as juvenile salmonids had significantly greater school sizes at 

overwater structures than at the other habitat types” (Toft et al., 2004). Shallow-water 

habitat will not be abruptly truncated at the Terminal but, instead, will grade gradually 

down to the maximum berth/turning basin depth. 

The Terminal location is 2,100 ft offshore, and there is significant shallow-water habitat 

available between the berth and shore through which juveniles could migrate. 

Unfortunately, the effect that the presence of Youngs Bay has on shore-oriented, migrating, 

juvenile salmonids is unknown. Because of a lack of reliable and consistent data on fish 

response to artificial light or in-water structures, it was impossible to incorporate a metric 

into the model that would account for attraction or avoidance at the Terminal. The only way 

that fish entrainment would be increased over that assumed by the model would be if, upon 

encountering the LNGC and Terminal on their downstream migration, juvenile salmonids 

were concentrated within the Area of Interest and remained there until they tired and were 

entrained. It is difficult to imagine a plausible reason for such behavior. 

Diel Migratory Behavior

Dawley et al. (1986) found little downstream movement by juvenile salmonids at night, and 

McComas et al. (2007 and 2008) did not find large differences between day and night 

migration, although fish may have been migrating more actively during the day. While 

Dauble et al. (1989) found more active migration at night, Carter et al. (2009) reported that 

acoustic-tagged salmonid smolts were present in the Columbia River estuary throughout all 

times of day during their migration seasons, with no clear patterns in diel presence at most 

acoustic arrays. The one exception was that more yearling Chinook salmon appeared to pass 

the Columbia River Bar (RM 1.75) just after sunrise than at other times of the day. Because 

of a lack of consistent findings with regard to salmonid diel movements and the fact that the 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

27

ballast and cooling water withdrawals will vary over the course of a 24-hour period in an 

unpredictable manner, it was impossible to incorporate a metric into the model to account 

for diel movement patterns. Thus, for each hour in any given day, the number of fish 

moving past the Terminal was assumed to be constant. 

As stated above, it was also assumed that fish move past the Terminal once on their 

downstream migrations, rather than holding near the Terminal or moving back and forth 

through the capture zones more than once. This is supported by recent studies indicating 

that median travel times from Bonneville Dam through the mouth of the Columbia River 

estuary are from approximately 3 to 4 days for both yearling (116 to 226 mm in length) and 

upriver-origin subyearling (94 to 155 mm) Chinook salmon (McComas et al., 2007 and 2008). 

Data in Carter et al. (2009) allow for finer grained estimates of downstream salmonid speed. 

The authors found that larger smolts tend to move more rapidly than their smaller cohorts. 

Acoustic telemetry data collected in the Columbia River estuary between 2004 and 2008 

indicated that yearling Chinook salmon typically migrated at a rate of about 80 kilometers 

(km) per day between Bonneville Dam and Vancouver, Washington. Yearling Chinook 

salmon migrated slower (approximately 60 km per day) through the section of the 

Columbia River between Vancouver and the mouth of the Columbia River, but once they 

committed to leaving the Columbia River, typically during an ebb tide, they migrated rather 

quickly at rates between 100 and 150 km per day between RM 5.2 and RM 1.75. Taken as a 

whole, data collected on arrays of acoustic receivers placed throughout the Columbia River 

estuary beginning in 2007 indicate that yearling and subyearling Chinook salmon and 

steelhead travel more slowly in the final 50 km of the Columbia River than in the previous 

200 km, before substantially increasing their travel rates as they exit the river and enter the 

Pacific Ocean. Increased travel rates were noted at RM 5.2, but it is unknown whether the 

fish have started to increase their migration speed at the Terminal location (RM 11) or 

whether their travel rate there is more similar to areas slightly upriver. However, even when 

the fish were described as migrating “more slowly” through the lower 50 km, their travel 

rates were still 32 to 40.8 km per day for subyearling Chinook, 76 km per day for steelhead, 

and 45.4 km per day for yearling Chinook. 

Such rapid travel times indicate that juvenile salmonids are not holding in the LCRE near 

the Terminal, although they likely rear extensively in island complexes upriver of the 

Terminal and in shallow shoreline areas. This is further supported by the findings of 

Truelove (2005), who observed no extended periods of holding in juvenile salmonids within 

the Columbia River estuary during tracking studies. 

Tidal Cycle Migratory Behavior 

When smolts reach the lower 8 km of the Columbia River, they most often exit the river and 

enter the plume on an ebb tide (Carter et al., 2009). It is reasonable to assume that juvenile 

salmonids would migrate downstream faster on the outgoing tide than they do on the 

incoming tide. Unfortunately, aside from that reported in Carter et al. (2009), there is very 

little information on salmonid behavior or migration rates in response to tidal conditions. 

Truelove (2005) found that spring/summer and fall Chinook, along with steelhead, swam 

more passively when the current was moving out of the estuary and more actively during 

slack current. When the current was moving into the estuary, however, steelhead were the 

only fish to exhibit passive swimming behavior, while spring/summer and fall Chinook 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

28

swam actively against the current. Unfortunately, relatively few steelhead and fall Chinook 

were recorded during slack and incoming currents, which limits the conclusions that can be 

drawn. 

Because ships will be present during all tidal conditions (and it is impossible to predict the 

portion of time they will spend at port during incoming, slack, and outgoing tides), it was 

not practical to incorporate differential entrainment rates due to tidal cycle in the model. 

Response to Intake Velocities 

In order for juvenile salmonids—even those with strong swimming abilities—to avoid 

entrainment, they would need to sense and then swim away from the intakes. It has been 

reported that fish are capable of sensing even small velocity differences of 0.328 ft/sec 

(Jones, 1968; in Bell, 1991). When different velocities are sensed, fish may avoid moving 

from one gradient to another, preferring to stay within water of constant velocity (Bell, 

1991). Therefore, it was assumed that salmonids would sense, and at least attempt to swim 

away from, the seachests. It was assumed unlikely that a fish migrating downstream past 

the Terminal would sense the intake, change course, and swim directly into the seachest. 

This is supported by the fact that salmonids tend to avoid enclosed areas and channels with 

overhead cover (Kemp et al., 2005; Bell, 1991). 

Given the assumption that all juvenile salmonids that encounter the seachests will attempt 

to escape before being entrained, it is then necessary to establish the minimum size 

salmonid that would be capable of escaping. Salmonids are strong swimmers, able to 

navigate rapidly flowing rivers and ocean currents. However, swimming speed is a function 

of fish size, with maximum and optimal swimming speed increasing with fish length, up to 

a certain point (Groot et al., 1995). In other words, larger fish are able to swim faster. 

Many authors have studied swimming ability, which is normally divided into three 

categories: cruising, sustained (or prolonged), and burst (or darting) speed. Cruising speed 

is the speed fish are capable of sustaining nearly indefinitely (longer than 200 minutes). 

Sustained swimming speed can be maintained for 15 seconds to 200 minutes, and burst 

speed can be maintained for less than 15 seconds and requires a recovery period (Groot et 

al., 1995). There is no guidance on salmonid ability to avoid unscreened intakes, but in 

regard to setting acceptable velocities at fish screens, Turnpenny et al. (1998) state the 

following: 

“Burst speeds are used only when the fish are strongly motivated, e.g. for 

darting at prey and to escape from danger...When not provided with a 

suitable escape route, fish will often be drawn into an intake, even though the 

intake approach velocity may be well below their burst speed potential; only 

when the water velocity is in the [sustained] to [cruising] swimming speed 

range of the fish do they move out of danger...Consequently, the [cruising] 

swimming speed is, in most cases the safest measure of setting the approach 

velocity...provided that the velocity is below the maximum [cruising] 

swimming speed, a fish should be able to swim ahead of the screen for 

several hours. Designs based on [sustained] swimming capability may be 

acceptable in situations where fish are demonstrably capable of finding the 

bypass route quickly. “ 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

29

In the case of the seachest, the “bypass route” is effectively all directions away from the 

seachest, and therefore a defensible argument could be made for applying sustained 

swimming speed as the most applicable escape criterion. In the initial modeling effort, it 

was assumed that fish would attempt to escape using only their cruising speed. This was an 

overly conservative assumption. 

Before being drawn into an intake, an individual fish would logically attempt to escape with 

increasing urgency. Unfortunately, there are no data on fish response to seachest intakes. 

Therefore, using best professional judgment, it was assumed that the proportion that would 

attempt to escape using cruising speed would follow a triangle distribution, as shown in 

Table 12. 

TABLE 12 

Percent of Time Escape Is at Cruising Speed 

Lowest 

Possible 

Most Likely 

Condition 

Highest 

Possible 

30% 35% 80% 

It was assumed that the remaining fish (which did not attempt to escape using cruising 

speed) would attempt to escape using sustained speed (60/65 [92 percent] of the remainder) 

or burst speed (5/65 [8 percent] of the remainder). In other words, under the most likely 

scenario, for every 100 fish, 35 would attempt to escape using cruising speed, 60 would 

attempt to escape using sustained speed, and 5 would attempt to escape using burst speed. 

At the high end of the cruising speed estimate, for every 100 fish, 80 would attempt to 

escape using cruising speed, 18 would attempt to escape using sustained speed, and 

2 would attempt to escape using burst speed. The cruising, sustained, and burst speeds 

obtainable by the individual fish varied with their size distributions, as described below. 

Salmonid Swimming Abilities 

Cruising swimming speeds are determined through bioassay principles. Times to fatigue 

are measured for fish swimming at various constant speeds. Sustained (or prolonged) 

speeds are also reported as “critical” swimming speeds, measured by using an increasingvelocity test (Groot et al., 1995). Groot et al. (1995) report cruising speed to be approximately 

2.5 body lengths per second (bl/sec), sustained speed to be 3 to 5 bl/sec, and burst speed to 

be 4.5 to 12 bl/sec. Critical swimming speeds have been reported by numerous authors, but 

they are often reported in different units, from bl/sec, to ft/sec, to cm/sec. Table 13 presents 

the available data for salmonids in the units reported in the source documents, and 

converted to ft/sec. 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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TABLE 13 

Salmonid Swimming Abilities 

Species 

Life 

Stage Size (mm) 

Critical

Swimming Speed 

(reported units) 

Speed 

(ft/sec) Source 

Atlantic salmon Parr 57 9.8 bl/s 1.83 Peake et al., 1997 

Unspecified salmon Parr 100 7.3 bl/s 2.4 Peake and 

McKinley, 1998, in 

Turnpenny et al., 

1998 

Atlantic salmon Parr 134 6.2 bl/s 2.72 Peake et al., 1997

Atlantic salmon Smolt 152 7.5 bl/s 3.74 

Unspecified salmon Smolt 120 7.1 bl/s 2.8 Booth et al.,1996, 

in Turnpenny et al., 

1998 

Sockeye NR 77.7 (mean) 8.3 bl/s 2.12 Taylor and Foote, 

1991 Kokanee NR 77.5 (mean) 7.3 bl/s 1.86 

Sockeye NR 91.4 (mean) 6.6 bl/s 1.98 

Kokanee/sockeye hybrids NR 91.9 (mean) 6.6 bl/s 1.99 

Sockeye NR 150 (approx.) 5 bl/s 2.4 Groot et al., 1995 

Coho NR 51 < 0.5 ft/sec < 0.5 

ft/sec 

Bell, 1991 

Coho NR 89 < 1.0 ft/sec < 1.0 

ft/sec 

Coho NR 121 < 1.3 ft/sec < 1.3 

ft/sec 

Sockeye NR 127 1.75 ft/sec 1.75

ft/sec 

Abbreviations: 

NR = not reported. 

bl/s = body length per second. 

ft/sec = feet per second. 

Aside from Bell (1991), who offers no source information for his data, the results are 

remarkably consistent for fish of different sizes—generally in the 2 ft/sec range for critical 

(sustained) swimming speed. The maximum intake velocity at the face of the seachest will 

be approximately 2.2 ft/sec, indicating that few juvenile salmonids would be susceptible to 

entrainment. 

In the initial modeling, a very conservative escape speed was assumed—2 bl/sec as 

suggested by Turnpenny et al. (1998), who stated, “The safe and easy option (although not 

necessarily the lowest cost option) is to adopt widely accepted standard criteria for fish 

escape velocity. “ Their stated “widely accepted standard” criterion was 2 bl/sec. 

It should also be noted that cruising speed is affected by salinity and temperature. In spite of 

the large inflows and tidal exchanges, which lead to a widely varying salinity and 

temperature regime (both daily and annually), the temperature and salinity at the Terminal 

location remain well within the tolerance limits of juvenile salmonids. Therefore, it was 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

31

assumed that temperature and salinity variations would not cause significant changes in 

swimming performance. 

As can be seen from Table 13, the lowest reported critical swimming speed is 5 bl/sec 

(except for the Bell [1991] data, which are suspect). Burst speeds have not been well defined 

(Groot et al., 1995), but they have been reported to exceed 10 bl/sec (Groot et al., 1995) and 

are assumed to be higher than the highest reported critical swimming speed of 9.8 bl/sec. 

For the purposes of modeling, escape speeds were assumed to be as shown in Table 14. 

TABLE 14 

Estimated Escape Speed 

Movement Speed (bl/s) 

Burst 10 

Sustained 5 

Cruising 2 

bl/s = body length per second. 

Because swimming speed (in ft/sec) is dependent on body length, length data were 

obtained from various sources, including Mr. Dean Ballinger of the Pacific States Marine 

Fisheries Center fish counting facility at Bonneville Dam. Table 15 contains the mean lengths 

and size ranges for various species as reported in 2008. 

TABLE 15 

Mean and Range Fish Lengths for Various Species at Bonneville Dam in 2008 

Species 

Mean 

Length 

(mm) Minimum (mm) Maximum (mm)

Number of Fish 

Sampled

Yearling Chinook 144.8 85 266 4,630 

Subyearling Chinook 107.5 60 206 8,825 

Non-ad-clipped steelhead 199.7 115 353 843 

Ad-clipped steelhead 234.7 118 373 1,436 

Coho 139.5 75 214 2,165 

Sockeye 130.1 77 197 865 

mm = millimeters. 

Source: Ballinger, 2009. 

The fish lengths input to the model are based on these data. Because length frequency 

distribution was not available, lengths were assumed to follow a triangle distribution using 

the minima, maxima, and means. Because lower river subyearlings are smaller, the 

population of subyearling Chinook was again divided into lower river and upriver 

components. The lengths from Bonneville (Table 15) were used for upriver subyearling 

Chinook. For lower river subyearling Chinook, data from Bottom et al. (2008) were used. 

Lower river subyearling Chinook were assumed to range from 35 to 150 mm, with a mean 

of 85 mm. 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

32

In the initial modeling (reported in the May 22 memo), only two velocity “capture zones” 

(instead of four) were established at the seachests. The first (Zone A) was the area in the 

immediate vicinity of the seachest where velocities exceed 0.66 ft/sec or 2 bl/sec for a 100-

mm fish. Zone B extended from the 0.66 ft/sec line to the maximum extent of influence 

around the seachests, where the intake velocity exceeded 0.4 ft/sec. It was assumed that 

only fish less than 100 mm in length would be entrained within Zone B, while all fish 

regardless of size (and, hence, regardless of swimming ability) would be entrained in Zone 

A. This was an overly conservative assumption. 

Methods Summary 

The probabilistic model takes into consideration multiple factors. First, it considers the size 

of the various capture zones around the seachests (where velocities exceed previously 

established criteria), based on ship water needs and likely tidal conditions. Then it 

determines what percentage of the time (annually) those capture zones are present and 

what percentage of the Area of Interest the capture zones occupy. Then, it calculates the 

number of fish of each species that are likely to pass through each capture zone annually 

based on total fish populations, and their distribution horizontally and vertically. Finally, it 

determines how many of each fish species are likely to escape from each capture zone based 

on swimming ability (which is size related) and their assumed reaction (cruising, sustained, 

or burst speed). The variables input to the model are summarized in Table 16. 

TABLE 16 

Model Inputs 

Variable

Deterministic

Values

Probabilistic Values 

Lower 

Limit Most Likely 

Upper 

Limit 

Cross-sectional area of LCRE between Oregon side 

and Desdemona Sands 

263,875 ft2

 

Cross-sectional area between surface and –20 feet 

Mean Tide Level 

149,750 ft2

 

Cross-sectional area between –20 feet mean tide level 

and river bottom from Oregon shore to Desdemona 

Sands (the Area of Interest) 

114,125 ft2

 

Percentage of time slack tide (no cross flow) 10% 20% 30% 

Percentage of time cross flow 1 percent of time slack tide 

Percentage of time ships would be 148,000-m3 class 0% 45% 100% 

Percentage of time ships would be 213,000-m3 class

35/55 of 

those not 

148,000 m3

Percentage of time ships would be 266,000-m3 class

20/55 of 

those not 

148,000 m3

Percentage of time ships would operate only one 

seachest

10% 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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TABLE 16 

Model Inputs 

Variable

Deterministic

Values

Probabilistic Values 

Lower 

Limit Most Likely 

Upper 

Limit 

Percentage of total juvenile population on the Oregon 

side (between Desdemona Sands and Oregon shore) 

 20% 40% 50% 

Percentage of total juvenile population in water 20 feet 

deep and less 

 40% 95% 99% 

Burst speed 10 bl/sec 

Sustained speed 5 bl/sec 

Cruising speed 2 bl/sec 

Percentage of fish that will attempt to escape using 

cruising speed 

 30% 35% 80% 

Percentage of fish that will attempt to escape using 

sustained speed 

60/65 of those 

not using 

cruising

speed 

Percentage of fish that will attempt to escape using 

burst speed 

5/65 of those 

not using 

cruising

speed 

Lower river subyearling Chinook size (mm) 35 85 140 

Upper river subyearling Chinook size (mm) 60 108 206 

Yearling Chinook size (mm) 85 145 266 

Coho size (mm) 75 140 214 

Steelhead size (mm) 115 222 373 

Sockeye size (mm) 77 130 197 

Abbreviations: 

ft2 = square feet. 

m3 = cubic meters. 

bl/sec = body lengths per second. 

mm = millimeters. 

This methodology differs significantly from the initial methodology in that it takes into 

consideration many additional variables and attempts to apply probabilities to each of the 

uncertain variables. Table 17 summarizes the differences between the two models and the 

rationale for changing the initial assumptions. 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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TABLE 17 

Variables and Assumptions Used in the Initial Modeling Approach and the Revised Approach 

Variable/Assumption Previous Approach Revised Approach Rationale 

Seachest depth 30 ft (9 m) deep Unchanged. Industry sources indicate 

that seachests are located at 

depths of 27 to 35 ft below 

water line. 

Ballast and cooling 

water needs 

Assumed maximum 

withdrawal rate (85 

ft3

/sec) for 20 hours per 

ship 

Adjusted the amount of 

water required based on 

the expected annual 

distribution of ship types. 

Industry sources provided 

typical ballast and cooling 

water estimates for various 

classes of ship. The initial 

approach was overly 

conservative. 

Ballast and cooling 

water withdrawal 

operations 

Assumed only one 

seachest in operation 

at all times 

Assumed one seachest in 

operation 10% of the time, 

two in operation 90% of the 

time.

Industry sources indicate 

that the use of two 

seachests is the typical 

practice. The initial approach 

was overly conservative, and 

Oregon LNG will 

contractually require 

shippers to operate two 

seachests unless there is an 

overriding reason not to do 

so.

Tidal flow Assumed slack water 

at all times 

Assumed slack water 

follows a triangle 

distribution as shown in 

Table 16. Average tidal flow 

is 1 percent slack water 

Initial approach was overly 

conservative; revised 

approach is based on Coast 

and Harbor Engineering 

modeling and represents 

typical tidal flow. 

Seasonal fish 

abundance (temporal 

distribution) 

Used Bonneville Dam 

passage and lower 

Columbia River 

sampling data to 

construct passage 

curves, and distributed 

ships at 3- and 4-day 

intervals during the 

passage period. 

Simply used the 

percentage of the year 

during which ships would 

be withdrawing water: 

15.4% of the year for 

ballast and cooling water 

withdrawal, 8.6% of the 

year for cooling water 

withdrawal only. 

Earlier modeling indicated 

that entrainment numbers 

were nearly identical using 

the two methods, and the 

“percentage time” method is 

much simpler to calculate.

Annual fish abundance Used 3-year mean 

from Ferguson (2006, 

2007, and 2008) 

Unchanged. Used best available data. 

Horizontal distribution Assumed equal 

distribution from 

Oregon to Washington 

sides 

Split population around 

Desdemona Sands using a 

triangle distribution as 

shown in Table 16. 

The little available evidence 

suggests that more fish use 

the north shipping channel 

(McComas et al., 2007 and 

2008; Truelove, 2005). 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

35

TABLE 17 

Variables and Assumptions Used in the Initial Modeling Approach and the Revised Approach 

Variable/Assumption Previous Approach Revised Approach Rationale 

Vertical distribution Assumed equal 

distribution throughout 

the water column, 

except for subyearling 

Chinook 

Assumed that 60% to 99% 

of all juvenile salmonids 

occur in the upper 20 ft of 

the water column, modeled 

as a triangle distribution as 

shown in Table 16. The 

remainder of the fish were 

assumed to be evenly 

distributed through the 

lower water column. 

The available evidence 

suggests that the majority of 

juvenile salmonids occur in 

the upper 10 ft of the water 

column, with the majority of 

the remainder in the upper 

20 ft (Dawley et al., 1986; 

NMFS, 2006; Bottom et al., 

2005; Truelove, 2005). 

Fish swimming ability Assumed that a 

cruising speed of 

2 bl/sec was the 

maximum swimming 

ability 

Established cruising speed 

as 2 bl/sec, sustained 

speed as 5 bl/sec, and 

burst speed as 10 bl/sec. 

Actual fish swimming ability 

is much greater than 

2 bl/sec, which was used in 

the initial model as a very 

conservative rule of thumb. 

Fish size Fish size was obtained 

from multiple sources 

for different species 

Unchanged. Best available data obtained 

from Bonneville Dam and 

published sources were 

used. 

Fish response Assumed that all fish 

would attempt to swim 

away from the 

seachests at cruising 

speeds 

Assumed that all fish would 

attempt to swim away from 

the seachests, but at 

various speeds. 

Data are limited, but if the 

fish sense a “pull” into the 

seachest, they are likely to 

attempt to escape. Escape 

path is effectively all 

directions away from the 

seachest. 

Migration Assumed all fish swim 

past the Terminal only 

once 

Unchanged. Migration rates indicate that 

fish do not spend significant 

time in the LCRE, except 

subyearling Chinook, which 

are likely to be located in 

shallow water near shore. 

Entrainment “zones” Divided area around 

seachests into two 

“zones,” the areas 

experiencing velocities 

> 0.6 ft/sec and 0.6 to 

0.4 ft/sec 

Divided “zone of influence” 

area around seachests into 

four “zones” (0.4 to 0.8, 0.8 

to 1.2, 1.2 to 1.6, and 1.6 to 

2.2 ft/sec), modeled using a 

uniform distribution within 

each range. 

Allowed for a much “finer 

grained” and more realistic 

analysis of fish escape. 

Abbreviations: 

ft = feet. 

m = meters. 

bl/sec = body lengths per second. 

ft3

/sec = cubic feet per second. 

LCRE = Lower Columbia River Estuary. 

ft/sec = feet per second. 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

36

Results

Before the total number of fish entrained annually can be determined, the number that are 

entrained per zone must be identified. The annual number of fish entrained per zone is 

equal to the number of fish in each potential capture zone that swim at a speed less than the 

intake velocity in that zone. The results are summed for each possible swim-speed response 

(cruising, sustained, burst) and then summed for all four zones. 

The estimated annual entrainments by species are as shown in Tables 18, 19, and 20. 

Table 18 shows entrainment by species. Table 19 shows ESA-listed fish entrainment, which 

is entrainments by species times the percentage of each species that is ESA listed. Table 20 

shows estimated entrainments by ESU. In the tables, the 50th percentile indicates that half of 

the model simulation iterations were above that number entrained, and half below. 

Likewise, the 90th percentile indicates that only 10 percent of the iterations had a higher 

level of entrainment. Another way of looking at this is an equal chance that the number of 

juvenile salmonids likely to be entrained is higher or lower than that presented as the 50th 

percentile number, while there is only a 10 percent chance that the number of juvenile 

salmonids entrained will be higher than that presented as the 90th percentile. 

TABLE 18 

Number of Fish Entrained Annually, by Species 

UR SY 

Chinook

LR SY 

Chinook

Yearling 

Chinook Coho Steelhead Sockeye 

Youngs 

Bay Coho 

Minimum 0.0 0.0 0.0 0.0 0.0 0.00 0.0000 

Maximum 21.0 58.9 24.2 12.9 2.8 2.28 0.0029 

10.0% 0.1 1.0 0.1 0.1 0.0 0.00 0.0000 

50.0% 1.0 4.2 0.3 0.3 0.0 0.04 0.0001 

90.0% 4.1 15.7 2.1 1.6 0.2 0.16 0.0004 

Abbreviations: 

UR = Upriver. 

SY = subyearling. 

LR = Lower river. 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

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TABLE 19 

Number of ESA-Listed Fish Entrained

ESA-listed 

SY

Chinook

ESA-listed 

Yearling 

Chinook

ESA-listed 

Coho 

ESA-listed 

Steelhead 

ESA-listed 

Sockeye 

ESA-listed 

YB Coho 

Minimum 0.0 0.0 0.0 0.0 0.00 0.0000 

Maximum 57.6 6.7 9.6 1.0 0.06 0.0021 

10.0% 1.3 0.0 0.0 0.0 0.00 0.0000 

50.0% 4.3 0.1 0.2 0.0 0.00 0.0001 

90.0% 13.3 0.6 1.2 0.1 0.01 0.0003 

Note:

The numbers of upriver and lower river subyearling Chinook from Table 18 are combined to include all 

subyearling Chinook. 

Abbreviations: 

ESA = Endangered Species Act. 

SY = subyearling. 

YB = Youngs Bay. 

TABLE 20 

Number of ESU Fish Estimated Entrained 

 Revised Methodology 

ESU

Estimate

Using Initial 

Methodology 

50th 

Percentile

90th 

Percentile

Lower Columbia River fall Chinook 48 3.62 13.81 

Snake River fall Chinook yearling and subyearling 2 0.15 0.56 

Upper Columbia River spring/summer Chinook 5 0.00 0.03 

Upper Willamette River Chinook 44 0.04 0.28 

Snake River spring/summer Chinook 12 0.01 0.07 

Lower Columbia River coho 128 0.22 1.19 

Youngs Bay coho 0.1 0.00 0.00 

Snake River sockeye 1 0.00 0.01 

Lower Columbia River steelhead 13 0.00 0.02 

Upper Columbia River steelhead 5 0.00 0.01 

Middle Columbia River steelhead 16 0.00 0.03 

Upper Willamette River steelhead 3 0.00 0.00 

Snake River steelhead 28 0.00 0.04 

ESU = Evolutionarily Significant Unit. 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

38

Figure 7 is an example tornado diagram. This diagram, for upriver subyearling (UR SY) 

Chinook, shows the relative importance of individual probabilistic variables to the total 

range of uncertainty in estimated entrainments. As shown, the most important uncertainties 

are fish size and the percentage of fish in the top 20 ft. 

FIGURE 7 

Example Tornado Diagram 

 Regression Sensitivity for UR SY Chinook/G50

Std b Coefficients

 

 Percent of total fish on t.../D9 .012

 Uniform Distribution / Zon.../G16 .019

-.035 Triangle Distri-bution/B7

 Uniform Distribution / Zon.../I16 .064

 Percent of total fish on t.../D9 .125

 Slack water / Triangle Dis.../D15 .14

 Cruising / Triangle Distri.../D35 .169

 Uniform Distribution / Zon.../J16 .24

-.438 Percent of fish in top 20 .../D11

-.467 Size (mm) / Triangle Distr.../D25

-0.75 -0.5 -0.25 0 0.25 0.5 0.75 1

Juvenile Salmonid Entrainment 

The ESU with the largest number of individual fish potentially entrained, of any ESU, is 

LCR Chinook, with approximately four individuals (and up to a maximum of 56 individual 

smolts) entrained per year. The largest impact to any particular ESU (on a percentage basis) 

would be to Snake River fall Chinook, with a potential entrainment of 0.56 individuals 

annually for 0.00004 percent of the population. Table 21 contains the 3-year mean of the 

population of each ESU as calculated from Ferguson (2006, 2007, and 2009), the potential 

entrainment (based on the 90th percentile), and the percentage of the population that the 

potential entrainment represents. 

When converted to adult equivalents using smolt-to-adult return (SAR) ratios from various 

hatcheries included in the ESUs (DART, 2009), entrainment due to ballast water withdrawal 

is responsible for the loss of much less than one adult from all ESUs (Table 22). Therefore, 

there would be essentially no effect on harvest or population recovery. 

TABLE 21 

Percentage of Each ESU/DPS Potentially Entrained 

ESU/DPS

3-Year Mean Population 

of Juveniles at Tongue 

Point 

Number

Potentially 

Entrained 

% of the Total 

Population 

Snake River sockeye 74,151 0.007 0.00001% 

Lower Columbia River coho 13,254,911 1.186 0.00001% 

Chum 1,467,982 0.000 0.00000% 

Snake River steelhead 3,144,333 0.043 0.00000% 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

39

TABLE 21 

Percentage of Each ESU/DPS Potentially Entrained 

ESU/DPS

3-Year Mean Population 

of Juveniles at Tongue 

Point 

Number

Potentially 

Entrained 

% of the Total 

Population 

Upper Columbia River 

steelhead 

489,128 

0.007 0.00000% 

Middle Columbia River 

steelhead 

1,061,491 

0.025 0.00000% 

Lower Columbia River 

steelhead 

1,302,406 

0.021 0.00000% 

Upper Willamette River 

steelhead 

279,199 

0.004 0.00000% 

Snake River spring/summer 

Chinook 

1,265,731 

0.075 0.00001% 

Snake River fall Chinook 1,354,555 0.561 0.00004% 

Upper Columbia River 

Chinook 

460,405 

0.033 0.00001% 

Lower Columbia River 

Chinook 

63,808,214 

13.806 0.00002% 

Upper Willamette River 

Chinook 

4,662,659 

0.282 0.00001% 

ESU/DPS = Evolutionarily Significant Unit/Distinct Population Segment. 

TABLE 22 

Adults from Each ESU Potentially Lost Due to Entrainment of Juveniles 

ESU

Total 

Estimated

Entrainment 

Mean SAR 

(years of data) Hatchery 

Adults Lost 

Due to Juvenile 

Entrainment 

Lower Columbia River fall Chinook 

(tule) 

12.5975791 0.008 (30) Big Creek 

0.1044 

Lower Columbia River fall Chinook 

(late fall) 

1.20815561 0.003 (3) Big Creek 

Snake River fall Chinook yearling and 

subyearling 

0.561235 0.009 (9) Lyons Ferry 0.0051 

Upper Columbia River spring/summer 

Chinook 

0.03287735 0.004 (12) Chiwawa 0.0001 

Upper Willamette River Chinook 0.28178787 0.006 (25) McKenzie 0.0017 

Snake River spring/summer Chinook 0.07533177 0.002 (12) Tucanon 0.0002 

Lower Columbia River coho 1.18624 0.026 (25) Bonneville 0.0308 

Snake River sockeye 0.007424 0.002 Six hatcheriesa 0.0000 

Lower Columbia River steelhead 0.02093233 0.003 (12) Skamaniab 0.0001 

Upper Columbia River steelhead 0.00725588 0.005 (6) Wells 0.0000 
OREGON LNG: PROBABILISTIC ANALYSIS OF ESA-LISTED SALMONID ENTRAINMENT AT BALLAST AND COOLING WATER INTAKES 

40

TABLE 22 

Adults from Each ESU Potentially Lost Due to Entrainment of Juveniles 

ESU

Total 

Estimated

Entrainment 

Mean SAR 

(years of data) Hatchery 

Adults Lost 

Due to Juvenile 

Entrainment 

Middle Columbia River steelhead 0.0254298 0.003 (16) Umatilla 0.0001 

Upper Willamette River steelhead 0.00395437 0.003 (7) Clackamasc 0.0000 

Snake River steelhead 0.04333903 0.004 (30) Dworshak 0.0002 

a

Limited data are available on sockeye returns; therefore, data from all available hatcheries were pooled. b

No data for any of the artificial propagation programs included in the ESU were available. Skamania hatchery had 

the largest data set for steelhead in the Lower Columbia River hydrologic unit. 

c

No hatchery stocks are included in these ESUs. 

Abbreviations: 

ESU = Evolutionarily Significant Unit. 

SAR = smolt-to-adult return. 

The total number of fish entrained and their contribution to their respective ESUs are 

remarkably small. This is due, in large part, to the size of the LCRE at the Terminal location. 

Because the amount of available habitat is so large, the density of juvenile salmonids in any 

given hour when the ships are at port, in any particular square meter of water, is very low. 

If the Terminal were located in an upriver location, where habitat is much more restricted, 

juvenile salmonids would have much greater density (assuming equal horizontal and 

vertical distribution) and entrainment, consequently, would be higher. 

As can be seen from Figure 7, the uncertain variable with the greatest impact on 

entrainment numbers is the percentage of fish in the top 20 ft of the water column. The 

majority of juvenile salmonids are believed to occur above this depth and therefore are not 

susceptible to entrainment. Additional data on juvenile salmonid vertical distribution in the 

water column would result in greater accuracy in the entrainment estimates. 

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the Hanford Reach, Columbia River.” Fishery Bulletin 87:775–790. 
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of Columbia River Basin Salmon and Steelhead: An Evaluation of Limiting Factors. 

National Oceanic and Atmospheric Administration (NOAA) technical 

memorandum. Northwest Fisheries Science Center. 

Groot, C., L. Margolis, W.C. Clarke. 1995. Physiological Ecology of Pacific Salmon. Canadian 

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Johnson, G.E., R.M. Thom, A.H. Whiting, G.B. Sutherland, N. Ricci, J.A. Southard, B.D. 

Ebberts, and J.D. Wilcox. 2003. An Ecosystem-based Approach to Habitat 

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Final Draft. Prepared by the Pacific Northwest National Laboratory, Columbia River 

Estuary Study Taskforce, Lower Columbia River Estuary Partnership, Bonneville 

Power Administration, and United States Army Corps of Engineers, Portland 

District. September 30. 

Kanarska, Y. and V. Maderich. 2003. “A Non-hydrostatic Numerical Model for Calculating 

Free-surface Stratified Flows.” Ocean Dynamics 53:176–185. 

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Salmon and Overhead Cover.” Journal of Fish Biology 67:5. Pages 1381–1391. 

LCRFRB. See Lower Columbia River Fish Recovery Board. 

Levings, C.D., C.D. McAllister, and B.D. Chang. 1986. “Differential Use of the Campbell 

River Estuary by Wild and Hatchery-reared Juvenile Chinook Salmon (Oncorhynchus 

tshawytscha).” Canadian Journal of Fisheries and Aquatic Sciences 43:1386–1397. 
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43

Levy, D.A. and T.G. Northcote. 1981. The Distribution and Abundance of Juvenile Salmon in 

Marsh Habitats of the Fraser River Estuary. Westwater Research Center, University of 

British Columbia. Technical Report 25. 117 pages. 

Lower Columbia River Fish Recovery Board (LCRFRB). 2004. Lower Columbia River Salmon 

Recovery and Fish and Wildlife Subbasin Plan. 

http://www.nwcouncil.org/fw/subbasinplanning/lowerColumbia/plan/RP%20V

ol%20I%20Ch%205%20Recovery%20Goals.pdf Accessed July 1, 2009. 

McComas, R.L., G.A. McMichael, J.A. Vucelick, L. Gilbreath, S.G. Smith, G. Matthews, T.J. 

Carlson, and J.W. Ferguson. 2008. A Study to Estimate Juvenile Salmonid Survival 

Through the Columbia River Using Acoustic Tags, 2006. 

McComas, R.L., G.A. McMichael, L. Gilbreath, S.G. Smith, G. Matthews, T.J. Carlson, and 

J.W. Ferguson. 2007. A Study to Estimate Juvenile Salmonid Survival Through the 

Columbia River Using Acoustic Tags, 2005.McElhany, P., M. Chilcote, J. Myers, and R. 

Beamsderfer. 2007. Viability Status of Oregon Salmon and Steelhead Populations in the 

Willamette and Lower Columbia Basins. Prepared for Oregon Department of Fish and 

Wildlife and National Marine Fisheries Service. 

Myers, K.W. and H.F. Horton. 1982. “Temporal Use of an Oregon Estuary by Hatchery and 

Wild Juvenile Salmon.” Pages 377–392 in: V.S. Kennedy (ed.). Estuarine Comparisons. 

Academic Press, Inc. New York. 

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Consultation and Magnuson-Stevens Act Essential Fish Habitat Consultation, Biological 

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Consultation, Conference, and Magnuson–Stevens Fishery Conservation and 

Management Act Essential Fish Habitat Consultation for the United States Army 

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Management Act Essential Fish Habitat Consultation for the City of Warrenton–

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(NOAA). 

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ODFW. See Oregon Department of Fish and Wildlife. 

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Development Council. 
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44

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45

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Appendix E 

Conceptual Wetland Restoration Monitoring Plan 

and Performance Standards and Review of Wetland 

Avoidance and Mitigation Efforts

 

Conceptual Wetland Restoration Monitoring Plan 

and Performance Standards
 
1 

TECHNICAL MEMORANDUM 

Conceptual Wetland Restoration Monitoring Plan and 

Performance Standards—Oregon Pipeline Project 

PREPARED FOR: Peter Hansen/Oregon Pipeline Company, LLC

COPY TO Jay Lorenz/CH2M HILL

PREPARED BY: Forrest Parsons/CH2M HILL

Claudia Steinkoenig/CH2M HILL

DATE: November 15, 2013

PROJECT NUMBER: 199863.PP.12

1.0 Introduction 

On behalf of Oregon Pipeline Company, LLC, CH2M HILL has prepared a restoration monitoring plan for

unavoidable temporary impacts to wetlands as a result of construction of the proposed Bidirectional Project

(Project). The Project will temporarily impact wetland functions and values through disturbance of soil and

removal of vegetation during the construction and installation of a buried liquefied natural gas (LNG)

pipeline (Pipeline). The goal of this monitoring plan is to confirm that performance standards are properly

followed and fulfill the objective of habitat restoration and avoidance or minimization of adverse effects to

the ecosystem. In conjunction with this goal, a series of conceptual wetland restoration planting plans is

provided in the attachment to this technical memorandum. The plans are arranged according to watershed,

as shown in Figure 1 in the attachment.

Approximately 118 acres of temporary1 wetland impacts will occur along the proposed Pipeline alignment.

Oregon LNG will conduct onsite restoration and ensure the reestablishment of wetlands in the Pipeline

corridor. This effort includes restoring soils and hydrology functions and revegetating disturbed areas with

salvaged plant material, reseeding with native seeds, or replanting with native plants. Site restoration will

include a functional lift of existing degraded plant communities through removal of nonͲnative species.

2.0 Monitoring Plan 

Seasonal monitoring will be conducted by a qualified botanist for a period of 10 years following final

installation using the standards summarized below in Section 3.0, Performance Standards.

The monitoring report will consist of the following:

x Vegetation transect (or transects depending on size of wetlands that detail herb, shrub, and tree aerial

cover at radii of 3 feet, 15 feet, and 30 feet, respectively)

x Percent of planted materials surviving, classified by condition (for example, vigorous, living, stressed)

x Percent cover for the following four classes: native forbs and grasses; nonͲnative forbs and grasses;

shrubs and trees; bare ground and rock

x Report on invasive vegetation, vandalism, dumping, wildlife damage or other conditions actually or

potentially harmful to the restoration

x Identification of maintenance concerns (for example, plants need to be replaced)



1 As defined in Oregon Administrative Rule 141Ͳ085Ͳ0010, temporary impacts means those impacts that do not result in the permanent loss of

function and/or area and are rectified within 12 months of project completion.
CONCEPTUAL WETLAND RESTORATION MONITORING PLAN AND PERFORMANCE STANDARDS—OREGON PIPELINE PROJECT 

2 

x Color photographs that show the restoration site, taken from a fixed photo point (or points depending

on size of wetland) drawn on a map of the restoration area, keyed to lines of sight from those photo

points

Table 1 summarizes the proposed restoration monitoring plan schedule.

TABLE 1

10-Year Restoration Monitoring Schedule 

Year

Monitoring and Restoration Activities

Season

Winter Spring Summer Fall

1  Monitor Restoration Sites

Noxious Weed Control (As Needed)

Monitor Restoration Sites

Noxious Weed Control (As Needed)

Monitor Restoration Sites

Replant (As Needed)

2 Submit Results of

Year 1 Monitoring

Monitor Restoration Sites

Noxious Weed Control (As Needed)

Monitor Restoration Sites

Noxious Weed Control (As Needed)

Monitor Restoration Sites

Replant (As Needed)

3 Submit Results of

Year 2 Monitoring

Monitor Sites Deficient During

Year 1 and 2

Noxious Weed Control (As Needed)

Monitor Sites Deficient During Year

1 and 2

Noxious Weed Control (As Needed)

Monitor Sites Deficient

During Year 1 and 2

Replant (As Needed)

4 Submit Results of

Year 3 Monitoring

Monitor Sites Deficient During Year

1 and 2 and Monitor 50% of Sites*

Noxious Weed Control (As Needed)

Monitor Sites Deficient During Year

1 and 2 and Monitor 50% of Sites*

Noxious Weed Control (As

Needed)*

Monitor Sites Deficient

During Year 1 and 2 and

Monitor 50% of Sites*

Replant (As Needed)

5 Submit Results of

Year 4 Monitoring

Monitor Sites Deficient During Year

1 and 2 and Monitor 50% of Sites*

Not Monitored Year 4

Noxious Weed Control (As Needed)

Monitor Sites Deficient During Year

1 and 2 and Monitor 50% of Sites*

Not Monitored Year 4

Noxious Weed Control (As Needed)

Monitor Sites Deficient

During Year 1 and 2

Monitor 50% of Sites Not

Monitored Year 4

Replant (As Needed)

6 Submit Results of

Year 5 Monitoring

Monitor Sites Deficient in Previous

Year

Noxious Weed Control (As Needed)

Monitor Sites Deficient in Previous

Year

Noxious Weed Control (As Needed)

Monitor Sites Deficient in

Previous Year

Replant (As Needed)

7 Submit Results of

Year 6 Monitoring

Monitor Sites Deficient in Previous

Year

Noxious Weed Control (As Needed)

Monitor Sites Deficient in Previous

Year

Noxious Weed Control (As Needed)

Monitor Sites Deficient in

Previous Year

Replant (As Needed)

8 Submit Results of

Year 7 Monitoring

Monitor Sites Deficient in Previous

Year

Noxious Weed Control (As Needed)

Monitor Sites Deficient in Previous

Year

Noxious Weed Control (As Needed)

Monitor Sites Deficient in

Previous Year

Replant (As Needed)

9 Submit Results of

Year 8 Monitoring

Monitor Sites Deficient in Previous

Year

Noxious Weed Control (As Needed)

Monitor Sites Deficient in Previous

Year

Noxious Weed Control (As Needed)

Monitor Sites Deficient in

Previous Year

Replant (As Needed)

10 Submit Results of

Year 9 Monitoring

Monitor All Restoration Sites

Noxious Weed Control (As Needed)

Monitor All Restoration Sites

Noxious Weed Control (As Needed)

Monitor All Restoration

Sites

Noxious Weed Control (As

Needed)

11   Submit Final Reports

*Choose sites using a stratified random approach across watersheds.
CONCEPTUAL WETLAND RESTORATION MONITORING PLAN AND PERFORMANCE STANDARDS—OREGON PIPELINE PROJECT 

3 

3.0 Performance Standards 

The proposed performance standards will be evaluated by a qualified biologist using best professional

judgment. Table 2 summarizes the performance standards that will be used to evaluate success of the

planting according to established landscape standards for wetland vegetation communities in the

appropriate zones west of the Cascade Crest (Franklin and Dyrness, 1973).

TABLE 2

Summary of Performance Standards

Objective Performance Standard

Ensure that all areas of

wetland have hydrology

through April 15

Hydrology present in accordance with USACE Wetland Delineation Manual (1987)

2 years with normal or below normal precipitation

Maintain structural diversity Grass, shrub, and forest habitat diversity present to an extent equal or better than

preconstruction conditions

Maintain species diversity Plant a diverse assemblage of species native to the project area or region to an extent equal or

better than preconstruction conditions

Ensure survivorship of trees

and shrubs

Planting density within 5 percent of planting plan—typically 60 to 80 percent survivorship (native

species recruitment on the site may be included)

Increase aerial cover in successive years; 15 percent aerial cover of trees 3 years after planting; 40

to 60 percent aerial cover of shrubs after 3 years

Ensure survivorship of ground

cover

30 to 50 percent ground after 1 year

60 to 80 percent ground cover 2 years after installation in emergent zones

50 percent ground cover within 2 years in shrub and forest habitat

Bare substrate represents no more than 20 percent cover after 3 years

Make cover of noxious weeds

and nonͲnative species

minimal

No more than 10 percent cover of invasive species such as reed canarygrass, Himalayan

blackberry, Evergreen blackberry, purple loosestrife, kudzu, Japanese knotweed, thistles, and

poison hemlock 3 years after installation

4.0 Maintenance 

If any monitoring report shows that performance standards are not achieved, Oregon LNG will recommend

corrective management actions. Wetlands with substandard performance will be monitored annually until

there are two successive years demonstrating successful performance. Corrective actions may include

invasive species control (typically spring/early summer); protective sleeves to minimize browsing damage by

herbivores (typically applied spring/summer); and replanting (typically dormant or rainy season). Biologists

will keep a written record to document the date of each visit, site conditions, and any corrective actions

taken.

5.0 References 

Franklin, J. F. and C. T. Dyrness. 1973. Natural Vegetation of Oregon and Washington. USDA Forest Service.

General Technical Report. 417 pp. Portland, Oregon.

U.S. Army Corps of Engineers (USACE). 1987. Corps of Engineers Wetland Delineation Manual. Prepared by

Environmental Laboratory for U.S. Army Corps of Engineers, Waterways Experiment Station,

Vicksburg, MS. Technical Report YͲ87Ͳ1.

Attachment 

Site Restoration Plans 
 
D

D

D

D

D

D

D

D

D

#*

OREGON

WASHINGTON

Cowlitz

Wahkiakum

Columbia

Clatsop

Tillamook Washington

Multnomah

80 70

60

50

40

30

20

10

0

Burris

Creek-Fr

Columbia 

Columbia

River-Cathlamet

Channel

Beaver

Creek-Columbia

River

Youngs

River

Middle

Nehalem

River

Clatskanie

River

Scappoose

Creek

Lower

Nehalem

River

Upper

Nehalem

River

 R:\LNGDEVELOPMENT_355036\MAPDOCUMENTS\2013_FILING\MISC_REQUESTS\CMP\TM_FIGURE1_WATERSHEDSCROSSED.MXD RMURPHY 11/8/2013 10:45:02 AM
Palustrine Emergent Wetland (PEM)

SEED MIX #1 SEED MIX FOR COASTAL LOWLANDS — NON-AGRICULTURAL

Common Name Scientific Name Form* Pounds per Acre

Per Live Seed (PLS)

Pacific Reedgrass Calamagrostis 

nutkaensis

Seed 8

Seaside Arrow 

Grass

Triglochin maritima Seed 8

Fowl Bluegrass Poa palustris Seed 8

Tufted Hairgrass Deschampsia 

caespitosa var. artica

Seed 2

Red Fescue Festuca rubra Seed 8

Lyngby’s Sedge Carex Lyngbyei Seed 10

Baltic Rush

* Substitution of species or substitution of plugs for seeds may be made, depending on 

availability and approval by Permitting Agency.

* Substitution of species or substitution of plugs for seeds may be made, depending on 

availability and approval by Permitting Agency.

Juncus articus var. 

baticus

Seed 10

SEED MIX #2 SEED MIX FOR COASTAL FOOTHILLS — NON-AGRICULTURAL

Common Name Scientific Name Form* Pounds per Acre

Per Live Seed (PLS)

Red Fescue Festuca rubra Seed 8

Colonial Bentgrass Agrostis capillaris Seed 8

Slender Hairgrass Deschampsia 

elongata

Seed 2

Slough Sedge Carex obnupta Seed 10

Small-fruited 

Bulrush

Scirpus microcarpus Seed 10

Sickle-leaved Rush Juncus ensfolius Seed 10

POTENTIAL WETLAND CROSSING

Lower Columbia Watershed (4th HUC)

ES042009005PDX 355036.PP.12 LNG_LCW_Watershed3_04.ai 08-27-09 cts

FIGURE 2

Lower Columbia Watershed

Palustrine Emergent Wetland Restoration - Typical

OREGON PIPELINE PROJECT Pipeline 10 Feet Easement Remaining Easement Remaining 

Pipeline

CL

Clearing Limits

 75 - 100 feet
Palustrine Scrub-Shrub (PSS)

SCRUB-SHRUB WETLAND COMMUNITY - SHRUBS, HERBS

Common Name Scientific Name Form*

Hooker Willow Salix hookeriana Live stake 8’ o.c. 

(4 stakes/hole)

Douglas Spiraea Spiraea douglasi 1 gal 6’ o.c.

Cluster of 9

POTENTIAL WETLAND CROSSING

Lower Columbia Watershed (4th HUC)

* Substitution of species or substitution of plugs for seeds may be made, depending on 

availability and approval by Permitting Agency.

Wetland Seed Mix #1 for Coastal Lowland/ Wetland Seed Mix #2 for Coastal Foothills

ES042009005PDX 355036.PP.12 LNG_LCW_Watershed2_05.ai 08-28-09 cts

FIGURE 3

Lower Columbia Watershed

Palustrine Scrub-Shrub Wetland Restoration - Typical

OREGON PIPELINE PROJECT Pipeline 10 Feet Easement Remaining Easement Remaining 

Pipeline

CL

Clearing Limits

 75 - 100 feet

Spacing

(on center)
Palustrine Forest Wetland (PFO)

Palustrine Emergent (PEM)

POTENTIAL WETLAND CROSSING

Lower Columbia Watershed (4th HUC)

SEED MIX #1 FOREST WETLAND COMMUNITY - FOREST, HERBS

Common Name Scientific Name Form*

Red Alder Alnus Rubra 2 gal 10’ o.c.

Western Red Cedar Thuja plicata 2 gal 15’ o.c.

Sitka Spruce Picea sitchens 2 gal 20’ o.c.

* Substitution of species or substitution of plugs for seeds may be made, depending on 

availability and approval by Permitting Agency.

Wetland Seed Mix #1 for Coastal Lowland/ Wetland Seed Mix #2 for Coastal Foothills

Spacing

(on center)

ES042009005PDX 355036.PP.12 LNG_LCW_Watershed1_05.ai 08-28-09 cts

FIGURE 4

Lower Columbia Watershed

Palustrine Forest/Palustrine Emergent 

Wetland Restoration - Typical

OREGON PIPELINE PROJECT Pipeline 10 Feet Easement Remaining Easement Remaining 

Pipeline

CL

Clearing Limits

 75 feet
Palustrine Emergent Wetland (PEM)

WETLAND SEED MIX #3

Common Name Scientific Name Form* Pounds per Acre

Per Live Seed (PLS)

Red Fescue Festuca rubra Seed 8

Colonial Bentgrass Agrostis capillaris Seed 8

Slender Hairgrass Deschampsia 

elongata

Seed 2

Slough Sedge Carex obnupta Seed 10

Small-fruited 

Bulrush

Scirpus microcarpus Seed 10

Sickle-leaved Rush Juncus ensfolius Seed 10

POTENTIAL WETLAND CROSSING

Nehalem Watershed (4th HUC)

Lower Columbia/Clatskanie (4th HUC)

Lower Willamette Watershed (4th HUC)

* Substitution of species or substitution of plugs for seeds may be made, depending on

availability and approval by Permitting Agency.

Pipeline

10 Feet

Easement

Remaining 

Easement

Remaining 

Pipeline

CL

Clearing Limits

 75 - 100 feet

ES042009005PDX 355036.PP.12 Rev7 06-17-13 cts/lh

FIGURE 

Nehalem Watershed 

Lower Columbia/Clatskanie 

Lower Willamette Watershed

Palustrine Emergent Wetland Restoration - Typical

OREGON PIPELINE PROJECT
SCRUB-SHRUB WETLAND COMMUNITY - SHRUBS, HERBS

Common Name Scientific Name Form*

Red-osier 

Dogwood

Cornus stolonifera 8-ft o.c.

Cluster of 10

Salmonberry

Wetland Seed Mix #3

Rubus spectabilis 1 gal

1 gal

6-ft o.c.

Cluster of 12

POTENTIAL WETLAND CROSSING

Nehalem Watershed (4th HUC)

Lower Columbia/Clatskanie (4th HUC)

Lower Willamette Watershed (4th HUC)

* Substitution of species or substitution of plugs for seeds may be made, depending on

availability and approval by Permitting Agency.

FIGURE 

Nehalem Watershed 

Lower Columbia/Clatskanie 

Lower Willamette Watershed

Palustrine Scrub-Shrub Wetland Restoration - Typical

OREGON PIPELINE PROJECT Pipeline 10 Feet Easement Remaining Easement Remaining 

Pipeline

CL

Clearing Limits

 75 - 100 feet

Spacing

(on center)

ES042009005PDX 355036.PP.12 Rev7 06-17-13 cts/lh

Palustrine Scrub-Shrub (PSS) 

Conversion to Palustrine Emergent Wetland (PEM)
FOREST WETLAND COMMUNITY - FOREST, HERBS

Common Name Scientific Name Form*

Red Alder Alnus rubra 2 gal 10’ o.c.

Western Red Cedar Thuja plicata 2 gal 15’ o.c.

Sitka Spruce

Wetland Seed Mix #3

Picea sitchens 2 gal 10’ o.c.

POTENTIAL WETLAND CROSSING

Nehalem Watershed (4th HUC)

Lower Columbia/Clatskanie (4th HUC)

Lower Willamette Watershed (4th HUC)

* Substitution of species or substitution of plugs for seeds may be made, depending on

availability and approval by Permitting Agency.

FIGURE 

Nehalem Watershed 

Lower Columbia/Clatskanie 

Lower Willamette Watershed

Palustrine Forest/Palustrine Emergent 

Wetland Restoration - Typical

OREGON PIPELINE PROJECT Pipeline 10 Feet Easement Remaining Easement Remaining 

Pipeline

CL

Clearing Limits

 75 feet

Palustrine Forest Wetland (PFO)

Palustrine Emergent (PEM)

Spacing

(on center)

ES042009005PDX 355036.PP.12 Rev7 06-17-13 cts/lh
 
Review of Wetland Avoidance and Minimization 

Efforts
 
Report 

Review of Wetland Avoidance and 

Minimization Efforts 

Oregon LNG Terminal and Oregon 

Pipeline Project 

Prepared for 

Oregon LNG 

Wetland Mitigation Subgroup 

Originally Filed September 15, 2009 

Revised November 2013 

Prepared by 

PDX/092460002.DOC iii 

ES110813182840PDX 

Contents 

1 Introduction ............................................................................................................................... 1Ͳ1

1.1 Summary of Impacts.............................................................................................................. 1Ͳ1

1.1 Project Background................................................................................................................ 1Ͳ2

2 Definitions, Avoidance, and Minimization................................................................................... 2Ͳ1

2.1 Avoidance and Minimization of Area .................................................................................... 2Ͳ1

2.2 Methods for Functional Assessments.................................................................................... 2Ͳ1

3 Measures for Wetland Avoidance............................................................................................... 3Ͳ1

3.1 Terminal Features.................................................................................................................. 3Ͳ1

3.2 Terminal—Summary of Wetland Classes............................................................................... 3Ͳ1

3.3 Avoidance Measures at Terminal .......................................................................................... 3Ͳ2

3.4 Pipeline Features and Summary of Wetland Classes............................................................. 3Ͳ3

3.4.1 Ancillary Features ..................................................................................................... 3Ͳ3

3.4.2 Access Roads............................................................................................................. 3Ͳ3

3.5 Avoidance Measures along Pipeline ...................................................................................... 3Ͳ3

3.6 Pipeline Siting Considerations ............................................................................................... 3Ͳ4

3.7 Pipeline Routing—Existing Utility Corridors and Roads......................................................... 3Ͳ4

3.8 Pipeline—National Wetland Inventory Preplanning ............................................................. 3Ͳ5

3.9 Avoidance of HighͲValue Wetlands ....................................................................................... 3Ͳ5

3.10 Pipeline—Avoidance of Large Wetland Areas....................................................................... 3Ͳ5

3.11 Locations of Additional Temporary Workspaces................................................................... 3Ͳ5

3.12 Construction Techniques....................................................................................................... 3Ͳ5

3.13 Construction Access Roads.................................................................................................... 3Ͳ6

4 Measures to Minimize Wetland Impacts..................................................................................... 4Ͳ1

4.1 Terminal Site Layout Alternatives.......................................................................................... 4Ͳ1

4.2 Pipeline Route Minimization Methods and Alignment Changes........................................... 4Ͳ1

4.2.1 Routing through Agricultural Wetlands with Previously Impacted Hydrological and

Habitat Functions...................................................................................................... 4Ͳ2

4.2.2 Reduced Construction Easement Area ..................................................................... 4Ͳ3

4.2.3 Locations of Temporary and Additional Temporary Workspaces............................ 4Ͳ3

5 Unavoidable Impacts to Wetlands.............................................................................................. 5Ͳ1

5.1 Terminal ................................................................................................................................. 5Ͳ1

5.1.1 Temporary Impacts................................................................................................... 5Ͳ1

5.1.2 Permanent Impacts................................................................................................... 5Ͳ1

5.2 Pipeline .................................................................................................................................. 5Ͳ1

5.2.1 Temporary Impacts................................................................................................... 5Ͳ2

5.2.2 Temporary Construction Zones................................................................................ 5Ͳ2

5.3 Permanent Impacts................................................................................................................ 5Ͳ2

5.4 Wetlands Affected by Permanent Cowardin Class Change ................................................... 5Ͳ2

6 Best Management Practices........................................................................................................ 6Ͳ1

6.1 Clay Plugs............................................................................................................................... 6Ͳ1

6.2 Soil Segregation ..................................................................................................................... 6Ͳ1

6.3 Rehabilitation of Wetlands Temporarily Impacted by the Project........................................ 6Ͳ1

6.3.1 Soil Segregation ........................................................................................................ 6Ͳ2

6.3.2 Seeding and Revegetation ........................................................................................ 6Ͳ2
REVIEW OF WETLAND AVOIDANCE AND MINIMIZATION EFFORTS 

OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

iv PDX/092460002.DOC 

ES110813182840PDX 

6.3.3 Monitoring and Adaptive Management Plan ........................................................... 6Ͳ2

6.3.4 Restoring Grading ..................................................................................................... 6Ͳ3

7 Conclusions ................................................................................................................................ 7Ͳ1

8 References.................................................................................................................................. 8Ͳ1

Tables (located at the end of text)

1 Summary of Wetland Acreage and Wetland Impacts

2 Permanent Wetland Impacts Associated with Terminal Site Layouts

3 Summary of HighͲValue Wetland Impacts

4 Temporary and Permanent Wetland Impacts—Terminal

5 Construction Temporary Wetland Impacts—Mainline and Ancillary Facilities

6 Permanent Impacts—Mainline and Ancillary Facilities

Figures (located after Tables at the end of text)

1 Project Location Map

2 Terminal Layout Wetland Disturbance

3 Alternative Terminal Site Layout
SECTION 1.0

PDX/092460002.DOC 1-1 

ES110813182840PDX 

Introduction 

On behalf of LNG Development Company, LLC (doing business as Oregon LNG) and the Oregon Pipeline

Company, LLC (collectively, Oregon LNG), CH2M HILL has prepared this report to review efforts to avoid and

minimize wetland impacts from the Oregon LNG Terminal and Oregon Pipeline Project (Project). Avoidance

and minimization efforts are evaluated in the context of both the quantity of area and the wetland function.

1.1 Summary of Impacts 

The Project will temporarily and permanently impact wetland functions and values as a result of disturbance

of soil and removal of vegetation during the construction of a liquefied natural gas (LNG) receiving terminal

(Terminal) and installation of a buried natural gas pipeline (Pipeline). Oregon LNG intends to avoid and

minimize disturbance to wetlands associated with the construction and operation of the Project to the

greatest extent possible while maintaining a viable project. Avoidance and minimization efforts are detailed

in subsequent sections of this report and include alternate siting options for the Terminal and associated

facilities, ongoing review of the Pipeline alignment, use of existing utility corridors and roads, relocation of

temporary and additional temporary workspace (TWS and ATWS), construction methods, and reduced

easement areas.

Preliminary wetland jurisdictional determinations were made for the wetlands and other waters identified in

the Project study area. For the purposes of this analysis, the Pipeline study area is approximately

2,180 acres, encompassing a 200ͲfootͲwide corridor centered on the proposed Pipeline. The study area at

the Terminal is approximately 325 acres, encompassing the turning basin, dock and pier, facilities, and

supporting infrastructure (entry road and electrical transmission line). Within this2,505acre study area,

which includes both the Terminal and Pipeline, approximately 391 acres of state and federal potential

jurisdictional wetlands, including agricultural wetlands, were identified in field and desktop surveys.

Jurisdictional delineations were conducted on properties with access. Desktop data (soil survey and National

Wetland Inventory) were used to map wetlands on properties where access was denied.

Several potential Pipeline routes and Terminal layouts were analyzed before a 100ͲfootͲwide Pipeline

corridor and Terminal layout (construction area) was chosen that avoids impacts to environmentally

significant areas to the greatest extent possible. The proposed Project area will impact (temporarily and

permanently) an estimated 174 acres of the total wetlands in the current study area. About 18.10 acres of

wetlands along the Pipeline are expected to be permanently impacted. Permanent impacts are calculated as

those representing a change in Cowardin class from Palustrine Forested (PFO) to Palustrine ScrubͲShrub

(PSS) or Palustrine Emergent (PEM), rather than a net loss of wetland area. Along the Pipeline and following

construction, no wetlands will be filled above the existing grade or covered with impervious material. About

35.02 acres of wetlands at the Terminal (facilities, dock and pier, and supporting infrastructure) will be

permanently filled above existing grade or covered with impervious material.

The remaining 120.7 acres of wetland impacts will be temporary as defined in Oregon Administrative Rules

(OAR) 141Ͳ085 0510. To offset temporary impacts along the proposed Pipeline alignment, Oregon LNG will

conduct onsite restoration and ensure the reestablishment of wetland and other aquatic resource

characteristics and functions in the areas disturbed by the Terminal and Pipeline activities. This includes

restoring soils and hydrology functions, and revegetating disturbed areas with salvaged plant material,

reseeding with native seeds, or replanting with native plants. Further detail will be provided in a

comprehensive restoration and rehabilitation plan. Table 1 summarizes the wetland acreages and impacts

within the Project study area.
REVIEW OF WETLAND AVOIDANCE AND MINIMIZATION EFFORTS 

OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

1-2 PDX/092460002.DOC 

ES110813182840PDX 

1.1 Project Background 

LNG Development Company, LLC (doing business as Oregon LNG) proposes to own, construct, and operate a

liquefied natural gas (LNG) bidirectional terminal (Terminal) consisting of marine facilities, LNG storage

tanks, LNG vaporization facilities, natural gas liquefaction facilities, and associated support facilities. The

Terminal will be located in Warrenton, Oregon. The Terminal will have a base load liquefaction capacity of

9.6 million metric ton per year, which requires approximately 1.25 billion standard cubic feet per day

(Bscf/d) of pretreated natural gas, and a base load regasification capacity of 0.5 Bscf/d.

Natural gas will be transported to and from the Terminal via an approximately 86.8ͲmileͲlong, 36ͲinchͲ

outsideͲdiameter (OD) bidirectional pipeline (Pipeline) that is being developed by Oregon Pipeline Company,

LLC (Oregon Pipeline; together with LNG Development Company, LLC, Oregon LNG).1 The Pipeline will

interconnect with the interstate transmission system of Northwest Pipeline LLC, a subsidiary of the Williams

Companies, at the Northwest Pipeline Interconnect near Woodland, Washington.2 The Pipeline will be

routed through Clatsop, Tillamook, and Columbia counties in Oregon, and Cowlitz County in Washington, as

shown on Figure 1. An electrically driven gas compressor station (Compressor Station) will be constructed at

milepost (MP) 80.8 of the Pipeline. The Terminal, Pipeline, and Compressor Station are collectively referred

to as the Bidirectional Project or Project. Approximately 82 miles of the Pipeline are in Clatsop, Tillamook,

and Columbia counties, Oregon, and the remaining approximately 5 miles are in Cowlitz County,

Washington.

Refer to the ApplicantͲPrepared Draft Biological Assessment (CH2M HILL, 2013a) for additional project

details.



1 The Terminal and Pipeline are proposed at the site, and along the route, of Oregon LNG’s proposed LNG import terminal and pipeline that currently

are pending before the Federal Energy Regulatory Commission (FERC) in Docket Numbers CP09Ͳ6Ͳ000 and CP09Ͳ7Ͳ000, as amended in Docket

Number PF12Ͳ18Ͳ000.

2 A separate application has been filed by Northwest for the Washington Expansion Project, a capacity expansion to Northwest Pipeline LLC’s existing

natural gas transmission facilities along the Interstate 5 corridor in the state of Washington.
SECTION 2.0

PDX/092460002.DOC 2-1 

ES110813182840PDX 

Definitions, Avoidance, and Minimization 

Avoidance and minimization efforts have been evaluated in the context of both area and wetland function.

Definitions used in OAR 141Ͳ085 0510 and the Washington State Environmental Policy Act (SEPA) (Chapter

43Ͳ21C Revised Code of Washington [RCW]) (Chapter 197Ͳ11Ͳ768 Washington Administrative Code [WAC])

provided guidance for this project.

“Mitigation” means the reduction of adverse effects of a proposed project by considering, in the

following order:

(a) Avoiding the effect altogether by not taking a certain action or parts of an action;

(b) Minimizing effects by limiting the degree or magnitude of the action and its implementation;

(c) Rectifying the effect by repairing, rehabilitating or restoring the affected environment;

(d) Reducing or eliminating the effect over time by preservation and maintenance operations during

the life of the action by monitoring and taking appropriate corrective measures; and

(e) Compensating for the effect by replacing or providing comparable substitute wetlands or other

waters.

“Temporary Impacts” are adverse impacts to waters of this state that are rectified within 24 months

from the date the impact occurred.

“Temporal Loss” means the loss of the functions and values of waters of this state that occurs between

the time of the impact and the time of their replacement through compensatory mitigation.

2.1 Avoidance and Minimization of Area 

Oregon LNG avoided wetlands to the greatest extent possible while still providing a Project route that is

constructible, yet with minimal impact, and is acceptable to the public and regulatory agencies.

Approximately 391 acres of wetlands were identified within the proposed Project area. This includes field

evaluated wetlands and those identified with proxy data. Most of the wetlands identified will be avoided.

Temporary and permanent impacts proposed will affect approximately 174 acres of the potential wetlands

in the study area.

A variety of methods have been implemented during Project design to avoid and minimize impacts to

wetlands. Examples of methods are as follows:

x Layout revisions

x Altering the Pipeline route

x CoͲalignment with existing easements and rightsͲofͲway

x Crossing the wetlands at the narrowest point possible

x Construction techniques

x Using horizontal directional drilling (HDD) to avoid wetlands

Efforts of wetland avoidance at the Terminal location and along the proposed Pipeline alignment are

discussed in Section 3.0. Minimization efforts are discussed in Section 4. 0.

2.2 Methods for Functional Assessments 

Wetland site characterization can be generally divided into two major categories: wetland classification and

wetland functional assessment. Wetland characterizations generally require both a wetland classification

and a functional assessment since the two are inextricably linked to one another. Wetland classification
REVIEW OF WETLAND AVOIDANCE AND MINIMIZATION EFFORTS 

OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

2-2 PDX/092460002.DOC 

ES110813182840PDX 

provides the organizational foundation for conducting a functional assessment. Wetland classifications are

used to define wetlands in terms of the geographic position and relationships, overall structure, and some of

the dynamic processes governing the appearance and function of the classified wetland(s).

Designations for each type of wetland follow the classifications developed by the U.S. Fish and Wildlife

Service (USFWS) in Classification of Wetlands and Deepwater Habitats of the United States (Cowardin et al.,

1979). Referred to as the Cowardin system, this classification is organized based on system, subsystem, and

class in a hierarchical structure. The following five systems are used in the classification:

x Marine: Open ocean overlying the continental shelf and associated highͲenergy coastline

x Estuarine: Deepwater tidal habitats and adjacent tidal wetlands that are semiͲenclosed by land but have

open, partly obstructed access to the ocean and are at least occasionally diluted by freshwater runoff

x Riverine: Freshwater wetlands contained within a natural or constructed channel that are not

dominated by trees, shrubs, persistent emergents, emergent mosses, or lichens

x Lacustrine: Freshwater wetlands located in a topographic depression or damned river channel that lack

trees, shrubs, or persistent emergents and are larger than 20 acres

x Palustrine: Nontidal freshwater wetlands dominated by trees, shrubs, or persistent emergents

Each system, with the exception of palustrine, is then further divided into subsystems based on tidal

influences, water depth, or reach of a flowing freshwater system. Systems and subsystems are further

divided into classes that describe the general appearance of the wetland in terms of dominant vegetation or

the nature and composition of the substrate where vegetative cover is less than 30 percent.

All applications with proposed impact to wetlands must include both a functions and values assessment for

the impact site. At this time, the Oregon Department of State Lands (ODSL) uses functional assessment

methods by region. The referenceͲbased method, Oregon Rapid Wetland Assessment Protocol (ORWAP), is

required for Tidal Waters, Willamette Valley, and all other hydrogeomorphic (HGM) classes. ORWAP is a

standardized protocol for rapidly assessing the effectiveness of various wetland functions and their value as

determined by the extent of opportunity for using the function and the need for its use in the watershed.

ORWAP assesses the effectiveness of 16 functions and the values of these functions, and five other wetland

attributes that are most commonly found in wetlands located in Oregon.

ODSL evaluates impacts associated with long linear projects that cross multiple watersheds by fourth field

hydrologic unit (HUC). Functional assessments typically use the ORWAP to evaluate wetlands. Wetlands will

be grouped by Cowardin class and HGM classification. All tidal or “significant” or high natural resource

wetlands, such as palustrine forested wetlands, will be evaluated individually within each fourth field HUC. A

summary of these data, by fourth field HUC, for each HGM class of wetland is provided in each of the two

wetland delineation reports contained in Appendix 2E of this report.

In the State of Washington, wetlands will be classified according to the USFWS classification system

(Cowardin et al., 1979) and the HGM classification system (Brinson, 1993). Wetlands will be qualitatively

assessed using the most current version of the Washington State Wetland Rating System for Western

Washington, developed by the Washington State Department of Ecology (Ecology), which includes updates

completed in 2008 (Hruby, 2004. Aerial photographs, Washington Department of Fish and Wildlife (WDFW)

priority habitat and species maps, and field observations will be used to complete this rating assessment.

The report titled Wetland Delineation Report for the Oregon LNG Bidirectional Project—Cowlitz County,

Washington, contained in Appendix 2E, will provide the wetland rating forms for the delineated wetlands.

For proxy data wetlands that have not been fieldͲaccessed, no data are available to complete a rating

assessment. When access is granted to these nonsurveyed areas, the wetlands will be qualitatively assessed

using the Washington State Wetland Rating System and will be forwarded to the Federal Energy Regulatory

Commission (FERC) with the formal wetland delineation under separate cover.
SECTION 2—DEFINITIONS, AVOIDANCE, AND MINIMIZATION 

PDX/092460002.DOC 

ES110813182840PDX 2-3

The Ecology wetland rating classifications will be used to determine buffer widths, as required by Cowlitz

County under Municipal Code 19.15. Standard buffer widths are established by comparing the wetland

rating category and the intensity of land uses proposed on development sites per Tables 19.15.120ͲA,

19.15.120ͲB, and 19.15.120ͲC of Municipal Code 19.15. For Category IV wetlands, the required water quality

buffers, per Table 19.15.120ͲB, are adequate to protect habitat functions. Where applicable, buffers based

on the standard widths are not required to extend beyond existing natural or constructed barriers, such as

rock outcroppings, dikes, levees, or roads, which isolate the area from the wetland resource.

In areas where access was not granted to the proposed Pipeline easement, wetlands were mapped using

proxy data. In these areas, National Wetland Inventory (NWI) mapped wetlands and mapped Natural

Resources Conservation Service (NRCS) hydric soils data were used along with the aerial photograph to

make a wetland boundary determination. For proxy data wetlands that have not been field accessed, no

data are available to complete a functional assessment. When access is granted to these nonsurveyed areas,

a functional assessment will be performed and forwarded to FERC with the final filing.

Based on the field data collected and the results of the functional assessment, impacts to highͲranking

wetlands were further avoided or minimized to the greatest extent possible. For the purpose of this report,

“highͲvalue wetlands” are defined two different ways: large wetlands (greater than 5.0 acres in size) and

palustrine forested (PFO) wetlands.

SECTION 3.0

PDX/092460002.DOC 3-1 

ES110813182840PDX 

Measures for Wetland Avoidance 

Avoidance measures for the Terminal area are outlined in Section 3.3. Avoidance measures along the

Pipeline are outlined in Sections 3.5 through 3.13.

3.1 Terminal Features 

The Terminal site is situated in the coastal lowlands ecoͲregion and located on the northern portion of the

East Bank Skipanon Peninsula (ESP) near the confluence of the Skipanon and Columbia Rivers in Warrenton,

Clatsop County, Oregon, at River Mile 11.5 of the Columbia River.

The major components and associated activities at the Terminal are:

x Marine terminal facility including an LNG carrier turning basin in the Columbia River

x Pier with a ship berth for one LNG carrier

x Marine cargo transfer system consisting of three LNG unloading arms, a single vapor return arm, and a

single LNG transfer pipeline connected to the onshore facility via a piping trestle

x Three fullͲcontainment LNG storage tanks, each with a usable storage capacity of 160,000 cubic meters(m3

)

x LNG spill containment and collection system

x Vaporization, vapor handling, regasification, and sendoutsystems

x Interconnecting facilitiesincluding piping, electrical, and controlsystems

x Electrical substation at the terminal

x Administrative offices, a control room, and warehouse, security, and other buildings and enclosures

x Utilities, telecommunications, and othersupporting systems

x Marine transport to and from the terminal, including docking and unͲdocking

x Use of tugboats during docking and unͲdocking maneuvers

x Dredging in the turning basin and disposal of dredged material

The ESP is located north of Harbor Street (also known as WarrentonͲAstoria Highway 105) in the City of

Warrenton, in Clatsop County, Oregon. Primary access to the general area is provided by U.S. 101. The

access road alignment proposed extends from the existing intersection at E. Harbor Street/NE King Avenue,

north across the ESP to the Terminal site along a 60ͲfootͲwide rightͲofͲway (ROW) previously platted for

NE King Avenue. This access road alignment will also result in fewer environmental impacts than other

alternatives because access to the ESP historically has been along this route.

3.2 Terminal—Summary of Wetland Classes 

The Terminal site was created from deposition of dredge material beginning in the early 1900s. As a result,

the vegetation in this area is immature and lacks unique, complex, or rare habitat features, and the sandy

dredge material substrate is vegetated in the lowͲlying areas with common facultative facultativeͲwetland,

and obligate wetland plants. Wetland classes associated with the Terminal site include estuarine intertidal

and PSS classes. Figure 2 shows the extent of estuarine and PSS wetlands affected by the Terminal site plan.

The estuarine class of wetlands has been further subdivided by tidal elevation into mudflats, lowͲmarsh, and
REVIEW OF WETLAND AVOIDANCE AND MINIMIZATION EFFORTS 

OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

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highͲmarsh wetlands. These subclassifications correspond to classes used by ODSL to regulate estuarine

wetlands in Oregon.

The estuarine class of wetlands has been further subdivided by tidal elevation into mudflats, lowͲmarsh, and

highͲmarsh wetlands. These subclassifications correspond to classes used by ODSL to regulate estuarine

wetlands in Oregon. The tidal mud flats and shallow subtidal habitat is the combined intertidal and subtidal

habitat lying between the lower edge of the low marsh vegetation line andͲ6 feet mean lower level water

(MLLW). Primary production in this region is dominated by benthic microalgae, which are important for

juvenile salmonids. The boundaries of the low marsh were defined as the inshore limit of mean higherͲhigh

water (composing the upper boundary) and the lowest extent of areas with greater than 30 percent

vegetated cover (composing the lower boundary). Emergent species with dominants, including Lyngbye’s

sedge (Carex lyngbyei), cattail (Typha latifolia), Pacific waterͲparsley (Oenanthe sarmentosa), and bulrush

(Scirpus lacustris), were common in the low marsh. The high marsh boundary is defined on the low side by

the mean higherͲhigh water elevation and on the high side by the upper limits of aquatic vegetation. This

area does not experience daily inundation but is periodically inundated by higher high tides.

The highͲmarsh community is characterized by Lyngby’s sedge, Pacific silverweed (Potentilla pacifica), soft

rush (Juncus effusus), and velvet grass (Holcus lanatus). Several small patches of shrubs are located in the

high marsh.

3.3 Avoidance Measures at Terminal 

Construction of the Terminal facilities will affect tidal and nontidal wetlands in the area, resulting in both

temporary and permanent impacts to wetlands. Impacts to wetlands associated with the Terminal and

related facilities are considered temporary if located within the area disturbed by construction but outside

the permanent facility and removal/fill footprint. Impacts to wetlands associated with the Terminal and

related facilities are considered permanent if located in the permanent facility or removal/fill footprint. The

Terminal’s location was selected to minimize the Project’s environmental impacts, including highͲvalue

wetlands, air emissions, water usage, and potential fisheries resources impacts, by siting the Terminal on

land that is appropriately zoned for industrial use, is on an existing deepͲwater channel, and is relatively

close to major natural gas pipeline networks and markets.

The initial conceptual design for the Terminal was a square layout that would have extended the area of fill

into the low marsh, mudflats, and shallow subͲtidal areas on the east side of the northern end of the ESP.

Subsequent layouts were designed along a northͲsouth axis to avoid these highͲvalue habitats. Estuarine

wetlands are considered highͲquality wetlands because of their importance to salmonids. There is greater

nutrient contribution to the estuary from high and low marshes than from interior palustrine wetlands.

Minor modifications to the site layout were made in the spring of 2009, relocating the flare and adjusting

the placement of vaporizers to avoid estuarine impacts.

The Terminal was designed and shaped to maximize its footprint in nonͲtidal areas of the ESP and conversely

minimize impacts to tidal waters. For example, the Terminal impacts are above mean higher high tide. The

flare for the Terminal was designed to be above the mean higher high tide line, thereby avoiding impacts to

lowͲmarsh habitat. After maximizing design considerations, construction of the Terminal and associated

facilities will result in permanent loss of wetlands from fill placement. The Terminal footprint includes

approximately 1.5 acres that lie within the 100Ͳyear floodplain.

Principles used in siting the Terminal facilities included the following:

x Avoiding impacts to low marsh and shallow subͲtidal habitats that have high functional value for salmon

x Maximizing the use of nonwetland area

x Avoiding estuarine wetlands would be more important than avoiding freshwater wetlands
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x Using existing roads (Northeast King Avenue) to access the Terminal site

x Demarcating wetlands outside of the construction corridor in the field and identified on work plans as

“no work zones” to avoid additional wetland impacts

3.4 Pipeline Features and Summary of Wetland Classes 

The Pipeline traverses the Volcanics and Willapa Hills subregions of the Coast Range ecoregion and the

Portland/Vancouver Basin subregion of the Willamette Valley ecoregion (Thorson et al., 2003). The Pipeline

will be in the Coast Range (MP 0 to MP 82) and Willamette Valley Ecoregions (MP 82 to MP 86.8). These

broad divisions represent similarities in geology, topography, and aspects of soils that affect the type of

vegetation occurring in these areas.

Wetland classes associated with the Pipeline include Riverine, PSS, and PFO, and PEM.

Construction of the Pipeline will result in shortͲterm disturbances to wetland hydrology, water quality and,

where new permanent easement is required, longͲterm disturbance in the form of functional conversion of

forested and scrubͲshrub wetlands to emergent wetlands. Oregon LNG has made extensive efforts to locate

the additional ATWS at least 50 feet from wetlands and other waterbodies. These extra workspaces are

necessary for certain construction techniques for HDD crossings of sensitive features, road crossings, and

additional conventional crossings of sensitive environmental features.

3.4.1 Ancillary Features 

Ancillary features such as the compressor station, meter stations, and contractor/pipe storage yards will be

located to avoid impacts to wetlands.

3.4.2 Access Roads 

The study area also includes access roads that intercept with the proposed Pipeline at varying distances

along the Pipeline route and include a 50Ͳfoot buffer that consists of 25 feet on either side of the centerline

of the road. ATWS will be accessed during construction via public road access points, Project access roads

and intersection points, and use of the construction easement. Access roads will have minimal impacts on

wetlands.

3.5 Avoidance Measures along Pipeline 

Oregon LNG conducted vigorous pipeline corridor selection studies to avoid and minimized disturbance to

wetlands to the maximum extent possible. Examples of avoidance of wetlands include the following:

x Altering the pipeline route or using HDD to avoid large wetland area

x Avoiding estuarine floodplains by routing behind dike areas

x Shifting pipeline alignment and temporary workspaces to follow existing utility corridor ROW

x Avoiding wetland larger than five acres and with high value PFO wetland

x Routing the pipeline through farmed wetlands that have altered hydrology and lack native vegetation

Wetlands outside of the construction corridor will be demarcated in the field and identified on work plans as

“no work zones” to avoid wetland impacts.

Extra work areas will be located at least 50 feet away from wetland boundaries except where the adjacent

upland consists of actively cultivated or rotated cropland or other disturbed land.
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3.6 Pipeline Siting Considerations 

The first step in identifying pipeline routes was the development of criteria to use in evaluating potential

routes. The evaluation criteria relate to public health and safety, environmental constraints, land use, and

engineering limitations.

Environmental constraints considered in the evaluation of route alternatives included the following:

x Habitat of protected and endangered species

x Wetlands, streams, rivers, lakes, and other ecologically sensitive areas

x Selected forest stands

x Selected agricultural lands

x Parks, recreation areas, wildlife refuges, and preserves

x Scenic and aesthetic resource areas

x Historic properties and archeological sites

x Landfills and contaminated soil areas

Engineering limitations in the evaluation of route alternatives included the following:

x Urban areas

x Existing utilities

x Highways, roads, and railroads

x Steep slopes, side hills, and rough terrain

x Areas with potential landslides or seismic activity

x Rivers, streams, and other water bodies

x Active, inactive, and future mining areas

x Available construction techniques

x HDD limitations for major crossings

x Bedrock construction methods.

Once the corridor was selected, field studies were conducted to assess wetland, wildlife, fisheries, and

cultural resources. Minor variations in the proposed route were examined in response to localized issues

identified through the more detailed field surveys and communications with agencies. During preliminary

consultations maps of the preferred alignment were reviewed by ODSL, Oregon Department of Fish and

Wildlife (ODFW), and USFWS. In addition, ODFW, and USFWS reviewed habitat maps. These reviews led to

identifying several dozen wetland and stream crossings for further field review. InterͲagency teams

conducted field trips that led to microͲsiting (minor route changes) to further avoid or minimize impacts to

water resources. In addition, OLNG adopted recommendations to increase the number of HDDs, a

construction technique that can be used to avoid impacts sensitive riparian and stream habitats.

3.7 Pipeline Routing—Existing Utility Corridors and Roads 

The Pipeline route will be coͲlocated with existing easements and ROWs (e.g., roads, railroads, and utility

lines) to the greatest extent practicable.

Oregon LNG demonstrates avoidance by seeking to parallel other linear features or property lines to the

extent possible or practical from a pipeline safety perspective. Utilization of existing infrastructure (e.g.,

highway and road ROWs, utility corridors, or previously developed areas) was one of the most important of

the routing criteria. Parallel construction along existing corridors minimizes impacts to additional land

owners, reduces clearing of new corridors, and lessens wetland and other natural resource impacts. In

addition, operation and maintenance incurred during the life of the pipeline can be reduced when corridors

are shared.
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3.8 Pipeline—National Wetland Inventory Preplanning 

To fill in any potential gaps in mapping, both paper base and electronic National Wetland Inventory (NWI)

maps were used. Pipeline alignment and temporary work spaces were sited to minimize disturbance to

wetlands to the maximum extent possible.

3.9 Avoidance of High-Value Wetlands 

PFO wetlands and wetlands greater than 5.0 acres were evaluated on an individual basis and for purposes of

analysis considered to be of high value. Further efforts to avoid or minimize permanent impacts to highͲ

value wetlands consist of sorting the wetlands by their size, Cowardin class, and functional value, and

reevaluating the potential for further avoidance or minimization. Wetlands were sorted by the functional

assessment ranking assigned to them during field work.

Of the 339 wetlands identified within the Terminal and Pipeline study area, 70 highͲvalue wetlands were

identified. With the use of avoidance measures such as route shifts and HDD, Oregon LNG has avoided

permanent impacts to 31 highͲvalue wetlands and minimized impacts to 28 highͲvalue wetlands. Table 7Ͳ1

in Section 7 of the Conceptual Mitigation Plan identifies all the highͲvalue wetlands and the specific

measures taken to further avoid and minimize permanent and temporary impacts.

3.10 Pipeline—Avoidance of Large Wetland Areas 

Large wetland areas will be avoided using the HDD construction method. More than 24 acres of highͲvalue

wetlands associated with the Adairs Slough in the Lewis and Clark River area will be avoided using the HDD

drilling method.

The Pipeline was also aligned so that highͲvalue streams could be crossed at a right angle or crossed using

HDD techniques, and avoided completely. Approximately 1.65 miles (27.5 percent) of the area from MP 0 to

MP 6 will be constructed using the HDD construction method. Most of this area is behind dikes where there

is potential for floodplain restoration, reconnecting historic floodplain to the tidal estuary.

3.11 Locations of Additional Temporary Workspaces 

Additional temporary work spaces are associated with HDD and perennial stream crossings. Most will be

located 150 feet away from the top of bank of streams which exceeds FERC’s minimum standard by

100 feet. ATWS is sited less than 150 feet where the existing zone of forested riparian cover is less than

150 feet or where the risks of erosion are low. ATWS in riparian areas could have an indirect effect on

streams or wetlands by increasing the risk of erosion near the wetland or waterbody as a result of land

clearing. Extending the distance between ATWS and a wetland or waterbody reduces the risks of sediments

eroding into the wetland or waterbody. Additionally, best management practices (BMPs) and erosion

control applications outlined in the Wetland Restoration Plan will contribute to reducing risks as well.

3.12 Construction Techniques 

Oregon LNG is committed to constructing and operating the proposed Project in a manner that will minimize

environmental impacts in compliance with applicable permits and approvals. Efforts will be made before,

during, and after proposed mainline Pipeline construction to minimize the extent and duration of ProjectͲ

related disturbance to wetland resources.

Oregon LNG will employ three different construction procedures to cross waterbodies; all are dry crossing

techniques. Intermittent or ephemeral streams lacking water at the time of construction will be crossed

using an open trench technique. Perennial streams or streams with water will be crossed with the flume

technique whereby the work area is temporarily dammed and stream water is passed through a flume
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thereby creating a dry work area. The third crossing method is horizontal directional drilling (HDD) whereby

the hole is drilled deep under the waterbody and the pipeline is pulled back through the drilled hole.

The HDD method is expensive and only used over long stretches of between 800 and 5,000 feet. The HDD

method is not a practical method to avoid all wetland or waterbody impacts. The advantages of HDD

methods are minimization of impacts to wetland soils, vegetation, and hydrology. In some cases, such as

small wetlands (less than 0.5 acre), HDD methods can potentially result in greater adverse impacts to the

surrounding environment. Additional temporary workspace is needed at each HDD site to accommodate the

specialized equipment, additional construction crews, and stockpiling materials excavated from entry and

exit pits. HDD entry and exit points must also be set back many feet from the wetland so that the required

depth of the pipe will be achieved beneath the wetland without bending the pipe in too much over too short

of a distance so that it becomes stressed. Excavated material from pits must also be transferred to a

temporary workspaces located outside of the wetland. Construction activities for HDD and associated tieͲin

activities require more time to install pipe per linear foot than the open trench and flume techniques

described above. Other disadvantages include additional time spent on construction utilizes more fuel to

operate equipment, is more expensive, and extends the time that construction related disturbances (noise,

air quality, visual) occur in any given wetland. As mentioned earlier, HDD can also result in a “fracͲout”

where drilling muds can enter the wetland and require cleanup.

3.13 Construction Access Roads 

Further avoidance efforts are demonstrated with the type of access road the project proposes to use. Access

to the temporary and permanent Pipeline easement and aboveground facilities will be through existing

public and private roads to the extent practical. Where the Pipeline parallels existing utilities, Oregon LNG

will use the utility maintenance access roads to the extent practical. Oregon LNG will also use a combination

of existing paved, existing gravel, modified gravel, pasture roads, and other conveyances as appropriate.

In general, access roads will lead to the Pipeline approximately every mile along the routes of the Pipeline.

Of the access roads to be used for the proposed Project, few existing road need improvements, primarily

little more than additional gravel. None of the new access roads are proposed in areas that will cross

wetlands or waterbodies. Existing drainage patterns and culverts will be maintained during construction.

Erosion and sedimentation controls will be installed at the limits of the access roads where necessary.

Oregon LNG will not construct any new permanent bridges or culverts along the Pipeline routes at stream

crossings. During land clearing and construction, streams up to about 30 feet wide will be crossed using

temporary bridges. Equipment will be driven around wider crossings. For postͲconstruction maintenance,

heavy equipment will not be driven across streambeds. Equipment such as a brushͲhog, which may be

required for controlling vegetation, will access the Pipelines via the predetermined existing access roads

stationed approximately every mile along each route. Should access by a brushͲhog type of machine be

impractical, clearing as required would be accomplished manually with hand tools.
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Measures to Minimize Wetland Impacts 

4.1 Terminal Site Layout Alternatives 

The main goal in development of the proposed layout was to minimize wetland impacts to the higher quality

wetland. The proposed layout was also developed to balance the excavation volume with the fill volume

such that imported fill material would be minimized. Estuarine wetlands are higher quality in terms of

providing functions for salmonids because of surface water connectivity. There is greater nutrient

contribution from estuarine wetlands than from interior palustrine wetlands. The proposed layout has less

impact to the estuarine wetland type than the palustrine wetland type.

Oregon LNG developed the proposed layout of the Terminal site layout (shown in Figure 2) after analyzing

wetland impacts associated with the original layout. The original site layout was prepared with the LNG

storage tanks and process equipment located based on the process flow from the LNG storage tanks to the

ambient air vaporizers and then on to the sendout metering station. This alternative layout, which is shown

in Figure 3, would likely result in the lowest construction cost for the process facilities, but does not consider

wetlands impacts or site grading. The steps involved in modifying the proposed layout in order to minimize

wetland impacts included the following:

x The barrier wall around the LNG storage tanks was moved towards the west while keeping the LNG

storage tanks in the same location. For both layouts, the tanks are located as far west as allowed by the

exclusion zone determined by thermal radiation.

x The LNG vaporizers and flare have been relocated to an area that is slightly higher than the surrounding

area and away from existing wetlands to the east and west of the property.

x Although the location of the process area (high pressure LNG pumps and the boiloff gas (BOG)

compressor building) is largely driven by process design, it has been moved into an area slightly elevated

from the surrounding area that separates existing wetlands in the east and west parts of the property.

x Buildings and utility systems have been located in the southwest corner of the property to minimize

access roads and are in areas that are close to the Skipanon River shoreline, away from existing wetlands

within the property.

Overall, the current layout has less impact to estuarine and palustrine wetland types than the two prior

layouts. Table 2 identifies minimization efforts within the Terminal area. It does not include the pier, access

road, or transmission line.

4.2 Pipeline Route Minimization Methods and Alignment 

Changes 

The steps involved in modifying the proposed Pipeline alignment in order to minimize wetland impacts

included the following:

x HDD methods will be used to install the proposed Pipeline several feet below the surface of wetlands

and streams.

x The Pipeline was aligned parallel or with existing road ROW, utility corridors, or previously disturbed

areas.

x The Pipeline route was aligned so that wetlands will be crossed at their narrowest point when possible.
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x The Pipeline was aligned so that streams will be crossed at a right angle to their banks in order to

minimize negative impacts to riparian areas and streambed.

x The width of the Pipeline ROW will be reduced to 75 feet when crossing nonagricultural wetlands to

minimize the area of disturbance.

x Temporary workspaces will be located in areas outside of wetlands to minimize the number of acres of

disturbance.

x Minimizing impacts to wetlands did have limitations due to rugged topography, high densities of

wetland areas, and a preference to avoid highͲquality wetland areas and streams. In areas where a high

density of wetlands existed, the proposed Pipeline was aligned in a way that minimized impacts to most

wetlands but still crossed some. The Pipeline route was sometimes aligned to cross wetlands with low

functional assessment values in order to avoid wetlands with higher values. If Pipeline could be

microsited to avoid every wetland, this would increase the overall length of the Pipeline and period of

active construction, which could result in more permanent impacts to the landscape and longer periods

of temporary disturbance and active construction along the Pipeline route.

x The Pipeline was also aligned so that highͲvalue streams could be crossed at a right angle or crossed

using HDD techniques and avoided completely. Approximately 1.65 miles (27.5 percent) of the area

from MP 0 to MP 6 will be constructed using the HDD construction method. Most of this area is behind

dikes where there is potential for floodplain restoration, reconnecting historical floodplain to the tidal

estuary.

x Before final design, Oregon LNG will consider where weightͲcoating is required between MP 0 and MP 6

in order to make the Pipeline compatible with high water tables or future restoration efforts, and will

coordinate with ODFW and other stakeholders to determine whether there are areas with a low water

table (i.e., areas not otherwise requiring weightͲcoating) and which are priority sites for restoration. At

this stage in planning, Oregon LNG will consider what reasonable measures could be taken to

accommodate future wetland restoration in those drier areas identified as priorities for restoration and

where weightͲcoating would not otherwise be needed.

4.2.1 Routing through Agricultural Wetlands with Previously Impacted 

Hydrological and Habitat Functions 

Some of the wetlands crossed by the proposed Pipeline route are agricultural wetlands. These wetland areas

may have wetland hydrology at least seasonally or have altered wetland hydrology (e.g., as a result of drain

tiling or irrigation ditches), but do not have wetland or native vegetation due to farming activities where

native vegetation is replaced by crops, and therefore provide low quality or only seasonal natural habitat for

most species.

Approximately 10.86 miles of wetlands are crossed by the Pipeline route and approximately 2.47miles are

agricultural wetlands. No longͲterm impacts to these wetlands are anticipated because, following

construction, these areas will be restored to their preconstruction topographical and hydrological patterns,

and will be allowed to return to their preexisting agricultural practices. This process will result in no net loss

of wetland acreage within the proposed Pipeline corridor. Oregon LNG will follow the construction

procedures and mitigation measures in Section VI.A.d of the FERC Wetland and Waterbody Construction and

Mitigation Procedures Modified by Oregon LNG (FERC Procedures; CH2M HILL, 2013b) related to standard

upland protective measures, including workspace and topsoil requirements, as they apply to these

agricultural wetlands. The width of the ROW will not be reduced to 75 feet in agricultural wetlands.

No compensatory mitigation other than soil restoration is planned for features identified as Agricultural

Wetlands in Oregon. During discussion with ODSL in November 2007 (see Resource Report 1—General

Project Description, Appendix 1K), it was indicated that ODSL and USACE will regulate wetlands in
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agricultural areas based on their definitions of farmed or previously converted wetlands. However, following

Pipeline construction in these areas, restoration of soils is expected to be adequate compensation for

temporary impacts.

4.2.2 Reduced Construction Easement Area 

Oregon LNG will make every effort to maintain a reduced construction easement width of 75 feet in

wetlands, in accordance with the FERC Procedures. Agricultural wetlands are not included in this width

restriction. During construction, vegetation will be manually cleared throughout the entire 75Ͳfoot

construction easement. There will be no grubbing, and the root systems will be left intact except for an

approximately 10ͲfootͲwide area directly over the pipe trench. This swath will be grubbed in preparation for

trenching and pipe placement. Work within the 75Ͳfoot construction easement will be conducted on mats

where wetland soils are wet at time of construction to minimize impacts to vegetation and to minimize soil

compaction.

Buffers will be clearly marked in the field during construction activities. Operation of construction

equipment in wetlands will be limited to that needed to clear the easement, dig the trench, fabricate the

pipe, install the pipe, backfill the trench, and restore the easement.

4.2.3 Locations of Temporary and Additional Temporary Workspaces 

The FERC Procedures require ATWS to be located at least 50 feet outside identified wetland boundaries,

except where the adjacent uplands consist of actively cultivated or rotated cropland or other disturbed land.

During discussions with USFWS and National. Marine Fisheries Service (NMFS) for this proposed Project, it

was agreed that (unless approved by USFWS, NMFS, and ODFW) ATWS will be set back 150 feet from

wetlands and streams. In addition, overnight parking of vehicles, storage of fuels and other hazardous

materials, and refueling activities will take place no closer than 150 feet from a wetland or a stream, unless

full containment of potential contaminants is provided. Under certain clearly defined conditions, and subject

to agency approval, ATWS may be placed closer to wetlands or waterbodies where the ATWS placement will

not increase impacts to streams or fish habitat. BMPs and erosion control applications outlined in the

Wetland Restoration Plan will be implemented to reduce risk of sediments entering the waterbodies.

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Unavoidable Impacts to Wetlands 

The Project proposes approximately 174 acres of temporary and permanent wetland impacts. Table 3

identifieswetlands with proposed permanent Cowardin class change by subbasin and milepost. The

wetlands HGM class, proposed area, and acres of impact are listed.

Avoidance of some wetlands was not feasible due to Project constraints. These constraints include:

x Large wetland complexes spanning several acres not entirely avoidable

x HDD method not feasible for small wetlands due to greater overall environmental impacts

x Orientation of sensitive stream crossings prevented complete avoidance of adjacent wetlands

x Preference to use existing utility and road ROW resulted in greater impacts to wetlands

5.1 Terminal 

Construction of the Terminal, pier, and entry road will affect estuarine and nontidal wetlands in the area,

resulting in both temporary and permanent impacts to wetlands. Siting of the proposed Terminal has gone

through several iterations in an effort to avoid impacts to highͲquality wetlands. Of the 114.74 acres of

wetlands identified within the Terminal study area, approximately 35.00 acres of permanent and 2.34 acres

of temporary impacts would result from activities associated with construction and operation of the

Terminal. Table 4 shows temporary and permanent wetland impacts at the Terminal.

5.1.1 Temporary Impacts 

Impacts to wetlands associated with the Terminal and related facilities are considered temporary if they

were within the area disturbed by construction but outside the permanent facility and removal/fill footprint.

The Terminal and related facilitates would temporarily impact approximately 02.34 acre of jurisdictional

nontidal wetlands and 0.0.00 acre of tidal waters of the U.S. and the State of Oregon. In accordance with

state and federal regulatory requirements, Oregon LNG will offset all temporary loss of wetland function and

values by restoring functions to the impacted area upon completion.

5.1.2 Permanent Impacts 

Permanent impacts to wetlands associated with the Terminal and related facilities include 3.46 acres of

jurisdictional nontidal wetlands and 31.57 acres of tidal waters. The impacts were quantified as permanent if

they were in the permanent facility or removal/fill footprint. For permanent Terminal impacts, Oregon LNG

intends to provide offsite compensatory mitigation.

5.2 Pipeline 

Construction of the proposed Pipeline will result in shortͲterm disturbances to wetland hydrology, water

quality, and, where new permanent easement is required, longͲterm disturbance in the form of functional

conversion of forested wetlands to scrubͲshrub wetlands within the 10Ͳfoot maintenance corridor. Impacts

to wetlands associated with the proposed Pipeline construction and operation were quantified based on the

proposed activity in temporary construction and permanent operation zones. Of the approximate 276 acres

of wetlands identified within the Pipeline study area, approximately 18 acres of permanent and 118 acres of

temporary impacts would result from activities associated with construction and operation of the Pipeline.

Tables 5 and 6 show temporary and permanent wetland impacts associated with the pipeline.
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5.2.1 Temporary Impacts 

The route alignment of the Pipeline would temporarily impact approximately 118 acres of jurisdictional

wetlands. Table 5 identifies temporary wetland impacts associated with the construction activities of the

Pipeline.

5.2.2 Temporary Construction Zones 

When constructing the proposed Pipeline through the wetlands, the only soil excavation will occur at the

Pipeline trench area, which will be about 10 feet wide, depending on depth of pipe. Temporary fill will occur

adjacent to the trench where soil and plant materials from the trench will be stockpiled.

During construction, vegetation will be handͲcleared throughout the entire 75Ͳfoot construction easement.

This swath will be grubbed in preparation for trenching and pipe placement. Work within the 75Ͳfoot

construction ROW will be conducted on mats to minimize soil compaction and minimize impacts to

vegetation. Following construction, all wetlands will be rehabilitated to preconstruction soil and hydrology

conditions, and revegetated.

As a result, the following assessment of Project construction impacts can be made for the 75ͲfootͲwide

construction corridor:

x All impacts to wetlands will be shortͲterm and temporary throughout the construction easement

(e.g., reestablishment of vegetation beginning within days or weeks of cessation of site work), with the

exception of the trench excavation area.

x In the estimated 10Ͳfoot wide trench area, impacts will be longerͲterm, and temporary and herbaceous

wetlands will recover more slowly as a result of clearing, grubbing, and soil excavation.

5.3 Permanent Impacts 

The route alignment for the Pipeline would permanently change the Cowardin class for 18 acres along the

Pipeline route, but no changes would occur along access roads. Table 6 identifies permanent impacts.

During operations, a 30ͲfootͲwide area within the 50ͲfootͲwide permanent easement will be routinely

maintained at a maximum frequency of once every 3 years. This area will be maintained free of trees over

15 feet tall. A 10ͲfootͲwide mow strip will be located within the 30ͲfootͲwide maintained area and centered

over the proposed Pipeline. This mow strip will be maintained annually in a nonwoody or treed condition to

allow lineͲofͲsight for aerial surveys. The result of Pipeline wetland crossings will be temporary impacts to all

wetland types during construction throughout the entire 75Ͳfoot construction; permanent Cowardin class

change of PSS and PFO to PEM in the 10Ͳfoot mow strip; and a permanent Cowardin class change of PFO to

PSS in the 30ͲfootͲwide maintained area, excluding the 10Ͳfoot mow strip.

5.4 Wetlands Affected by Permanent Cowardin Class 

Change 

Approximately 391 acres of wetlands were identified in the entire project area. Permanent unavoidable

impacts consist of approximately 53 acres of wetlands. Within the Pipeline project area, the permanent

impacts (18 acres) do not reflect a net loss of wetland, but rather a change to the wetland’s Cowardin class

from PFO to PSS or PEM.
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Best Management Practices 

The construction schedule will consider the recommended ODFW inͲwater work periods unless an extension

of those work periods is granted. The start and end dates are variable depending on the region and the

stream; start dates can begin as early as June 1 and end dates are as late as October 15.

The construction schedule will also consider biological patterns to minimize potential impacts to species and

habitats, specifically, BMPs will include the following:

x Work in the Lower Columbia River Estuary will be timed to take advantage of seasonal low and high

tides.

x Land clearing will begin between May 15 and June 1, after the end of the rainy season.

x A cover crop (in nonagricultural areas) will be planted and erosion control implemented prior to the

rainy season following land clearing.

x Riparian areas will be cleared the same year in which the Pipeline is constructed. Riparian areas will be

kept intact when land is cleared a year in advance of construction.

x Work timing will be coordinated with the biological needs of specialͲstatus species. For example, no

harvesting of trees in riparian areas will occur until migratory bird species have completed nesting

activities, after August 15 and before April 15, unless biological surveys indicate the absence of nesting.

x Vegetation clearing will take advantage of the dry season.

x Revegetation will focus on the cool, rainy season.

6.1 Clay Plugs 

Where the Pipeline trench may drain a wetland (steep slopes), clay plugs will be constructed or the trench

bottom will be sealed as necessary to maintain the original wetland hydrology.

6.2 Soil Segregation 

Oregon LNG will segregate the topsoil up to 1 foot deep over the area disturbed by trenching in wetlands

where hydrologic conditions permit this practice, and this topsoil will be placed in the trench at the end of

backfilling of trench spoils once the trench is backfilled. In accordance with the FERC Procedures, restoration

and monitoring of wetland crossings will be conducted to help ensure successful wetland revegetation.

Oregon LNG will abide by additional wetland construction methods, monitoring, and restoration as required

by the FERC Procedures.

6.3 Rehabilitation of Wetlands Temporarily Impacted by the 

Project 

The rehabilitation/restoration plan is proposed for all the acres of temporary wetland impacts.

Rehabilitation of the Pipeline construction corridors to preconstruction wetland conditions will involve:

x Topsoil segregation and replacement

x Topsoil management to maintain viability of seedbank and vegetative propagules

x Reconstruction of grades

x Permanent erosion control seeding with native wetland species

x Seedbed preparation where soils are displaced or compacted by equipment
REVIEW OF WETLAND AVOIDANCE AND MINIMIZATION EFFORTS 

OREGON LNG TERMINAL AND OREGON PIPELINE PROJECT 

6-2 PDX/092460002.DOC 

ES110813182840PDX 

6.3.1 Soil Segregation 

For the trench excavation area, natural revegetation with native species will be encouraged by providing

suitable soil conditions and applying salvaged topsoil from cleared trench area; weedͲinfested topsoil will

not be reapplied. Proper topsoil stockpile procedures (aeration, moisture, and shading) will ensure that

viable plant propagation sources (e.g., viable seeds, rhizomes, roots, spores, fungi) are replaced following

construction in the trench area. Temporary erosion control seeding with sterile wheat grass will be used to

stabilize soil until natural revegetation occurs.

6.3.2 Seeding and Revegetation 

The wetland areas temporarily impacted by vegetation clearing, equipment traffic, and material storage

outside the trench area will be rehabilitated by reestablishing wetland vegetation from seedbank

germination and vegetative propagation via resprouting of liveroots and propagules left intact and

protected during construction. Sterile wheat grass cover will be used to temporarily stabilize soil until

natural germination occurs. In some instances, a permanent native wetland seed mix will be applied to

ensure adequate cover of the site by desirable species. The seeding and planting mixtures recommended by

the U.S. Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS) for Oregon will

be used as a basis for developing a ProjectͲspecific seed mixture. Measures will be taken to control the

spread of noxious weeds.

For natural regeneration of temporarily cleared forested wetlands outside the 10ͲfootͲwide maintenance

corridor, the following actions will be taken:

x Where feasible, vegetation will be cut during winter months when the plants are in senescence.

x Work crews will minimize damage to stumps (especially stumps less than 10 inches in diameter that are

most capable of vegetatively reproducing) and to root stock left after vegetation clearing.

x To reduce injury to viable roots and shoots, construction traffic will be managed to reduce areas

1) affected by soil compaction and rutting; 2) supported by mats, pallets, or other ground pressure

dissipaters in moist or wet soils; and 3) characterized by low ground pressure equipment where terrain

allows.

x Woody debris, chipped woody vegetation, and unmerchantable logs greater than 12 inches will be

salvaged for surface application outside the 10ͲfootͲwide maintenance corridor where existing downed

wood is insufficient.

x Various site specific seed mixes will be used for temporary erosion control seeding to avoid conflicts

with the permanent cover.

x Where compatible with preconstruction woody species, seeds of native woody wetland species will be

incorporated into permanent erosion control seed mixes.

x After construction if annual monitoring indicates that disturbed wetland areas are not successfully

revegetating with desirable woody plants, supplemental planting will be undertaken.

6.3.3 Monitoring and Adaptive Management Plan 

The project proposes a 10Ͳyear monitoring period after construction activities to evaluate the rejuvenation

of vegetation in the temporary and permanent wetland impact areas. If the annual monitoring report

indicates that disturbed areas are not successfully revegetating with wetland herbaceous or woody plants

similar to preconstruction conditions, supplemental seeding or planting will be undertaken. Woody species

used for replanting would resemble local reference conditions.
SECTION 6—BEST MANAGEMENT PRACTICES 

PDX/092460002.DOC 6-3 

ES110813182840PDX 

The Monitoring and Adaptive Management Plan consists of a 10Ͳyear monitoring period with the following

conditions:

x Monitoring of vegetation establishment that consists of vegetation transect or transects, depending on

size of wetlands that detail herb, shrub, and tree aerial cover at radii of 3 feet, 15 feet, and 30 feet,

respectively

x Percent of planted materials surviving, classified by condition (e.g., vigorous, living, stressed)

x Percent cover for the following four classes: native forbs and grasses, nonͲnative forbs and grasses,

shrubs and trees, and bare ground and rock

x Report on invasive vegetation, vandalism, dumping, wildlife damage, or other conditions actually or

potentially harmful to the restoration

x Identify maintenance concerns (e.g., plants need to be replaced).

x Color photograph that shows the restoration site, taken from a fixed photo point (or points depending

on size of wetland) drawn on a map of the restoration area, keyed to lines of sight from those photo

points

6.3.4 Restoring Grading 

Restoration and cleanup will begin after the trench is backfilled. The disturbed areas will be graded as

closely as practical to preconstruction contours. During cleanup, trash that remains in the easement will be

removed and disposed of in approved areas in accordance with applicable regulations. Organic refuse

unsuitable for spreading over the easement will be disposed of at an authorized facility. Disturbed areas will

be restored as closely as practical to their original condition, permanent erosion control measures will be

installed as appropriate, and revegetation measures will be implemented. In addition, line markers will be

installed directly above the buried Pipelines in accordance with 49 CFR 192, Transportation of Natural and

Other Gas by Pipeline: Minimum Federal Safety Standards, Subpart M, “Maintenance,” 192.707.

SECTION 7.0

PDX/092460002.DOC 7-1 

ES110813182840PDX 

Conclusions 

Wetlands were considered throughout the development of the proposed Project. Efforts will be made

before, during, and after proposed Pipeline construction to avoid and minimize the extent and duration of

ProjectͲrelated disturbance to wetland resources and compensate for disturbance to wetlands where

limitations exist. Past and proposed actions and results are summarized as follows:

x Numerous stages of planning and review have been implemented to avoid and minimize impacts to

wetlands. The first step was to identify Pipeline routes and then evaluate these potential routes.

Extensive review of environmental constraints, public health and safety, land use, and engineering

constraints limited the number of potential Pipeline routes. Once the corridor was selected, field studies

were conducted to assess wetland, wildlife, fisheries, and cultural resources. Based on these studies,

more than 40 Pipeline revisions were made to avoid and minimize impacts to these resources wherever

it was feasible.

x Of the approximate 391 acres of wetlands identified in the project area, approximately 53 acres are

proposed for permanent impacts. Within the Pipeline project area, the permanent impacts (18 acres) do

not reflect a net loss of wetland but rather a change to the wetland’s Cowardin class from PFO to PSS.

x During operations, a 30ͲfootͲwide area within the 50ͲfootͲwide permanent easement will be routinely

maintained at a maximum frequency of once every 3 years. This area will be maintained free of trees

over 15 feet tall. A 10ͲfootͲwide mow strip will be located within the 30ͲfootͲwide maintained area and

centered over the proposed Pipeline. The 10ͲfootͲwide mow strip will be maintained annually in a

nonwoody or treed condition to allow lineͲofͲsight for aerial surveys.

x Oregon LNG developed multiple strategies to minimize impacts where wetlands could not be avoided

due to several limitations. These include rugged topography, high densities of wetland areas, and a

preference to avoid highͲquality wetland areas and streams. Strategies to minimize ProjectͲrelated

impacts to wetlands include maintaining a reduced construction easement width of 75 feet in wetlands

and set back ATWS 150 feet from wetlands and streams in nonagricultural wetlands.

x Further revisions to the proposed Project were made after consultation with ODFW, USFWS, and ODSL.

These revisions included additional techniques to avoid impacts to highͲquality wetlands that include

coͲlocating the Pipeline route with existing ROWs, using existing access routes, altering and adding

additional HDD sites, and slightly moving the Pipeline alignment and Terminal layout.

x Oregon LNG will also be implementing BMPs to rehabilitate impacted wetlands to preconstruction

conditions. These practices include installation of clay plugs to maintain original hydrology of wetlands,

segregation of soils during construction, grade wetlands to preconstruction contours, and revegetate

wetlands with appropriate native vegetation. A final quality control exercise will be conducted to ensure

maximum avoidance and minimization to wetlands has occurred. For permanent, unavoidable impacts

to wetlands, Oregon LNG intends to purchase mitigation credits, provide onsite or offsite compensatory

mitigation, or participate in an inͲlieu fee program.

During the planning phase, extensive methods and tactics have been considered, prescribed, and

incorporated as features of the Project’s design to ensure that resultant and unwanted disturbances to

wetlands are avoided and minimized.

SECTION 8.0

PDX/092460002.DOC 8-1 

ES110813182840PDX 

References 

Adamus, P.R. 2001. Guidebook for Hydrogeomorphic (HGM)ͲBased Assessment of Oregon Wetland and

Riparian Sites: Statewide Classification and Profiles. Oregon Department of State Lands, Salem, OR.

Adamus, P.R. 2005. Hydrogeomorphic (HGM) Assessment Guidebook for Tidal Wetlands of the Oregon Coast

Part 1 Rapid Assessment Method. Report to Coos Watershed Association, U.S. Environmental

Protection Agency, and Oregon Department of State Lands, Salem.

Brinson, M.M. 1993. A Hydrogeomorphic Classification of Wetlands. U.S. Army Corps of Engineers

Waterways Experimental Station. Vicksburg, MS. WRPͲDEͲ4.

CH2M HILL. 2013a. ApplicantͲPrepared Draft Biological Assessment for LNG Development Company, LLC, and

Oregon Pipeline Company, LLC. Prepared for LNG Development Corporation, LLC, and Oregon

Pipeline Company, LLC.

CH2M HILL. 2013b. FERC Wetland and Waterbody Construction and Mitigation Procedures Modified by

Oregon LNG. Prepared for LNG Development Company, LLC, and Oregon Pipeline Company, LLC.

Appendix 2B to Resource Report 2—Water Use and Quality. June 2013.

Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of Wetlands and Deepwater

Habitats of the United States. USFWS, FWS/OBSͲ79/31.

Hruby, T. 2004. Washington State Wetland Rating System for Western WashingtonͲRevised. Washington

Department of Ecology: Olympia, WA. Publication #04Ͳ06Ͳ025.

Tables

% of 

Temporary 

Impacts in 

Study Area

Acreage of 

Permanent 

Impacts

% of 

Permanent 

Impacts in 

Study Area

% of Total 

Wetland 

Impacts in 

Study Area

Acres Acres Acres Acres

Terminal 114.74 Terminal 2.34 2.04% 35.02 30.52% Terminal 37.36 32.56%Pipeline (mainline) 276.06 Pipeline 118.36 42.87% 18.1 6.56% Pipeline 136.46 49.43%

Total 390.80 Total 120.70 30.89% 53.12 13.59% Total 173.82 44.48%

a Terminal includes facility area, dock and pier, entry road, and water/wastewater facilities.

TABLE 1

Summary of Wetland Acreage and Wetland Impacts

Wetland Acreage in 

Study Areaa

Acreage of Temporary 

Impacts

Total Wetland Impacts 

in Study Area
Original Terminal Layout Terminal Layout in FERC 

Submittal October 2008

Current Terminal 

Layout

Estuarineb 22.4 19.1 27.6

Palustrinec 0.6 4.1 5.3

TOTAL 23 23.2 32.9

c Impacts to Palustrine wetland include Interior Freshwater habitat type as classified by the Oregon 

Department of Fish and Wildlife.

TABLE 2

Permanent Wetland Impacts Associated with Terminal Site Layoutsa

Wetland Type

Impacted Area (acres)

a Wetland impacts are from the onshore Terminal facilities only and do not include impacts from the entry 

road, transmission line, or pier.

b Impacts to Estuarine wetlands include Mud Flat, Low Marsh, and High Marsh habitat types as classified by 

the Oregon Department of Fish and Wildlife.
3

TABLE 3

Wetland ID Study Area Milepost 4th HUC- Subbasin HGM Class

Cowardin 

Class

Size 

(Acres)

Permanent

Class Change

Acres

Ch

W99CL0021 Pipeline 0.8 Lower Columbia

Estuarine and Marine Wetland E2USN 23.39 0.00 

W40CL001 Pipeline 2.7 Lower Columbia TBD PSS 8.05 0.00 W40CL002 Pipeline 2.9 Lower Columbia TBD PFO 1.84 0.41 W40CL003 Pipeline 3 Lower Columbia TBD PFO 0.34 0.07 W99CL033 Pipeline 3.7 Lower Columbia TBD PFO 1.20 0.53 

W99CL077A Pipeline 3.7 Lower Columbia TBD AW 6.23 0.00 

W5BCL042F Pipeline 4.2 Lower Columbia TBD AW 8.82 0.00 

W42CL001 Pipeline 4.5 Lower Columbia TBD PEM 7.17 0.00 

W5BCL073 Pipeline 4.5 Lower Columbia TBD PFO 0.07 0.00 

W40CL018 Pipeline 5 Lower Columbia TBD PFO 0.72 0.10 W39CL009 Pipeline 5.1 Lower Columbia TBD PFO 0.11 0.09 

W1BCL001 Pipeline 7.9 Lower Columbia Slope PFO 1.22 0.36 

W39CL005 Pipeline 11 Lower Columbia TBD PFO 0.86 0.24 W39CL007 Pipeline 11 Lower Columbia TBD PFO 0.44 0.12 W39CL012 Pipeline 11.1 Lower Columbia TBD PFO 0.26 0.09 

W1BCL012 Pipeline 18.6 Lower Columbia Riverine PFO 0.22 0.13 W1BCL014 Pipeline 18.6 Lower Columbia Flats PFO 0.84 0.34 W1BCL015 Pipeline 18.9 Lower Columbia Slope PFO 0.09 0.03 W1BCL016 Pipeline 19 Lower Columbia Slope PFO 0.04 0.00 W1BCL018 Pipeline 19 Lower Columbia Slope PFO 0.01 0.01 W1BCL021 Pipeline 19.3 Lower Columbia Slope PFO 0.14 0.00 W2BCL008 Pipeline 19.6 Lower Columbia Riverine PFO 0.95 0.30 W7BCL006 Pipeline 22.4 Lower Columbia Slope PFO 0.16 0.08 W6BCL003 Pipeline 22.5 Lower Columbia Riverine PFO 0.23 0.10 W3BCL101 Pipeline 36.3 Nehalem TBD PSS/PFO 1.98 1.00 W3BCL100 Pipeline 36.5 Nehalem TBD PSS/PFO 0.53 0.15 

W3BCL101b Pipeline 36.7 Nehalem TBD PSS/PFO 10.58 5.41 

W3BCL003 Pipeline 37.1 Nehalem Slope PFO 0.72 0.10 

Pipeline

Summary of High-Value Wetland Impacts
4

TABLE 3

Wetland ID Study Area Milepost 4th HUC- Subbasin HGM Class

Cowardin 

Class

Size 

(Acres)

Permanent

Class Change

Acres

Ch

Pipeline

Summary of High-Value Wetland Impacts

W3BCL002 Pipeline 37.2 Nehalem Slope PFO 0.06 0.05 

W1BCL050A Pipeline 39.6 Nehalem Slope PFO 1.69 0.78 W8BCL007B Pipeline 41 Nehalem TBD PFO 0.74 0.23 W8BCL011A Pipeline 41.4 Nehalem TBD PFO 0.07 0.02 W8BCL011B Pipeline 41.5 Nehalem TBD PFO 0.65 0.18 

W8BCL012 Pipeline 41.6 Nehalem Depressional PFO 0.50 0.15 W8BCL013 Pipeline 41.7 Nehalem Depressional PFO 0.37 0.14 W8BCL018 Pipeline 42.3 Nehalem Riverine PFO 1.30 0.48 W1BCL044 Pipeline 43.4 Nehalem Slope PFO 0.56 0.12 

W1BTI001 Pipeline 44.2 Nehalem Riverine PFO 0.31 0.12 

W6BCO004 Pipeline 47.6 Nehalem Riverine PFO 0.13 0.06 W3BCO111 Pipeline 50.6 Nehalem Slope PFO 0.22 0.14 W3BCO112 Pipeline 50.8 Nehalem Slope PFO 0.31 0.14 W3BCO100 Pipeline 57.7 Nehalem TBD PFO 0.39 0.13 W3BCO102 Pipeline 63.5 Nehalem Slope PFO 0.65 0.25 W3BCO010 Pipeline 63.7 Nehalem Depressional PEM/PFO 0.25 0.06 W6BCO005 Pipeline 69.1 Nehalem Riverine PFO 0.46 0.25 W3BCO007 Pipeline 72.9 Lower Willamette Depressional PFO 0.40 0.34 W1BCO023 Pipeline 73.5 Lower Willamette Riverine PFO 0.26 0.12 W6BCO002 Pipeline 74.6 Lower Willamette Riverine PFO 1.64 0.73 W6BCO001 Pipeline 74.9 Lower Willamette Riverine PFO 0.12 0.04 W3BCO013 Pipeline 76.4

Lower Columbia - 

Clatskanie Riverine PEM/PFO 0.35 0.10 

W3BCO117 Pipeline 79.1

Lower Columbia - 

Clatskanie Slope PFO 0.90 0.33 

W5BCO013 Pipeline 81.5

Lower Columbia - 

Clatskanie Riverine PFO 1.85 1.24 

W99CO003 Pipeline 81.6

Lower ColumbiaClatskanie

Freshwater Forested/Shrub Wetland PFO 0.27 0.06 
5

TABLE 3

Wetland ID Study Area Milepost 4th HUC- Subbasin HGM Class

Cowardin 

Class

Size 

(Acres)

Permanent

Class Change

Acres

Ch

Pipeline

Summary of High-Value Wetland Impacts

W99CO006 Pipeline 81.8

Lower Columbia - 

Clatskanie TBD PFO 0.95 0.27 

W99CO007 Pipeline 81.8

Lower Columbia - 

Clatskanie

Freshwater Forested/Shrub Wetland PFOC 0.37 0.37 

W99CW001 Pipeline 82.7

Lower Columbia - 

Clatskanie Riverine PEM 5.37 0.00 

W99CW002 Pipeline 83

Lower Columbia - 

Clatskanie

Freshwater Emergent Wetland PEMC 35.21 0.00 

W6BCW001 Pipeline 84.2

Lower Columbia - 

Clatskanie Depressional PEM 7.64 0.00 

W99CW007 Pipeline 84.9

Lower Columbia - 

Clatskanie

Freshwater Emergent Wetland PEMC 11.34 0.00 

W99CW005 Pipeline

83.0 (HDD 

Pullback)

Lower Columbia - 

Clatskanie

Freshwater Forested/Shrub Wetland PFOA 0.32 0.32 

152.88 16.88 

W4BCL05 Terminal Terminal Lower Columbia Tidal EEM 45.97 22.33 W4BCL06 Terminal Terminal Lower Columbia Tidal EEM 7.56 0.00 W4BCL07 Terminal Terminal Lower Columbia Tidal EEM 19.75 0.02 W5BCL084 Terminal Terminal Lower Columbia Depressional PFO 0.02 0.00 W5BCL085 Terminal Terminal Lower Columbia Depressional PFO 0.44 0.26 W99CL0001 Terminal Terminal Lower Columbia TBD PFO 0.04 0.00 W99CL0002 Terminal Terminal Lower Columbia

Freshwater Forested/Shrub Wetland PFO/SSC 0.43 0.07 

W99CL0006 Terminal Terminal Lower Columbia TBD PFO 0.23 0.11 W99CL0007 Terminal Lower Columbia

Freshwater Forested/Shrub Wetland PFOA 1.01 0.89 

Terminal

Total
6

TABLE 3

Wetland ID Study Area Milepost 4th HUC- Subbasin HGM Class

Cowardin 

Class

Size 

(Acres)

Permanent

Class Change

Acres

Ch

Pipeline

Summary of High-Value Wetland Impacts

W99CL0009 Terminal Lower Columbia TBD PFO 0.10 0.01 

75.53 23.70 

TBD = Proxy wetland data were used for sites where access was not provided. Hydrogeomorphic class could not be determined. 

Total
TABLE 4

Terminal

Component HUC4 Sub-basin HGM Code

Impact

Type EEM PEM PEM/SSC PEMC PFO PF

PERM 0.00 0.92 0.00 0.00 0.16 

TEMP 0.00 0.62 0.00 0.00 0.00 

0.00 1.54 0.00 0.00 0.16 

0.00 1.54 0.00 0.00 0.16 

Depressional PERM 0.00 0.55 0.00 0.00 0.00 

0.00 0.55 0.00 0.00 0.00 

TBD PERM 0.00 0.00 0.00 0.00 0.00 

0.00 0.00 0.00 0.00 0.00 

Tidal PERM 27.57 0.49 0.00 0.00 0.00 

27.57 0.49 0.00 0.00 0.00 

27.57 1.03 0.00 0.00 0.00 

Tidal PERM 0.02 0.00 0.00 0.00 0.00 

0.02 0.00 0.00 0.00 0.00 

0.02 0.00 0.00 0.00 0.00 

Depressional TEMP 0.00 0.79 0.00 0.00 0.00 

0.00 0.79 0.00 0.00 0.00 

Freshwater Emergent Wetland TEMP 0.00 0.00 0.03 0.22 0.00 

0.00 0.00 0.03 0.22 0.00 

Freshwater Forested/Shrub Wetland PERM 0.00 0.00 0.00 0.00 0.00 

0.00 0.00 0.00 0.00 0.00 

PERM 0.00 0.00 0.00 0.00 0.12 

TEMP 0.00 0.63 0.00 0.00 0.00 

0.00 0.63 0.00 0.00 0.12 

0.00 1.42 0.03 0.22 0.12 

27.59 3.99 0.03 0.22 0.28 

TBD = Proxy wetland data were used for sites where access was not provided. Hydrogeomorphic class could not be determined.

Temporary and Permanent Wetland Impacts—TerminalGrand Total

Depressional TotalDepressional TotalTBD TotalTidal TotalTidal Total

Water/Wastewater Components

Lower Columbia

Entry Road TotalFacility Area TotalPier Total

TBDDepressional

Total Nontidal - TemporaryTotal Tidal - PermanentTotal Tidal - TemporaryTerminalEntry RoadFacility AreaPierWater/Wastewater Components Total

Lower ColumbiaLower ColumbiaLower Columbia

TBD Total

Total Nontidal - Permanent

Depressional TotalFreshwater Emergent Wetland TotalFreshwater Forested/Shrub Wetland Total
TABLE 5

4th HUC HGM AW E1UBL E2USN PEM PEM/PFO PEMC PSS PSSC Grand T

Depressional 2.00 0.00 0.00 6.33 0.00 0.00 1.85 0.00 10.18

Estuarine and Marine Deepwater 0.00 0.24 0.00 0.00 0.00 0.00 0.00 0.00 0.24

Estuarine and Marine Wetland 0.00 0.00 11.29 0.00 0.00 0.00 0.00 0.00 11.29

Flats 0.00 0.00 0.00 0.81 0.00 0.00 0.11 0.00 0.92

Riverine 0.00 0.00 0.00 0.82 0.00 0.00 1.00 0.00 1.82

Slope 0.00 0.00 0.00 0.60 0.00 0.00 0.55 0.00 1.15

TBD 32.99 0.00 0.00 8.46 0.00 0.00 4.19 0.00 45.64

34.99 0.24 11.29 17.01 0.00 0.00 7.70 0.00 71.23

Depressional 0.00 0.00 0.00 4.45 0.00 0.00 0.00 0.00 4.45Freshwater Emergent Wetland 0.00 0.00 0.00 0.00 0.00 27.64 0.00 0.00 27.64

Freshwater Forested/Shrub Wetland 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.83 0.83

Riverine 0.00 0.00 0.00 1.46 0.04 0.00 0.19 0.00 1.69

Slope 0.00 0.00 0.00 0.33 0.00 0.00 0.48 0.00 0.81

TBD 0.14 0.00 0.00 2.27 0.00 0.00 0.00 0.00 2.40

0.14 0.00 0.00 8.50 0.04 27.64 0.67 0.83 37.82

Lower Willamette Depressional 0.00 0.00 0.00 0.00 0.00 0.00 0.12 0.00 0.12

0.00 0.00 0.00 0.00 0.00 0.00 0.12 0.00 0.12

Depressional 0.00 0.00 0.00 1.29 0.00 0.00 0.97 0.00 2.26Flats 0.00 0.00 0.00 0.04 0.00 0.00 0.00 0.00 0.04Freshwater Forested/Shrub Wetland 0.00 0.00 0.00 0.00 0.00 0.00 0.46 0.00 0.46

Riverine 0.00 0.00 0.00 1.16 0.00 0.00 0.01 0.00 1.17

Slope 0.00 0.00 0.00 2.17 0.00 0.00 0.00 0.00 2.17

TBD 2.73 0.00 0.00 0.16 0.00 0.00 0.19 0.00 3.08

2.73 0.00 0.00 4.83 0.00 0.00 1.64 0.00 9.19

37.85 0.24 11.29 30.33 0.04 27.64 10.13 0.83 118.3

4th HUC HGM Grand TotalN/A N/A No Impacts4th HUC HGM Grand TotalN/A N/A No Impacts

Construction Temporary Wetland Impacts—Mainline and Ancillary Facilities

Mainline TotalTBD = Proxy wetland data were used for sites where access was not provided. Hydrogeomorphic class could not be determined.Access Roads- Permanent ImpactsContractor/Storage Yards- Permanent ImpactsMainlineLower ColumbiaLower Columbia - ClatskanieNehalemLower Columbia TotalLower Columbia - Clatskanie TotalLower Willamette TotalNehalem TotalN/A = not applicable.
TABLE 6

Permanent Impacts—Mainline and Ancillary Facilities

4th HUC HGM PEM/PFO PFO PFOA PFOC PSS PSS/PFO 

Flats 0.00 0.34 0.00 0.00 0.00 0.

Riverine 0.00 0.66 0.00 0.00 0.00 0.

Slope 0.00 0.49 0.00 0.00 0.00 0.

TBD 0.00 1.65 0.00 0.00 0.00 0.

0.00 3.14 0.00 0.00 0.00 0.

Freshwater Forested/Shrub Wetland 0.00 0.06 0.32 0.37 0.00 0.

Riverine 0.10 1.24 0.00 0.00 0.22 0.

Slope 0.00 0.33 0.00 0.00 0.43 0.

TBD 0.00 0.27 0.00 0.00 0.00 0.

0.10 1.90 0.32 0.37 0.65 0.

Depressional 0.00 0.34 0.00 0.00 0.07 0.

Riverine 0.00 0.89 0.00 0.00 0.00 0.

0.00 1.24 0.00 0.00 0.07 0.

Depressional 0.06 0.29 0.00 0.00 0.00 0.

Riverine 0.00 0.91 0.00 0.00 0.00 0.

Slope 0.00 1.57 0.00 0.00 0.00 0.

TBD 0.00 0.56 0.00 0.00 0.00 6.

0.06 3.33 0.00 0.00 0.00 6.

Mainline Total 0.16 9.60 0.32 0.37 0.73 6.

4th HUC HGM Grand TotalN/A N/A No Impacts4th HUC HGM Grand TotalN/A N/A No Impacts

Nehalem TotalTBD = Proxy wetland data were used for sites where access was not provided. Hydrogeomorphic class could not be determined.Contractor/Storage Yards- Permanent ImpactsAccess Roads- Permanent ImpactsMainline- Permanent Cowardin Type ChangesLower ColumbiaLower Columbia - ClatskanieLower WillametteNehalemLower Columbia TotalLower Columbia - Clatskanie TotalLower Willamette TotalN/A = not applicable.
 
Figures
 
") #*

#*

OREGON

WASHINGTON

£¤30

£¤101

£¤101

£¤30

£¤26

Clatsop

Columbia

Tillamook Washington Multnomah

Pacific

Lewis

Wahkiakum

Cowlitz

Clark

Astoria

Banks

Bay

City

Beaverton

Cannon

Beach

Clatskanie

Columbia

City

Cornelius

Forest

Grove

Garibaldi

Gearhart

Hillsboro

Manzanita

Nehalem

North

Plains

Portland

Rainier

Rockaway

Beach

St.Helens

Scappoose

Seaside

Vernonia

Warrenton

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§ ̈¦5 § ̈¦205

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Appendix F 

Channel Response Matrix for Pipeline Crossings of 

Endangered Species Act Streams 

 

TECHNICAL MEMORANDUM

Channel Response Matrix for Pipeline Crossings of Perennial 

Endangered Species Act Streams 

PREPARED FOR: Oregon LNG 

PREPARED BY: Greg White/CH2M HILL 

Paul Casperson/CH2M HILL 

Dana Larson/CH2M HILL 

COPIES: Jay Lorenz/CH2M HILL 

DATE: May 16, 2013 

Introduction 

This technical memorandum presents the results of a high-level stream channel assessment and scour analysis for 

the waterbodies crossed by the Oregon Pipeline. Oregon LNG proposes to construct and operate the Oregon 

Pipeline and associated LNG terminal. The Oregon Pipeline consists of approximately 86.8 miles of 36-inchdiameter pipeline to be constructed between Warrenton, Oregon, and Woodland, Washington, crossing three 

counties, Clatsop, Columbia, and Cowlitz. The pipeline will cross numerous intermittent and perennial streams 

and rivers. Specific scour analyses and migration studies may be performed at a later date for specific crossings as 

required by Oregon LNG and/or permitting agencies. 

This stream channel assessment combines an evaluation of channel morphology and channel-forming processes 

to simplify a wide variety of channels into a manageable analysis framework. Channel segments (subreach units) 

are areas of streams that respond to disturbances in a similar fashion based on similarities in channel-forming 

processes. The assessment of channel conditions provides a context for evaluating the influence of changes in 

land management or activities on channel conditions and processes. Major changes in channel morphology 

(scour) are caused by changes in discharge, sediment supply, and vegetation in the channel. The scour analysis 

focuses on fluvial-dominated stream channels and provides a first-cut method of identifying stream crossings with 

a potential for vertical and/or lateral scouring (i.e., lateral channel migration). 

Methods 

Streams with perennial flow regimes and supporting Federal Endangered Species Act (ESA)-listed salmonids were 

evaluated to determine which pipeline crossings have a predisposition for vertical scouring or lateral migration. A 

total of 120 streams crossed by the Oregon Pipeline have perennial flow regimes, support ESA-listed salmonids, or 

have designated critical habitat. Twenty-four of those streams support ESA-listed salmonids or have designated 

critical habitat. Although some intermittent and ephemeral drainages not supporting ESA-listed salmonids will 

require further investigation prior to final engineering design, these sites were not included at this time for this 

study. 

Stream segment slope (gradient) and channel confinement provide a useful orientation for stream classification 

and provide a method to distinguish between the possible responses of a stream channel to disturbances. 

Channel confinement is the ratio of the valley or floodplain width to the channel width. 

Stream slope at potential pipeline crossings was determined from field reconnaissance surveys. Where field 

reconnaissance surveys were not conducted, channel gradient was determined from 1:24,000 U.S. Geological 

Survey (USGS) topographic maps by measuring the distance between a contour line upstream and a contour line 

downstream of the crossing, or by using Washington 10-meter Digital Elevation Model (DEM) elevations. Channel 

confinement was determined by measuring the valley width or floodplain (distance between contour lines on 

either side of the channel at the crossing based on a 1:24,000 USGS topographic map) and comparing this width 

to the channel width (ordinary high water [OHW] width). 

ES030613113935PDX 1 
CHANNEL RESPONSE MATRIX FOR PIPELINE CROSSINGS OF PERENNIAL ENDANGERED SPECIES ACT STREAMS 

After determining channel gradient, channel confinement, and valley width at Pipeline crossings, streams were 

grouped into categories based on their similarities and channel characteristics. Streams with specific similarities 

are expected to have similar responses to disturbances or be predisposed to specific conditions. These responses 

or conditions are based in part on the Washington Department of Natural Resources (DNR) Watershed 

Assessment Methodology (1994) Channel Response Matrix. This approach is also consistent with previous pipeline 

projects in the area that have included multiple waterbody crossings. In addition, the Rosgen channel type 

(Rosgen, 1996), which was identified by channel characteristics collected during field reconnaissance surveys, was 

used to verify and support DNR Channel Response Matrix characteristics. 

Ephemeral drainages (defined as streams with flows generated by periodic surface runoff along the Pipeline route 

were not analyzed for scour events. Ephemeral drainages, as defined in the assessment method, only flow during 

and shortly after a large precipitation event and lack the hydrological and morphological characteristics of a 

perennial or intermittent stream. Ephemeral drainages may not have a well-defined channel and may be 

vegetated. Therefore, ephemeral drainages are not considered to have vertical or lateral scour potential. 

However, ephemeral drainages could experience mass wasting events, such as landslides or slope failure, which 

could affect the pipeline. Landslide and slope failure potential along the Pipeline are further evaluated in Resource 

Report 6 — Geologic Resources. 

In addition to ephemeral drainages, non-ESA intermittent streams were also excluded as they are primarily minor 

waterways with generally lower scour risk. However, as discussed above, they may still experience mass wasting 

events that could affect the pipeline. 

According to Rosgen (1996) and personal communication with Janine Castro of the U.S. Fish and Wildlife Service 

(Castro, 2009), only streams with a gradient of less than 4 percent typically have the potential for significant 

lateral scouring at the reach level. Streams with a greater than 4 percent gradient have no functional floodplain 

and therefore have no, or little, potential for lateral channel migration at the reach scale. 

At ESA stream crossings and within Federal Emergency Management Agency floodways, the pipeline will be 

buried at a depth that minimizes the risk of exposure from vertical scour and channel migration. The actual depth 

of the pipeline will be determined during final engineering to address risks of vertical scour and channel 

migration. 

Results 

Stream channels with similar characteristics are expected to respond to disturbances similarly or be predisposed 

to specific events. Channel slope can be used as a surrogate for stream energy, which is the dominant aspect 

controlling channel morphology. Channel confinement controls the characteristics of potential channel responses 

and manifests the long-term history of a valley (DNR, 1994). Increased entrenchment is one possible channel 

response to disturbance. Entrenchment is defined as the vertical containment and the degree to which a channel 

is incised in the valley floor (DNR, 1994). 

Channel slope and confinement are general indicators of a stream’s transport capacity and the balance between 

sediment supply and transport capacity (DNR, 1994). The Channel Response Matrix provides a simple method for 

categorizing potential channel responses in terms of gradient and channel confinement and is based on 

geomorphic reasoning and professional experience. The matrix differentiates between fluvial and mass-wasting 

dominated channels. Twenty percent channel slope typically defines the upper limit of fluvially dominated 

channel systems (DNR, 1994). 

The DNR Channel Response Matrix shows a channel’s predisposition to specific events given specific channel 

characteristics. These characteristics are based on channel slope, channel confinement, and valley width. The 

potential channel responses based on these characteristics include fine sediment deposition, bank erosion, wood 

loss, debris flow scour, and debris flow deposition. Channel reaches can be grouped into source, transport, and 

response reaches using gradient as the criterion. Reaches greater than 20 percent gradient are considered source 

reaches, 3 to 20 percent gradient are transport reaches, and less than 3 percent gradient are response reaches. 

ES030613113935PDX 2 
CHANNEL RESPONSE MATRIX FOR PIPELINE CROSSINGS OF PERENNIAL ENDANGERED SPECIES ACT STREAMS 

Six gradient groupings are used to generally correspond to gradients associated with changes in channel 

morphology that reflect relative transport capacity and the response potential (DNR, 1994). 

The 24 streams evaluated using this methodology were categorized into six distinct groups based on slope, 

channel width, and confinement (Table 1). Table 2 (located at the end of this technical memorandum) provides 

specific stream crossing ID numbers, stream slope (gradient %), valley width, confinement, and vertical and/or 

lateral scour potential for each of the 24 ESA perennial streams. 

TABLE 1

Channel Response Matrix for Pipeline Crossings of Perennial Waterbodies and Streams Supporting ESA-listed Salmonids 

Channel Type 

Scour Potential of Evaluated Stream Crossings (Vertical/Lateral) 

None 

(at Reach 

Scale)/ Slight Slight/ Moderate Moderate/ Severe 

Moderate to 

Severe/ None Severe/ None 

Severe (Mass 

Wasting 

Dominated)/ None 

Valley Width (VW) > 4 Channel 

Width (CW) (Unconfined) 

11 3 7 1 

2 CW < VW < 4 CW 

(Moderately Confined) 

1 

VW < 2 CW (Confined) 1 

Gradient and Typical Channel Bed Morphology 

Channel Gradient Percentage 

(Stream Type) 

< 1 

(Pool-Riffle) 

1 to 2 

(Pool-Riffle, 

Plane-Bed) 

2 to 4 

(Plane-Bed, 

Forced Pool-Riffle) 

4 to 8 

(Step-Pool) 

8 to 20 

(Cascade) 

> 20 

(Colluvial) 

Source: DNR, 1994. 

Notes: Valley width (VW) = distance between first contour lines on either side of channel (1:24,000 scale USGS). Channel width (CW) = OHW 

channel width. 

Based on DNR (1994) Standard Watershed Analysis Methodology, six channel types with the potential for either 

lateral (bank erosion causing channel migration) and/or vertical (debris flow) scour potential were identified for 

streams being crossed by the pipeline. Of the 24 perennial/ ESA stream crossings, 11 possess some potential for 

vertical scouring or debris flow events, while 23 have at least some potential for lateral channel migration. 

Unconfined channels with slopes less than 1 percent (11 streams) are associated with: 

x Fine sediment deposition 

x Bank erosion 

x Wood accumulation 

Unconfined channels with slopes between 1 and 2 percent (3 streams) are associated with: 

x Wood loss 

x Scour potential 

x Fine sediment deposition 

x Bank erosion 

Unconfined channels with slopes between 2 and 4 percent (7 streams) are associated with: 

x Dam break flood 

x Debris flow deposition 

x Bank erosion 

x Coarse sediment deposition 

x Scour potential 

x Wood loss 

ES030613113935PDX 3 
CHANNEL RESPONSE MATRIX FOR PIPELINE CROSSINGS OF PERENNIAL ENDANGERED SPECIES ACT STREAMS 

Unconfined channels with slopes between 4 and 8 percent (1 stream) are associated with: 

x Debris flow scour/debris flow deposition 

x Dam break flood 

x Wood loss 

Moderately confined channels with slopes less than 1 percent (1 stream) are associated with: 

x Fine sediment deposition 

x Bank erosion 

x Wood accumulation 

Confined channels with slopes less than 1 percent (1 stream) are associated with: 

x Coarse sediment deposition 

x Wood loss 

Ten of the evaluated waterways will be crossed via horizontal directional drilling (HDD). Of these 10 crossings, one 

(Bear Creek) has more than a slight vertical scour potential. Of the remaining nine HDD crossings, all have no 

vertical scour potential and have a slight lateral scour potential. The remaining crossing has a severe lateral scour 

potential (Bear Creek). 

This high-level method of scour potential determination relies exclusively on gradient, valley width, and channel 

width, excluding additional factors such as substrate type. For certain waterways, historical observation and 

empirical evidence suggest that the scour potential may be different than that estimated by this model. In these 

cases, engineering will determine the accurate depth for the pipe crossing. 

Conclusions 

Of the 24 perennial ESA streams being crossed by the pipeline, 11 have a slight or higher potential for vertical 

scouring. Of these, eight have a moderate or higher potential for vertical scouring. One channel has a severe 

potential for vertical scouring, and eight channels are mass-wasting dominated (MWD). The only stream with 

moderate/severe vertical scour potential is an intermediate waterway. Seven of the MWD streams are classified 

as intermediate, with the one remaining classified as minor. Thirteen streams have no vertical scour potential. Of 

the streams evaluated, five are considered major streams (100 feet or greater in width as defined by the Federal 

Energy Regulatory Commission’s Wetland and Waterbody Construction and Mitigation Procedures [2003]), none 

of which have a slight or higher potential for experiencing vertical scouring flows (no vertical scour potential). 

One crossing (Little Clatskanie River) has no or negligible potential for lateral channel migration (lateral scouring) 

at the reach scale, 13 have a slight potential, 3 have a moderate potential, and 7 have a severe potential for 

lateral channel migration. Of the seven streams with a severe potential for lateral scour, all are intermediate 

waterbodies. The five major stream crossings have a slight potential for lateral channel migration. Potential for 

vertical scour and channel migration will be used to inform engineers which streams require special attention 

regarding depth of pipeline during final design. 

Literature Cited 

Castro, J.M. 2009. Personal communications with Janine Castro, Ph.D. Geomorphologist, U.S. Fish and Wildlife 

Service, Portland, Oregon. April 9, 2009. 

Federal Energy Regulatory Commission. 2003. Wetland and Waterbody Construction and Mitigation Procedures. 

http://www.ferc.gov/industries/gas/enviro/guidelines.asp. January 17, 2003. 

Rosgen, D. 1996. Applied River Morphology. Wildland Hydrology, Pagosa Springs, Colorado. 

Washington Department of Natural Resources (DNR). 1994. Board Manual: Standard Methodology for Conducting 

Watershed Analysis Under Chapter 222-22 WAC. Washington Department of Natural Resources, Olympia, 

Washington. 

ES030613113935PDX 4 
CHANNEL RESPONSE MATRIX FOR PIPELINE CROSSINGS OF 

TABLE 2 Oregon Pipeline Crossings of Perennial ESA Streams 

Stream ID 

MP at 

Crossing 

Crossing 

Method Flow Regime 

Waterbody 

Type Waterbody 

Valley 

Width 

(ft)a

OHW 

Width 

(ft) Channel Confinementb

Gradient 

(%)c

S99CL001 1.0 HDD Perennial Major Adairs Slough 5,258 110 Unconfined <1 NS5BCLo74 1.5 HDD Perennial Intermediate Vera Creek 4,960 20 Unconfined <1 NS40CL002 3.1 HDD Perennial Major Lewis and Clark River 5,808 1250 Unconfined <1 NS5BCL064 4.5 Dry/Flume Perennial Intermediate Barrett Slough 3,844 12 Unconfined <1 NS99CL064 5.7 HDD Perennial Major Lewis and Clark River 2,261 340 Unconfined <1 NS1BCL001 7.9 Dry/Flume Perennial Intermediate Heckard Creek 1,139 10 Unconfined <1 NS99CL018 11.0 HDD Perennial Intermediate Lewis and Clark River 1,365 35 Unconfined <1 NS2BCL008A 25.4 Dry/Flume Perennial Intermediate Little Fishhawk Creek 104 15 Unconfined <1 NS2BCL008B 31.4 Open cut Perennial Intermediate Alder Creek 421 15 Unconfined 3.6 MS99CL108 33.5 HDD Perennial Major Nehalem River 3,601 120 Moderately Confined <1 NS8BCL005 41.0 Open cut Perennial Intermediate Rock Creek 470 20 Unconfined 2.2 MS1BCL021 43.1 Dry/Flume Perennial Intermediate South fork Rock Creek 2,302 15 Unconfined 3.0 MS1BCL022 43.4 HDD Perennial Intermediate Bear Creek 436 12 Unconfined 2.3 MS6BCO002 47.5 Dry/Flume Perennial Intermediate North Fork Wolf Creek 143 30 Unconfined 1.0 SlS3BCO012 50.5 Dry/Flume Perennial Intermediate Clear Creek 780 30 Unconfined 2.1 MS3BCO107 55.7 Dry/Flume Perennial Intermediate Cedar Creek 976 10 Unconfined 1.6 SlS3BCO101 57.7 HDD Perennial Intermediate Rock Creek 1,157 30 Unconfined <1 NS3BCO014 63.8 HDD Perennial Intermediate Nehalem River 113 30 Moderately Confined <1 NS99CO020 70.7 Open cut Perennial Intermediate Clatskanie River 219 19 Unconfined <1 NS5BCO001 71.8 Open cut Perennial Minor Little Clatskanie River 244 2 Unconfined 4 MS3BCO010 73.0 Open cut Perennial Intermediate Milton Creek 317 12 Unconfined 3.2 MS3BCO018 76.4 Open cut Perennial Minor Merril Creek 376 1 Unconfined 1.1 SlS99CO011 81.6 Open cut Perennial Intermediate Deer Island Slough 780 38 Unconfined 2.1 MS99BCO014 82.4 HDD Perennial Major Columbia River 5,637 3300 Confined <1 Na Valley width (VW) = distance between first contour lines on either side of channel (1:24,000 scale U.S. Geological Survey). b Channel confinement based on Channel Response Matrix (Table E-2) in DNR (1994): 

VW > 4CW = Unconfined 2CW < VW < 4CW = Moderately Confined VW < 2CW = Confined 

c Where gradient not field collected, used 1:24,000 USGS topographic maps. Gradient listed as 0.0% means gradient < 1%. d For vertical scour potential, “None” means on a reach scale. There will still likely be pool scour etc. e Lateral channel migration potential based on DNR (1994): ES030613113935PDX 
CHANNEL RESPONSE MATRIX FOR PIPELINE CROSSINGS OF 

TABLE 2 Oregon Pipeline Crossings of Perennial ESA Streams 

Stream ID 

MP at 

Crossing 

Crossing 

Method Flow Regime 

Waterbody 

Type Waterbody 

Valley 

Width 

(ft)a

OHW 

Width 

(ft) Channel Confinementb

Gradient 

(%)c

None = Could be microbank erosion but not lateral channel migration. Slight = Unconfined or moderately confined channel with gradient < 1%. Moderate = Unconfined or moderately confined channel with gradient 1% - 2%. Severe = Unconfined or moderately confined channel with gradient 2% - 4%. 

Stream ID = stream identification number ft = feet 

MP = milepost ES030613113935PDX 
 

Appendix G 

Drawings of Typical 

Non-ESA-Listed Stream Crossings 

 









 

Appendix H 

Migratory Bird Avoidance and Monitoring Plan for 

the Oregon LNG Project 

 
 
ES030613113935PDX 1 

TECHNICAL MEMORANDUM

Migratory Birds—Regulatory Review and Mitigation 

PREPARED FOR: Resource Report 3 

PREPARED BY Bridget Canty/PDX 

Jay Lorenz/PDX 

Renee Storey/PDX 

DATE: May 1, 2013 

Introduction 

Migratory birds are protected by the federal Migratory Bird Treaty Act (MBTA) of 1918, as amended (16 United 

States Code [U.S.C.] 703-712). The Memorandum of Understanding between the Federal Energy Regulatory 

Commission and U.S. Department of the Interior United States Fish and Wildlife Service (USFWS) regarding 

implementation of Executive Order 13186, “Responsibilities of Federal Agencies to Protect Migratory Birds” (FERC 

and USFWS, 2011) (MBTA MOU) provides guidance on complying with the MBTA. This technical memorandum 

provides regulatory background on migratory birds relative to commercial logging and Pipeline operations. It also 

presents recommendations for avoidance of impacts to migratory birds and for stewardship compliance with the 

MBTA MOU. Oregon LNG proposes to clear land, including trees on commercial timberland, within a nominal 

100-foot-wide construction corridor and associated additional temporary workspaces to accommodate the 

Pipeline. Vegetated habitats, including commercial forests, may provide habitat for many species of migratory 

birds, including raptors and songbirds. 

Regulatory Background 

Section 703 of the MBTA prohibits the taking, killing, possession, transportation, and importation of migratory 

birds, their eggs, parts, and nests, except when specifically authorized by the U.S. Department of the Interior. The 

MBTA has no provision for allowing unauthorized take. 

The MBTA MOU specifies that both parties shall support the conservation intent of Executive Order 13186, and 

the migratory bird conventions, to the extent possible and practicable, by the following: 

x Integrating bird conservation principles, measures, and practices into agency actions; 

x Avoiding or minimizing the take of migratory birds and adverse effects on their habitat; 

x Improving habitat conditions for migratory birds on lands affected by energy projects; and 

x Preventing or abating pollution detrimental to migratory birds and their habitats. 

While the MBTA provides no mechanism for allowing unauthorized take, the USFWS recognizes that some birds 

may be taken during such activities as pipeline construction, even if all reasonable measures to avoid take are 

implemented. The USFWS Office of Law Enforcement carries out its mission to protect migratory birds not only 

through investigation and enforcement, but also through fostering relationships with individuals and industries 

that proactively seek to eliminate their impacts on migratory birds. Although it is not possible under the MBTA to 

absolve individuals, companies, or agencies from liability (even if they implement avian mortality avoidance or 

similar conservation measures), the USFWS Office of Law Enforcement focuses on those individuals, companies, 

or agencies that take migratory birds with disregard for their actions and the law, especially when conservation 

measures have been developed but are not properly implemented (Rockies Express Pipeline LLC and USFWS, 

2008). 

A number of court cases have dealt with the authority of the MBTA and logging operations (Lurman, 2007). 

In 2000, nine environmental groups, including the Center for Environmental Law, submitted a document 

(SEM-99-002) asserting that the Federal government was failing to enforce Section 703 of the MBTA. The 
MIGRATORY BIRDS—REGULATORY REVIEW AND MITIGATION 

2 ES030613113935PDX

submitters claimed that logging operations consistently result in violations of the MBTA, killing an enormous 

number of birds, or destroying their nests and eggs. The submitters assert that, despite being aware of these 

violations, the United States never prosecutes logging operations that violate the MBTA. The submitters 

specifically referred to two cases in California where migratory birds were killed. The first case involves the logging 

of several hundred trees by a private landowner during the nesting season of great blue herons, allegedly 

resulting in hundreds of crushed eggs. The second case involves a logging company’s alleged intentional burning 

of four trees on private land, including one allegedly used by a nesting pair of osprey. 

In 2003, the North American Commission for Environmental Cooperation (CEC) conducted a legal review of how 

the MBTA has been applied to private logging operations (CEC, 2003). The CEC determined that there has never 

been a prosecution of a private timber harvest operation since the MBTA was enacted in 1918. The CEC concluded 

the following: 

x USFWS has long had an “unwritten policy relative to the MBTA that no enforcement or investigative action 

should be taken in incidents involving logging operations, that result in the taking of non-endangered, nonthreatened migratory birds and/or their nests” 

x Because of limited resources, USFWS has “concentrated its regulatory, enforcement, and scientific efforts to 

reducing unintentional takes of migratory birds caused by those activities where industry has created 

hazardous conditions which often attract migratory birds to their death (i.e., birds attracted to perching on 

power lines or open oil pits that appear as water ponds to overflying birds” 

x “Alternative statutes and non-enforcement initiatives are more effective and efficient in protecting migratory 

birds [and] habitat modification per se is not prohibited by the MBTA. This means that establishing a violation 

of the MBTA due to logging activities poses more significant technical challenges than many other types of 

MBTA violations. Therefore, the USFWS has thus far made bona fide decisions to allocate enforcement 

resources to investigating and prosecuting other possible violations instead of those caused by logging 

activities. The USFWS made its resource allocation decisions in good faith and always with the objective to 

conserve migratory bird populations and their habitats in sufficient quantities to prevent them from becoming 

threatened or endangered.” (CEC, 2003) 

On advice of counsel, it does not appear that the MBTA imposes an affirmative duty to take specific action under 

the MBTA, other than to avoid taking of migratory birds. Logging associated with clearing a Pipeline corridor by 

itself does not trigger the need for a permit or other regulatory approval under the MBTA, as habitat destruction 

alone does not constitute a “take” under the MBTA (Seattle Audubon Society v. Evans, 952 F.2d 297 [9th Cir., 

1991]; City of Sausalito v. O’Neill, 386 F.3d 1186 [9th Cir., 2004]). However, in the interest of being good stewards 

of the environment that the Pipeline will affect, it is recommended that measures be taken to avoid take. 

Mitigation 

Oregon LNG will take reasonable and prudent measures to avoid the taking of birds protected by the MBTA and in 

accordance with the MBTA MOU. These measures are in addition to those that may be imposed to protect birds 

protected under the Endangered Species Act, such as the northern spotted owl and marbled murrelet (see 

Resource Report 3, Appendix 3E). 

Land clearing will take place the same year as Pipeline construction (see Resource Report 1 for a Project 

schedule). Clearing will take place as late as possible in the spring and early summer to avoid as much of the 

nesting season as possible. Oregon LNG proposed land clearing in the late summer and early fall prior to Pipeline 

construction. The National Marine Fisheries Service (NMFS) was concerned that such a schedule increased risk of 

erosion into streams, particularly salmon-bearing streams. The USFWS, in consultation with NMFS, advised 

Oregon LNG that the preferred schedule would be to conduct land clearing the same year as construction. The 

corridor would then be rehabilitated at the end of the construction season, thereby limiting and minimizing 

exposure and risk of soil erosion. 
MIGRATORY BIRDS—REGULATORY REVIEW AND MITIGATION 

ES030613113935PDX 3 

Assuming that vegetation clearing cannot be avoided during the entire nesting and breeding season, Oregon LNG 

will provide biologists to conduct a preconstruction reconnaissance of the Terminal and Pipeline corridor to 

identify any active migratory bird nests. If one or more active nests are identified within the construction corridor, 

biologists will mark the location(s) of the nest(s) in the field and on the construction plans and delay vegetation 

clearing around the active nest(s) until such time as the nest(s) have fledged or failed (due to natural causes). 

If one or more active nests are identified outside the construction corridor but nearby, the biologists will monitor 

the nest(s) during construction for signs of disturbance. If it appears that the monitored nest(s) are exhibiting 

disturbance that could lead to unintentional indirect take pursuant to the MBTA, construction should be halted 

temporarily until such time as the nest has fledged or failed (due to natural causes). Trees with nests may be cut 

during the non-nesting season. Preconstruction surveys will include an aerial survey for raptor nests in late March 

prior to trees leafing out. 

Vegetation clearing shall not occur within 500 feet of any existing eagle, osprey, or other raptor nest locations or 

trees used by such birds unless a variance is granted, in writing, by USFWS. Band-tailed pigeon nesting or roosting 

tree(s), as well as any tree(s) near an existing great blue heron rookery, are not to be removed unless the USFWS 

approves it in writing. Removing trees in a designated nest patch of a northern spotted owl shall be avoided. 

Removing trees in a cluster of trees known to provide nesting for marbled murrelets shall be avoided. 

Unintentional take, the observation that land clearing has unintentionally killed a migratory bird, shall be reported 

to Oregon LNG’s designated environmental compliance officer within 24 hours of such an incident. The 

environmental compliance officer will be responsible for reporting the unintentional take to USFWS. 

Oregon LNG will rehabilitate the Pipeline corridor to provide habitat for birds and other wildlife. In addition, 

Oregon LNG proposed extensive upland and riparian habitat mitigation in the Applicant-Prepared Conceptual 

Mitigation Plan for the Oregon LNG Terminal and Oregon Pipeline Project (CH2M HILL, 2009). The habitat 

mitigation proposed in the conceptual mitigation plan places an emphasis on preservation and management 

toward late-successional forests and riparian habitats that are in decline in the Coast Range. The combination of 

rehabilitation of the Pipeline corridor, long-term conservation of upland, and riparian habitats will benefit 

migratory birds. 

References 

CH2M HILL. 2009. Applicant-Prepared Conceptual Mitigation Plan for the Oregon LNG Terminal and Oregon 

Pipeline Project. FERC Dockets Docket Nos. CP09-6-000 and CP09-7-000. 

Federal Energy Regulatory Commission (FERC) and U.S. Fish and Wildlife Service (USFWS). 2011. Memorandum of 

Understanding - Executive Order 13186, “Responsibilities of Federal Agencies to Protect Migratory Birds.” 

Lurman, J. 2007. “Agencies in Limbo: Migratory Birds and Incidental Take by Federal Agencies.” Journal of Land 

Use 23(1): 39-60. 

North American Commission for Environmental Cooperation (CEC). 2003. Final Factual Record for Submission 

SEM-99-002 (Migratory Birds). North American Environmental Law and Policy, Volume 11. 

Rockies Express Pipeline LLC and U.S. Fish and Wildlife Service (USFWS). 2008. Guidelines for Achieving 

Compliance with the Migratory Bird Treaty Act and Executive Order No. 13186 Through Voluntary 

Conservation Measures Associated with the Construction and Operation of the Rockies Express Pipeline – 

East Project in Missouri, Illinois, Indiana, and Ohio. Available at: http://elibrarybackup.ferc.gov/idmws/common/downloadOpen.asp?downloadfile=20080411%2D4002%2819086457%2

9%2Epdf&folder=18065594&fileid=11641229&trial=1.
APPENDIX F4 

WETLAND MITIGATION PLAN

Wetland Mitigation Plan 

Chapter 1—Introduction 

1.1 Purpose and Organization of Wetland Mitigation Plan 

The purpose of the wetland mitigation plan is to present additional information on wetlands that are located 

within the construction and permanent easements (also referred to as temporary workspace and 

permanent easement) for the Oregon LNG Pipeline, Terminal, and related aboveground facilities 

(collectively referred to as the Project). The wetlands under discussion are identified in the wetland 

delineation reports in Appendix 2E of Resource Report 2—Water Use and Quality. The wetland information 

provided in this mitigation plan includes a summary of wetland impacts by hydrogeomorphic (HGM) and 

Cowardin class by subbasin (the 4th-field hydrologic unit code [HUC] unit); and the approach to mitigating 

wetland impacts associated with the Project. 

Chapter 2—Impact Assessment 

2.1 Methodology 

2.1.1 Terminal 

Impacts to wetlands associated with the Terminal and related facilities were quantified as temporary if they 

were within the area disturbed by construction but outside the permanent facility and removal/fill footprint. 

The impacts were quantified as permanent if they were within the permanent facility or removal/fill 

footprint. Figure 1 of Resource Report 2—Water Use and Quality, as updated in the April 3, 2014, Terminal 

Supplement filed with FERC (LNG Development Corporation, LLC [d/b/a Oregon LNG] and 

CH2M HILL, 2014), shows the Terminal footprint and affected wetlands. 

2.1.2 Pipeline 

Impacts to wetlands associated with the Pipeline construction and operation were quantified based on the 

proposed activity in temporary construction and permanent operation zones. Planned construction and 

operation activities in wetlands are described in Section 2.3.3 and Table 5 of Resource Report 2; Appendix 

1 of Resource Report 1—General Project Description; and in Appendix 2B of Resource Report 2. Figure 1 

illustrates the construction and operation effects to wetlands by Cowardin class. Table 1 provides a 

summary of how wetland impacts associated with temporary and permanent easements and planned 

maintenance activities were determined. 

1 
WETLAND MITIGATION PLAN 

TABLE 1

Determination of Wetland Impacts Associated with Permanent and Temporary Easements and Planned Maintenance 

Activities 

75-foot Wetland Crossing Width 

50-foot-wide Permanent Easement 

25-foot-wide 

Construction Easement 

A B C D 

Easement 10-foot-wide mow strip 

centered over Pipeline 

Additional 20-foot-wide area 

(10 feet on each side of the 

mow strip) 

20-foot-wide area on 

outside boundary of 

easement (outer 10 feet of 

50-foot-wide permanent 

easement) 

25-foot-wide additional 

area needed for construction; 5 feet on one side 

and 20 feet on the other 

side of the 50-foot-wide 

permanent easement 

Frequency of 

Maintenance 

Activities 

Annual mowing Every 3 years, routine 

maintenance to cut trees 

over 15 feet tall 

No maintenance activity No maintenance activity 

Wetland Type Type of Wetland Impact Type of Wetland Impact Type of Wetland Impact Type of Wetland Impact 

PEM Temporary during 

construction 

Temporary during 

construction 

Temporary during 

construction 

Temporary during 

construction 

PSS Temporary wetland impacts 

during construction; 

permanent conversion of 

wetland type to PEM 

Temporary Temporary Temporary 

PFO Temporary wetland impact 

during construction; 

permanent conversion of 

wetland type to PEM 

Temporary wetland impact 

during construction; 

permanent conversion of 

wetland type to PEM or PSS 

Temporary impact during 

construction 

Temporary impact during 

construction 

PEM = Palustrine Emergent Wetland 

PFO = Palustrine Forested Wetland 

PSS = Palustrine Scrub-shrub 

When constructing the Pipeline through nonagricultural wetlands, soil excavation will occur at the Pipeline 

trench area, which will be about 10 feet wide, depending on the depth of the pipe. Temporary fill will occur 

next to the trench, where soil and plant materials from the trench will be stockpiled. Indirect soil 

disturbance, resulting in removal/fill, is expected to occur throughout the 75-foot-wide construction 

corridor from aboveground vegetation removal and mechanized land clearing, which could result in soil 

displacement. Following construction, wetlands will be rehabilitated to preconstruction soil and hydrology 

conditions, and revegetated. Operational vegetation maintenance activities will preclude forested wetlands 

in the 30-foot-wide maintenance corridor and the scrub-shrub wetlands from the 10-foot-wide corridor 

centered over the pipe. 

As a result of the operation activities, the following assessment of Project operational impacts can be made 

for the 50-foot-wide permanent easement: 

x Impacts to emergent wetlands within the 50-foot-wide permanent easement will be temporary.

x Impacts to scrub-shrub wetlands within the 50-foot-wide permanent easement will be temporary, with

the exception of the 10-foot-wide mow strip over the Pipeline. Scrub-shrub wetlands within the 10-footwide mow strip will retain their wetland hydrology and hydric soil, but the dominant vegetation will shift

to mostly herbaceous and trailing woody groundcover. Scrub-shrub wetlands outside the 10-foot-wide

mow strip but within the 30-foot-wide maintenance easement will be restored to scrub-shrub

vegetation. However, shrubs within the 30-foot-wide maintenance easement exceeding 15 feet in

2 
WETLAND MITIGATION PLAN 

height may be cut for Pipeline safety. Therefore, for purposes of determining impacts requiring 

compensatory mitigation, impacts to scrub-shrub wetlands within the 30-foot-wide maintenance 

easement will be considered permanent impacts requiring compensatory mitigation. 

x Impacts to forested wetlands within the 50-foot-wide permanent easement will be temporary with the

exception of a 30-foot-wide maintenance corridor over the Pipeline. Preconstruction forested wetlands

will retain their wetland hydrology and hydric soil, but the dominant vegetation will shift to mostly

herbaceous and trailing woody groundcover within the 10-foot-wide mow strip and to scrub-shrub

wetlands elsewhere in the 30-foot-wide maintenance corridor where trees exceeding 15 feet in height

may be cut for Pipeline safety. However, because of the temporal lag in restoring forested wetlands, for

purposes of determining impacts requiring compensatory mitigation, impacts to forested wetlands

within the 50-foot-wide permanent easement will be considered permanent impacts requiring

compensatory mitigation.

The following assessment of Project construction impacts can be made for the portions of the 75-foot-wide 

construction corridor outside the 50-foot-wide permanent easement: 

x Impacts to emergent wetlands within the 75-foot-wide construction easement outside of the 50-footwide permanent easement will be temporary.

x Impacts to scrub-shrub wetlands within the 75-foot-wide construction easement outside of the 50-footwide permanent easement will be temporary.

x Impacts to forested wetlands within the 75-foot-wide construction easement outside of the 50-footwide permanent easement will be temporary. However, because of the temporal lag in restoring

forested wetlands, for purposes of determining impacts requiring compensatory mitigation, impacts to

forested wetlands within the 75-foot-wide construction easement will be considered permanent

impacts requiring compensatory mitigation.

2.2 Results 

For the Terminal and associated facilities, wetland impacts are categorized as temporary (as a result of 

construction-related activities) or permanent (as a result of removal/fill associated with construction of 

the Terminal and associated facilities). Table 2 shows the wetland impacts associated with the Terminal 

and associated facilities by watershed subbasin (4th-field HUC) and by HGM and Cowardin wetland class. 

For the Pipeline mainline and associated aboveground facilities, the Project’s impacts to wetlands were 

determined using the method described in Section 2.1.2. Impacts were categorized as temporary wetland 

impacts or permanent Cowardin class changes. Temporary wetland impacts include impacts to wetlands 

within the 75-foot-wide construction corridor as a result of construction and operation of the Project. 

Permanent Cowardin class changes include impacts to forested or scrub-shrub wetlands within the 10-footwide and 30-foot-wide prescribed maintenance zones shown on Figure 1. 

Table 3 presents a summary of temporary impacts for the Pipeline and ancillary facilities by watershed 

subbasin (4th-field HUC) and by HGM and Cowardin wetland class. Table 4 presents a summary of 

permanent Cowardin class changes for the Pipeline and ancillary facilities by watershed subbasin (4th-field 

HUC) and by HGM and Cowardin wetland class. 

3 
WETLAND MITIGATION PLAN 

TABLE 2

Terminal and Ancillary Facilities —Temporary and Permanent Wetland Impacts (acres) 

4th-field HUC HGM Impact Type E2EM PEM PSS PFO Grand Total 

Lower Columbia Estuarine Fringe Permanent 28.04 0.01 28.05 

Temporary 1.31 0.01 1.32 

Estuarine Fringe Total 29.35 0.02 0.00 0.00 29.37 

Depressional Permanent 0.03 1.42 4.21 0.16 5.82 

Temporary 0.00 1.42 0.15 0.00 1.57 

Depressional Total 0.03 2.84 4.36 0.16 7.39 

TBD Permanent 1.05 1.05 

Temporary 0.25 0.01 0.27 

TBD Total 0.00 0.25 0.01 1.05 1.31 

Terminal Total 29.38 3.12 4.37 1.21 38.08 

Note: Includes Terminal access road and water/wastewater pipelines. 

E2EM = Estuarine Intertidal Emergent 

HGM = hydrogeomorphic 

HUC = hydrologic unit code 

PEM = Palustrine Emergent Wetland 

PFO = Palustrine Forested Wetland 

PSS = Palustrine Scrub-shrub 

TBD = to be determined. Proxy wetland data were used for sites where access was not provided. Hydrogeomorphic class could 

not be determined. Before construction, these wetland areas will be delineated and the HGM class will be determined. 

TABLE 3

Pipeline and Ancillary Facilities—Temporary Wetland Impacts (acres) 

4th-field HUC HGM AW E2USN PEM PSS Grand Total 

Lower Columbia Depressional 1.61 5.92 1.85 9.38 

Estuarine Fringe 5.06 5.06 

Flats 0.81 0.07 0.87 

Riverine 0.79 0.79 

Slope 0.60 0.32 0.91 

TBD 30.20 11.03 3.40 44.63 

Lower Columbia Total 31.81 5.06 19.14 5.64 61.65 

Nehalem Depressional 1.25 0.46 1.71 

Flats 0.04 0.04 

Riverine 1.02 0.01 1.04 

Slope 2.17 2.17 

TBD 2.73 0.16 0.25 3.14 

Nehalem Total 2.73 4.65 0.72 8.09 

Lower Willamette Depressional 0.12 0.12 

Lower Willamette Total 0.12 0.12 

Lower Columbia-Clatskanie Depressional 0.02 0.02 

Riverine 0.02 0.16 0.18 

Slope 0.33 0.68 1.01 

TBD 13.13 13.13 

Lower Columbia-Clatskanie Total 13.50 0.84 14.33 

4 
WETLAND MITIGATION PLAN 

TABLE 3

Pipeline and Ancillary Facilities—Temporary Wetland Impacts (acres) 

4th-field HUC HGM AW E2USN PEM PSS Grand Total 

Lewis TBD 0.18 0.18 

Lewis Total 0.18 0.18 

Pipeline Total 34.54 5.06 37.47 7.30 84.37 

Note: Includes compressor stations, pipe yards, and access roads. 

AW = Agricultural Wetland 

E2USN = Estuarine Intertidal Unknown Temporary Tidal Regular 

HGM = hydrogeomorphic 

HUC = hydrologic unit code 

PEM = Palustrine Emergent Wetland 

PSS = Palustrine Scrub-shrub 

TBD = to be determined. Proxy wetland data were used for sites where access was not provided. Hydrogeomorphic class 

could not be determined. Before construction, these wetland areas will be delineated and the HGM class will be 

determined. 

TABLE 4

Pipeline and Ancillary Facilities—Permanent Wetland Impacts (acres) 

4th-field HUC HGM PFO PSS PSS/PFO Grand Total 

Lower Columbia Depressional 1.00 1.00 

Flats 0.34 0.04 0.38 

Riverine 0.66 0.66 

Slope 0.49 0.24 0.73 

TBD 2.79 1.35 4.14 

Lower Columbia Total 4.28 2.63 6.91 

Nehalem Depressional 0.29 0.37 0.66 

Riverine 0.91 0.91 

Slope 1.45 1.45 

TBD 0.20 0.18 6.41 6.79 

Nehalem Total 2.85 0.55 6.41 9.82 

Lower Willamette Depressional 0.34 0.07 0.42 

Riverine 0.89 0.89 

Lower Willamette Total 1.24 0.07 1.31 

Lower Columbia-Clatskanie Riverine 0.98 0.16 1.14 

Slope 0.33 0.23 0.55 

TBD 2.96 2.96 

Lower Columbia-Clatskanie Total 4.27 0.39 4.66 

Pipeline Total 12.64 3.64 6.41 22.70 

Note: No impacts to wetlands in pipe yards. 

Cowardin = Cowardin et al., 1979 

HGM = hydrogeomorphic 

HUC = hydrologic unit code 

PFO = Palustrine Forested Wetland 

PSS = Palustrine Scrub-shrub 

TBD = to be determined. Proxy wetland data were used for sites where access was not provided. Hydrogeomorphic class could 

not be determined. Before construction, these wetland areas will be delineated and the HGM class will be determined. 

5 
WETLAND MITIGATION PLAN 

Chapter 3—Mitigation 

3.1 Introduction 

This chapter lays out the approach to wetland mitigation based on the determination of impacts in 

Chapter 2. The approach to mitigation follows the U.S. Army Corps of Engineers (USACE) and Oregon 

Department of State Lands (DSL) rules and guidance with the goal of no net loss of wetland functions and 

values. The approach follows the USACE and DSL mitigation sequencing and, where compensation is 

required, uses a watershed approach to select available resource replacement sites that offer the greatest 

functional benefits. 

3.2 Avoidance 

The wetland delineation report submitted to DSL (Appendix 2E) shows the wetlands identified in the Project 

study area. The Project will avoid most wetlands in the study area. Temporary and permanent impacts for 

the Terminal and Pipeline total approximately 145 acres of wetlands identified in the study area, which 

covers more than 2,700 acres. During several design iterations, the Pipeline alignment and temporary 

workspaces were shifted away from wetlands and other waters, where possible, reducing the acreage of 

impact. In addition, during construction, wetlands outside of the construction corridor will be demarcated in 

the field and identified on work plans as “no work zones” to avoid additional wetland impacts. 

Site visits were conducted with state and federal agency staff to view stream crossings identified as areas of 

concern during preliminary agency reviews. Micrositing adjustments were made to avoid or minimize 

impacts to wetlands or streams. For example, in a location where the pipeline was proposed to cross a 

beaver marsh on the Clatskanie River, the route was relocated to avoid the wetland and limit impacts to a 

narrow stream crossing.

Large wetland areas will be avoided using the horizontal directional drill (HDD) construction method. More 

than 24 acres of wetlands associated with the Adairs Slough and the Lewis and Clark River area will be 

avoided using the HDD drilling method. Further avoidance efforts are demonstrated with the type of access 

road the Project proposes to use. Access to the temporary and permanent Pipeline easement and 

aboveground facilities will be through existing public and private roads to the extent practical. Where the 

Pipeline parallels existing utilities, Oregon LNG will use the utility maintenance access roads to the extent 

practical. Oregon LNG will also use a combination of existing paved, existing gravel, modified gravel, pasture 

roads, and other conveyances as appropriate. 

Construction measures will be implemented to avoid impacts to wetlands along the Pipeline route. The 

width of the construction corridor will be narrowed from 100 to 75 feet across nonagricultural wetlands. 

HDDs beneath streams and adjacent wetlands will also avoid impacts to wetlands and waterbodies. 

3.3 Minimization 

Efforts will be made before, during, and after Pipeline construction to minimize the extent and duration of 

Project-related disturbances to wetland resources. For example, Oregon LNG will segregate and salvage the 

top 1 foot of topsoil from nonsaturated wetland areas to be disturbed by trenching (generally coincident 

with the 10-foot-wide mow strip maintained during operation) and replace the topsoil at the finish grade 

after trench reconstruction. The duration of temporary wetland disturbance during Pipeline construction 

will be minimized. The backfilled trench will contain anti-seep plugs at appropriate intervals to prevent a 

French drain effect. A detailed description of other measures to minimize construction and postconstruction maintenance effects on wetlands is provided in Appendix 2B, FERC Wetland and Waterbody 

Construction and Mitigation Procedures, Modified by Oregon LNG, Section VI. 

Temporal disturbance to streams will be minimized by limiting in-water work at crossings to 48 hours or less 

and application of best management practices (see Appendix 2H, Stormwater Pollution Prevention Plan for 

6 
WETLAND MITIGATION PLAN 

Construction of the Oregon LNG Pipeline, Including Erosion Prevention and Sediment Control Plan; Spill 

Prevention, Control, and Countermeasures Plan; and Frac-out Contingency Plan). 

Techniques for modifying the Pipeline alignment to minimize wetland impacts include the following: 

x HDD methods will be used to install the Pipeline many feet below the surface of wetlands and streams.

x The Pipeline will be aligned parallel or with existing road right-of-way (ROW) utility corridors, or

previously disturbed areas.

x The Pipeline will be aligned so that wetlands are crossed at their narrowest point, when possible.

x The Pipeline will be aligned so that streams are crossed at a right angle to their banks to minimize

negative impacts to riparian areas and streambeds.

x The width of the Pipeline ROW will be reduced to 75 feet when crossing nonagricultural wetlands to

minimize the area of disturbance.

x TWS will be located in areas outside of wetlands to minimize the number of acres of disturbance.

In selecting the proposed route, Oregon LNG sought to minimize impacts to the environment and 

landowners by paralleling other linear features to the greatest extent possible or practical. Minimizing 

impacts to wetlands did have limitations due to rugged topography, high densities of wetland areas, and a 

preference to avoid high-quality wetland areas and streams. In areas where a high density of wetlands 

existed, the Pipeline was aligned in a way that minimized impacts to most wetlands. The Pipeline route was 

sometimes aligned to cross wetlands with low functional assessment values to avoid wetlands with higher 

values. If the Pipeline could be microsited to avoid every wetland, the overall length of the Pipeline and 

period of active construction would increase, which could result in more permanent impacts to the 

landscape and longer periods of temporary disturbance and active construction along the Pipeline route. 

3.4 Compensation 

For the Project, the approach to compensatory mitigation follows the USACE and U.S. Environmental 

Protection Agency (EPA) Wetland Compensatory Mitigation Rule (March 2008) and DSL guidance 

emphasizing a watershed-level approach to compensation. Previous EPA and USACE guidance favored 

mitigation in proximity of impacts, but the Wetland Compensatory Mitigation Rule lists this hierarchy of 

mitigation preferences: (1) mitigation banks, (2) in-lieu fee programs, and (3) permittee-responsible 

mitigation (in the event neither of the previous two options is practicable). Compensatory mitigation should 

be directed to restoring impaired functions in a watershed context. 

Oregon LNG proposes a three-pronged approach to compensatory mitigation for Pipeline impacts consisting 

of: (1) rehabilitation of wetlands temporarily impacted by construction in situ, (2) purchase of mitigation 

credits from wetland mitigation banks (if available) or in-lieu fee programs, and (3) replacement of lost 

wetland functions through wetland restoration, creation, or enhancement. These three compensatory 

mitigation approaches are described in more detail subsequently. Under each of the approaches described 

below, in-kind replacement of affected wetlands (that is, Palustrine Emergent [PEM], Palustrine Scrub-shrub 

[PSS], and Palustrine Forested Wetland [PFO]) will be proposed where feasible). Out-of-kind compensatory 

mitigation may be justified where there have been significant losses of a particular Cowardin (Cowardin 

et al., 1979) classification or function within a watershed (for example, loss of estuarine floodplain as a 

result of diking or loss of marsh habitat along streams as a result of depleted populations of beavers). 

Depending on the functions being replaced, out-of-kind mitigation may be a viable compensatory mitigation 

strategy, especially when, for a given watershed, there are important goals for recovery of other aquatic 

functions or habitat for important species. 

Final plans will be provided to the Federal Energy Regulatory Commission (FERC) following final filing. 

7 
WETLAND MITIGATION PLAN 

3.4.1 Terminal 

Offsite Compensatory Wetland Mitigation for Temporary and Permanent Impacts. For the Terminal, 

3.16 acres of temporary and approximately 34.92 acres of permanent impacts will occur as a result of 

Terminal and ancillary facilities construction. 

Between 1870 and 1983, the area of tidal swamps and marshes in the Columbia River estuary was reduced 

by 35 percent. Within Youngs Bay, by 1983, tidal swamps and marshes were reduced to about 11 percent of 

their former area in 1879 (Thomas, 1983). The reduction of swamp and marsh habitat around Youngs Bay 

was primarily the result of diking. 

Oregon LNG secured 120 acres at the mouth of the Youngs River on the west bank for Terminal wetland 

mitigation (Figure 2). The mitigation site is a portion of the historical tidal swamp and marsh that was lost to 

diking. The riverside parcel is currently used for grazing and protected from flooding by a levee. Oregon LNG 

intends to breach the levee to create estuarine wetland habitat and provide access for federally listed 

salmonids and other aquatic species. Salmonid and other fish habitat at this strategic site at the mouth of 

the Youngs River will be enhanced by restoring meandering historical channels within the property. To 

ensure that juvenile salmonids can utilize newly created marsh habitat during low tide conditions, Oregon 

LNG will create breaches in areas that facilitate connection to existing subtidal habitat in Youngs Bay. 

Hydrodynamic modeling conducted by Coast and Harbor Engineering (2011) showed that breaching the dike 

in two or three locations will reconnect the historical floodplain with the tidal estuary, providing in-kind 

mitigation for wetland impacts at the Terminal. To protect inland residents, the existing dike will be 

modified to encompass the 120-acre mitigation site. Hydrodynamic modeling suggests that after resumption 

of more natural tidal regimes, the property will establish as low marsh. After native freshwater marsh plants 

have recolonized the property, the marsh is expected to provide productive new rearing habitat for juvenile 

salmon that use Youngs Bay, and possibly for green sturgeon prey. 

The area is large enough to provide mitigation for wetland impacts at the Terminal at a 3:1 ratio (in 

accordance with Oregon Administrative Rule 141-085-0690[4][C]) and for other wetland impacts in the 

Lower Columbia 4th-field HUC. 

A legal instrument is in place for Oregon LNG to use the property at the mouth of the Youngs River on the 

west bank for mitigation, including an agreement for a long-term conservation easement as a condition of a 

deed. Provisions are in place for supporting long-term maintenance and management, including a revolving 

or endowment fund. Oregon LNG will prepare a long-term management plan to be implemented by a thirdparty conservator. 

Mitigation Goals and Objectives. Mitigation goals include the following: 

x Reconnect 120 acres of historical floodplain with the Columbia River estuary.

x Create a low-maintenance and self-sustaining system.

x Assure that the safety of landowners behind the dike is maintained.

Mitigation objectives include the following: 

x Restore a minimum of 2,600 feet (approximately 0.5 mile) of side-channels or sloughs.

x Achieve 100 percent inundation during high tides.

x Restore emergent and forest habitat dominated by a diversity of native plants

Temporary impact areas will be rehabilitated onsite after construction. Rehabilitation initially involves 

seedbed preparation and control of noxious weeds. Some vegetation will regenerate naturally from the 

seedbank and vegetative propagules. Supplemental propagules of water parsley (Oenanthe sarmentosa), 

Pacific silverweed (Argentina egedii), and Lyngby’s sedge (Carex lyngbyei) will be planted in the late winter, 

as needed, to rehabilitate temporary impacts to wetlands at the Terminal. If shoreline monitoring 

determines that potentially damaging erosion is occurring, and that stabilization measures will reduce 

8 
WETLAND MITIGATION PLAN 

erosion potential, appropriate measures pursuant to federal and state permits will be implemented. Soft 

armoring techniques will be emphasized, such as vegetation and brush layering. 

3.4.2 Pipeline 

Temporary Impacts. Compensation for temporary impacts to wetlands as a result of Pipeline construction 

will be mitigated through onsite wetland rehabilitation. To the extent feasible, rehabilitation of the Pipeline 

construction corridors to preconstruction wetland conditions will be undertaken. This will involve topsoil 

segregation and replacement, topsoil management to maintain viability of seedbank and vegetative 

propagules, reconstruction of grades, permanent erosion control seeding with native wetland species, and 

seedbed preparation where soils are displaced or compacted by equipment. This mitigation measure is 

appropriate for approximately 84.37 acres of temporary Pipeline impacts shown in Table 3. Figures 3 

through 8 show typical wetland restoration for Palustrine Emergent, Palustrine Scrub-shrub, and Palustrine 

Forest/Palustrine Emergent wetlands within the Lower Columbia Watershed and the Nehalem Watershed. 

The wetland areas temporarily impacted by vegetation clearing, equipment traffic, and material storage 

outside the trench area will be rehabilitated by reestablishing wetland vegetation from seedbank 

germination and vegetative propagation via resprouting of live roots and propagules left intact and 

protected during construction. Sterile wheat grass cover will be used to temporarily stabilize soil until 

natural germination occurs. In some instances, a permanent native wetland seed mix will be applied to 

ensure adequate cover of the site by desirable species. If annual monitoring during the 3 years after 

construction indicates that disturbed areas are not successfully revegetating with wetland herbaceous or 

woody plants similar to preconstruction conditions, supplemental seeding or planting will be undertaken. 

Woody species will resemble local reference conditions. Measures will be taken to control the spread of 

noxious weeds. 

For natural regeneration of temporarily cleared forested wetlands outside the 30-foot-wide maintenance 

corridor, the following actions will be taken: 

x To reduce injury to viable roots and shoots, construction traffic will be managed to reduce areas

affected by soil compaction and rutting; supported by mats, pallets, or other ground pressure dissipaters

in moist or wet soils; and characterized by low-ground pressure equipment where terrain allows.

x Woody debris, chipped woody vegetation, and unmerchantable logs greater than 12 inches in diameter

will be salvaged for surface application outside the 30-foot-wide maintenance corridor where existing

downed wood is insufficient.

x Sterile wheatgrass will be used for temporary erosion control seeding to avoid conflicts with the

permanent cover.

x Where compatible with preconstruction woody species, seeds of native woody wetland species will be

incorporated into permanent erosion control seed mixes.

x If annual monitoring during the 3 years after construction indicates that disturbed wetland areas are not

successfully revegetating with desirable woody plants, supplemental planting will be undertaken.

Permanent Impacts. Permanent Cowardin class changes from shrub wetland to herbaceous wetland and 

forested wetland to herbaceous or shrub wetland will occur as a result of Pipeline construction and 

maintenance. PFO and PSS wetlands will be restored in situ to the greatest extent possible. However, 

compensatory mitigation will be provided to compensate for the temporal loss of wetland functions. 

Compensation for 22.70 acres of permanent Cowardin class changes will be mitigated with offsite wetland 

mitigation and 4.66 acres is proposed for compensation with an in-lieu program. 

9 
WETLAND MITIGATION PLAN 

Compensation for 6.91 acres of permanent Cowardin class changes in the Lower Columbia watershed will be 

mitigation through offsite, in-kind mitigation using the property at the mouth of the Youngs River on the 

west bank. The mitigation site is discussed in Section 3.4.1. 

Compensation for 11.13 acres of permanent Cowardin class changes in the Nehalem, and Lower Willamette 

watershed will be mitigation through offsite, in-kind mitigation at the Nehalem River mitigation site. 

Compensation for 4.66 acres of permanent Cowardin class in the Lower Columbia-Clatskanie watershed will 

be compensation with an approved in-lieu fee program will be the primary method to compensate for 

wetland impacts in Lower Columbia/Clatskanie watershed. Compensatory wetland mitigation plans are 

discussed below. 

Offsite Wetland Mitigation for Permanent Cowardin Class Changes. To offset unavoidable permanent 

Cowardin class changes to approximately 11.13 acres of wetlands associated with the Pipeline segments in 

the Nehalem and Lower Willamette River basin, Oregon LNG is working with property owners to restore, 

create, and enhance approximately 75 acres of wetland habitat in the floodplain at a site adjacent to the 

Nehalem River in the Nehalem subbasin (Figure 2). The property contains a large remnant river oxbow with 

an outlet to the Nehalem River. Much of the property consists of a monoculture of reed canary grass and is 

used for grazing cattle. A ratio of 1:1 restoration, 3:1 for enhancement, and 1:5:1 of wetland creation is 

proposed. 

This mitigation site provides conservation opportunities aligned with the strategy goals for the Coast Range 

and Willamette Valley ecoregions documented in The Oregon Conservation Strategy (Oregon Department of 

Fish and Wildlife [ODFW], 2008). The location of the proposed mitigation site is unique in that plant 

assemblages observed onsite are found in both the western Willamette Valley and the foothills of the 

eastern side of the Coast Range. The site contains forested communities that may be the most western 

outliers for their distribution range. A number of the communities identified onsite are listed by the Oregon 

Biodiversity Information Center as G2S2 or “imperiled because of rarity with 6-20 occurrences or few 

remaining acres both globally and within the state” (Kagan et al., 2004). 

Mitigation objectives for the site include the following: 

x Floodplain enhancement and forest restoration. The floodplain is mowed and grazed annually.

Mitigation would create additional wetlands within the floodplain, which would retain floodwater and

slow the velocity of the water flowing back into the river as floodwaters recede. Floodplain forest would

be restored by replanting native species. Mitigation objectives are to expand and restore the floodplain

forest and scrub-shrub communities.

x Salmon restoration and enhancement. Ecological goals include increasing the quantity and quality of

off-channel juvenile salmonid habitat for Nehalem River salmonid populations. The Nehalem River is a

major river in the northern Coast Range that flows into the Pacific Ocean at the Nehalem Bay estuary.

The river provides habitat for spring and fall run Chinook salmon, coho salmon, and winter steelhead

(StreamNet, 2013). Salmon fry access the site via the remnant oxbow tributary during annual freshets

and become entrapped within the reed canary grass. Mitigation objectives include the establishment of

slow-water salmonid refugia that contains high-quality habitat. Site modifications would restore

necessary contours and reestablish native vegetation.

x Wildlife habitat and plant species expansion. Mitigation objectives are to increase PFO and PSS wetland

habitat through wetland restoration, creations, and enhancement; increase the variety of plant species

and communities; and increase structural diversity within the existing communities.

In-lieu Fee Programs for Permanent Impacts. There are no known mitigation banks with forested wetland 

components located in the Lower Columbia/Clatskanie subbasins. Compensatory mitigation for these 

impacts would occur through in-lieu fee programs. Oregon LNG will coordinate with local watershed 

councils to implement mitigation at multiple sites. Mitigation will focus on rehabilitating impaired functions 

10 
WETLAND MITIGATION PLAN 

within watersheds that will improve fish and wildlife habitat. Sites with the following characteristics will be 

identified for wetland mitigation: floodplain habitat where native plant diversity has been lost as a result of 

invasion of non-native species; riparian areas that no longer function as wetlands because they were 

drained by down-cutting of stream beds; locations where stream sinuosity can be restored to enhance 

riparian wetlands; and locations where beaver-like marshes can be restored. 

Once potential appropriate sites are identified, negotiations with the respective landowners will commence, 

followed by: site data collection; draft mitigation site design; DSL, USACE, and EPA coordination and review; 

and final mitigation site design. Detailed mitigation planning will progress during agency and public review 

processes and will be completed prior to issuance of removal-fill permits, in keeping with the permit 

processing. 

Chapter 4—References 

Coast and Harbor Engineering. 2011. Youngs River Mitigation Site Hydraulic Technical Analysis. Prepared for 

Oregon LNG. 

Cowardin, Lewis M., Virginia Carter, Francis C. Golet, and Edward T. LaRoe. 1979. Classification of Wetlands 

and Deepwater Habitats of the United States. FWS./OBS-79/31. December 1979. 

Kagan, J.S., J. A. Christy, M. P. Murray, and J. A. Titus. 2004. Classification of Native Vegetation of Oregon. 

Oregon Natural Heritage Program. January 2004. 

LNG Development Corporation, LLC (d/b/a Oregon LNG) and CH2M HILL. 2014. Supplement to June 7, 2013, 

Amendment to Application for Authorization Under Section 3(a) of the Natural Gas Act to Site, 

Construct, and Operate Liquefied Natural Gas Facilities—Proposed Terminal Modifications. Filed with 

the Federal Energy Regulatory Commission on April 3, 2014. 

Oregon Department of Fish and Wildlife (ODFW). 2008. The Oregon Conservation Strategy. Oregon 

Department of Fish and Wildlife, Salem, Oregon. February 2008. 

StreamNet. 2013. Fish Distribution Map Information. http://map.streamnet.org/. Accessed September 2013. 

Thomas, D.W. 1983. Changes in the Columbia River Estuary Habitat Types Over the Past Century. Columbia 

River Estuary Data Development Program, Columbia River Estuary Study Taskforce. Astoria, Oregon. 

U.S. Army Corps of Engineers (USACE) and U.S. Environmental Protection Agency (EPA). 2008. Compensatory 

Mitigation for Losses of Aquatic Resources; Final Rule. 73 Federal Register 19594. March 28, 2008. 

11 
Figures 
Figures 

1 Typical Wetland Crossing Impacts 

2 Wetland Mitigation Sites 

3 Lower Columbia Watershed Palustrine Emergent Wetland Restoration—Typical 

4 Lower Columbia Watershed Palustrine Scrub-Shrub Wetland Restoration—Typical 

5 Lower Columbia Watershed Palustrine Forest/Palustrine Emergent Wetland Restoration—Typical 

6 Nehalem Watershed Palustrine Emergent Wetland Restoration—Typical 

2 Nehalem Watershed Palustrine Scrub-Shrub Wetland Restoration—Typical 

2 Nehalem Watershed Palustrine Forest/Palustrine Emergent Wetland Restoration—Typical 

FIGURE 1

Typical Wetland Crossing Impacts

NOT TO SCALE

36-in gas pipeline

10 ft 10 ft 5 ft 5 ft 10 ft 10 ft 5 ft 20 ft

No Maintenance

Construction Only

 15 ft

No Maintenance

Construction Only

 30 ft

Maintained on 3-year cycle. 

Trees exceeding 15 feet may be cut.

Temporary Impact to 

All Wetland Types

Temporary Impact to 

All Wetland Types

D A BC D C B

Letters correspond to the columns in Resource Report 2, in 2P-1 only.

D C B A

Permanent Class Change

of PFO to PEM/PSS

30-ft Maintained Easement

Mow Strip

Annual

Maintenance

Temporary Impact to PEM

Temporary Impact to PSS

Permanent Class Change

of PSS to PEM

75-ft Construction Easement

50-ft Permanent Easement
*#

D

D

D

D

D

^_

^_

CLATSOP CO.

COLUMBIA CO.

TILLAMOOK CO.

WASHINGTON CO.

PACIFIC CO. WAHKIAKUM CO.

Astoria

Cannon

Beach

Gearhart

Manzanita Nehalem

Seaside

Warrenton

Wheeler

Chinook

Cathlamet

East

Cathlamet

UV104

UV409

UV202

UV407

UV4

UV401

UV103

UV53

40

30

20

10

0

£¤26

£¤30

£¤101

§ ̈¦105

LEGEND

Pipeline Route

D Pipeline Route Milepost (Ten Mile)

*# Terminal Location

^_ Terminal Mitigation Site

^_ Pipeline Mitigation Site

Major Road

Rivers, Lakes, and Ocean

City

County Boundary

 ́

024

Miles

Figure 2

Wetland Mitigation Sites

Clatsop

Columbia

Tillamook Washington

Multnomah

Pacific

Lewis

Wahkiakum

Clark

Cowlitz

OREGON

WASHINGTON
Palustrine Emergent Wetland (PEM)

SEED MIX #1 SEED MIX FOR COASTAL LOWLANDS — NON-AGRICULTURAL

Common Name Scientific Name Form* Pounds per Acre

Per Live Seed (PLS)

Pacific Reedgrass Calamagrostis 

nutkaensis

Seed 8

Seaside Arrow 

Grass

Triglochin maritima Seed 8

Fowl Bluegrass Poa palustris Seed 8

Tufted Hairgrass Deschampsia 

caespitosa var. artica

Seed 2

Red Fescue Festuca rubra Seed 8

Lyngby’s Sedge Carex Lyngbyei Seed 10

Baltic Rush

* Substitution of species or substitution of plugs for seeds may be made, depending on

availability and approval by Permitting Agency.

* Substitution of species or substitution of plugs for seeds may be made, depending on

availability and approval by Permitting Agency.

Juncus articus var. 

baticus

Seed 10

SEED MIX #2 SEED MIX FOR COASTAL FOOTHILLS — NON-AGRICULTURAL

Common Name Scientific Name Form* Pounds per Acre

Per Live Seed (PLS)

Red Fescue Festuca rubra Seed 8

Colonial Bentgrass Agrostis capillaris Seed 8

Slender Hairgrass Deschampsia 

elongata

Seed 2

Slough Sedge Carex obnupta Seed 10

Small-fruited 

Bulrush

Scirpus microcarpus Seed 10

Sickle-leaved Rush Juncus ensfolius Seed 10

POTENTIAL WETLAND CROSSING

Lower Columbia Watershed (4th HUC)

FIGURE 

Lower Columbia Watershed

Palustrine Emergent Wetland Restoration - Typical

OREGON PIPELINE PROJECT Pipeline 10 Feet Easement Remaining Easement Remaining 

Pipeline

CL

Clearing Limits

 75 - 100 feet
SCRUB-SHRUB WETLAND COMMUNITY - SHRUBS, HERBS

Common Name Scientific Name Form*

Hooker Willow Salix hookeriana Live stake 8’ o.c. 

(4 stakes/hole)

Douglas Spiraea Spiraea douglasi 1 gal 6’ o.c.

Cluster of 9

POTENTIAL WETLAND CROSSING

Lower Columbia Watershed (4th HUC)

Palustrine Scrub-Shrub (PSS) 

Conversion to Palustrine Emergent Wetland (PEM)

* Substitution of species or substitution of plugs for seeds may be made, depending on

availability and approval by Permitting Agency.

Wetland Seed Mix #1 for Coastal Lowland/ Wetland Seed Mix #2 for Coastal Foothills

FIGURE 

Lower Columbia Watershed

Palustrine Scrub-Shrub Wetland Restoration - Typical

OREGON PIPELINE PROJECT Pipeline 10 Feet Easement Remaining Easement Remaining 

Pipeline

CL

Clearing Limits

 75 - 100 feet

Spacing

(on center)
POTENTIAL WETLAND CROSSING

Lower Columbia Watershed (4th HUC)

SEED MIX #1 FOREST WETLAND COMMUNITY - FOREST, HERBS

Common Name Scientific Name Form*

Red Alder Alnus Rubra 2 gal 10’ o.c.

Western Red Cedar Thuja plicata 2 gal 15’ o.c.

Sitka Spruce Picea sitchens 2 gal 20’ o.c.

* Substitution of species or substitution of plugs for seeds may be made, depending on

availability and approval by Permitting Agency.

Wetland Seed Mix #1 for Coastal Lowland/ Wetland Seed Mix #2 for Coastal Foothills

Spacing

(on center)

FIGURE 

Lower Columbia Watershed

Palustrine Forest/Palustrine Emergent 

Wetland Restoration - Typical

OREGON PIPELINE PROJECT Pipeline 10 Feet Easement Remaining Easement Remaining 

Pipeline

CL

Clearing Limits

 75 feet

Palustrine Forest Wetlands (PFO)

Conversion to Palustrine Emergent Wetland (PEM)
Palustrine Emergent Wetland (PEM)

WETLAND SEED MIX #3

Common Name Scientific Name Form* Pounds per Acre

Per Live Seed (PLS)

Red Fescue Festuca rubra Seed 8

Colonial Bentgrass Agrostis capillaris Seed 8

Slender Hairgrass Deschampsia 

elongata

Seed 2

Slough Sedge Carex obnupta Seed 10

Small-fruited 

Bulrush

Scirpus microcarpus Seed 10

Sickle-leaved Rush Juncus ensfolius Seed 10

POTENTIAL WETLAND CROSSING

Nehalem Watershed (4th HUC)

Lower Columbia/Clatskanie

Lower Willamette Watershed

* Substitution of species or substitution of plugs for seeds may be made, depending on

availability and approval by Permitting Agency.

Pipeline

10 Feet

Easement

Remaining 

Easement

Remaining 

Pipeline

CL

Clearing Limits

 75 - 100 feet

FIGURE 

Nehalem Watershed

Palustrine Emergent Wetland Restoration - Typical

OREGON PIPELINE PROJECT
SCRUB-SHRUB WETLAND COMMUNITY - SHRUBS, HERBS

Common Name Scientific Name Form*

Red-osier 

Dogwood

Cornus stolonifera 8-ft o.c.

Cluster of 10

Salmonberry

Wetland Seed Mix #3

Rubus spectabilis 1 gal

1 gal

6-ft o.c.

Cluster of 12

POTENTIAL WETLAND CROSSING

Nehalem Watershed (4th HUC)

Lower Columbia/Clatskanie

Lower Willamette Watershed

* Substitution of species or substitution of plugs for seeds may be made, depending on

availability and approval by Permitting Agency.

FIGURE 

Nehalem Watershed

Palustrine Scrub-Shrub Wetland Restoration - Typical

OREGON PIPELINE PROJECT Pipeline 10 Feet Easement Remaining Easement Remaining 

Pipeline

CL

Clearing Limits

 75 - 100 feet

Spacing

(on center)

Palustrine Scrub-Shrub (PSS) 

Conversion to Palustrine Emergent Wetland (PEM)
FOREST WETLAND COMMUNITY - FOREST, HERBS

Common Name Scientific Name Form*

Red Alder Alnus rubra 2 gal 10’ o.c.

Western Red Cedar Thuja plicata 2 gal 15’ o.c.

Sitka Spruce

Wetland Seed Mix #3

Picea sitchens 2 gal 10’ o.c.

POTENTIAL WETLAND CROSSING

Nehalem Watershed (4th HUC)

Lower Columbia/Clatskanie

Lower Willamette Watershed

* Substitution of species or substitution of plugs for seeds may be made, depending on

availability and approval by Permitting Agency.

FIGURE 

Nehalem Watershed

Palustrine Forest/Palustrine Emergent 

Wetland Restoration - Typical

OREGON PIPELINE PROJECT Pipeline 10 Feet Easement Remaining Easement Remaining 

Pipeline

CL

Clearing Limits

 75 feet

Palustrine Forest Wetland (PFO)

Palustrine Emergent (PEM)

Spacing

(on center)
APPENDIX F5 

TECHNICAL MEMORANDUM: OREGON LNG PIPELINE WATERBODY 

CROSSING—FISH SALVAGE PLAN

ES030613113935PDX 1 

TECHNICAL MEMORANDUM 

Oregon LNG Pipeline Waterbody Crossing: Fish Salvage Plan 

PREPARED FOR: Oregon LNG—Resource Report 3

COPY TO: Jay Lorenz/CH2M HILL

PREPARED BY: Greg White/CH2M HILL

DATE: May 21, 2013

Introduction 

The construction of the proposed Oregon LNG Pipeline from the Terminal at Warrenton to existing infrastructure

near Woodland, Washington, will cross approximately 235 freshwater systems. Crossing methods that require

in‐water activities and dry crossing methods may require fish salvage activities. This technical memorandum

describes the crossing methods that will potentially involve fish salvage activities, as well as the measures that will

be implemented to conduct fish salvage activities where required.

Waterbody Crossing Methods 

In part, the waterbody type, width, fish species usage, geography, and engineering feasibility will determine the

crossing method employed. Potential crossing methods include Dam‐and‐Pump, Open‐cut, Flume, and Horizontal

Directional Drilling (HDD). Intermittent and ephemeral waterbodies will likely be dry during the crossing

construction period and, therefore, fish will not be present. These waterbodies will be crossed using the Open‐cut

method and will not require fish salvage. However, if water is present at the time of construction, the presence of

fish will be determined before construction below the ordinary high water elevation. If fish are present, fish

salvage activities will be conducted prior to construction activities.

Waterbody crossings that employ HDD will not require fish salvage activities because no in‐water activities will

occur. The only waterbody crossing methods that will require potential fish salvage are those that isolate the

construction area from the actively flowing waterbody, thereby dewatering a portion of the waterbody and

potentially stranding fish. HDD and de‐watered waterbodies are called “dry construction” methods. The dry

construction methods that would require potential fish salvage activities are the Dam‐and‐Pump and Flume

crossing methods.

Dam-and-Pump Crossing Method 

The Dam‐and‐Pump crossing method may be used without prior approval for crossings of waterbodies where

pumps can adequately transfer streamflow volumes around the work area, and where there are no concerns

regarding fish passage. The Dam‐and‐Pump crossing method was considered. However, it is not proposed in this

filing. If it is used, implementation of the Dam‐and‐Pump crossing method will meet the following performance

criteria:

 Use sufficient pumps, including onsite backup pumps, to maintain downstream flows.

 Construct dams with materials that prevent sediment and other pollutants from entering the waterbody (for

example, sandbags or clean gravel with plastic liner).

 Screen pump intakes.

 Prevent streambed scour at pump discharge.

 Monitor the dam and pumps to ensure proper operation throughout the waterbody crossing.
OREGON LNG PIPELINE WATERBODY CROSSING: FISH SALVAGE PLAN 

2 ES030613113935PDX

Flume Crossing Method 

The Flume crossing method is the proposed method of choice and will require implementation of the following

steps:

 Install flume pipe before any trenching.

 Use sandbag or sandbag and plastic sheeting diversion structure or equivalent to develop an effective seal

and to divert streamflow through the flume pipe (some modifications to the stream bottom may be required

to achieve an effective seal).

 Properly align flume pipe(s) to prevent bank erosion and streambed scour.

 Do not remove flume pipe during trenching, pipe laying, or backfilling activities, or during initial streambed

restoration efforts.

 Remove all flume pipes and dams that are not also part of the equipment bridge as soon as final cleanup of

the streambed and bank is complete.

Authorizations 

Crossing methods that involve in‐water or in‐channel work will be constructed during the designated Oregon

Department of Fish and Wildlife (ODFW) in‐water work window (ODFW, 2008) or authorized Washington State

Department of Fish and Wildlife (WDFW) in‐water work timing unless specific written authorization stating

otherwise is provided. The ODFW in‐water work windows for waterbodies to be crossed by the Pipeline are

provided in Attachment 1. The WDFW does not have designated in‐water work windows, and each crossing of

Burris Creek or its tributaries will be negotiated with WDFW. In‐water work window guidelines minimize potential

adverse impacts to fish and wildlife and their habitats. They also avoid sensitive life stages, including spawning,

rearing, and migration.

Before fish salvage activities are conducted at all stream crossings, ODFW/WDFW/National Marine Fisheries

Service (NMFS) Scientific Taking Permits will be obtained for all species that may be encountered at any of the

crossing areas, including species listed under the federal Endangered Species Act (ESA).

A qualified fisheries biologist will be onsite to oversee and conduct all fish salvage operations. Any fish or

lampreys that are captured will be handled according to requirements in the Scientific Taking Permits and will

generally involve the following procedures:

 Before and intermittently during isolation of the in‐water work area, capture fish trapped in the area by using

a trap, seine, electrofishing, or other methods as are prudent to minimize risk of injury, and then release them

at a safe release site.

 Do not use electrofishing if water temperatures exceed 18 degrees Celsius (°C) or are expected to rise above

18°C, unless no other method of capture is available.

 Take fish by backpack electrofishing, seining, or other approved method. If electrofishing equipment is used to

capture fish, comply with NMFS electrofishing guidelines (NMFS, 2000).

 Handle ESA‐listed fish with extreme care, keeping fish in water to the maximum extent possible during seining

and transfer procedures to prevent the added stress of out‐of‐water handling.

 Ensure that water quality conditions are adequate in buckets or tanks used to transport fish by providing

circulation of clean, cold water; using aerators to provide dissolved oxygen; and minimizing holding times.

 Release fish into a safe release site as quickly as possible, and as near as possible to capture sites.

 Do not transfer ESA‐listed fish to anyone except NMFS personnel, unless otherwise approved in writing by

NMFS.
OREGON LNG PIPELINE WATERBODY CROSSING: FISH SALVAGE PLAN 

ES030613113935PDX 3 

 Allow NMFS or its designated representative to accompany the capture team during the capture and release

activity, and to inspect the team’s capture and release records and facilities. Submit an electronic copy of the

Salvage Report Form to NMFS within 10 calendar days of completion of the salvage operation.

 Rescue/salvage (take) of fish during isolation of in‐water work areas at Pipeline waterbody crossings will

include handling of adults and/or juveniles. All fish handled must be recorded in the annual report for the

Scientific Taking Permit.

 In‐water work (fish salvage or construction) may occur between the specific designated in‐water, or

negotiated, work windows for each specific waterbody. Exceptions to these in‐water work periods must be

approved by the local ODFW/WDFW District Fish Biologist or his/her representative and submitted to the

ODFW ESA Program Specialist or WDFW District Biologist, in writing, before work commences outside the

approved in‐water work windows.

 Activities must be coordinated with the local ODFW/WDFW District Fish Biologist prior to any sampling.

 Indirect mortality may not exceed 10 percent of the total take, or—for species listed under the federal ESA—

up to a specified number of individuals. In the event that mortality for any species exceeds the specified rate,

the permittee will contact the ESA Program Specialist, ODFW, and/or WDFW prior to any further activity.

Waterbodies with Fish Salvage Requirements 

Waterbodies to be crossed using the Open‐Cut, Flume, Dam‐and‐Pump, or HDD methods are provided in

Attachment 2. It is assumed that fish will not be present in intermittent or ephemeral streams, which will be

Open‐Cut. However, if water is present at an intermittent or ephemeral crossing, the presence of fish will be

determined prior to construction below the ordinary high water elevation and fish salvage activities will be

conducted, if necessary.

Named streams that are known to support anadromous salmonids in the Northern Oregon Coastal basins, Oregon

lower Columbia River tributaries, and Washington lower Columbia River tributaries will be crossed using the

Flume crossing method. These streams are listed in Table 1.

TABLE 1

Anadromous Fish and Resident Salmonid Species Documented at Proposed Flume Pipeline Crossing Sites in the

Northern Oregon Coastal Streams and Rivers, Oregon Lower Columbia River Tributaries, and Washington Lower

Columbia River Tributariesa

Pipeline

Milepost River or Creek Crossed

Fish Species Presentb

Anadromous Salmonids Resident Salmonidsb

1.5 Vera Creek Coho salmon Unknown, presumed presentc

4.5 Barrett Slough Coho salmon Unknown, presumed presentc

7.9 Heckard Creek Coho salmon Unknown, presumed presentc

11.0 Lewis and Clark River Fall Chinook salmon, coho salmon, , winter steelhead trout Unknown, presumed presentc

18.5 Rock Creek No anadromous fish (barrier downstream) Coastal cutthroat trout

19.3 Osgood Creek No anadromous fish (barrier downstream) Coastal cutthroat trout

20.1 Fox Creek No anadromous fish (barrier downstream) Coastal cutthroat trout

21.4 South Fork Youngs River No anadromous fish (barrier downstream) Coastal cutthroat trout

23.4 Fall Creek No anadromous fish (barrier downstream) Coastal cutthroat trout

31.4 Alder Creek Coho salmon Unknown, presumed presentc

47.6 North Fork Wolf Creek Spring Chinook salmon, coho salmon, winter steelhead trout Unknown, presumed presentc

50.5 Clear Creek Coho salmon Unknown, presumed presentc
OREGON LNG PIPELINE WATERBODY CROSSING: FISH SALVAGE PLAN 

4 ES030613113935PDX

TABLE 1

Anadromous Fish and Resident Salmonid Species Documented at Proposed Flume Pipeline Crossing Sites in the

Northern Oregon Coastal Streams and Rivers, Oregon Lower Columbia River Tributaries, and Washington Lower

Columbia River Tributariesa

Pipeline

Mil

River or Creek Crossed Fish Species Presentb

55.7 Cedar Creek Coho salmon Unknown, presumed presentc

70.7 Clatskanie River Coho salmon, winter steelhead trout Unknown, presumed presentc

71.8 Little Clatskanie River Coho salmon Unknown, presumed presentc

a

Northern Oregon Coastal Basins include the Lower Columbia and the Nehalem basins along the pipeline route.  

b Sources: anadromous species—StreamNet and Kostow, 1995; resident species—Kostow, 1995; Kavanaugh et al., 2005.

c Although no documentation confirming the presence of resident cutthroat trout was identified, because of their wide distribution,

they are likely present in most of the crossed streams but are assumed present in all.

Many perennial named and unnamed streams that the Pipeline will cross are likely to support resident coastal

cutthroat trout and/or nongame fish species such as sculpin. Perennial streams are assumed to support fish and

will require fish salvage at the crossing site.

Fish Salvage Procedures 

Fish species likely to be encountered during fish salvage activities include salmonids (salmon and trout, including

salmon and trout listed under the federal ESA), cyprinids (minnows), cottids (sculpins), gasterosteids

(sticklebacks), acipenserids (sturgeons), petromyzontids (lampreys), catostomids (suckers), ictalurids (catfish), and

centrarchids (sunfish and bass).

Fish will be salvaged using backpack electrofishing equipment, traps, seines, or other approved methods. If

electrofishing equipment is to be used and potential ESA species may be present, NMFS electrofishing guidelines

will be followed (NMFS, 2000; Attachment 3). Electrofishing is the most appropriate method for capturing

lamprey ammocoetes (larvae) during salvage activities. Traps can be used, but they typically capture lampreys as

they migrate upstream or downstream.

A qualified fisheries biologist will be onsite to oversee and conduct all fish salvage operations. All crossings will be

constructed during the ODFW in‐water work window or WDFW negotiated in‐water construction timing period

unless specifically authorized in writing by ODFW or WDFW. Because lampreys may be present at waterbody

crossings, special salvage procedures have been incorporated into this fish salvage plan to account for the capture

of lamprey ammocoetes or other larval stages (see 2[a] below).

In general, the following steps will be conducted during salvage activities at crossing sites:

1. Set block nets upstream and downstream of the area to be crossed to ensure that fish or lampreys cannot

enter the construction area.

2. Conduct the salvage between the block nets by using electrofishing equipment, seine, trap, or other approved

method. If using electrofishing equipment, a minimum two‐pass method will be employed to ensure that all

fish and lampreys are captured. Electrofishing equipment is the most appropriate method for capturing larval

lamprey during salvage activities at crossing sites.

a. The first electrofishing pass of the minimum two‐pass method will be specifically for capturing larval

lamprey. The electrofishing unit will be set to deliver three pulses/second (125 volts direct current [dc]) at

25 percent duty cycle, with a 3:1 burst pulse train (three pulses on, one pulse off) to remove larvae from

the substrate (U.S. Fish and Wildlife Service [USFWS], 2002). Once larvae emerge, 30 pulses/second will

be applied to stun the larvae.

b. The second and subsequent electrofishing passes will be to capture fish that may be in the area and were

not captured during the first electrofishing pass. The electrofishing unit will be set accordingly to deliver
OREGON LNG PIPELINE WATERBODY CROSSING: FISH SALVAGE PLAN 

ES030613113935PDX 5 

the appropriate pulse rate/second at the appropriate voltage and duty cycle based in part on fish size,

streamflow, velocity, depth, temperature, and conductivity.

3. Captured fish and lampreys will be handled to the minimal extent possible and placed in containers of clean,

aerated water. Individuals will be held in containers for the minimal time necessary. All captured individuals

will be enumerated, identified, and noted in a field logbook prior to being released. Captured individuals will

be released into a safe site as quickly as possible, and as near as possible to capture sites.

4. After fish and lampreys have been captured in the construction area, install the flume or dam‐and‐pump

equipment.

5. Inspect the isolated area for stranded fish or lampreys and salvage if necessary.

Construct crossing, restore waterbody channel, and remove flume equipment to restore flow in the construction

area per the guidelines below:

1. Apply the method to waterbodies where downstream siltation must be avoided. Flumes are generally not

recommended for use on waterbodies with a broad unconfined channel, permeable substrate, excessive

discharge, or where a significant amount of bed or bank alteration is required to install flumes or dams.

2. Schedule crossing during low‐flow period, if possible.

3. Complete all watercourse activities as expediently as possible. However, in accordance with Federal Energy

Regulatory Commission (FERC) procedures, the duration of construction will be limited to 24 hours across

minor waterbodies (10 feet wide or less) and 48 hours across intermediate waterbodies (between 10 and

100 feet wide).

4. Do not refuel mobile equipment within 150 feet of a waterbody. Refuel stationary equipment per the Spill

Prevention, Control, and Countermeasures Plan (Resource Report 2 [CH2M HILL, 2013], Appendix 2H).

5. Minimize riparian clearing to accommodate stream size, terrain, and existing vegetation conditions, and to

avoid removal of significant trees, where possible, at the margins of the temporary construction zone. Existing

large woody debris will be salvaged for reinstallation, and a sufficient quantity of large‐diameter conifer logs

will be stockpiled for post‐construction aquatic habitat enhancement.

6. Install temporary equipment crossing.

7. In agricultural land, strip topsoil from spoil storage area.

8. Store instream spoil on banks a minimum of 25 to 50 feet from the top of the bank.

9. Leave hard plugs at the stream bank edge until just prior to pipe installation.

10. Size the flume to handle 150 percent of the anticipated flows. Install the flume in the watercourse and

maintain the correct alignment until it is removed.

11. Construct an upstream dam followed by a downstream dam. Install a flange on the upstream end of the flume

and seal it to substrate with sandbags and polyethylene liner where necessary to ensure a watertight barrier.

“Key” dams into banks or construct a secondary dam, if necessary.

12. Pump stream channel between the dams, if necessary. Discharge water through a dewatering structure and

onto a stable, well‐vegetated area to prevent erosion and sedimentation. Do not discharge heavily silt‐laden

water in the stream.

13. Construct sediment barriers (straw bales and/or silt fences) to prevent silt‐laden water and spoil from flowing

back into the watercourse. Constructed sediment barriers shall extend along the sides of the stockpiles and

the ends of dams. Barriers may be temporarily removed to allow construction activities but must be replaced

by the end of each work day.

14. Complete prefabrication of the instream pipe section and weight the pipe, as necessary, prior to

commencement of instream activity.
OREGON LNG PIPELINE WATERBODY CROSSING: FISH SALVAGE PLAN 

6 ES030613113935PDX

15. Trench through the watercourse. Install temporary (soft) plugs, if necessary, to control water flow and trench

sloughing.

16. Maintain streamflow, if present, through the flume throughout crossing construction.

17. Lower‐in the pipe, install the trench plug, and backfill immediately.

18. Backfill with native material.

19. Restore the watercourse channel to the approximate preconstruction profile and substrate.

20. Restore stream banks to their approximate original condition and stabilize them, as required.

Restoration and cleanup will begin after the trench is backfilled or as soon as weather and site conditions permit

and be in accordance with landowner requests, the FERC Plan, and as described in Resource Report 2 (CH2M HILL,

2013), Appendix 2D. These fish salvage procedures will be followed at all Pipeline crossings requiring fish salvage.

A field log will be kept for each fish salvage documenting the number of fish by species and age group (adult or

juvenile); disposition of released fish noting any injuries or mortalities; date; salvage team members; and general

observations. After all stream crossings and salvages have been completed, a report will be compiled that

summarizes the number of fish salvaged by species and their disposition. This report will be submitted to

ODFW/WDFW/NMFS in compliance with the ODFW/WDFW/NMFS Scientific Taking Permits.

Literature Cited 

CH2M HILL. 2013. Oregon LNG Bidirectional Project Resource Report 2 — Water Use and Quality. May 2013.

Kavanaugh, P., K. Jones, C. Stein, and P. Jacobsen. 2005. Fish Habitat Assessment in the Oregon Department of

Forestry Upper Nehalem and Clatskanie Study Area. Oregon Department of Fish and Wildlife Aquatic

Inventories Project, Salem, Oregon.

Kostow, K. 1995. Biennial Report on the Status of Wild Fish in Oregon. Oregon Department of Fish and Wildlife,

Portland, Oregon.

National Marine Fisheries Service (NMFS). 2000. Guidelines for Electrofishing Waters Containing Salmonids Listed

Under the Endangered Species Act. National Marine Fisheries Service. June 2000.

Oregon Department of Fish and Wildlife (ODFW). 2008. Oregon Guidelines for Timing of In‐Water Work to Protect

Fish and Wildlife Resources. Oregon Department of Fish and Wildlife. June 2008.

StreamNet. 2007. Fish Data for the Northwest. http://www.streamnet.org/.

U.S. Fish and Wildlife Service (USFWS). 2002. Letter from USFWS Columbia River Fisheries Program Office,

Vancouver, Washington, to Northwest Power Planning Council, Portland, Oregon, regarding proposal for

Project 200001400, Evaluate Habitat Use and Population Dynamics of Lampreys in Cedar Creek.

March 15, 2002.
Attachment 1 

Oregon Guidelines for Timing of In-water Work to 

Protect Fish and Wildlife Resources 

OREGON GUIDELINES

FOR

TIMING OF IN-WATER WORK

TO PROTECT FISH AND WILDLIFE RESOURCES

June, 2008

Purpose of Guidelines - The Oregon Department of Fish and Wildlife, (ODFW),

under its authority to manage Oregon’s fish and wildlife resources has updated the

following guidelines for timing of in-water work. The guidelines are to assist the

public in minimizing potential impacts to important fish, wildlife and habitat

resources.

“The guidelines are to assist

the public in minimizing

potential impacts...”.

Developing the Guidelines - The guidelines are based on ODFW district fish

biologists’ recommendations. Primary considerations were given to important fish

species including anadromous and other game fish and threatened, endangered, or

sensitive species (coded list of species included in the guidelines). Time periods were

established to avoid the vulnerable life stages of these fish including migration,

spawning and rearing. The preferred work period applies to the listed streams, unlisted

upstream tributaries, and associated reservoirs and lakes.

“The guidelines are based

on ODFW district fish

biologists’

recommendations”.

Using the Guidelines - These guidelines provide the public a way of planning in-water

work during periods of time that would have the least impact on important fish,

wildlife, and habitat resources. ODFW will use the guidelines as a basis for

commenting on planning and regulatory processes. There are some circumstances where

it may be appropriate to perform in-water work outside of the preferred work period

indicated in the guidelines. ODFW, on a project by project basis, may consider

variations in climate, location, and category of work that would allow more specific

in-water work timing recommendations. These more specific timing recommendations

will be made by the appropriate ODFW district office through the established planning

and regulatory processes.

“These guidelines provide

the public a way of planning

in-water work during

periods of time that would

have the least impact on

important fish, wildlife and

habitat resources”.

Modification of Guidelines - There may be limited situations where minor

modification of the timing guidelines is warranted. ODFW may consider new

information, the need for greater detail, or other factors that would generally improve

the quality and usefulness of these guidelines. ODFW through the appropriate district

office may modify or clarify timing guidelines within the district as needed. Statewide

updates to guidelines will occur on a periodic basis.

“ODFW through the

appropriate district office

may modify or clarify timing

guidelines within the district

as needed”.

Public Comments - A limited technical public review of these updated guidelines was

conducted. A few responses provided specific biological information and

recommendations for changing in-water work periods. Applicable ODFW districts

reevaluated their timing recommendations based on this public response. Other

comments concerned format and application of the timing guidelines. Some responses

stated that different types of in-water activities should have different timing guidelines.

ODFW recognizes there will be occasions that more specific timing guidelines may

need to be established for specific activities. The established planning and regulatory

processes can accommodate that need.

 ________

“A limited technical public

review of these updated

guidelines was conducted”.
Northwest Region North Coast Watershed District

WATERWAY PREFERRED WORK PERIOD 1 

1

 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed unless 

otherwise indicated. 

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources – June, 2008 

Page 2 

Columbia River Management (971) 673-6000

Columbia River Estuary (Mouth to Tongue Pt.) November 1 – February 28 

(MAR,SHL,CHF,CHS,SS,CO,STW,STS,CT*) 

Columbia River (Tongue Pt. to Bonneville Dam) November 1 – February 28 

(CHF,CHS,SS,CO,STW,CS,CHR,CT,STS*) 

Northwest Region

North Coast Watershed District

Tillamook Office - (503) 842-2741

Pacific 

Columbia River (See Columbia River Management) 

Youngs River July 15 - September 30 (CO,STW *) 

Young’s Bay Tributaries July 1 – September 15 (CO,CT,STW) 

Wallooskee River June 1 - September 30 (CO,CT*) 

Other Columbia R. Est. Tribs. (Mouth to Tongue Pt.) July 1 - September 15 (CHF,STW*) 

Other Columbia R. Est. Tribs (Tongue Pt. to Hunt Creek) July 15 - September 15 ( CHF, STW*) 

Necanicum 

Necanicum River & tributaries July 1 - September 15 (CO,CHF,STW*) 

Necanicum and Neawanna Estuary November 1-February 15 

(MAR,SHL,CO,CHF,STW) 

Ecola Creek and Tributaries July 1-September 15 (CO,CT,STW) 

Nehalem 

Nehalem Estuary November 1 - February 15 

(MAR,SHL,CHS,CHF,CO,STW,*) 

Lower Nehalem River (below Hwy 26 at Elsie) July 1 - September 15 (CHF*) 

N. Fk. Nehalem River July 1 - September 15 (CHF,STW*) 

Cook Creek July 1 - September 15 (CHF,STW*) 

Salmonberry River August 15 - September 15 (CHS,STW*) 

Other Lower Nehalem River Tributaries July 1 - September 15 (CHF,CO,STW*) 

Upper Nehalem River and Tribs. (above Hwy 26 at Elsie) July 1 - August 31 (CHS,STW*) 

Tillamook 

Tillamook Estuary November 1 - February 15 

(MAR,SHL,CHF,CHS,STW,CO,CS*) 

Miami,Kilchis,Wilson,Trask,Tillamook Rivers & Tribs. July 1 - September 15 

 (CHF,CHS,STW,CO,CS*) 

 Other Tillamook Bay Tributaries July 1 – September 15 (CO,CT) 

Netarts Bay November 1 - February 15 

 (MAR,SHL,CHF,STW,CO,CS*) 

Sand Lake November 1 - February 15 

(MAR,SHL,CHF,STW,CO,CS*) 

Nestucca 

Nestucca Estuary November 1 - February 15 

(MAR,SHL,CHF,CHS,STW,CO,CS*) 
Northwest Region North Coast Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed unless

otherwise indicated.

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources - June, 2008

Page 3

Nestucca River & Tributaries July 1 - September 15

(CO,CHS,CHF,CS,STW*)

Little Nestucca River & Tributaries July 1 – September 15 (CO,CHS,CHF,CS,STW)

Neskowin Creek and Tributaries July 1 - September 15 (CO,CS,STW*)

Other North Coastal Tributaries (Columbia River to Neskowin Cr.) July 1 – September 15 (CO,CT)

Coastal Lakes October 1 – February 15 (CT)

Coastal lake Tributaries July 1 – September 15 (CT)

Newport Office - (541)-867-4741

Pacific

Salmon

Salmon River Estuary November 1 - February 15 (MAR,SHL*)

Salmon River July 1 - September 15 (CHF,CO,CS,STW,CT*)

Siletz

Siletz River Estuary November 1 - February 15 (MAR,SHL*)

Siletz River July 1 - August 31(CHF,CHS,CO,CS,STW,STS,CT*)

Yaquina

Yaquina River Estuary November 1 - February 15 (MAR,SHL*)

Yaquina River July 1 - September 15 (CHF,CO,STW,CT*)

Alsea

Alsea River Estuary November 1 - February 15 (MAR,SHL*)

Alsea River July 1 - August 31 (CHF,CHS,CO,STW,CT*)

Yachats River July 1 - September 15 (CHF,CO,STW,CT*)

Siuslaw

Siuslaw River Estuary November 1 - February 15

(MAR,SHL,CHF,CO,STW,CT*)

Siuslaw River July 1 - September 15 ( CHF,CO,STW,CT*)

Other Coastal Tributaries July 1 - September 15 (CO,STW,CT*)

Coastal Lakes October 1 – February 15 (STW,CO,CT)

Coastal Lake Tributaries July 1 – September 15 (STW,CO,CT)

North Willamette Watershed District

Clackamas Office (971) 673-6000

Columbia

Columbia River ( Hunt Creek to Bonneville Dam) See Columbia River Management

Columbia River ( Within District above Bonneville Dam) November 15 - March 15

(CHF,CHS,CHR,SS,CO,CS,STW,STS,CT*)

Columbia R. Tribs. (Hunt Creek to St. Helens) July 15 - September 15 (CHF,STW*)

Clatskanie River July 15 - September 15 (CHF,STW*)
Northwest Region North Willamette Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1

 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed unless 

otherwise indicated. 

2 Winter window only for activities below -20’Columbia River Datum 

3 Winter window only for activities below -20’ National Geodetic Vertical Datum 1947 

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources – June, 2008 

Page 4

Willamette 

Multnomah Channel (including Scappoose Bay) July 1 - October 31 & December 1 - January 312

(CHF,CHS,CO,STW,STS,CT,WW *) 

Milton Cr. & Scappoose Cr. July 15 - August 31 (CO,STW,JUV,WW*) 

Willamette River (mouth to Willamette Falls) July 1 - October 31 & December 1 - January 313

 (CHF,CHS,CO,STW,STS,CT,WW *) 

Columbia Slough June 15 - September 15 (JUV,WW) 

Johnson 

Johnson Creek July 15 - August 31 (STW,CO,CT,CHF*) 

Johnson Cr. Tribs. July 15 - August 31 (CT,STW,CHF,CO*) 

Kellogg Creek July 15 - September 30 (STW,CO,CT*) 

Tryon Creek July 15 - September 30 (STW,CO,CT*) 

Clackamas River July 15 - August 31 

(CHF,CHS,STW,CO,STS,CT*) 

Abernethy Creek July 15 - September 30 (CO,STW,CT*) 

Other Willamette River tribs. July 15 – September 30 (CT*) 

Willamette River (Will. Falls to Newberg ) June 1 - October 31 & December 1 - January 31 

 (CHS,STW*) 

Tualatin

All Tualatin River Tributaries July 15 - September 30 (CO,STW,CT,WW*) 

Tualatin River (below Scoggins Cr.) June 1 - September 30 (CO,STW,CT,WW*) 

Tualatin River (above Scoggins Cr.) July 15 - September 30 (CO,STW,CT,WW*) 

Beaver Creek July 15 - September 30 (CT*) 

Molalla/Pudding River 

Molalla River (below Hwy 213) June 1 – September 30 (STW,CT*) 

Other Molalla River Tributaries (below Hwy 213) July 15 - September 30 (CT*) 

 Molalla River (above Hwy 213) July 15 - August 31 (CHS,STW,CT,RB*) 

 N. Fk & M. Fk Molalla July 15 - August 31 (CHS,STW,CT,RB*) 

Other Molalla River Tributaries (above Hwy 213) July 15 - September 30 (STW,CT*) 

Pudding River June 1 - September 15 (CHS,STW,CT*) 

Butte Creek July 15 - September 30 (STW,CT*) 

Abiqua Creek July 15 - August 31 (CHS,STW,CT,RB*) 

Silver Creek July 15 - September 30 (STW,CT*) 

Other Pudding River Tributaries June 1 - September 30,STW,CT,RB*) 

Other Willamette River tribs. July 15 – October 15 (CT*) 

Willamette River (Newberg to Yamhill River) June 1 – September 30 (CHS,STW,CT,RB*) 

Chehalem Creek July 15 - September 30 (CT*) 

Yamhill River July 15 - September 30 (STW,CT*) 

Other Willamette River tribs. July 15 – September 30 (CT*) 

Fairview Cr.,Arata Cr., Salmon Cr. June 15 - September 15 (CT,WW*) 

Sandy River July 15 - August 31 (CHS,CHF,CO,STW*) 

Tanner Creek July 15 - August 15 (CHF,CHS,CO,STW*) 

Columbia River Tributaries (St. Helens to Sandy River) July 15 - August 31 (CHF,CO,STW,CT *) 

Columbia River Tributaries (Sandy River to Herman Cr.) July 15 - August 31 (CO,STW,STS,CT *) 
Northwest Region South Willamette Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1

 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed unless 

otherwise indicated. 

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources – June, 2008

Page 5

South Willamette Watershed District 

Corvallis Office - (541) 757-4186

 Willamette 

 Willamette River (Yamhill River to McKenzie River) June 1 – October 15 (CHS,STW,CT,RB*) 

 Spring Valley Creek July 1 - October 15 (CT*) 

 Glenn Creek July 1 - October 15 (CT*) 

 Mill Creek June 1 – October 15 (CT,RB*) 

 Rickreall Creek July 1 – October 15 (STW,CT*) 

 Luckiamute River July 1 - October 15 (STW,CT*) 

 Santiam River June 1 – October 15 (CT*)

 North Santiam River (below Big Cliff Dam) July 15 - August 31 (CHS,STW,CT,RB*)

 Stout Cr., Rock Cr., & Mad Cr. July 15 - October 15 (STW,CT,RB*) 

 Lt. N. Fk. Santiam River July 15 - August 31 (CHS,STW,CT,RB*) 

 Sinker, Elkhorn Cedar Creeks & tributaries July 15 - October 15 (STW,CT,RB*) 

 Other Tributaries June 1 - October 15 (CT*) 

 Other Santiam River Tributaries (below Big Cliff Dam) June 1 - October 15 (CT*) 

 North Santiam River (above Detroit Dam) June 1 - August 31 (CHS, K,CT,RB*)

 Breitenbush River June 1 - August 31 (CHS, K,CT,RB*) 

 South Santiam River (below Foster Dam) July 15 - August 31 (CHS,STW,CT,RB*)

 Crabtree Cr.,Thomas Cr. & Wiley Cr. July 15 - August 31 (CHS,STW,CT,RB*)

 McDowell Cr. July 15 - October 15 (STW,CT*) 

 Other South Santiam River Tributaries (below Foster Dam) June 1 - October 15 ( CT*) 

 South Santiam River (above Foster Dam) July 15 - August 31 (CHS,STW,CT,RB*) 

 Middle Santiam River & Quartzville Creek June 1 - October 15*(K,CT,RB*)

 Marys River July 1 - October 15 (CT*) 

 Long Tom River July 1 - October 15( CT*) 

 Other West Bank Will. R. Tribs. (Will. Falls to McKenzie R.) July 1 - October 15 (CT*) 

 Calapooia 

 Calapooia River (below Holley) June 1 - October 15 (CT*) 

 Calapooia River (above Holley) July 15 - August 31 (CHS,STW,CT,RB*)

 Other East Bank Will. R. Tribs. (Will. Falls to Harrisburg) June 1 - October 15 (CT*) 

Springfield Office - (541) 726-3515

Willamette 

 Willamette River (above McKenzie River) June 1 - October 31(CHS,RB*) 

 McKenzie River Basin 

 McKenzie River (below Leaburg Dam) by specific arrangement (CHS,CT,RB,BUT,OC*) 

 Tributaries of McKenzie River (below Leaburg Dam) June 1 - October 31 (CT,RB, OC*) 

 McKenzie River (above Leaburg Dam) July 1 - August 15 (CHS,BUT,CT,RB*) 

 Blue River (above Blue River Dam) June 1 - October 31 (CT,RB*) 

 Middle Fork Willamette River Basin 

Middle Fork Willamette River (Confluence with the 

 Coast Fork Willamette to Dexter Dam) by specific arrangement (CHS,STW,CT,RB,OC*) 

 Fall Creek & Little Fall Creek July 1 - August 31 (CHS,STW,CT,RB*) 

 Lost Creek July 1 - August 31 (CHS,STW,CT,RB*)

 Rattlesnake Creek by specific arrangement (STW,CT,RB,OC*)
Northwest Region South Willamette Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1

 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed unless 

otherwise indicated. 

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources – June, 2008

Page 6 

Other Middle Fork Willamette River tributaries June 1 – October 31 (CT,RB*) 

(Confluence with the Coast Fork Willamette to Dexter Dam) 

 Middle Fork Willamette River Basin (Dexter Dam to Hills Creek Dam) by specific arrangement (CHS,CT,RB,OC*) 

North Fork Middle Fork Willamette River July 1 – August 31 (CHS, CT,RB*) 

 Salmon Creek July 1 – August 31 (CHS, CT,RB*) 

 Salt Creek July 1 – August 31 (CHS, CT,RB, OC*) 

 Middle Fork Willamette River (above Hills Creek Dam) July 1 - August 15 (CHS,BUT,CT,RB*) 

 Coast Fork Willamette River Basin 

 Coast Fork Willamette River by specific arrangement (CHS,RB,OC*) 

(Confluence with the Middle Fork Willamette to Cottage Grove Dam) 

 Coast Fork Willamette River (above Cottage Grove Dam) May 15 – November 30 (CT*) 

 Row River (below Dorena Dam) June 1 - October 31(CHS,CT,RB*)

 Row River (above Dorena Dam) May 15 – November 30 (CT*) 

Southwest Region

Umpqua Watershed District

Roseburg Office - (541) 440-3353

Pacific

 Umpqua River 

 Umpqua River Estuary & Smith Est. November 1 –January 31 

(MAR,SHL,CHS,CHF,CO,STW,STS,,CT*) 

 Umpqua River (Scottsburg and above) July 1 - August 31(CHS,CHF,CO,STW,STS,CT*) 

 Umpqua River Tribs. July 1 - September 15 (CHF,CO,STW,CT*) 

 North Umpqua 

 North Umpqua River (below Soda Springs Dam) by specific arrangement 

(CHF,CHS,CO,STW,STS,CT*) 

 Tribs. North Umpqua (below Soda Springs) July 1 - September 15 (CHS,CO,STW,STS,CT*) 

 North Umpqua River (above Soda Springs Dam) June 15 - October 15 (RB,BT,BR*) 

 South Umpqua 

 South Umpqua River July 1 - August 31(CHF,CHS,CO,STW,CT*) 

 South Umpqua Tribs. July 1 - September 15 ( CHF,CO,STW,CT*) 

Charleston Office - (541) 888-5515

 Pacific 

 Coos 

 Coos Bay Estuary and River (to Millicoma R./S. Coos R. confluence) October 1 - February 15 

(MAR,SHL,JUV,CHF,CO,STW,CT *) 

 Millicoma River, S. Coos R. and tribs. July 1 – September 15 (CHF,CO,STW,CT,MD*) 

 Coquille 

 Coquille River Estuary (Mouth to Bear Creek) October 1 – February15 

(MAR,SHL,JUV,CHF,CO,STW,CT *) 

 Coquille River and tribs. (Bear Creek and above) July 1 - September 15 (CHF,CO,STW,CT*) 

 Other Coastal Tributaries July 1- September 15 (CHF,CO,STW,CT*) 

 Coastal Lakes July 1 – September 15 (CO,STW,CT*) 

 Coastal Lake Tributaries July 1 - September 15 (CO,STW,CT*) 
Southwest Region Rogue Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1

 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed unless 

otherwise indicated. 

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources – June, 2008

Page 7 

Rogue Watershed District

Gold Beach Field Office – (541) 247-7605

Pacific

New 

 New River October 1- May 31 (JUV CHF*) 

 New River Tributaries July 15 - September 30 (CO,STW,CT*) 

 Floras Creek Estuary October 1- May 31 (JUV CHF*) 

 Floras Creek (above Hwy 101 bridge) July 15 - September 30 (CHF,CO,STW,CT*) 

Sixes

 Sixes River Estuary October 1- May 31 (JUV CHF*) 

 Sixes River (above Hwy 101 bridge) July 15 - September 30 (CHF,CO,STW,CT*) 

Elk

 Elk River Estuary October 1- May 31 (JUV CHF*) 

 Elk River (above Hwy 101 bridge) July 15 - September 30 (CHF,CO,STW,CT*) 

Euchre/Coastal Tributaries 

 Euchre Creek Estuary November 1 - May 31 (JUV CHF*) 

 Euchre Creek (above County bridge) July 15 - September 30 (CHF,CO,STW,CT*) 

 Hubbard Cr., Brush Cr. July 15 - September 30 (CO,STW,CT*) 

 Mussel Cr. July 15 - October 31 (STW,CT*) 

Rogue

 Rogue River Estuary October 1 - May 31 (JUV CHF*) 

 Rogue River (Elephant Rock to Marial) May 1 - September 30 (CHF*) 

 Rogue River Tributaries (below Marial) July 15 - September 30 (CHF,CO,STW,CT*) 

Hunter

 Hunter Creek Estuary November 1 - May 31 (JUV CHF*) 

Hunter Creek (above County bridge) July 15 - September 30 (CHF,CO,STW,CT*) 

Pistol

 Pistol River Estuary November 1 - May 31 (JUV CHF*) 

 Pistol River (above County bridge) July 15 - September 30 (CHF,CO,STW,CT*) 

 Chetco/Coastal Tributaries 

 Chetco River Estuary October 1 - May 31 (JUV CHF*) 

 Chetco River (above Tide Rock) July 15 - September 30 (CHF,CO,STW,CT*) 

 Meyers Cr., Thomas Cr., Whalehead Cr. July 15 - October 31 (STW,CT*) 

Winchuck 

 Winchuck River Estuary October 1 - May 31 (JUV CHF*) 

 Winchuck River (above South Fork) July 15 - September 30 (CHF,CO,STW,CT*) 

Other Coastal Tributaries July 15 - October 31 (CT*) 

Central Point Office (541) 826-8774

 Rogue 

 Rogue River ( Marial to William Jess Dam) June 15 - August 31 (CHS,STW*) 

 Illinois River June 15 - September 15 (CHF,STW*) 

 Applegate River July 1 - September 15 (CHF,STW*) 

 Other Rogue River Tributaries (above Marial). June 15 - September 15 (CHS,STW*) 

 Rogue River (above William Jess Dam) June 15 - September 15 (BT,CT*) 
High Desert Region Deschutes Watershed District

WATERWAY PREFERRED WORK PERIOD

1

 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed unless 

otherwise indicated. 

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources – June, 2008 

Page 8 

High Desert Region

Deschutes Watershed District 

The Dalles Office - (541) 296-4628

 Columbia 

 Columbia River (Within District Bonneville to John Day Dam) November 15 - March 15 

(CHF,CHS,SS,CO,STW,STS*) 

Columbia River Tributaries July 15 - September 30 (STW,CO,RB*) 

 Fifteenmile Creek July 15 - October 31 (STW,RB*) 

 Hood River 

Hood River July 15 - August 31 (CHF,CHS,CO,STS,STW*) 

East Fork Hood River & Tribs. July 15 – August 31 (CHF,CO,STS,STW*) 

Middle Fork Hood River & Tribs. July 15 – August 15 (STW,CHS,BUT*) 

West Fork Hood River & Tribs. July 15 – August 15 (CHS,STS,STW*) 

 Deschutes 

Deschutes River (below Pelton Dam) February 1 - March 15 (CHF,STS,RB*) 

White River July 1 - October 31 (RB*) 

Buckhollow Cr. July 1 - October 31 (STS,RB*) 

Bakeoven Cr. July 1 - October 31 (STS,RB*) 

Trout Cr. July 1 - October 31 (STS,RB*) 

Bend Office - (541) 388-6363

 Deschutes 

 Metolius 

 Metolius River by specific arrangement (K,RB,BR,BUT*) 

Spring Creek by specific arrangement(K,RB*,BUT) 

Lake Creek by specific arrangement (K,RB) 

 Deschutes River (Pelton Dam through Lake Billy Chinook) July 1 - September 30 ( RB,BR*) 

 Crooked River 

Crooked River (below Prineville Dam) July 1 - October 31 (RT*) 

Prineville Reservoir July 1 - October 31 (RT*) 

Crooked River (above Prineville Dam) July 1 - October 31 (RT*) 

 N.Fk. Crooked River (above Big Summit Prairie) July 1 - September 30 (RT*) 

 Deschutes River (Lake Billy Chinook to Bend) July 1 - September 30 (RB,BR,BUT,K*) 

 Whycus Creek July 1 - October 15 (RB,BR,BUT*) 

 Tumalo July 1 - October 15 (RB,BR*) 

 Deschutes River (Bend-North Canal Dam to Benham Falls) July 1 - October 15 (RB,BR*) 

 Deschutes River (Benham Falls to Wickiup Dam) July 1 - October 15 ( RB,BR*) 

 Little Deschutes River July 1 - October 15 (RB,BR*) 

 Fall River July 1 - October 15 (RB,BR*) 

 Deschutes River(Wickiup Reservoir to Crane Prairie Dam) July 1 - August 31 (RB,BR,K *) 

 Deschutes River (Crane Prairie Reservoir to Little Lava Lake) July 1 - August 31 (RB,BT,K*) 

 Odell/Davis Lake and Tributaries by specific arrangement (K,RB,BUT*)

Klamath Watershed District

Klamath Falls Office - (541) 883-5732

 Klamath 

 Klamath River (below Keno) July 1 - September 30 ( RB*,SUSP,RB,RT) 

Cottonwood Creek July 1 – September 30 (STW*) 

Jenny Creek July 1 – January 31 (SCRT,JCS*) 

 Klamath River (above Keno) July 1 – January 31 (SNS,BCHUB,RT*) 

Lost River above Bonanza July 1 – January 31 (RT,SNS 

 Lost River below Bonanza July 1 - March 31 (RT*) 

Williamson River August 1 - September 3(BT,BR,RT,SNS,LRS,KLS*)
High Desert Region Klamath Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1

 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed unless 

otherwise indicated. 

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources – June, 2008

Page 9 

 Klamath River (above Keno) July 1 – January 31 (SNS,BCHUB,RT*) 

Lost River above Bonanza July 1 – January 31 (RT,SNS*)

 Lost River below Bonanza July 1 - March 31 (RT*) 

Williamson River August 1 - September 30 

(BT,BR,RT,SNS,LRS,KLS*) 

 Sprague River August 1 - September 30 

(BUT,LRS,SNS,RT,BT,BR *) 

Sycan River August 1 - September 30 

(RT,BT,BR,BUT,LRS,SNS*) 

 Wood River August 1 - September 30 (RT,BR,BUT,SNS*) 

 Sevenmile Creek August 1 - September 30 (RT,BR*) 

Klamath Lake and Agency Lake July 1 - January 31 (RT,LRS,SNS,BCHUB*) 

Silver Lake tributaries July 15 - September 30 (RT,BT*) 

Summer Lake and tributaries July 15 - September 30 ( TCHUB,RT *) 

Chewaucan River July 15 - September 30 (RT*) 

Goose Lake tributaries July 15 - September 30 

(GRT,GLAM,SSUC,GCB,PRCH,PSCL,MSUC*)

Warner Valley tributaries July 15 - September 30 (WSUC,FD,RT*) 

Malheur Watershed District

Hines Office - (541) 573-6582

Columbia 

 Snake 

Snake River (Malheur County) Open 

Malheur

Malheur River (below Namorf Dam) Open 

Willow Cr. (below Malheur Res.) Open 

Willow Cr. (above Malheur Res.) October 1 - March 31 (RB,RT*) 

Cottonwood, Cr., Squaw Cr October 1 - March 31 (RB,RT*) 

vvvvOther Tributaries vvvivvvvvvOctober 1 - March 31 (RB,RT*) 

 Malheur River (Namorf Dam to Wolf Creek ) November 1 - March 31 (RT*) 

North Fork Malheur (mouth to Beulah Res.) November 1 - March 31 (RT,RB*) 

North Fork Malheur (above Beulah Res.) July 1 - August 31 (BUT,RT,BT*) 

South Fork Malheur October 1 - March 31 (RT*) 

Malheur River (Including Wolf Creek and above) July 1 - August 31 (BUT,RT,BT*) 

 Owyhee River 

Owyhee River (below dam) November 1 - March 31 (RB,BT*) 

Owyhee River (above dam) October 1 - March 31 (RB,RT*) 

 Succor Creek October 1 - March 31 (RT*) 

Silvies River (above 5mi dam) October 1 - March 31 (RT,*) 

Silver Creek (above Hwy 45) October 1 - March 31 (RT*) 

Donner Blitzen River (Steen Mtns) October 1 - March 31 (RT*) 

vvvAlvord Basin vvvvOctober1-March31(LCT,AC*)

Catlow Valley tributaries October 1 - March 31 (LCT,CTC,RT*) 

Trout Creek Mountains streams October 1 - March 31 (LCT,AC,RB,CT*) 

vvvQuinn River October 1 - March 31 (LCT,RB,CT*)
Northeast Region John Day Watershed District

WATERWAY PREFERRED WORK PERIOD 1

1

 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed 

unless otherwise indicated. 

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources – June, 2008

 Page 10 

Northeast Region

John Day Watershed District

John Day Office - (541) 575-1167

Columbia River 

 Lower John Day 

 John Day River (below John Day) July 15 - August 31 (STS,RT*) 

 Rock Creek 

 Rock Creek (Gilliam Co.) July 15 - September 30 (STS,RT*) 

 North Fork John Day 

 North Fork John Day River (below U.S. 395) July 15 - August 31 (STS,RT*) 

 Middle Fork John Day 

 Middle Fork John Day River (below US 395) July 15 - August 31 (STS,RT*) 

 Middle Fork John Day River (above US 395) July 15 - August 15 (CHS,STS,RT,BUT*) 

 North Fork John Day River (above U.S. 395) July 15 - August 15 (CHS,STS,BUT*) 

Upper John Day 

 South Fork John Day River 

 South Fork John Day River July 15 - August 31 (STS,RT*) 

 John Day River (above John Day) July 15 - August 15 (CHS,STS,BUT,RT,CT*) 

 Canyon Creek July 15 - August 31 (STS,RB,CT*) 

Pendleton Office - (541) 276-2344

Columbia 

 Columbia River (John Day Dam upstream) December 1 – March 31 (CHF,CHS,CO,STS*) 

 Willow Creek July 1 - December 31 (RT, STS*) 

 Umatilla 

 Umatilla River (below Cayuse) July 15 - September 30 (CHF,CHS,CO,STS,RT, BUT*) 

 Butter Creek July 1 - December 31 (RT*) 

 Birch Creek July 1 - October 31 (STS,RT*) 

 McKay Creek 

 McKay Creek (below reservoir) December 1 - March 31 (CHF,CHS,CO,STS,RT,BUT*) 

 McKay Creek (above reservoir) July 1 - December 31 (RT*) 

 Wildhorse Creek July 1 - October 31 (CHF,CHS,CO,STS,RT*) 

 Umatilla River (above Cayuse) July 1 - August 15 (CHS,CHF,STS,RT,CO,BUT,WF*) 

 Meacham Creek 

Meacham Creek (below north fork) July 1 - August 15 (CHS,STS,RT,BUT, WF*) 

zxxzMeacham Creek (above north fork) July 1 - October 31 (STS,RT,BUT,WF*) 

Cold Spring Creek June 1 - December 31 

Walla Walla 

 Walla Walla River (below forks) July 1 - September 30 (CHS,STS,RT,BUT,WF*) 

 Pine Creek July 1 - October 31 (STS,RT*) 

 Little Walla Walla Distributary System 

 Little Walla Walla (above Ferndale Rd) December 1 – March 31(STS,RT,BUT*) 

Little Walla Walla (below Ferndale Rd) July 1 - October 31 (STS,RT,BUT*) 

 
Northeast Region John Day Watershed District

1 WATERWAY PREFERRED WORK PERIOD

1

 Work period is established for named stream, all upstream tributaries, and associated lakes within the watershed unless 

otherwise indicated. 

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources – June, 2008 

Page 11 

Mill Creek July 1 - August 15 (CHS,STS,RT,BUT,WF*) 

Cottonwood Creek July 1 - October 31 (STS,RT*) 

Birch Creek July 1 - October 31 (STS,RT*) 

Couse Creek July 1 - October 31 (STS,RT*) 

South Fork Walla Walla River July 1 - August 15 (CHS,STS,RT,BUT,WF*) 

North Fork Walla Walla River 

NF Walla Walla River (below Little Meadows Cyn) July 15 - September 30 (STS,RT,BUT,WF) 

NF Walla Walla River (above Little Meadows Cyn) July 1 - August 31 (STS,RT,BUT,WF) 

Grande Ronde Watershed District

Enterprise Office - (541) 426-3279

 Columbia 

 Snake River (state line to Hells Canyon Dam) July 1 - October 15 (CHF,CHS,SS,STS*) 

 Grande RondeGrande Ronde River (below Wallowa River) July 1 - September 15 (CHF,STS*) 

Wenaha River July 1 - August 15 (CHS,STS,BUT*) 

Joseph Creek July 1 - March 31 (STS*) 

Wallowa River July 15 - August 15 (CHS,STS,RB,BT,BUT *) 

 Imnaha River (above Big Sheep Creek) July 15 - August 15 (CHS,STS,BUT*) 

 Imnaha River (below Big Sheep Creek) July 1 – October 15 (CHF,STS*) 

La Grande Office - (541) 963-2138

 Columbia 

 Snake 

 Grande Ronde 

 Grande Ronde River (Wallowa River to Highway 244 Bridge) July 1 - October 15 (CHS,STS,RB,BUT*) 

 Minam River July 1 – August 15 (CHS,STS,RB,BUT*) 

 Lookingglass Creek July 1 - August 15 (CHS,STS,RB,BUT*) 

 Catherine Creek 

 Catherine Creek (to, and including Little Creek) July 1 - October 15 (CHS,STS,RB,BUT*) 

 Catherine Creek (above Little Creek) July 1 – August 15 (CHS,STS,RB,BUT* 

 Grande Ronde River (above highway 244 bridge) July 1 - July 31 (CHS,STS,RB,BUT*) 

Snake River Reservoir July 1 - November 30 (WW*) 

 Snake River Reservoir Tributaries July 1 - October 31 (RB*) 

 Burnt River July 1 - October 31 (RB,BT*) 

 Pine Creek July 1 – August 31 (RB,BUT *) 

Powder River (mouth to Phillips Reservoir) July 1 - October 31 (RB*) 

Anthony Creek July 1 – August 31 (RB,BUT*) 

North Powder R. (above Dutch Flat Cr.) July 1 – August 31 (RB,BUT*) 

Wolf Creek (above Wolf Creek Res.) July 1 – August 31 (RB,BUT*) 

Big Muddy Creek (above Foothill Rd.) July 1 – August 31 (RB,BUT*) 

Pine Creek (above North Fork Pine Cr.) July 1 – August 31 (RB,BUT*) 

Salmon Creek (above Pocahontas Road) July 1 – August 31 (RB,BUT*) 

 Powder River (above Phillips Reservoir) July 1 – August 31 (RB,BUT*) 

Deer Creek (above Phillips Reservoir) July 1 – August 31 (RB,BUT*) 
1

 Work period is established for named stream, all upstream tributaries, and associated lakes within the 

watershed unless otherwise indicated. 

Oregon Guidelines for Timing of In-Water Work to Protect Fish and Wildlife Resources – June, 2008 

Page 12 

*Coded fish species defined below provide the primary basis for timing guidelines. The species list should 

be considered general information and is not necessarily comprehensive nor accurate. 

AC - Alford chub 

BCHUB – blue chub 

BR - brown trout 

BT - brook trout 

BUT - bull trout 

CR – crappie 

CHF - Chinook salmon, fall 

CHR - Chinook salmon, summer 

CHS - Chinook salmon, spring 

CO - coho salmon 

CS - chum salmon 

CT - cutthroat trout (includes sea run) 

CTC - Catlow tui chub 

GCB - goose lake chub 

FD – Foskett speckled dace 

GLAM - Goose Lake lamprey 

GSUC - Goose Lake sucker 

JCRT – Jenny Creek red band trout 

JCS – Jenny Creek sucker 

JUV - juvenile salmonids 

K – kokanee 

KLS – Klamath largescale sucker 

LCT - Lahontan cutthroat trout 

LRS – Lost River sucker 

MAR - various marine species of fish 

MD – Millicoma dace 

MMS - Malheur mottled sculpin 

MSUC – Modoc sucker 

OC – Oregon sucker 

PRCH - pit roach 

PSCL - pit sculpin 

RB - rainbow trout 

RT - red band trout 

SHL - various marine shell fish 

SNS shortnose sucker 

SS - sockeye salmon 

SSUC – Sacramento sucker 

STS - steelhead summer 

STW - steelhead winter 

SUSP – sucker species 

TCHUB – tui chub 

WF – mountain white fish 

WSUC – Warner sucker 

WW - various warm water game fish 
Attachment 2 

Waterbodies to Be Crossed Using the Open-Cut, 

Flume, Dam-and-Pump, or HDD Methods 

WATERBODIES TO BE CROSSED USING THE OPEN-C

ES030613113935PDX ATTACHMENT 2Waterbodies to Be Crossed Using Open‐Cut, Flume, Dam‐and‐Pump, or HDD Methods

Milepost Stream ID

Stream

Typea Water Bodyb

Hydrologic Unit

Code

(4th Order) Crossing Method

Water Body

Typec Fish Speciesd

M

S

H

1.0 S99CL001 Perennial Adairs Slough Lower Columbia Method 2 ‐ HDD Minor Co 0 1.5 S5BCL074 Perennial Vera Creek Lower Columbia Method 1 ‐ Flume Minor Co 02.9 S99CL067 Perennial Lewis and Clark River Lower Columbia Method 2 ‐ HDD Minor Co 04.1 S5BCL059 Perennial Tributary of Barrett Slough Lower Columbia Method 1 ‐ Flume Minor Co 04.2 S5BCL062 Ephemeral Tributary of Barrett Slough Lower Columbia Method 3 ‐ Open cut Minor Co 04.2 S5BCL063 Intermittent Tributary of Barrett Slough Lower Columbia Method 3 ‐ Open cut Minor Co 04.4 S5BCL064 Perennial Barrett Slough Lower Columbia Method 1 ‐ Flume Minor Co 0 4.5 S5BCL066 Intermittent Tributary of Barrett Slough Lower Columbia Method 3 ‐ Open cut Minor Co 04.7 S5BCL068 Intermittent Tributary of Green Slough Lower Columbia Method 3 ‐ Open cut Minor Co 04.8 S5BCL069 Intermittent Tributary of Green Slough Lower Columbia Method 3 ‐ Open cut Minor Co 05.0 S5BCL071 Intermittent Tributary of Lewis and Clark River Lower Columbia Method 3 ‐ Open cut Minor FaCh 05.2 S5BCL072 Perennial Tributary of Lewis and Clark River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 05.7 S99CL064 Perennial Lewis and Clark River Lower Columbia Method 2 ‐ Method 2 ‐ 

HDD

Major Co, FaCh 0 

5.9 S38CL003 Proxy Data Tributary of Lewis and Clark River Lower Columbia TBD Minor Co 06.8 S5BCL075 Ephemeral Tributary of Johnson Slough Lower Columbia Method 3 ‐ Open cut Minor 7.9 S1BCL001 Perennial Heckard Creek Lower Columbia Method 1 ‐ Flume Intermediate Co 08.6 S1BCL002 Intermittent Tributary of Lewis and Clark River Lower Columbia Method 3 ‐ Open cut Minor Co ,FaCh 18.8 S1BCL018 Perennial Tributary of Lewis and Clark River Lower Columbia Method 1 ‐ Flume Intermediate Co, FaCh 19.1 S1BCL003 Intermittent Tributary of Lewis and Clark River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 09.3 S1BCL004 Intermittent Tributary of Lewis and Clark River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 09.7 S1BCL005 Intermittent Tributary of Lewis and Clark River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 09.7 S1BCL006 Ephemeral Tributary of Lewis and Clark River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 09.9 S1BCL007 Intermittent Tributary of Lewis and Clark River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 010.0 S1BCL008 Perennial Tributary of Lewis and Clark River Lower Columbia Method 1 ‐ Flume Intermediate Co, FaCh 011.0 S99CL034 Proxy Data Lewis and Clark River Lower Columbia TBD Minor Co, FaCh 012.8 S1BCL016 Perennial Tributary of Speelyai Creek Lower Columbia Method 1 ‐ Flume Minor Co 113.8 S5BCL040 Perennial Tributary of Youngs River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 213.8 S5BCL041 Perennial Tributary of Youngs River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 213.9 S5BCL042 Intermittent Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 213.9 S5BCL043 Ephemeral Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 2
ATTACHMENT 2 

WATERBODIES TO BE CROSSED USING THE OPEN-CUT, FLUME, DAM-AND-PUMP, OR HDD METHODS ATTACHMENT 2-2 ATTACHMENT 2Waterbodies to Be Crossed Using Open‐Cut, Flume, Dam‐and‐Pump, or HDD Methods

Milepost Stream ID

Stream

Typea Water Bodyb

Hydrologic Unit

Code

(4th Order) Crossing Method

Water Body

Typec Fish Speciesd

M

S

H

14.1 S5BCL045 Perennial Tributary of Youngs River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 214.2 S5BCL044 Perennial Tributary of Youngs River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 214.9 S5BCL038 Intermittent Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 215.3 S5BCL035 Intermittent Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 215.6 S5BCL030 Perennial Tributary of Youngs River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 215.6 S5BCL034 Perennial Tributary of Youngs River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 215.8 S5BCL031 Perennial Tributary of Youngs River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 216.1 S99CL024 Proxy Data Tributary of Lewis and Clark River Lower Columbia TBD Minor Co, FaCh 016.1 Bayney Creek Lower Columbia16.7 S5BCL032 Ephemeral Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 217.3 S5BCL077 Perennial Tributary of Youngs River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 317.8 S5BCL079 Intermittent Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 417.9 S5BCL078 Intermittent Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 417.9 S5BCL080 Intermittent Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 418.4 S5BCL076 Perennial Tributary of Rock Creek Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 418.5 S1BCL009 Perennial Rock Creek Lower Columbia Method 1 ‐ Flume Intermediate Co, FaCh 418.8 S1BCL010 Intermittent Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 519.0 S1BCL011 Perennial Tributary of Youngs River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 519.1 S1BCL012 Intermittent Unnamed Lower Columbia Method 1 ‐ Flume Minor 219.3 S1BCL014 Perennial Osgood Creek Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 519.6 S2BCL013A Perennial Tributary of Osgood Creek Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 520.1 S2BCL013B Perennial Fox Creek Lower Columbia Method 1 ‐ Flume Intermediate Co, FaCh 621.4 S38CL013 Perennial South Fork Youngs River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 721.8 S5BCL058 Perennial Tributary of Youngs River Lower Columbia Method 1 ‐ Flume Intermediate Co, FaCh 722.1 S5BCL049 Perennial Tributary of Youngs River Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 722.2 S5BCL048 Ephemeral Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 722.5 S6BCL020 Intermittent Tributary of Fall Creek Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 822.6 S6BCL017 Ephemeral Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 822.6 S6BCL018 Ephemeral Tributary of Fall Creek Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 822.8 S6BCL015 Ephemeral Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 8
WATERBODIES TO BE CROSSED USING THE OPEN-C

ES030613113935PDX ATTACHMENT 2Waterbodies to Be Crossed Using Open‐Cut, Flume, Dam‐and‐Pump, or HDD Methods

Milepost Stream ID

Stream

Typea Water Bodyb

Hydrologic Unit

Code

(4th Order) Crossing Method

Water Body

Typec Fish Speciesd

M

S

H

22.8 S6BCL016 Ephemeral Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 823.0 S6BCL019 Perennial Tributary of Fall Creek Lower Columbia Method 1 ‐ Flume Intermediate Co, FaCh 823.4 S38CL014 Perennial Fall Creek Lower Columbia Method 1 ‐ Flume Minor Co, FaCh 924.3 S5BCL016 Intermittent Tributary of Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co, FaCh 224.4 S5BCL018 Perennial Tributary of Fishhawk Creek Nehalem Method 1 ‐ Flume Minor Co, FaCh 224.4 S5BCL017 Intermittent Tributary of Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co, FaCh 224.8 S2BCL001 Intermittent Tributary of Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co, FaCh 224.8 S2BCL002 Intermittent Tributary of Fishhawk Creek Nehalem Method 3 ‐ Open cut Intermediate Co, FaCh 225.1 S2BCL003 Ephemeral Tributary of Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co, FaCh 125.2 S2BCL005 Perennial Tributary of Fishhawk Creek Nehalem Method 1 ‐ Flume Intermediate Co, FaCh 125.2 S2BCL004 Intermittent Tributary of Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co, FaCh 125.3 S2BCL007 Perennial Tributary of Fishhawk Creek Nehalem Method 3 ‐Method 3 ‐ 

Open cut

Minor Co, FaCh 1

25.4 S2BCL008A Perennial Tributary of Fishhawk Creek Nehalem Method 1 ‐ Flume Intermediate Co, FaCh 125.7 S2BCL009 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 ‐ Flume Intermediate Co 425.7 S38CL015 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 ‐ Flume Minor Co 425.7 S2BCL010 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co 425.9 S2BCL012 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co 426.3 S5BCL019 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 ‐ Flume Minor Co 326.5 S5BCL029 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 ‐ Flume Minor Co 326.6 S5BCL027 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 ‐ Flume Minor Co 326.6 S5BCL028 Ephemeral Tributary of Little Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co 326.8 S5BCL023 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 ‐ Flume Minor Co 326.8 S5BCL025 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 ‐ Flume Minor Co 327.0 S5BCL022 Ephemeral Tributary of Little Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co 327.2 S5BCL021 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 ‐ Flume Minor Co 327.3 S5BCL020 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 ‐ Flume Minor Co 227.4 S5BCL015 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 ‐ Flume Minor Co 227.6 S5BCL014 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co 227.8 S5BCL012 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co 227.8 S5BCL013 Intermittent Tributary of Little Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co 2
ATTACHMENT 2 

WATERBODIES TO BE CROSSED USING THE OPEN-CUT, FLUME, DAM-AND-PUMP, OR HDD METHODS ATTACHMENT 2-4 ATTACHMENT 2Waterbodies to Be Crossed Using Open‐Cut, Flume, Dam‐and‐Pump, or HDD Methods

Milepost Stream ID

Stream

Typea Water Bodyb

Hydrologic Unit

Code

(4th Order) Crossing Method

Water Body

Typec Fish Speciesd

M

S

H

27.9 S5BCL011 Ephemeral Tributary of Little Fishhawk Creek Nehalem Method 3 ‐ Open cut Minor Co 228.1 S5BCL010 Perennial Tributary of Little Fishhawk Creek Nehalem Method 1 ‐ Flume Minor Co 228.4 S5BCL007 Intermittent Tributary of East Humbug Creek Nehalem Method 3 ‐ Open cut Minor Co 128.5 S5BCL004 Intermittent Tributary of East Humbug Creek Nehalem Method 3 ‐ Open cut Minor Co 128.5 S5BCL005 Intermittent Tributary of East Humbug Creek Nehalem Method 3 ‐ Open cut Minor Co 129.0 S5BCL001 Intermittent Tributary of East Humbug Creek Nehalem Method 3 ‐ Open cut Minor Co 029.0 S5BCL002 Intermittent Tributary of East Humbug Creek Nehalem Method 3 ‐ Open cut Minor Co 029.4 S6BCL011 Ephemeral Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 829.4 S6BCL013 Ephemeral Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 829.4 S6BCL014 Ephemeral Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 829.5 S6BCL010 Ephemeral Tributary of Youngs River Lower Columbia Method 3 ‐ Open cut Minor Co, FaCh 829.9 S6BCL008 Ephemeral Tributary of East Humbug Creek Nehalem Method 3 ‐ Open cut Minor Co 030.2 S6BCL007 Intermittent Tributary of East Humbug Creek Nehalem Method 3 ‐ Open cut Minor Co 030.4 S6BCL006 Perennial Tributary of East Humbug Creek Nehalem Method 1 ‐ Flume Minor Co 030.9 S2BCL021 Ephemeral Tributary of East Humbug Creek Nehalem Method 3 ‐ Open cut Minor Co 031.4 S2BCL008B Perennial Alder Creek Nehalem Method 1 ‐ Flume Minor Co 0 31.6 S6BCL005 Perennial Tributary of East Humbug Creek Nehalem Method 1 ‐ Flume Minor Co 032.0 S3BCL001 Intermittent Tributary of Nehalem River Nehalem Method 3 ‐ Open cut Minor Co, SpCh,

FaCh

0

32.0 S3BCL002 Intermittent Tributary of Nehalem River Nehalem Method 3 ‐ Open cut Minor Co, SpCh,

FaCh

0

32.1 S3BCL003 Intermittent Tributary of Nehalem River Nehalem Method 3 ‐ Open cut Minor Co, SpCh,

FaCh

0

32.1 S3BCL004 Intermittent Tributary of Nehalem River Nehalem Method 3 ‐ Open cut Minor Co, SpCh,

FaCh

0

32.3 S3BCL005 Intermittent Tributary of Nehalem River Nehalem Method 3 ‐ Open cut Minor Co, SpCh,

FaCh

0

32.3 S3BCL006 Intermittent Tributary of Nehalem River Nehalem Method 3 ‐ Open cut Minor Co, SpCh,

FaCh

0

32.4 S3BCL007 Intermittent Tributary of Nehalem River Nehalem Method 3 ‐ Open cut Minor Co, SpCh,

FaCh

0

33.5 S99CL108 Perennial Nehalem River Nehalem Method 2 ‐ Method 2 ‐ 

HDD

Major Co, SpCh,

FaCh

0 
WATERBODIES TO BE CROSSED USING THE OPEN-C

ES030613113935PDX ATTACHMENT 2Waterbodies to Be Crossed Using Open‐Cut, Flume, Dam‐and‐Pump, or HDD Methods

Milepost Stream ID

Stream

Typea Water Bodyb

Hydrologic Unit

Code

(4th Order) Crossing Method

Water Body

Typec Fish Speciesd

M

S

H

33.5 Perennial Nehalem River Nehalem34.4 S5BCL046 Perennial Tributary of Nehalem River Nehalem Method 1 ‐ Flume Minor Co, SpCh,

FaCh

1

35.5 S6BCL026 Perennial Osweg Creek Nehalem Method 1 ‐ Flume Intermediate Co, SpCh,

FaCh

0

37.5 S38CL011 Perennial North Fork Quartz Creek Nehalem Method 1 ‐ Flume Minor Co 037.5 S8BCL009 Perennial Tributary of South Fork Rock Creek Nehalem Method 1 ‐ Flume Intermediate Co 0 38.5 S8BCL005 Perennial Rock Creek Nehalem Method 2 ‐ HDD Intermediate Co 0 39.6 S1BCL029 Intermittent Tributary of Military Creek Nehalem Method 3 ‐ Open cut Minor Co 039.8 S1BCL027 Intermittent Tributary of Military Creek Nehalem Method 3 ‐ Open cut Minor Co 039.8 S1BCL028 Intermittent Tributary of Military Creek Nehalem Method 3 ‐ Open cut Minor Co 042.6 S1BCL020 Perennial Tributary of South Fork Rock Creek Nehalem Method 1 ‐ Flume Minor Co 043.1 S1BCL021 Perennial South Fork Rock Creek Nehalem Method 2 ‐ HDD Intermediate Co 0 43.3 S1BCL022 Perennial Bear Creek Nehalem Method 2 ‐ HDD Intermediate Co 0 43.5 S1BCL023 Intermittent Tributary of Bear Creek Nehalem Method 2 ‐ HDD Minor Co 043.7 S1BCL024 Perennial Tributary of Bear Creek Nehalem Method 1 ‐ Flume Minor Co 043.9 S1BCL025 Intermittent Tributary of Bear Creek Nehalem Method 3 ‐ Open cut Minor Co 044.0 S1BCL026 Intermittent Tributary of Bear Creek Nehalem Method 3 ‐ Open cut Minor Co 044.2 S1BTI001 Perennial Bear Creek Nehalem Method 1 ‐ Flume Minor Co 044.3 S1BTI002 Intermittent Tributary of Bear Creek Nehalem Method 3 ‐ Open cut Minor Co 044.8 S6BCL004 Intermittent Tributary of East Humbug Creek Nehalem Method 3 ‐ Open cut Minor Co 045.1 S1BTI003 Ephemeral Tributary of Wolf Creek Nehalem Method 3 ‐ Open cut Minor Co, SpCh 247.6 S99CO001 Perennial North Fork Wolf Creek Nehalem Method 1 ‐ Flume Proxy Data Co, SpCh, St 048.3 S1BCO000 Perennial Tributary of North Fork Wolf Creek Nehalem Method 1 ‐ Flume Minor TBD 050.5 S3BCO012 Perennial Clear Creek Nehalem Method 1 ‐ Flume Intermediate Co 053.6 S3BCO002 Perennial Fall Creek Nehalem Method 1 ‐ Flume Minor TBD 255.7 S3BCO107 Perennial Cedar Creek Nehalem Method 1 ‐ Flume Minor Co 055.9 S3BCO106 Perennial Tributary of Cedar Creek Nehalem Method 1 ‐ Flume Minor not confirmed 057.7 S3BCO100 Perennial Tributary of Rock Creek Nehalem Method 2 ‐ HDD Minor not confirmed 057.7 S3BCO101 Perennial Rock Creek Nehalem Method 2 ‐ HDD Intermediate Co, SpCh, St 063.8 S3BCO014 Perennial Nehalem River Nehalem Method 2 ‐ HDD Intermediate Co, SpCh, St 0
ATTACHMENT 2 

WATERBODIES TO BE CROSSED USING THE OPEN-CUT, FLUME, DAM-AND-PUMP, OR HDD METHODS ATTACHMENT 2-6 ATTACHMENT 2Waterbodies to Be Crossed Using Open‐Cut, Flume, Dam‐and‐Pump, or HDD Methods

Milepost Stream ID

Stream

Typea Water Bodyb

Hydrologic Unit

Code

(4th Order) Crossing Method

Water Body

Typec Fish Speciesd

M

S

H

66.3 S3BCO103 Intermittent Tributary of Oak Ranch Creek Nehalem Method 3 ‐ Open cut Minor not confirmed 066.3 Perennial Oak Ranch Creek Nehalem69.0 S99CO004 Intermittent Tributary of Oak Ranch Creek Nehalem Method 3 ‐ Open cut Proxy Data not confirmed 070.1 S3BCO003 Intermittent Tributary of Clatskanie River Lower Columbia‐

Clatskanie

Method 3 ‐ Open cut Intermediate not confirmed 0

70.7 S3BCO004 Perennial Clatskanie River Lower Columbia‐

Clatskanie

Method 1 ‐ Flume Intermediate Co, St 0

71.8 S5BCO001 Perennial Little Clatskanie River Lower Columbia‐

Clatskanie

Method 1 ‐ Flume Minor Co 0

72.5 S3BCO008 Perennial/Int

ermittent

Tributary of Deer Island Slough Lower Willamette Method 1 ‐ Flume Minor not confirmed 0

72.8 S3BCO010 Perennial Deer Island Slough Lower Willamette Method 1 ‐ Flume Intermediate Co, St 073.4 S1BCO004 Perennial Apilton Creek Lower Willamette Method 1 ‐ Flume Minor TBD 073.5 S1BCO005 Intermittent Tributary of Apilton Creek Lower Willamette Method 3 ‐ Open cut Minor TBD 074.5 S99CO009 Intermittent Tributary of Deer Island Slough Lower Willamette Method 3 ‐ Open cut Proxy Data not confirmed 074.7 S99CO012 Perennial Deer Island Slough Lower Willamette Method 1 ‐ Flume Proxy Data Co, St 076.0 S3BCO110 Intermittent Tributary of Merrill Creek Lower Columbia‐

Clatskanie

Method 3 ‐ Open cut Minor not confirmed 0

76.2 S99CO013 ? Merrill Creek Lower Columbia‐

Clatskanie

Method 1 ‐ Flume Proxy Data TBD 0

78.1 S2BCO009 Intermittent Tributary of Merrill Creek Lower Columbia‐

Clatskanie

Method 3 ‐ Open cut Minor not confirmed 0

78.2 S3BCO122 Perennial Tributary of Merrill Creek Lower Columbia‐

Clatskanie

Method 1 ‐ Flume Minor Co 0

78.8 S3BCO120 Intermittent Tributary of Merrill Creek Lower Columbia‐

Clatskanie

Method 3 ‐ Open cut Minor not confirmed 0

78.8 S3BCO119 Intermittent Tributary of Merrill Creek Lower Columbia‐

Clatskanie

Method 3 ‐ Open cut Minor not confirmed 0

79.7 S3BCO115 Perennial Tributary of Merrill Creek Lower Columbia‐

Clatskanie

Method 1 ‐ Flume Minor TBD 2

81.4 S99CO011 Perennial Benham/Deer Island Slough Lower Columbia‐

Clatskanie

Method 1 ‐ Flume Proxy Data TBD 0

81.8 S3BCO123 Intermittent Dyna Nobel Channel Lower Columbia‐

Clatskanie

Method 3 ‐ Open cut Intermediate TBD 0
WATERBODIES TO BE CROSSED USING THE OPEN-C

ES030613113935PDX ATTACHMENT 2Waterbodies to Be Crossed Using Open‐Cut, Flume, Dam‐and‐Pump, or HDD Methods

Milepost Stream ID

Stream

Typea Water Bodyb

Hydrologic Unit

Code

(4th Order) Crossing Method

Water Body

Typec Fish Speciesd

M

S

H

81.9 S99CO014 Perennial Columbia River Lower Columbia‐

Clatskanie

Method 2 ‐ HDD Major TBD 0

83.3 S99CW001 Perennial Tributary of Burris Creek Lewis Method 1 ‐ Flume Proxy not confirmed 184.0 S99CW003 Perennial Tributary of Burris Creek Lewis Method 1 ‐ Flume Proxy TBD 385.1 S99CW002 Perennial Burris Creek Lewis Method 1 ‐ Flume Proxy TBD 085.1 S99CW006 Perennial Tributary of Burris Creek Lewis Method 1 ‐ Flume Minor not confirmed 085.1 S99CW007 Perennial Tributary of Burris Creek Lewis Method 1 ‐ Flume Proxy not confirmed 285.7 S99CW009 Perennial Tributary of Burris Creek Lewis Method 1 ‐ Flume Proxy not confirmed 286.1 S99CW010 Perennial Tributary of Burris Creek Lewis Method 1 ‐ Flume Proxy not confirmed 186.1 Perennial Burris Creek Lewisa As determined by field observation or the U.S. Geological Survey (USGS) 7.5‐minute topographic maps. Intermittent: has surface flow for at least 3 months 

connection to groundwater; ephemeral ‐ has only surface flow for a portion of the year, no connection to groundwater; perennial: contains flow all year lon

b Waterbody names are as depicted on USGS 7.5‐minute topographic maps.c Stream designation includes minor, intermediate, and major waterbodies crossed by the Project. Minor waterbodies include all waterbodies less than or eq

edge at the time of crossing; intermediate waterbodies include all waterbodies greater than 10 feet wide but less than or equal to 100 feet wide at the wate

major waterbodies include all waterbodies greater than 100 feet wide at the water's edge at the time of crossing.

d Fisheries classifications within the state of Oregon are considered to be coldwater fisheries (see Oregon LNG Bidirectional Project Resource Report 3 — Fish

[CH2M HILL, May 2013] for more information).

Abbreviations:Co = Coho SalmonE = Ephemeral

FaCh = Fall Chinook Salmon

I = Intermittent

MP = Milepost

NA = Not available

NDA = No data available

P = Perennial

SpCh = Spring Chinook Salmon

St = Winte

TBD = To b

Proxy Data = These data were provided by the National Wetlands Inventory (NWI) database, the Warrington Local Wetland Inventory (LWI) database, the Pa

Framework, and the Natural Resources Conservation Service (NRCS) Soil Survey Geographic (SSURGO) database.

The data do not include certain information, such as stream type, stream width, or wetland type. Once the final Pipeline route is approved and access to the

be collected.Data will be provided in the final submittal of environmental resource reports.

Additional Notes:

Stream ID numbers beginning in S99 are for areas with no field access and are based on aerial photo and Pacific Northwest Hydrography Network database.

Remaining data are from field surveys.

Duplicate milepost numbers occur because of rounding of mileposts to nearest tenth of a mile.

Attachment 3 

Guidelines for Electrofishing Water 

Containing Salmonids Listed Under the 

Endangered Species Act 

1

National

Marine

Fisheries

Service

Guidelines for Electrofishing Waters 

Containing Salmonids Listed Under 

the Endangered Species Act

June 2000

Purpose and Scope

The purpose of this document is to provide guidelines for the safe use of backpack

electrofishing in waters containing salmonids listed by the National Marine Fisheries Service (NMFS)

under the Endangered Species Act (ESA). It is expected that these guidelines will help improve

electrofishing technique in ways which will reduce fish injury and increase electrofishing efficiency. 

These guidelines and sampling protocol were developed from NMFS research experience and input

from specialists in the electrofishing industry and fishery researchers. This document outlines

electrofishing procedures and guidelines that NMFS has determined to be necessary and advisable

when working in freshwater systems where threatened or endangered salmon and steelhead may be

found. As such, the guidelines provide a basis for reviewing proposed electrofishing activities submitted

to NMFS in the context of ESA Section 10 permit applications as well as scientific research activities

proposed for coverage under an ESA Section 4(d) rule.

These guidelines specifically address the use of backpack electrofishers for sampling juvenile or

adult salmon and steelhead that are not in spawning condition. Electrofishing in the vicinity of adult

salmonids in spawning condition and electrofishing near redds are not discussed as there is no justifiable

basis for permitting these activities except in very limited situations (e.g., collecting brood stock, fish

rescue, etc.). The guidelines also address sampling and fish handling protocols typically employed in

electrofishing studies. While the guidelines contain many specifics, they are not intended to serve as an

electrofishing manual and do not eliminate the need for good judgement in the field.

Finally, it is important to note that researchers wishing to use electrofishing in waters containing

listed salmon and steelhead are not necessarily precluded from using techniques or equipment not

addressed in these guidelines (e.g., boat electrofishers). However, prior to authorizing the take of listed

salmonids under the ESA, NMFS will require substantial proof that such techniques/equipment are

clearly necessary for a particular study and that adequate safeguards will be in place to protect

threatened or endangered salmonids. Additional information regarding these guidelines or other

research issues dealing with salmon and steelhead listed under the ESA can be obtained from NMFS’

Protected Resources Divisions in:

Washington, Oregon, and Idaho California

Leslie Schaeffer Dan Logan

NMFS NMFS 

525 NE Oregon Street, Suite 500 777 Sonoma Ave., Room 325

Portland, Oregon 97232-2737 Santa Rosa, California 95404-6515

Phone: (503) 230-5433 Phone: (707) 575-6053 

FAX: (503) 230-5435 FAX: (707) 578-3435

Internet Address: Leslie.Schaeffer@noaa.gov Internet Address: Dan.Logan@noaa.gov
2

Appropriateness of Electrofishing

Backpack electrofishing for salmonids has been a principal sampling technique for decades,

however, recent ESA listings underscore the need to regulate the technique and assess its risks and

benefits to listed species (Nielsen 1998). With over 25 Evolutionarily Significant Units (ESUs) of

threatened or endangered salmonids now identified along the U.S. West Coast, researchers can expect to

encounter one or more listed species in nearly every river basin in California, Oregon, Washington, and

Idaho. There are few if any non-invasive ways to collect distribution, abundance, or morphophysiological data on salmonids in freshwater. This is reflected in the requirement that all activities that

involve intentional take of juvenile salmonids for research or enhancement of an ESA listed species

require an ESA Section 10 permit from NMFS. While NMFS has not precluded the use of

electrofishing in all cases, researchers must present rigorous study designs and methods for handling fish

prior to NMFS authorizing electrofishing to take listed salmonids under the ESA.

NMFS believes there is ample evidence that electrofishing can cause serious harm to fish and the

general agency position is to encourage researchers to seek out other less invasive ways to sample listed

species. Direct observation by snorkeling is one of the least invasive ways to collect information concerning

abundance and distribution, although there can be both practical (e.g., poor viability) and statistical (e.g.,

large numbers of fish, low observation probability) constraints to direct observation. Preliminary efforts

should be directed at study designs that use less invasive methods. If such methods cannot provide the

quality of data required or when the benefit exceeds potential mortality risk, then electrofishing can be

considered. Electrofishing used on a limited basis to calibrate direct observations (e.g., Hankin and

Reeves 1988) is commonly used and methods are currently under development that increase the use of

direct observation counts (e.g., bounded counts, “multiple snorkel passes”) which, in many cases, will

further reduce the need for electrofishing.

Electrofishing Guidelines

Training

Field supervisors and crew members must have appropriate training and experience with electrofishing

techniques. Training for field supervisors can be acquired from programs such as those offered from the U.

S. Fish and Wildlife Service - National Conservation Training Center (Principles and Techniques of

Electrofishing course) where participants are presented information concerning such topics as electric

circuit and field theory, safety training, and fish injury awareness and minimization. A crew leader having at

least 100 hours of electrofishing experience in the field using similar equipment must train the crew. The

crew leader’s experience must be documented and available for confirmation; such documentation may be

in the form of a logbook. The training must occur before an inexperienced crew begins any electrofishing

and should be conducted in waters that do not contain ESA-listed fish. Field crew training must include the

following elements:

1. A review of these guidelines and the equipment manufacturer’s recommendations, including basic

gear maintenance.

2. Definitions of basic terminology (e.g. galvanotaxis, narcosis, and tetany) and an explanation of how

electrofishing attracts fish.

3. A demonstration of the proper use of electrofishing equipment (including an explanation of how

gear can injure fish and how to recognize signs of injury) and of the role each crew member
3

performs.

4. A demonstration of proper fish handling, anesthetization, and resuscitation techniques.

5. A field session where new individuals actually perform each role on the electrofishing crew.

Research Coordination

Research activities should be coordinated with fishery personnel from other agencies/parties to avoid

duplication of effort, oversampling small populations, and unnecessary stress on fish. Researchers should

actively seek out ways to share data on threatened and endangered species so that fish samples yield as

much information as possible to the research community. NMFS believes that the state fishery agencies

should play a major role in coordinating salmonid research and encourages researchers to discuss their

study plans with these agencies prior to approaching NMFS for an ESA permit.

Initial Site Surveys and Equipment Settings

1. In order to avoid contact with spawning adults or active redds, researchers must conduct a careful visual

survey of the area to be sampled before beginning electrofishing. 

2. Prior to the start of sampling at a new location, water temperature and conductivity measurements

should be taken to evaluate electroshocker settings and adjustments. No electrofishing

should occur when water temperatures are above 18°C or are expected to rise

above this temperature prior to concluding the electrofishing survey. In

addition, studies by NMFS scientists indicate that no electrofishing should occur

in California coastal basins when conductivity is above 350 μS/cm.

3. Whenever possible, a block net should be placed below the area being sampled to capture stunned fish

that may drift downstream.

4. Equipment must be in good working condition and operators should go through the manufacturer's

preseason checks, adhere to all provisions, and record major maintenance work in a logbook.

5. Each electrofishing session must start with all settings (voltage, pulse width, and pulse rate) set to the

minimums needed to capture fish. These settings should be gradually increased only to the point

where fish are immobilized and captured, and generally not allowed to exceed conductivity-based

maxima (Table 1). Only direct current (DC) or pulsed direct current (PDC) should be used.

Table 1. Guidelines for initial and maximum settings for backpack electrofishing.

Initial

settings

Maximum

 settings

Notes

Voltage 100 V Conductivity (μS/cm) Max. Voltage

 < 100 1100 V

 100 - 300 800 V

 > 300 400 V

 In California coastal basins, settings 

 should never exceed 400 volts. 

 Also, no electrofishing should 

 occur in these basins if 

 conductivity is greater than

 350 μS/cm.

Pulse width 500 μs 5 ms

Pulse rate 30 Hz 70 Hz In general, exceeding 40 Hz will 

 injure more fish
4

Electrofishing Technique

1. Sampling should begin using straight DC. Remember that the power needs to remain on until the fish is

netted when using straight DC. If fish capture is unsuccessful with initial low voltage, gradually increase

voltage settings with straight DC.

2. If fish capture is not successful with the use of straight DC, then set the electrofisher to lower voltages with

PDC. If fish capture is unsuccessful with low voltages, increase pulse width, voltage, and pulse

frequency (duration, amplitude, and frequency).

4. Electrofishing should be performed in a manner that minimizes harm to the fish. Stream segments should be

sampled systematically, moving the anode continuously in a herringbone pattern (where feasible)

through the water. Care should be taken when fishing in areas with high fish concentrations, structure

(e.g., wood, undercut banks) and in shallow waters where most backpack electrofishing for juvenile

salmonids occurs. Voltage gradients may be high when electrodes are in shallow water where

boundary layers (water surface and substrate) tend to intensify the electrical field. 

5. Do not electrofish in one location for an extended period (e.g., undercut banks) and regularly check block

nets for immobilized fish. 

6. Fish should not make contact with the anode. Remember that the zone of potential injury for fish is 0.5 m

from the anode.

7. Electrofishing crews should be generally observant of the condition of the fish and change or terminate

sampling when experiencing problems with fish recovery time, banding, injury, mortality, or other

indications of fish stress. 

8. Netters should not allow the fish to remain in the electrical field any longer than necessary by removing

stunned fish from the water immediately after netting.

Sample Processing and Recordkeeping

1. Fish should be processed as soon as possible after capture to minimize stress. This may require a larger

crew size.

2. All sampling procedures must have a protocol for protecting held fish. Samplers must be aware of the

conditions in the containers holding fish; air pumps, water transfers, etc., should be used as necessary to

maintain safe conditions. Also, large fish should be kept separate from smaller prey-sized fish to avoid

predation during containment.

3. Use of an approved anesthetic can reduce fish stress and is recommended, particularly if additional handling

of fish is required (e.g., length and weight measurements, scale samples, fin clips, tagging). 

4. Fish should be handled properly (e.g., wetting measuring boards, not overcrowding fish in buckets, etc.).

5. Fish should be observed for general condition and injuries (e.g., increased recovery time, dark bands,

apparent spinal injuries). Each fish should be completely revived before releasing at the location of

capture. A plan for achieving efficient return to appropriate habitat should be developed before each

sampling session. Also, every attempt should be made to process and release ESA-listed specimens

first.

8. Pertinent water quality (e.g., conductivity and temperature) and sampling notes (e.g., shocker settings, fish

condition/injuries/mortalities) should be recorded in a logbook to improve technique and help train new

operators. It is important to note that records of injuries or mortalities pertain to the entire

electrofishing survey, including the fish sample work-up.
5

Citations and Other References

Dalbey, S. R., T. E. McMahon, and W. Fredenberg. 1996. Effect of electrofishing pulse shape and

electrofishing-induced spinal injury on long-term growth and survival of wild rainbow trout. North

American Journal of Fisheries Management 16:560-569.

Hankin, D. G., and G. H. Reeves. 1988. Estimating total fish abundance and total habitat area in small streams

based on visual estimation methods. Canadian Journal of Fisheries and Aquatic Sciences 45:834-844.

Hollender, B. A., and R. F. Carline. 1994. Injury to wild brook trout by backpack electrofishing. North

American Journal of Fisheries Management 14:643-649.

Nielsen, J. L. 1998. Electrofishing California’s endangered fish populations. Fisheries 23:6-12.

Nielsen, L.A., and D.L. Johnson, editors. 1983. Fisheries techniques. American Fisheries Society, Bethesda,

Maryland.

Reynolds, J. B., and A. L. Kolz. 1988. Electrofishing injury to large rainbow trout. North American Journal of

Fisheries Management 8:516-518.

Sharber, N. G., and S. W. Carothers. 1988. Influence of electrofishing pulse shape on spinal injuries in adult

rainbow trout. North American Journal of Fisheries Management 8:117-122.

Sharber, N. G., S. W. Carothers, J.P. Sharber, J. D. deBos, Jr., and D. A. House. 1994. Reducing

electrofishing-induced injury of rainbow trout. North American Journal of Fisheries Management

14:340-346.

Schreck, C.B., and P.B. Moyle, editors. 1990. Methods for fish biology. American Fisheries Society,

Bethesda, Maryland.

APPENDIX F6 

TECHNICAL MEMORANDUM: MIGRATORY BIRDS—REGULATORY 

REVIEW AND MITIGATION

ES030613113935PDX 1

TECHNICAL MEMORANDUM

Migratory Birds—Regulatory Review and Mitigation

PREPARED FOR: Resource Report 3

PREPARED BY Bridget Canty/PDX

Jay Lorenz/PDX

Renee Storey/PDX

DATE: May 1, 2013

Introduction

Migratory birds are protected by the federal Migratory Bird Treaty Act (MBTA) of 1918, as amended (16 United 

States Code [U.S.C.] 703-712). The Memorandum of Understanding between the Federal Energy Regulatory 

Commission and U.S. Department of the Interior United States Fish and Wildlife Service (USFWS) regarding 

implementation of Executive Order 13186, “Responsibilities of Federal Agencies to Protect Migratory Birds” (FERC 

and USFWS, 2011) (MBTA MOU) provides guidance on complying with the MBTA. This technical memorandum 

provides regulatory background on migratory birds relative to commercial logging and Pipeline operations. It also 

presents recommendations for avoidance of impacts to migratory birds and for stewardship compliance with the

MBTA MOU. Oregon LNG proposes to clear land, including trees on commercial timberland, within a nominal

100-foot-wide construction corridor and associated additional temporary workspaces to accommodate the 

Pipeline. Vegetated habitats, including commercial forests, may provide habitat for many species of migratory 

birds, including raptors and songbirds.

Regulatory Background

Section 703 of the MBTA prohibits the taking, killing, possession, transportation, and importation of migratory 

birds, their eggs, parts, and nests, except when specifically authorized by the U.S. Department of the Interior. The 

MBTA has no provision for allowing unauthorized take.

The MBTA MOU specifies that both parties shall support the conservation intent of Executive Order 13186, and 

the migratory bird conventions, to the extent possible and practicable, by the following: 

• Integrating bird conservation principles, measures, and practices into agency actions; 

• Avoiding or minimizing the take of migratory birds and adverse effects on their habitat; 

• Improving habitat conditions for migratory birds on lands affected by energy projects; and 

• Preventing or abating pollution detrimental to migratory birds and their habitats.

While the MBTA provides no mechanism for allowing unauthorized take, the USFWS recognizes that some birds 

may be taken during such activities as pipeline construction, even if all reasonable measures to avoid take are 

implemented. The USFWS Office of Law Enforcement carries out its mission to protect migratory birds not only 

through investigation and enforcement, but also through fostering relationships with individuals and industries 

that proactively seek to eliminate their impacts on migratory birds. Although it is not possible under the MBTA to 

absolve individuals, companies, or agencies from liability (even if they implement avian mortality avoidance or 

similar conservation measures), the USFWS Office of Law Enforcement focuses on those individuals, companies, 

or agencies that take migratory birds with disregard for their actions and the law, especially when conservation 

measures have been developed but are not properly implemented (Rockies Express Pipeline LLC and USFWS, 

2008).

A number of court cases have dealt with the authority of the MBTA and logging operations (Lurman, 2007). 

In 2000, nine environmental groups, including the Center for Environmental Law, submitted a document 

(SEM-99-002) asserting that the Federal government was failing to enforce Section 703 of the MBTA. The 
MIGRATORY BIRDS—REGULATORY REVIEW AND MITIGATION

2 ES030613113935PDX

submitters claimed that logging operations consistently result in violations of the MBTA, killing an enormous 

number of birds, or destroying their nests and eggs. The submitters assert that, despite being aware of these 

violations, the United States never prosecutes logging operations that violate the MBTA. The submitters 

specifically referred to two cases in California where migratory birds were killed. The first case involves the logging 

of several hundred trees by a private landowner during the nesting season of great blue herons, allegedly 

resulting in hundreds of crushed eggs. The second case involves a logging company’s alleged intentional burning 

of four trees on private land, including one allegedly used by a nesting pair of osprey.

In 2003, the North American Commission for Environmental Cooperation (CEC) conducted a legal review of how 

the MBTA has been applied to private logging operations (CEC, 2003). The CEC determined that there has never 

been a prosecution of a private timber harvest operation since the MBTA was enacted in 1918. The CEC concluded 

the following:

• USFWS has long had an “unwritten policy relative to the MBTA that no enforcement or investigative action 

should be taken in incidents involving logging operations, that result in the taking of non-endangered, nonthreatened migratory birds and/or their nests”

• Because of limited resources, USFWS has “concentrated its regulatory, enforcement, and scientific efforts to 

reducing unintentional takes of migratory birds caused by those activities where industry has created 

hazardous conditions which often attract migratory birds to their death (i.e., birds attracted to perching on

power lines or open oil pits that appear as water ponds to overflying birds”

• “Alternative statutes and non-enforcement initiatives are more effective and efficient in protecting migratory 

birds [and] habitat modification per se is not prohibited by the MBTA. This means that establishing a violation

of the MBTA due to logging activities poses more significant technical challenges than many other types of

MBTA violations. Therefore, the USFWS has thus far made bona fide decisions to allocate enforcement 

resources to investigating and prosecuting other possible violations instead of those caused by logging 

activities. The USFWS made its resource allocation decisions in good faith and always with the objective to 

conserve migratory bird populations and their habitats in sufficient quantities to prevent them from becoming 

threatened or endangered.” (CEC, 2003)

On advice of counsel, it does not appear that the MBTA imposes an affirmative duty to take specific action under 

the MBTA, other than to avoid taking of migratory birds. Logging associated with clearing a Pipeline corridor by 

itself does not trigger the need for a permit or other regulatory approval under the MBTA, as habitat destruction 

alone does not constitute a “take” under the MBTA (Seattle Audubon Society v. Evans, 952 F.2d 297 [9th Cir.,

1991]; City of Sausalito v. O’Neill, 386 F.3d 1186 [9th Cir., 2004]). However, in the interest of being good stewards 

of the environment that the Pipeline will affect, it is recommended that measures be taken to avoid take.

Mitigation

Oregon LNG will take reasonable and prudent measures to avoid the taking of birds protected by the MBTA and in 

accordance with the MBTA MOU. These measures are in addition to those that may be imposed to protect birds 

protected under the Endangered Species Act, such as the northern spotted owl and marbled murrelet (see 

Resource Report 3, Appendix 3E).

Land clearing will take place the same year as Pipeline construction (see Resource Report 1 for a Project 

schedule). Clearing will take place as late as possible in the spring and early summer to avoid as much of the 

nesting season as possible. Oregon LNG proposed land clearing in the late summer and early fall prior to Pipeline 

construction. The National Marine Fisheries Service (NMFS) was concerned that such a schedule increased risk of 

erosion into streams, particularly salmon-bearing streams. The USFWS, in consultation with NMFS, advised 

Oregon LNG that the preferred schedule would be to conduct land clearing the same year as construction. The 

corridor would then be rehabilitated at the end of the construction season, thereby limiting and minimizing 

exposure and risk of soil erosion.
MIGRATORY BIRDS—REGULATORY REVIEW AND MITIGATION

ES030613113935PDX 3

Assuming that vegetation clearing cannot be avoided during the entire nesting and breeding season, Oregon LNG 

will provide biologists to conduct a preconstruction reconnaissance of the Terminal and Pipeline corridor to 

identify any active migratory bird nests. If one or more active nests are identified within the construction corridor, 

biologists will mark the location(s) of the nest(s) in the field and on the construction plans and delay vegetation 

clearing around the active nest(s) until such time as the nest(s) have fledged or failed (due to natural causes). 

If one or more active nests are identified outside the construction corridor but nearby, the biologists will monitor 

the nest(s) during construction for signs of disturbance. If it appears that the monitored nest(s) are exhibiting 

disturbance that could lead to unintentional indirect take pursuant to the MBTA, construction should be halted 

temporarily until such time as the nest has fledged or failed (due to natural causes). Trees with nests may be cut 

during the non-nesting season. Preconstruction surveys will include an aerial survey for raptor nests in late March

prior to trees leafing out.

Vegetation clearing shall not occur within 500 feet of any existing eagle, osprey, or other raptor nest locations or 

trees used by such birds unless a variance is granted, in writing, by USFWS. Band-tailed pigeon nesting or roosting 

tree(s), as well as any tree(s) near an existing great blue heron rookery, are not to be removed unless the USFWS 

approves it in writing. Removing trees in a designated nest patch of a northern spotted owl shall be avoided. 

Removing trees in a cluster of trees known to provide nesting for marbled murrelets shall be avoided.

Unintentional take, the observation that land clearing has unintentionally killed a migratory bird, shall be reported 

to Oregon LNG’s designated environmental compliance officer within 24 hours of such an incident. The 

environmental compliance officer will be responsible for reporting the unintentional take to USFWS.

Oregon LNG will rehabilitate the Pipeline corridor to provide habitat for birds and other wildlife. In addition, 

Oregon LNG proposed extensive upland and riparian habitat mitigation in the Applicant-Prepared Conceptual 

Mitigation Plan for the Oregon LNG Terminal and Oregon Pipeline Project (CH2M HILL, 2009). The habitat 

mitigation proposed in the conceptual mitigation plan places an emphasis on preservation and management 

toward late-successional forests and riparian habitats that are in decline in the Coast Range. The combination of 

rehabilitation of the Pipeline corridor, long-term conservation of upland, and riparian habitats will benefit 

migratory birds.

References

CH2M HILL. 2009. Applicant-Prepared Conceptual Mitigation Plan for the Oregon LNG Terminal and Oregon 

Pipeline Project. FERC Dockets Docket Nos. CP09-6-000 and CP09-7-000.

Federal Energy Regulatory Commission (FERC) and U.S. Fish and Wildlife Service (USFWS). 2011. Memorandum of 

Understanding - Executive Order 13186, “Responsibilities of Federal Agencies to Protect Migratory Birds.”

Lurman, J. 2007. “Agencies in Limbo: Migratory Birds and Incidental Take by Federal Agencies.” Journal of Land 

Use 23(1): 39-60.

North American Commission for Environmental Cooperation (CEC). 2003. Final Factual Record for Submission 

SEM-99-002 (Migratory Birds). North American Environmental Law and Policy, Volume 11.

Rockies Express Pipeline LLC and U.S. Fish and Wildlife Service (USFWS). 2008. Guidelines for Achieving 

Compliance with the Migratory Bird Treaty Act and Executive Order No. 13186 Through Voluntary 

Conservation Measures Associated with the Construction and Operation of the Rockies Express Pipeline –

East Project in Missouri, Illinois, Indiana, and Ohio. Available at: http://elibrarybackup.ferc.gov/idmws/common/downloadOpen.asp?downloadfile=20080411%2D4002%2819086457%2

9%2Epdf&folder=18065594&fileid=11641229&trial=1.