ENVIRONMENTAL IMPACT ANALYSIS

SECTION 4

4-1 Geologic Conditions, Resources, And Hazards

4.0 ENVIRONMENTAL IMPACT ANALYSIS

The environmental consequence of constructing and operating the Terminal Expansion 

and Pipeline Expansion facilities would vary in duration and significance. Four levels of impact 

duration were considered: temporary, short-term, long-term, and permanent. A temporary 

impact would generally occur during construction, with the resource returning to preconstruction 

conditions almost immediately afterward. A short-term impact could continue for up to 3 years 

following construction. An impact was considered long-term if the resource would require more 

than 3 years to recover. A permanent impact could occur as a result of an activity that modifies a 

resource to the extent that it would not return to preconstruction conditions during the life of the 

Project, such as the construction and operational impact of an LNG storage tank or a compressor 

station. We considered an impact to be significant if it would result in a substantial beneficial or 

adverse change in the physical environment and the relationship of people with the environment. 

In this section, we discuss the affected environment, general construction and operational 

impacts, and proposed mitigation measures for each resource. We also discuss the design and 

construction of the facility to resist natural hazards. Cameron LNG and Cameron Interstate, as 

part of their proposals, agreed to implement certain measures to reduce impacts on 

environmental resources. We evaluated the proposed mitigation measures to determine whether 

additional measures would be necessary to reduce impacts. Where we identified the need for 

additional mitigation, the measures appear as bulleted, boldfaced paragraphs in the text. We will 

recommend that these measures be included as specific conditions to authorizations that the 

Commission may issue to Cameron LNG and Cameron Interstate. Conclusions in this EIS are 

based on our analysis of the environmental impact and the following assumptions:

• Cameron LNG and Cameron Interstate would comply with all applicable federal 

laws and regulations;

• the proposed facilities would be constructed as described in section 2.0 of this 

document; and

• Cameron LNG and Cameron Interstate would implement the mitigation measures 

included in the applications and supplemental filings to the FERC.

4.1 GEOLOGIC CONDITIONS, RESOURCES, AND HAZARDS 

4.1.1 Geologic Setting

The proposed Project lies within the Gulf Coastal Plain geomorphic province and is 

immediately underlain by sediments deposited during the Holocene and Pleistocene epochs of 

the Quaternary period. In Cameron, Beauregard, and Calcasieu Parishes, these sediments are 

underlain by southward-dipping sedimentary rocks of pre-Pleistocene Cenozoic age that are 

present in surficial outcrops in Texas and northern Louisiana. 

4.1.1.1 Terminal Expansion

The site is gently sloping with existing grade elevations ranging between 2 and 22 feet 

above current mean sea level (MSL). Much of the Project site is covered with dredge soil 

material from historic maintenance dredging of the Calcasieu Ship Channel conducted by the 
Geologic Conditions, Resources, And Hazards 4-2

COE. Additional excavated materials were placed on the property during construction of the 

existing Cameron LNG Terminal. Figure 4.1-1 is a detailed geologic map of the area in the 

vicinity of the terminal expansion.

Geotechnical investigations indicate that the subsurface sediments immediately 

underlying the proposed site consist of a 2- to 8-foot-thick layer of dredged and man-made fill 

material (Fugro 2012b). Below that depth, there is a 70- to 80-foot-deep layer of very soft to 

stiff cohesive soils and loose to medium-dense cohesionless soils over layers of stiff to very stiff 

Pleistocene-aged cohesive deposits that extend to a depth of about 200 feet (Fugro 2012b). The 

geotechnical studies suggest that bedrock is not present at the site. Therefore, Cameron LNG 

would not conduct blasting during construction. 

Cameron LNG would clear, grade, and fill the Terminal Expansion site to the extent 

necessary to install the liquefaction facilities on a level platform with sufficient space to execute 

the work safely. The final grade elevations would be above predicted hurricane storm surge 

elevations, based on Federal Emergency Management Agency (FEMA) and COE data, and 

sloped as necessary to provide for site drainage. Cameron LNG would use on-site materials as 

structural backfill, to the extent permitted by the engineering specifications, and use clean 

imported fill to supplement the onsite materials. Final grade surfacing and landscape would 

consist of gravel, asphalt, concrete, topsoil, and grass surface areas. Cameron LNG would drive 

precast concrete piles to support all key terminal expansion components and structures. These 

key components and structures include the LNG storage tanks, liquefaction trains, combustion 

turbine shelters, machinery structures and interconnecting pipe racks, structures, and sleepers. 

4.1.1.2 Pipeline Expansion 

The southern portion of the proposed pipeline route lies predominantly within sediments 

of the late Pleistocene Beaumont Formation in the extensive Gulf Coast geomorphic province. 

To the northeast, the route extends predominantly through sediments of the early Pleistocene 

Lissie Allo formation, and the terrain consists of gently rolling hills underlain by interbedded 

sand, gravelly sand, sandy gravel, and gravel rich fluvial deposits. The relief of the pipeline 

route ranges from 5 feet to approximately 65 feet above MSL. 

Geotechnical investigations indicate that the subsurface sediments underlying the

proposed route consist of silt and clayey silt over moderate to highly plastic cohesive soils 

consisting of silty clay (firm to stiff) (Fugro 2007). Below that level are layers of noncohesive 

soils containing sandy silt and sandy clay from 8 to 25 feet below the ground surface (Fugro 

2012b). Bedrock does not occur near the surface; therefore, Cameron Interstate would not 

conduct blasting. 

Cameron Interstate committed to conducting geotechnical studies to determine general 

subsurface conditions and to evaluate the potential for settlement at the Holbrook Compressor 

Station site. Further, Cameron Interstate would develop engineering designs to avoid or 

minimize any geotechnical hazards, such as settlement, at the site. That work would consist of 

development and implementation of a subsurface exploration program and a laboratory testing 

program. In general, we believe these methods would identify the geotechnical conditions at the 

site, including settlement potential, and provide the basis for developing mitigation measures to 

limit settlement impacts on the Holbrook Compressor Station.
4-3 Geologic Conditions, Resources, And Hazards

Figure 4.1-1 Geologic Resources Near the Terminal Expansion
Geologic Conditions, Resources, And Hazards 4-4

4.1.2 Mineral Resources

4.1.2.1 Terminal Expansion

Except for oil and gas, the only known potentially economic mineral resource in the 

general vicinity of the Terminal Expansion is salt. However, no mineral resources considered to 

be potentially exploitable are known to occur within the Terminal Expansion and no known 

mining resources exist within a 1-mile radius of the proposed site (USGS 2001). 

Oil and gas exploration and production occur in the general area west of the site, in the 

West Hackberry Oil Field. However, construction and operation of the expanded terminal would 

not affect those activities. Therefore, we conclude that the Terminal Expansion would not 

impact mining or oil and gas exploration activities.

4.1.2.2 Pipeline Expansion

The Pipeline Expansion would not cross any identified oil or gas production areas, and 

is therefore unlikely to affect present or future oil or gas activities in the vicinity of the route. 

Potentially exploitable mineral resources that are known to occur within the general vicinity of 

the proposed pipeline route include salt (salt domes), construction-grade sand and gravel, and 

crushed stone. However, the proposed route does not cross historic, current, or proposed mining 

areas; therefore, we believe construction of the pipeline would not affect mining activities. 

4.1.3 Geologic Hazards

Geologic hazards are defined by the American Geological Institute as “geologic 

conditions or phenomena that present a risk or are a potential danger to life and property, either 

naturally occurring or man-made” (Bates and Jackson 1984). Potential geologic hazards in the 

vicinity of the Project include seismic ground shaking, fault offsets, soil liquefaction, slope 

failures/landslides, tsunamis, erosion, flooding, and ground subsidence. Neither volcanism nor 

karst topography occurs within the vicinity of the proposed Project and these geologic hazards 

were excluded from further consideration.

4.1.3.1 Geotechnical Site Characterization

A geotechnical investigation was performed at the site of the Terminal Expansion facility 

by Fugro in April and May of 2012 (Fugro 2012). The investigation consisted of 6 soil borings 

to depths of 115 to 200 feet and 25 cone penetration tests to depths of 50 to 120 feet, with the 

results presented in Fugro’s August 2012 report. The site grades ranged between 2 feet and 22 

feet above MSL at the boring and cone penetrometer locations. 

The subsurface conditions consist of 2 to 8 feet of fill underlain by very soft to firm 

recently deposited cohesive soils that extend to depths ranging from 10 to 30 feet below site 

grade. These soils are underlain by firm-to-stiff cohesive soils and loose-to-medium dense sands 

to depths of 70 to 80 feet. In the areas explored between 70 and 200 feet deep, very stiff-to-hard 

Pleistocene clays and medium-dense to very dense sands were encountered. 

The Terminal Expansion site would be cleared, graded, and filled to achieve a general 

site grade of 13 feet above sea level. Due to the presence of very soft normally consolidated 
4-5 Geologic Conditions, Resources, And Hazards

soils, Cameron LNG would support all settlement sensitive structures on deep foundations. 

Lightly loaded structure or equipment insensitive to settlement may be supported on concrete 

pads. 

Due to raising the site grade up to 11 feet, settlement of the soft soils would continue for 

a long time and create downdrag on piles. Therefore, piles must be designed for downdrag 

loads. The foundations would be supported on 14- or 18-inch-square prestressed concrete piles 

designed for downdrag using the pile capacity curves and the recommended factors of safety in 

the Fugro (2012) geotechnical report.

Cameron LNG’s Terminal Expansion must be constructed to satisfy the design 

requirements of 49 CFR 193, NFPA 59A-2001, 2006 International Building Code, and American 

Society of Civil Engineer (ASCE) 7-05. For seismic design, the facility would also be designed 

to satisfy the requirements of NFPA 59A-2006 and ASCE 7-05.

4.1.3.2 Seismic Ground Shaking Hazards

The proposed Project is within the seismotectonic setting known as the Texas Gulf 

Coastal Plains region. Tertiary and Quaternary structures in the Texas Gulf Coastal Plains are 

related to the tectonic environment of the Gulf of Mexico passive margin. This passive margin 

environment is characterized by northeast-southwest-oriented horizontal principal compressive 

stresses, large-scale basin inward slumping of the Gulf Coastal Plains section toward the basin, 

and vertical crustal motions. The vertical crustal motions are associated with flexural loading of 

the Gulf Coastal Plains and offshore sedimentary basins, and erosion and exhumation of the 

Great Plains (Fugro 2012c).

Terminal Expansion

Cameron LNG indicated that there were no reported active seismogenic faults within a 

125-mile radius of the proposed Terminal Expansion (Fugro 2012a). Further, Cameron LNG’s 

geologic fault detection study of the proposed Terminal Expansion site determined that there is 

no likelihood of surface fault rupture at the site (Fugro 2012a).

The proposed Terminal Expansion is in an area of low seismicity. Earthquakes have 

occurred in Louisiana, but their occurrence has been infrequent, with most having a magnitude 

too low to be felt by people or to have caused serious damage to property or structures (USGS 

2001). 

Western Louisiana lies within an area that USGS estimates the peak ground accelerations 

on a rock site to be in the range of 2 to 4 percent of the acceleration of gravity (0.02 to 0.04 g) 

and have a 2 percent probability of being exceeded in 50 years (USGS 2010). These peak 

ground accelerations can be amplified by factors of two or more on soft soil sites, which are 

typical of those in the vicinity of the Project.

Geotechnical investigations of the Terminal Expansion site determined that the site is

classified as Site Class E (soft clay soil) in accordance with the International Building Code and 

standard ASCE 7-05 (Fugro 2012b). Sites with soil conditions of this type experience significant 

amplifications of surface earthquake ground motions. 
Geologic Conditions, Resources, And Hazards 4-6

The Seismic Design of the Project’s Category I items, including the new LNG tank, are 

to be based on site-specific Safe Shutdown Earthquake (SSE) and Operating Basis Earthquake 

(OBE) ground motions developed by Fugro (2012c). The site specific SSE is a ground motion 

which has a 2 percent probability of exceedance in 50 years, while the OBE has a 10 percent 

probability of exceedance in 50 years. The site-specific peak ground and spectral acceleration 

values of the SSE and OBE are provided in table 4.1.3-1.

TABLE 4.1.3-1

Probability of Seismic Hazards at the Terminal Expansion a

Probability/Return Period Peak Ground 

Acceleration (g)

Spectral Acceleration at 

0.2 Second (g)

Spectral Acceleration at 

1 Second (g)

10 percent in 50/475 years 0.041 0.107 0.075

2 percent in 50 /2475 years 0.121 0.292 0.230

a From tables 7.2-1 and 7.2-2 of Fugro (2012c) Maximum Rotated Component.

The facility structures and systems, other than the LNG tank and associated safety 

systems, are being designed to the seismic design ground motion as specified in ASCE 7-05. 

Fugro (2012c) performed a site-specific Probabilistic Seismic Hazard Analysis for the 

Terminal Expansion to determine the “. . . location, size, and resulting shaking intensity of future

earthquakes . . .” and “. . . [a] description of the distribution of future shaking that may occur at a

site” based on Baker (2008). The results of the analysis are presented in table 4.1.3-1. The 

predicted ground accelerations are relatively low compared to other locations in the United 

States.

The design of the facility is currently at the Front End Engineering Design (FEED) level 

of completion. Cameron LNG has proposed a feasible design and it has committed to 

conducting a significant amount of detailed design work for the Terminal Expansion if the 

Project is authorized by the Commission. Information regarding the development of the final 

design, as detailed below, would need to be reviewed by FERC staff in order to ensure that the 

final design addresses the requirements identified in the FEED. Further, the timing of the 

production of this information should occur prior to the stage Cameron LNG has indicated in its 

application and subsequent filings. Therefore, we are recommending that:

• Cameron LNG should file the following information, stamped and sealed by 

the professional engineer-of-record, with the Secretary of the Commission 

(Secretary):

a. LNG tank and foundation design based on the seismic design ground 

motions in Cameron LNG’s Resource Report 13, Appendix I dated 

February 2013;

b. LNG Liquefaction facility structures and foundations designs;

c. seismic specifications used in conjunction with procuring equipment; 

and 
4-7 Geologic Conditions, Resources, And Hazards

d. quality control procedures to be used for design and construction.

In addition, Cameron LNG should file, in its Implementation Plan, the 

schedule for producing this information. 

Pipeline Expansion

USGS Seismic Hazard Maps that address the areas of the pipeline expansion route and 

the Holbrook Compressor Station indicate that for a rock site, peak ground accelerations of 2 to 4 

percent of the acceleration of gravity (0.02 to 0.04 g) have a 2 percent probability of exceedance 

in 50 years (USGS 2010). These peak ground accelerations increase when site amplification 

effects are considered. However, even with this amplification, the seismic hazard risk along the 

proposed route is considered to be relatively low compared to other locations in the United 

States. 

Fugro (2012a) conducted a geologic fault hazard study of the proposed pipeline route and 

compressor station area and determined that there is no likelihood of surface fault rupture along 

the route. 

4.1.3.3 Soil Liquefaction

Soil liquefaction occurs when a saturated soil loses its load bearing capability through an 

increase in pore water pressure that results from seismic ground shaking. Saturated sandy soils 

with low silt and clay content are susceptible to soil liquefaction during seismic events. 

Because the potential for seismic ground shaking in the vicinity of the Project is low, the 

probability of soil liquefaction is also low. Additionally, Cameron LNG would address possible 

issues associated with potential liquefaction and associated loss of strength in the fill soils by 

using piles in foundation design for aboveground facilities. 

4.1.3.4 Landslide Incidence and Susceptibility 

Landslides are defined as the movement of rock, debris, or soil down a slope (USGS 

2010).The topography of the terminal expansion site and along the pipeline route is relatively 

flat, with very little grade change. As a result, the Project has a low risk of landslides. 

4.1.3.5 Ground Subsidence

Subsidence hazards involve either the sudden collapse of the ground to form a depression 

or the slow subsidence or settlement of sediments near the ground’s surface. Ground subsidence 

in the vicinity of the Project could result from natural geologic processes or from man-made 

processes, such as subsurface mining and removal of groundwater from aquifer systems.

Terminal Expansion

Cameron LNG determined that subsidence (settlement due to raising the site grade) 

relating to underlying soil settlement after facility construction would likely occur and would be 

addressed during facility design and construction. As a result, Cameron LNG would construct 

all major facilities of the terminal expansion, such as the LNG storage tank and liquefaction 

trains, using pile supported foundations that would eliminate the risk of soil subsidence affecting 
Geologic Conditions, Resources, And Hazards 4-8

facility stability. Pile supported foundations were successfully installed for the existing Cameron 

LNG Terminal. Cameron LNG would design the piles for downdrag loads due to settlement of 

the soils. 

However, the final grade of the site and the protective earth berms are subject to 

settlement. The Moffat & Nichol (2013) Revised Storm Surge Update Study indicates that 

subsidence along the Gulf Coast occurs at rate between 0.1 and 0.2 inch per year, while sea level 

rise is estimated at 0.1 inch per year. The Moffat & Nichol Study recommends that the Terminal 

Expansion be designed for a relative sea level rise of 0.3 inch per year or 6.0 inches over the next 

20 years. Cameron LNG incorporated a design allowance of 1 foot for sea level rise and 

subsidence in the finished grade elevations, including protective berms. Although subsidence is 

anticipated, we believe the Terminal Expansion design would minimize any subsidence effects 

during operation.

Pipeline Expansion

Limited groundwater pumping or oil and gas production occurs in the vicinity of the 

proposed pipeline route, and the rate of subsidence in the vicinity of the proposed Holbrook 

Compressor Station is low. In addition, there is no evidence of sinkholes or other indications of 

subsidence along the proposed pipeline route (which is parallel and adjacent to other pipelines) 

or at aboveground facilities. As a result, we conclude subsidence is not expected along the

proposed Pipeline Expansion. However, as noted above, Cameron Interstate committed to 

conducting geotechnical studies to determine general subsurface conditions and to evaluate the 

potential for settlement at the Holbrook Compressor Station site. In addition, as Cameron 

Interstate would design the pipeline and aboveground facilities to withstand minor subsidence, 

we would not expect subsidence to have an adverse effect on the Pipeline Expansion. 

4.1.4 Other Hazards

4.1.4.1 Flooding/Storm Damage

A flood occurs when the water level in a stream or river channel overflows the natural or 

man-made bank. Storm surge and tsunamis can also cause flooding. The 100-year flood 

represents a river channel water level that, based on an analysis of the historic record, is likely to 

be equaled or exceeded every 100 years, meaning that there is a 1 percent chance that the water 

level will be equaled or exceeded in any individual year during a flood event. Maximum 

tsunami inundation elevations at the Terminal Expansion site are judged to be less than 

maximum storm surge elevations. Therefore, the 100-year flood is generally used for planning 

purposes for buildings within the river channel and adjacent floodplain to assess the likelihood of 

inundation of areas within the floodplain over time. Flash floods typically result from intense 

rapid precipitation in upstream areas that leads to extensive short-duration runoff into the stream 

channel. 

Storm surge is a coastal phenomenon associated with low pressure weather systems, 

typically intense hurricanes and winter storms. The surge of ocean water inland above the high 

tide mark is a result of low barometric pressure combined with high winds pushing on the ocean 

surface causing the water to “pile up” higher than ordinary sea level. The storm surge effect is 

enhanced if it occurs at high tide (U.S. Air Force Reserves 2006).
4-9 Geologic Conditions, Resources, And Hazards

Terminal Expansion

Cameron LNG considered the potential threat of storm surge associated with hurricane 

winds in its facility design. The 500-year return period storm surge still water level is 11.3 feet 

above MSL at the Terminal Expansion site (Moffat and Nichol 2012). When global sea levels

rise, subsidence, and freeboard are added, the resulting design 500-year return-period storm 

surge elevation increases to 12.4 feet above MSL. The 100-year return-period storm-surge stillwater level is 8.1 feet above MSL at the site. When global sea level rise, subsidence, and 

freeboard are added, the design 100-year return-period storm-surge elevation increases to 9.4 feet 

above MSL. The top of support for equipment in the liquefaction and common areas would be 

12.5 feet above MSL, with the maximum finished grade 12.0 feet above MSL, and the minimum 

finished grade 11.5 feet above MSL. In the flare area, the top of support equipment would be 

10.0 feet above MSL, with a finished grade of 9.5 feet above MSL. The perimeter road 

surrounding this area would be 9.5 feet above MSL, which is above the design 100-year returnperiod storm-surge elevation. Cameron LNG would install the new full-containment LNG 

storage tank at an elevation consistent with the existing three LNG tanks; the elevation of the top 

of the foundation would be 14.0 feet above MSL and the bottom of the foundation would be 11.0 

feet above MSL. Cameron LNG would also extend the existing storm surge barrier around the 

new LNG storage tank at an elevation of 9.0 feet above MSL.

The Terminal Expansion is subject to flooding from hurricanes, tropical storms, and other 

weather systems. Cameron LNG’s design considers a hurricane storm surge with a 500-year 

return period. When subsidence and the rise in sea level are considered, the resulting design 

elevation to be resisted is several feet greater than the 100-year base flood map elevations 

provided in the FEMA Flood Risk Insurance Maps. 

The elevations of the existing LNG tank at the Cameron LNG Terminal are designed 

such that the top of the foundation is 1.6 feet higher than the 500-year storm surge elevation. 

Furthermore, finished grade of the Terminal Expansion would be greater than the 500-year storm 

surge elevation. The finished grade elevation in the flare area and the remaining general facility 

areas are greater than the 100-year storm surge elevation. In addition, Cameron LNG would 

design its Terminal Expansion in accordance with 49 CFR 193.2067. Design factors regarding 

wind are discussed in section 4.12.3. 

Pipeline Expansion

Extreme storm events can lead to flood hazards along the proposed pipeline expansion 

corridor, particularly along river floodplains and in low lying areas. However, buried pipelines 

are rarely affected by flooding. Cameron Interstate would construct aboveground facilities, such 

as the modified interconnections and metering and regulating stations, above the 100-year flood 

level as determined by the COE and FEMA. 

Flooding resulting from hurricane surge effects was evaluated by the COE in its 1979

Flood Insurance Study. Based on the COE evaluation, these surges would not have an 

impact on the compressor station site. However, a portion of the compressor station site is within 

the FEMA 100-year flood zone. Cameron Interstate would evaluate the potential for flooding at 

the compressor station site during detailed engineering, and would construct all building pads at

elevations that are above the 100-year flood zone level to prevent flooding of equipment. As a 
Geologic Conditions, Resources, And Hazards 4-10

result, we believe that the Pipeline Expansion aboveground facilities would not be affected by 

flooding or storm surge.

A portion of the Holbrook Compressor site would be within the 100-year flood zone and 

would result in an increase in impervious surfaces. As required by Executive Order 11988 

(floodplain Management), we considered the potential impacts of construction of Project-related 

facilities in a floodplain, as well as alternatives to siting a portion of the compressor station site 

in a floodplain (see section 3.6.1). Cameron Interstate committed to evaluating the potential for 

flooding at the compressor station site during its detailed engineering and would construct all 

building pads at elevations that prevent flooding of equipment. As a result, the floodplain 

portion of the compressor station site would not be completely filled, and we conclude that use 

of the floodplain portion of the site would not increase flooding.

4.1.4.2 Shoreline Erosion and Localized Scour

Shoreline erosion occurs when waves, shoreline currents, and vessel wakes disturb 

shoreline soils and the mobilized soil is transported from the site. Irregular or changing stream 

channel morphology, often related to man-made structures or stream channel debris, can lead to 

scouring of channel bottom materials during periods of high water flow, sometimes developing 

deep scour holes where water vortices develop. 

Terminal Expansion 

Shoreline erosion could occur along the terminal expansion site and the shoreline of the 

Calcasieu Ship Channel due to waves, currents, and the wake of large vessels transiting the 

channel. Cameron LNG would retain a 150- to 200-foot-wide vegetation buffer along the 

shoreline from the work dock to the northern end of the Terminal Expansion. Cameron LNG 

would also include erosion protection measures in the design of the work dock to minimize the 

potential for shoreline erosion. For example, to maintain soil stability, Cameron LNG would 

install a sheet pile and slope protection system consisting of articulating concrete block mats, 

rock filled marine mattresses, and/or graded rock riprap along the shoreline. 

Pipeline Expansion

Cameron Interstate would use the HDD crossing method at all perennial waterbody 

crossings; therefore, the pipeline would be buried below the maximum scour depth calculated to 

occur during the 100-year flood event. As a result, we conclude scouring would not impact the 

pipeline. 

4.1.5 Paleontology

While fossils in Louisiana are generally rare, there have been occasional discoveries of 

relatively recent fossil remains of animals such as camels and mastodons. Holocene and 

Pleistocene marine fossil fragments are sometimes found within sedimentary units deposited in 

these epochs, but these fragments have little scientific value. Project facilities would not impact 

any older underlying geologic formations or the fossils, if any, within them.
4-11 Soils

4.2 SOILS

4.2.1 Soil Types and Limitations

Soil types that occur within the proposed Project area, as identified by the U.S. 

Department of Agriculture (USDA), Soil Conservation Service (SCS) (USDA SCS 1995), and 

the general limitations of these soils (USDA SCS 1988), as well as potential impacts on these 

soils from the proposed Project, are presented in this section.

4.2.1.1 Terminal Expansion

Soils within the proposed Terminal Expansion site are aquents, udifluvents, Creole 

mucky clay, and Gentilly muck. Aquents are altered or disturbed soils where the original soil 

material has been removed, repositioned, or fill has been added. Aquent soils result from human 

activities and are typically associated with urban and other types of development. Udifluvents 

are soils that are naturally occurring near flowing waterbodies that have deposited the soils. The 

Creole mucky clay and Gentilly muck consist of sandy, clayey soils that are very poorly drained 

and very slowly permeable. Cohesive and cohesionless soils are present in the upper 2 to 8 feet 

at the Terminal Expansion site, with recently deposited very soft to firm, cohesive soils below 

that to depths generally ranging from about 10 to 30 feet below grade. These soils were 

underlain by alternating strata of firm to stiff, cohesive soils and loose to medium-dense 

cohesionless soils to a depth of about 70 to 80 feet below grade. Soil limitations identified at the 

Terminal Expansion site include moderate water and wind erosion potential, hydric soils, and 

low to moderate revegetation potential. The erosion potential of soils is reduced by the generally 

level topography of the site.

Most areas on the Terminal Expansion site where aquent soils occur are former 

marshlands, where materials from COE maintenance dredging of the Calcasieu Channel were 

deposited. These soils consist of coarse sands to clays, sometimes with stratified layers of

varying thickness. Construction of the Terminal Expansion would impact approximately 318.0 

acres of udifluvent soils, 68.4 acres of aquents, 48.9 acres of Creole mucky clay, and 2.9 acres of 

Gentilly muck (the remaining 64.0 acres of the 502.2-acre site is open water).27 

To minimize impacts on soils, Cameron LNG would construct and restore the Terminal 

Expansion in accordance with the FERC Plan, which includes erosion control and sedimentation 

control measures, and provisions for restoration and revegetation. We believe that adherence to 

the FERC Plan would minimize erosion during construction.

As a part of construction of the Terminal Expansion, Cameron would dredge about 

205,000 yd3 from the berthing area for the work dock. The dredged sediments would be 

disposed in an area west of the Terminal Expansion site and owned and operated by Cameron 

LNG. The disposal would be accomplished in accordance with the requirements of the DA 

permit (includes a Section 404 permit under the CWA [Section 404 permit] and a Section 10 

permit under the Rivers and Harbors Act [Section 10 permit]) issued to Cameron LNG by the 

 27 The area of open water stated in this section does not match that of other sections because portions of the onsite ponds are periodically dry and the soils of those dry areas are included in the areas listed for soil types. 

The open water area includes the berthing area for the work dock.
Soils 4-12

COE on February 12, 2014, the amended CUP issued to Cameron LNG by LDNR on January 21, 

2014, and the Modified Maintenance Dredge Permit issued to Cameron LNG by LDNR on 

November 20, 2013. Cameron LNG would pipe dredge spoil to this permitted area and convert 

an open water area to tidally influenced brackish marsh as described in section 4.4.4.

4.2.1.2 Pipeline Expansion

Soils within the proposed compressor station site consist of Glenmora silt loam, Guyton 

silt loam, and Brimstone silt loam. Soil limitations identified at the compressor station site 

include a moderate water and wind erosion potential, low to moderate shrink/swell potential, and 

slight to moderate revegetation potential. The proposed pipeline route crosses a variety of soils, 

as listed in Appendix E. Soil limitations along the proposed pipeline route vary widely, 

including areas of moderate water erosion potential; moderate to high wind erosion potential; 

low, moderate, and high shrink/swell potential; and low to moderate revegetation potential (see 

Appendix E). To minimize impacts on soils, Cameron Interstate would construct and restore the 

Pipeline Expansion in accordance with the Cameron Interstate Plan, which includes provisions 

for erosion control, restoration, revegetation, and special construction techniques for saturated

soils and agricultural areas. We believe adherence to the Cameron Interstate Plan would

minimize erosion during construction.

4.2.2 Prime Farmland Soils

Prime farmland soils have the best combination of physical and chemical characteristics 

for producing food, feed, forage, fiber, and oilseed crops (USDA Natural Resource Conservation 

Service [NRCS] 2012a). In general, prime farmland soils experience adequate and dependable 

precipitation, a favorable temperature and growing season, have acceptable acidity or alkalinity, 

and have few or no surface stones. They are permeable to water and air. Prime farmland soils 

are not excessively erodible or saturated with water for long periods of time. 

4.2.2.1 Terminal Expansion

There are no prime farmland soils on the Terminal Expansion site. Therefore, there 

would be no impacts on prime farmland soils in this area. 

4.2.2.2 Pipeline Expansion

Approximately 15 miles of the proposed pipeline route (72 percent) contains prime 

farmland soils. Construction of the pipeline would impact about 182.0 acres of prime farmland 

soils, and operation would impact about 31.0 acres of prime farmland. Construction and 

operation of the compressor station would permanently impact approximately 14.8 acres of 

prime farmland soil. These soils are currently in silviculture use and would be permanently 

removed from agricultural use. 

Most impacts on prime farmland soils from construction of the pipeline would be shortterm and would not affect the potential use of prime farmland for future agricultural purposes. 

Cameron Interstate would implement the measures in its Plan during construction and 

restoration, including topsoil segregation, temporary erosion controls such as silt fence, staked 

hay or straw bales, and sand bags, as necessary, soil decompaction, and revegetation. We 

believe implementation of Cameron Interstate’s Plan would minimize potential impacts on prime 
4-13 Soils

farmland soils and restore the areas along the proposed route to preconstruction conditions. 

Although construction and operation of the Holbrook Compressor Station would result in 

permanent impacts on about 14.8 acres of prime farmland soil, due to the amount of prime 

farmland in the vicinity of the Project, we do not believe that this would be a significant impact 

on prime farmland soils in the area.

4.2.3 Hydric Soils

Hydric soils are formed under conditions of saturation, flooding, or ponding long enough 

during the growing season to develop anaerobic conditions in the upper part (USDA NRCS 

2012b). These soils are typically associated with wetlands. Soils that are artificially drained or 

protected from flooding (for example, by levees) are still considered hydric if the soil in its 

undisturbed state would meet the definition of a hydric soil.

4.2.3.1 Terminal Expansion 

The aquent and udifluvent soils present on the Terminal Expansion site are categorized as 

hydric soils due to their high water content. The 68.4 acres of aquent soils that would be 

disturbed by construction of the Terminal Expansion were previously disturbed during dredging 

of the Calcasieu Ship Channel. Of the 318.0 acres of udifluvent soils that would be disturbed by 

construction, about 57.0 acres were previously disturbed by construction of the existing Cameron 

LNG Terminal. Cameron LNG would permanently impact the area of hydric soil within the 

Terminal Expansion site by installing the liquefaction facilities. Given the disturbed nature of 

these soils, we believe the conversion of 386.4 acres of hydric soils as a result of operation of the 

proposed liquefaction facilities would not be a significant impact.

4.2.3.2 Pipeline Expansion

The Basile and Guyton silt loams, Brimstone silt loam, Caddo-Messer silt loam, KinderMesser silt loam, and Mowata-Vidrine silt loams along the proposed pipeline route are classified 

as hydric or partially hydric soils. The proposed route extends through about 13.8 miles of 

hydric and partially hydric soils, resulting in an impact of about 168.0 acres of those soils during 

construction. If construction of the pipeline occurs when these soils are saturated, compaction 

and rutting could occur. Cameron Interstate would mitigate compaction impacts in residential 

and agricultural areas through decompaction during restoration, in accordance with its Plan. 

High groundwater levels that accompany hydric soils could create a buoyancy hazard for the 

pipeline. However, in those areas, Cameron Interstate would either coat the pipeline with 

concrete or use weights to provide the weight required to counteract the buoyancy. The Guyton 

silt loam and the Brimstone silt loam at the proposed compressor station site are classified as 

hydric soils (about 10.3 acres). Disturbance of these soils could also cause compaction and 

rutting. After construction, about 15.0 acres would be permanently disturbed for the compressor 

station facilities or gravel ground cover. The remaining soils at the site would be restored in 

accordance with Cameron Interstate’s Plan. We believe implementation of Cameron Interstate’s 

Plan during construction would minimize potential impacts on hydric soils.

4.2.4 Compaction Potential

Soil compaction modifies the structure and reduces the porosity and moisture-holding 

capacity of the soil. The degree of soil compaction during construction is dependent on moisture 
Soils 4-14

content and soil texture. Fine textured soils with poor internal drainage and high shrink-swell 

potential are the most susceptible to compaction. Construction equipment traveling over wet 

soils could disrupt soil structure, reduce pore space, increase runoff potential, and cause rutting. 

Moist or saturated soils are more likely to compact or rut.

4.2.4.1 Terminal Expansion

Some of the soils on the proposed Terminal Expansion site are susceptible to compaction 

and rutting. During construction, loss of soil productivity due to compaction and damage to soil 

structure from heavy equipment are likely to occur. However, these areas would be developed, 

replaced by structures, paving, and gravel, and would not be used to support vegetation; 

therefore, compaction is not a concern. Cameron LNG would restore other disturbed areas in 

accordance with the FERC’s Plan to minimize impacts from construction.

4.2.4.2 Pipeline Expansion

Due to the presence of sandy clay loam, or finer soils, with poor drainage characteristics

along the proposed route, several areas have the potential to experience soil compaction. There 

are also several areas of silt loam soils in the proposed compressor station site that have the 

potential for soil compaction. As stated in Cameron Interstate’s Plan, compaction would be 

mitigated in residential and agricultural areas crossed by the proposed pipeline and at the 

compressor station site. Mitigation for soil compaction would include segregating topsoil, 

postponing soil disturbances when soils are excessively wet, and using deep tillage operations 

during right-of-way restoration using a paraplow or similar implement. We believe that use of 

these measures would minimize soil compaction impacts resulting from construction of the 

proposed pipeline and compressor station. 

4.2.5 Erosion

Erosion is a continuing natural process that can be accelerated by human disturbance. 

Factors that influence erosion potential include soil characteristics, climate, topography, 

vegetative cover, soil texture, surface roughness, percent slope, and length of slope. Water 

erosion typically occurs on loose, exposed soils with a low permeability on moderate to steep 

slopes. Wind erosion generally occurs in an arid climate with soils containing little vegetative 

growth and high wind conditions.

Clearing, grading, and equipment movement could accelerate the erosion process and, 

without adequate protection, result in discharge of sediment into waterbodies and wetlands. Soil 

loss due to erosion could also reduce soil fertility and impair revegetation rates.

4.2.5.1 Terminal Expansion

The erosion potential of soils at the liquefaction facility site is minimal due to the level 

nature of the site. Cameron LNG would further minimize the erosion potential of these soils by 

adhering to the erosion protection measures in the FERC Plan during construction and 

restoration of the expanded terminal. In addition, Cameron LNG would use one of the two 

ponds on the site as a stormwater retention pond during construction to minimize runoff and 

would modify its existing storm water system, as necessary, to accommodate the additional 
4-15 Soils

runoff from the new facilities. We believe Cameron’s implementation of the FERC Plan during

construction, restoration, and operation would minimize erosion.

4.2.5.2 Pipeline Expansion

Soils along the pipeline route and at the compressor station site have moderate water and 

wind erosion potentials (see Appendix E for pipeline soils). Construction would disturb soils,

resulting in a temporary increase in the potential for erosion. To limit the effects of erosion, 

Cameron Interstate would implement the erosion control measures in its Environmental Plan 

(Appendix C) during construction and restoration of the pipeline right-of-way and the 

compressor station site. Cameron Interstate would implement and maintain these erosion and 

sedimentation control measures, such as silt fencing, during construction and through restoration

until revegetation has occurred. Following restoration, Cameron Interstate would monitor the

disturbed areas, maintain erosion control structures, and repair observed erosion. We believe 

implementation of these measures during construction and restoration would minimize overall 

soil erosion.

4.2.6 Revegetation Potential

Successful restoration and revegetation in areas that are temporarily disturbed during 

construction is important to maintain ecosystem productivity and to protect the underlying

soils from potential damage, such as erosion.

4.2.6.1 Terminal Expansion

Although Cameron LNG would cover much of the terminal site by paving, gravel, major 

structures, and other Project facilities, some areas would require revegetation. Cameron LNG 

would implement the requirements of the FERC Plan for revegetation of disturbed areas

following construction. This would include seeding disturbed areas with native vegetation as 

recommended by soil conservation authorities. We believe that if upland revegetation is

conducted in accordance with these measures, the areas disturbed by construction would be

successfully revegetated to preconstruction conditions and the impacts on soils would be minor 

and short-term.

4.2.6.2 Pipeline Expansion

The revegetation potential of soils along the proposed pipeline route varies from slightly 

poor to severely poor. Cameron Interstate would revegetate the non-cultivated portions of the 

construction right-of-way in accordance with its Plan and any specific landowner requests. 

This would include seeding disturbed areas with native vegetation as recommended by soil 

conservation authorities and monitoring all disturbed areas to ensure successful revegetation. 

We believe that if upland revegetation is conducted in accordance with these measures, areas

disturbed by construction would be successfully revegetated to preconstruction conditions and 

impacts on soils would be minor and temporary. 

Soils at the proposed Holbrook Compressor Station site have a slightly to moderately 

poor revegetation potential. After the facilities are installed, Cameron Interstate would final 

grade the site. Cameron Interstate would permanently impact about 15.3 acres of the 25.0-acre 

site with aboveground facilities or gravel; the remaining soils would be revegetated. We believe 
Water Resources 4-16

that implementation of Cameron Interstate’s Plan would minimize impacts on soils and 

adequately restore these areas.

4.2.7 Soil Contamination

Contamination from spills or leaks of fuels, lubricants, and coolant from construction 

equipment could adversely affect soils. Cameron LNG and Cameron Interstate developed spill 

prevention and containment procedures in their respective Environmental Plans. See Appendix

C to view Cameron Interstate’s Environmental Plan and access the FERC’s eLibrary to view 

Cameron LNG’s Environmental Plan.

28 These plans identify cleanup procedures to be 

implemented in the event of soil contamination from spills or leaks of fuel, lubricants, coolants, 

or solvents. We evaluated these procedures and believe their implementation would avoid or

minimize soil contamination during construction and operation of the Project.

4.2.7.1 Terminal Expansion

Cameron LNG stated that it had not encountered contaminated soil at the existing LNG 

Terminal and does not anticipate any contaminated soil at the proposed site of the Terminal 

Expansion. If unanticipated contaminated soil is discovered within the site, Cameron LNG 

would follow the procedures of its Unanticipated Hazardous Waste Discovery Plan included in 

their Environmental Plan. We have reviewed this plan and find it adequate.

4.2.7.2 Pipeline Expansion

Contaminated soil was not encountered during construction of the pipelines that are 

adjacent to the proposed route, and it is not likely that past activities along the proposed right-ofway would have resulted in soil contamination. If unanticipated contaminated soil is discovered 

during construction of the proposed pipeline, Cameron Interstate would follow the procedures of 

its Unanticipated Hazardous Waste Discovery Plan included in their Environmental Plan (see 

Appendix C), which we have reviewed and find adequate.

4.3 WATER RESOURCES

4.3.1 Groundwater

4.3.1.1 Existing Groundwater Resources

The proposed Project is in the Gulf Coastal Plain Physiographic Province and is 

underlain by the upper portion of the Coastal Lowlands Aquifer System, known locally as the 

Chicot Aquifer. The Chicot Aquifer is the principal source of groundwater in the Project area for 

municipal, industrial, agricultural, and domestic use (USGS 1998).

The Chicot Aquifer consists of a complex series of unconsolidated or poorly consolidated 

wedges of discontinuous beds of sand, silt, and clay. In southeastern Louisiana, the aquifer 

consists of three separate hydrologic units referred to as the 200-foot sand, the 500-foot sand, 

and the 700-foot sand, based on the average depths at which these units are encountered (USGS 

 28 The Cameron LNG Environmental Plan can be viewed on FERC’s eLibrary under Docket No. CP13-25-000 

(Accession No: 20121207-5141) with Cameron LNG’s Application.
4-17 Water Resources

1998). The 200-foot sand ranges from 50 to 100 feet thick and has the highest water quality of 

the three aquifer layers and is primarily used for domestic purposes. The 500-foot sand ranges 

from 170 feet to 200 feet thick and is the most heavily used layer of the Chicot Aquifer, which is 

used primarily as a source of industrial and public water supply. The 700-foot sand ranges from 

85 to 150 feet thick and has been impacted by salt-water intrusion (USGS 2003). Recharge to 

the aquifer system occurs by direct infiltration of rainfall and is therefore susceptible to surficial 

contamination.

The Project area is also underlain by shallow, discontinuous, surficial aquifers, which 

consist mainly of alternating deposits of clays, silts, and sands. Surficial groundwater depths 

range from 2 to 10 feet, depending on local geologic conditions. 

Public and Private Water Supply Wells and Springs

The Chicot Aquifer System has been designated by EPA as a sole-source aquifer (53 

CFR 20893). EPA defines a sole- or principal-source aquifer as one that supplies at least 50 

percent of the drinking water consumed in the area overlying the aquifer. These areas have no 

alternative drinking water sources that could physically, legally, and economically supply all 

those who depend upon the aquifer for drinking water. 

The proposed site of the Terminal Expansion is not within an “Area of Groundwater 

Concern” or “Critical Area of Groundwater Concern” (LDEQ 2013). 

Public and private water supply wells in the vicinity of the Terminal Expansion were 

identified from the LDNR Strategic Online Natural Resources Information System database 

(LDNR 2012). A total of five wells are on or adjacent to the proposed Terminal Expansion site, 

three of which are on either the existing Cameron LNG Terminal property or the proposed 

Terminal Expansion site. Two of the wells were drilled for construction of the existing terminal. 

One of those wells remains active and Cameron LNG would use it during construction of the 

Terminal Expansion. The second well was plugged and abandoned. The third well, which is 

within the proposed site of the Terminal Expansion, is an inactive domestic water supply well. 

The two remaining wells near the proposed Terminal Expansion site are not within 150 

feet of the proposed construction area. One of these wells, owned by Cameron Parish 

Waterworks District 10, was issued for public water supply. On December 10, 2012 Cameron 

LNG met with representatives from Cameron Parish Waterworks District 10 to discuss the 

Terminal Expansion. The Cameron Parish Waterworks District 10 board of directors reviewed 

the Terminal Expansion and was satisfied with the proposed layout and proximity to the well. 

The board of directors also stated that they are satisfied with the proposed steps Cameron LNG 

would implement should groundwater contamination occur as a result of construction, including 

provision of an alternative water source, if needed.

Two registered water supply wells are within 150 feet of the construction area of the 

proposed Pipeline Expansion, but are listed as plugged and abandoned (LDNR 2012). No public 

water supply wells, wellhead protection areas, or springs are within 150 feet of the proposed 

Pipeline Expansion. 
Water Resources 4-18

4.3.1.2 Groundwater Impacts and Mitigation

Impacts on groundwater resources could result from construction and operation of the 

proposed Project. These potential impacts are discussed below.

Terminal Expansion

Cameron LNG would drive pilings for any structures imposing a significant foundation 

load, including the LNG storage tank and the work dock, to depths ranging from 95 feet to 110 

feet. Pilings could create conduits for contaminants to potentially impact surficial groundwater, 

but would not likely intrude into the shallowest aquifer (200-foot-deep sand aquifer). Pilings 

would be confined to the surficial layers of the aquifer system. The dense surficial clays that 

confine the 200-foot-deep sand layer of the aquifer would prevent movement into and 

contamination of the aquifer. Therefore, installation of pilings during construction would have 

little or no impact on groundwater.

Cameron LNG would dredge about 205,000 yd3 of material for the proposed work dock 

to accommodate barges. This would increase the water depth from about 3.5 feet to about 15

feet below MSL. The proposed depth is shallower than the depth of the existing LNG carrier 

turning basin and berthing area. No known effects on groundwater occurred from initial and 

maintenance dredging of those areas, thus we do not anticipate any groundwater impacts as a 

result of dredging for the work dock area. 

Impacts on groundwater resources could occur due to an accidental spill, leak, or other 

release of a hazardous substance during construction or operation of the expanded terminal. The 

Cameron LNG Environmental Plan includes the FERC Plan and Procedures as well as specific 

spill prevention and response procedures for construction activities. In addition, Cameron LNG 

would update its existing SPCC Plan to include the expanded terminal operations. The SPCC 

Plan includes actions Cameron LNG would take to avoid or minimize impacts on groundwater 

and other resources if a release occurs. 

The soils between the Chicot Aquifer and surficial aquifers have a low permeability and 

if a hazardous substance is released, it may not reach the 200-foot sand portion of the aquifer. In 

addition, with implementation of spill prevention and mitigation measures during construction 

and operation, it is not likely that an accidental release of hazardous substances would result in a 

significant impact on groundwater resources. If contaminated groundwater is encountered 

during construction, Cameron LNG would discontinue activities associated with the 

contaminated water and investigate the source of contamination. If activities associated with 

construction are shown to be the source of contamination, Cameron LNG would assess the level 

of contamination and provide an alternative water source to any wells or water sources affected, 

as discussed in section 4.1.1.1.

The expanded Terminal would result in conversion of 502.2 acres to industrial land, 

including gravel and impervious surface, in the Project area, thereby reducing groundwater 

infiltration (section 4.8.1). Cameron LNG would direct stormwater from the Terminal 

Expansion to one of the existing manmade ponds within the Terminal Expansion boundary or 

through existing drainage ditches (see section 4.3.2.2 for additional details on stormwater). 
4-19 Water Resources

However, this addition of impervious material is minor compared to the surrounding area where 

percolation is possible. 

Hydrostatic testing of the new LNG storage tank and piping of the Terminal Expansion 

facilities would require about 45 million gallons of water. Dust generated from vehicular and 

equipment traffic could increase sedimentation of the Calcasieu Ship Channel. To mitigate this 

effect, Cameron LNG proposes to use approximately 28 million gallons of water for dust control. 

If an on-site concrete batch plant is used during construction, it would require an additional 

560,000 gallons of water. Water would also be required for the Terminal Expansion’s fire water 

system. 

Cameron LNG would obtain all water from an existing on-site well that is capable of 

drawing from both the 200-foot and 500-foot sands of the Chicot Aquifer. The well would be 

used intermittently, with an average flow rate of about 1,280 gpm. The flow rate and estimated 

volume of water that Cameron LNG would use is similar to that used during construction of the 

existing Cameron LNG Terminal. Although groundwater levels would be temporarily impacted 

by the withdrawals, the estimated overall volume is a small percentage of the total volume 

removed from the aquifer for domestic and industrial uses per day and the aquifer would 

recharge quickly. Estimated daily withdrawal from the Chicot Aquifer for public supply, 

industry, irrigation, and other uses is 662 million gallons per day (Sargent 2007); total 

withdrawals over the course of construction of the Terminal Expansion would be approximately 

73.5 million gallons. In addition, there were no known groundwater impacts from hydrostatic 

testing of the existing LNG storage tanks and piping. Therefore, we conclude that use of the 

well water during construction would not result in a significant impact on groundwater resources. 

During operation of the expanded terminal, Cameron Parish Waterworks District 2 would 

supply water through an existing connection; therefore groundwater quantities would not be 

affected. Cameron LNG and Cameron Parish Waterworks District 2 would agree to water usage 

volumes and rates.

Through use of the measures discussed above, we believe impacts on groundwater 

resources at the Terminal Expansion would be minimized to the extent practicable and not 

significant.

Pipeline Expansion

Construction of the proposed pipeline would require trenching to a depth of about 8 feet 

below the ground surface. In areas where surficial groundwater is near the ground surface, 

trench excavation could intersect the water table, requiring trench dewatering. Trench 

dewatering may result in localized, minor changes to the water table, which could also impact 

the hydrology of nearby wetland areas. Because Cameron Interstate would complete pipeline 

construction at a given location within a short period of time and water would be discharged to 

nearby areas, potential dewatering impacts would be temporary and localized, and water table 

elevations would reestablish soon after the trench is backfilled. Where the trench may be 

continually flooded and dewatering would not be feasible, Cameron Interstate would float the 

pipe into place and install it using the push-pull method, as described in section 2.6.3.
Water Resources 4-20

Some construction activities – such as trench excavation, grading, and filling of the 

excavated trench – could cause minor fluctuations in shallow groundwater levels or increase 

turbidity within shallow groundwater adjacent to the construction activity. These impacts would 

be limited to the area of disturbance and are not expected to have a significant impact on 

groundwater quality or quantity. 

Near-surface soil compaction caused by heavy construction vehicles could locally reduce 

the soil’s ability to absorb water, which would increase surface runoff and the potential for 

ponding. In areas where forest and portions of wetlands are removed during construction, water 

infiltration normally enhanced by the vegetation would reduce locally until the area is 

revegetated, which could temporarily affect water recharge to deeper aquifer layers. However, 

Cameron Interstate’s Procedures provide measures to minimize impacts on groundwater during 

construction of the Pipeline Expansion, including returning the ground surface as closely as 

practical to pre-construction contours, installing trench breakers to prevent groundwater 

movement or loss from nearby wetlands, decompacting the ground as necessary, and 

revegetating the right-of-way to ensure restoration of pre-construction overland flow and 

recharge patterns. As a result of incorporation of these procedures, we believe impacts on 

groundwater due to changes in the ground surface of the right-of-way would be minor and

temporary. 

Spills of construction fuels, lubricants, and other potentially hazardous substances could 

affect shallow groundwater and unconsolidated aquifers. Potential contamination due to 

accidental spills or leaks of hazardous materials associated with vehicle fueling, vehicle 

maintenance, and storage of construction materials presents the greatest potential threat to 

groundwater resources during construction. The Cameron Interstate Environmental Plan 

prescribes spill response procedures, mitigation measures, and hazardous substance storage and 

disposal procedures to minimize the potential for a spill. During operation of the Holbrook 

Compressor Station, Cameron Interstate would install a double-walled 2,400-gallon aboveground 

diesel storage tank within concrete curbing to minimize the potential for a spill. Cameron 

Interstate provided an SRP and its Plan to avoid or minimize impacts on groundwater and other 

resources if a release occurs.

Low permeability sediments between the Chicot Aquifer and surficial aquifers, combined 

with implementation of the Cameron Interstate Plan and Procedures during construction and the 

SRP during operation of the Holbrook Compressor Station, would avoid or minimize impacts on 

groundwater due to spills of hazardous substances. 

During operation of the Holbrook Compressor Station, potable water would be supplied 

from a local public water system. Cameron Interstate would install an underground septic 

system, in accordance with local and state permits, to manage sanitary and sewage wastewater. 

Installation of the septic system could cause minor fluctuations or increase turbidity in shallow 

groundwater within the construction area, similar to trenching and pipeline installation. Seepage 

or other leaks from the septic system could contaminate groundwater; however, proper 

maintenance reduces the likelihood of seepage or other leaks. Additionally, the low permeability

of sediments between the Chicot Aquifer and surficial aquifers would avoid or minimize impacts 

on groundwater due to seepage or leaks from the septic tank. These impacts would be limited to 

the area immediately adjacent to the proposed tank and we believe would not significantly

impact groundwater quality or quantity in the area. 
4-21 Water Resources

Through use of the measures discussed above, we believe Cameron Interstate would 

minimize impacts on groundwater along the proposed pipeline route to the extent practicable.

4.3.2 Surface Water

4.3.2.1 Existing Surface Water Resources

Terminal Expansion

The proposed Terminal Expansion is within the Lower Calcasieu Watershed, which

encompasses an area of about 1,080 square miles and drains to the Lower Calcasieu River that 

flows to the Gulf of Mexico. The channel extends from the Louisiana coastline to the Port of 

Lake Charles, a distance of about 36 miles, and is used for vessel transits to and from the port. 

The channel, which is maintained by the COE, is approximately 40 feet deep and is a Traditional 

Navigable Water as defined by 33 CFR 329. 

Water uses of the Calcasieu Ship Channel in the vicinity of the proposed Terminal 

Expansion site are designated as primary contact recreation, secondary contact recreation, fish 

and wildlife propagation, and oyster propagation (LDEQ 2012a). Water and sediment quality 

within the channel have been impacted by point and non-point sources of pollutants due to direct 

use of the channel, upstream land use activities and physical habitat alteration, and vessel and 

boat traffic. The area of the channel adjacent to and downstream of the Terminal Expansion is 

not included on the EPA-approved 303(d) list of impaired waters (LDEQ 2012b).

Two manmade, freshwater, ponds are present on the proposed Terminal Expansion site. 

One is permitted by the COE and the LDNR, Office of Coastal Management for placement of 

dredged material from maintenance of the turning basin in the Calcasieu Ship Channel. 

However, the pond has not yet been used for this purpose. Neither pond is known to contain 

contaminated sediments.

During construction of Cameron LNG’s existing terminal and prior to dredging, Cameron 

LNG conducted an evaluation of the sediment within the Calcasieu Ship Channel. That

evaluation concluded that sediments in the channel were not contaminated (CH2MHill 2003). If 

requested by the COE, Cameron LNG would test for contaminated sediments prior to 

construction within the proposed dredge area during construction of the work dock.

No potable water intakes are within 3 miles downstream of the Terminal Expansion site.

Pipeline Expansion

The proposed pipeline route crosses the West Fork Calcasieu and Upper Calcasieu 

Watersheds. The Pipeline Expansion would require 29 crossings of 28 waterbodies (one 

waterbody would be crossed twice); including 4 perennial streams, 7 intermittent streams, 16

ephemeral streams, and 1 pond (see Appendix F for stream details). Perennial streams are 

defined as waterbodies that hold water continually throughout the year. Intermittent streams

have well defined stream banks, but lack the hydrological characteristics associated with 

perennial streams. These streams hold water during wet or seasonal portions of the year and do 

not flow continuously. Ephemeral streams are not always well defined and hold water only 

during and immediately after rain events. 
Water Resources 4-22

The FERC classifies surface waters based on size: major waterbodies are greater than 100 

feet wide, intermediate waterbodies are greater than 10 feet wide but less than or equal to 100 

feet wide, and minor waterbodies are less than or equal to 10 feet wide. Two of the waterbodies 

crossed by the proposed pipeline are major waterbodies, the Houston River at MP 1.8 and 

Hickory Branch at MP 10.3. 

The proposed route would not cross any waterbodies within 3 miles upstream of any 

public water intakes.

Sensitive Waterbodies

Waterbodies may be considered sensitive for a number of reasons, including the presence 

of significant fisheries, habitat for threatened or endangered species, high-quality recreational or 

visual resources, historic value, or the presence of impaired water or contaminated sediments. 

The proposed route crosses five waterbodies on the EPA-approved 303(d) list of impaired 

waterbodies (LDEQ 2012b): the Houston River at MP 1.8, Little River at MP 5.6, Beckwith 

Creek at MP 8.8, Hickory Branch at MP 10.3, and Indian Bayou at MP 14.8. The route also 

crosses two waterbodies designated as Louisiana Natural and Scenic Rivers under the Louisiana 

Scenic Rivers Act of 1998: Beckwith Creek at MP 8.8 and Hickory Branch at MP 10.3

4.3.2.2 Surface Water Impacts and Mitigation

Terminal Expansion

We assessed impacts associated with the export of LNG, the use of LNG carriers 

(including traffic, transit, and ballast water discharges), and LNG spills in our previous EIS and 

two EAs for the existing Cameron LNG Terminal (see section 2.1.1). Because Cameron LNG is 

not proposing to change the authorized frequency or size of LNG vessels, impacts associated 

with these activities are not addressed in this EIS. However, we note that ballast water 

management requirements have changed since those reviews were conducted. LNG captains 

would be required to comply with these more stringent requirements, found in 33 CFR 151.2025 

(Ballast Water Management Requirements). As a result, our earlier assessments of potential 

impacts due to ballast water exchange remain appropriate. 

Because very few, if any, of the barges used for construction of the proposed Project 

would have ballast systems, and because Cameron LNG did not request an increase in the 

number of LNG carriers currently authorized to use the existing terminal, the proposed Project 

would not have impacts associated with ballast water discharge in the Calcasieu Ship Channel or 

Gulf Intracoastal Waterway beyond those previously assessed. 

Work Dock

Construction of the proposed work dock would require dredging approximately 205,000 

yd3 of material from the Calcasieu Ship Channel. Dredging of the work dock berth would result 

in impacts similar to those that occurred during construction and maintenance dredging of the 

adjacent existing LNG terminal’s berthing area by Cameron LNG29 and during routine 

 29 Dredging impacts were previously addressed in the 2003 EIS for the existing Cameron LNG Terminal (FERC 

Docket No. CP02-374) and the 2006 EA for Cameron LNG Expansion Project (Docket No. CP06-422).
4-23 Water Resources

maintenance dredging of the Calcasieu Ship Channel by the COE. Because the sediments within 

the area are anticipated to consist primarily of fine particles based on other nearby dredging 

projects, dredging would result in the temporary and local suspension of sediments and minor 

increased turbidity levels that would be limited to the period of dredging and a short time after 

dredging ceases. To minimize turbidity increases, Cameron LNG would use a hydraulic dredge 

with a suction header during dredging. Cameron LNG would also use turbidity curtains, as 

necessary, to capture suspended sediments from dredging activities. This impact would be 

temporary and we believe turbidity would return to pre-dredging levels soon after dredging is 

completed. 

Although it is possible that the sediments dredged during construction could contain 

contamination, the sediments would not be different from those dredged during construction of 

the existing LNG Terminal, which were not found to contain contaminants, as previously 

discussed. Cameron LNG received an amended CUP and a Modified Maintenance Dredge 

Permit from LDNR and a DA permit from the COE (see table 1.5-1). The CUP and DA permits 

included mitigation plans. The three permits provide Cameron LNG with authorization from 

both agencies to perform dredging and filling of coastal wetlands, assuming all other 

authorizations, certificates, and permits are obtained for the Project. Cameron LNG would

dispose of dredged sediments from construction of the dock in accordance with the 

requirements of the permits on property owned and operated by Cameron LNG west of the

existing Cameron LNG Terminal site. Cameron LNG would pipe dredged material to this

permitted area and create a tidally influenced brackish marsh, as described in its mitigation plan 

in the DA permit (provided in Appendix K) and described in section 4.4.4. 

Barges and support vessels would deliver large equipment and construction materials to 

the work dock, which would increase ship traffic in the Calcasieu Ship Channel and the Gulf 

Intracoastal Waterway. The proposed work dock is designed to accommodate two barges 

simultaneously without obstructing ship traffic in the channel; therefore, the impacts of increased 

barge and support vessel traffic would only occur during transit of those vessels to and from the 

work dock. Barge traffic may result in some suspension of bottom sediments and temporarily 

increase turbidity. The increase in turbidity could result in localized, minor, and temporary 

decreases in dissolved oxygen. 

Barges and support vessels would take in cooling water for vessel boilers while in transit 

and discharge the cooling water after use. The cooling water would be circulated in a closed 

system and would not have chemicals added to it. Discharge of the cooling water would 

potentially result in highly localized and temporary increases in water temperature in the 

waterway and ship channel. However, based on an analysis on larger marine vessels conducted 

for a similar project, the temperature change would be insignificant (generally would dissipate to 

a change of temperature of 1°C or less warmer than ambient conditions 15 to 30 meters from the 

discharge source) given the total volume of water within the discharge area (FERC 2009). 

Hydrostatic Testing

Cameron LNG would hydrostatically test the piping and LNG storage tank to verify the 

integrity of those facilities prior to placing them in service. Hydrostatic test water would be 

pumped from the active on-site well discussed in section 4.3.3, and no chemicals would be added 

to the hydrostatic test water. After completion of hydrostatic testing, Cameron LNG would 
Water Resources 4-24

discharge the hydrostatic test water to the Calcasieu Ship Channel in compliance with the FERC 

Procedures. In addition, Cameron LNG stated it would filter and dissipate the energy of test 

water before discharging it to the Calcasieu Ship Channel. Because well water would be used, 

no chemicals would be added to the test water, the water would only contact new pipe, and 

Cameron LNG would implement the FERC Procedures, we believe that the withdrawal, use, and 

discharge of hydrostatic test water by Cameron LNG would not result in a significant impact on 

surface waters. In addition, Cameron LNG would comply with the stipulations regarding 

sampling and testing hydrostatic test water included in its LDEQ discharge permit, which may 

further reduce the potential for impacts.

Erosion and Runoff

Construction would increase the amount of impervious surfaces at the Terminal 

Expansion site, which would increase stormwater runoff volumes. Cameron LNG would modify 

its existing stormwater system, as necessary, to accommodate the additional runoff from the 

expanded terminal. To minimize impacts from potential erosion and sedimentation on the 

Calcasieu Ship Channel due to land disturbance during construction of the Terminal Expansion, 

construction activities would be conducted in accordance with the Cameron LNG Environmental 

Plan, including the FERC Plan. As mandated by these plans, Cameron LNG would install and 

maintain all necessary erosion and sedimentation control structures to avoid impacts on the 

Calcasieu Ship Channel. 

Construction of the Terminal Expansion facilities would involve draining and filling of 

one of the two freshwater pond basins on the Terminal Expansion site. The second pond would 

be used as a stormwater retention basin during construction and may later be filled during 

operation of the Terminal Expansion. Impacts associated with filling these ponds would be 

permanent. 

During construction of the Terminal Expansion, Cameron LNG would route stormwater 

through sediment removing devices, such as filter fabric, to remove sediment from the flow. 

One of the existing manmade ponds within the Terminal Expansion boundary would hold a 

portion of stormwater runoff; other runoff would flow off of the property through existing 

drainage ditches. Cameron LNG provided runoff calculations that indicate that the pond could 

hold runoff from a 10-year rain event; if necessary, to avoid overflow, Cameron LNG would 

pump water from the pond to the existing drainage ditch on the west side of the Terminal 

Expansion property. During normal operation of the proposed Terminal Expansion facilities, 

surface water discharges would consist of stormwater runoff. Stormwater runoff would collect 

in a series of trenches or discharge as sheet flow off the site. The LNG and refrigerant spill 

containment trenches and sumps would also collect stormwater, which would be pumped to the 

Calcasieu Ship Channel in accordance with the Louisiana Pollutant Discharge Elimination 

System (LPDES) Permit that LDEQ issued to Cameron LNG on December 23, 2013. Cameron 

LNG would retain an existing vegetated buffer about 150 to 200 feet wide along the shoreline 

from the work dock to the northern terminus of the Terminal Expansion that would act as a 

stormwater filter prior to discharge into the ship channel. 

With implementation of the FERC’s Plan and Procedures and Cameron LNG’s design of 

the Project, we believe erosion and runoff from construction and operation would be minimized 

and not significant.
4-25 Water Resources

Inadvertent Spills

Water quality of the Calcasieu Ship Channel could be adversely affected by a spill, leak, 

or other release of hazardous materials during construction. Transport of released hazardous 

materials into the Calcasieu Ship Channel by stormwater runoff would degrade water quality and 

could impact aquatic organisms. To minimize the potential for a release of hazardous materials 

and to avoid or minimize the impacts of a release, Cameron LNG would implement the spill 

procedures in its Environmental Plan during construction and would implement the procedures

included in its revised SPCC Plan during operation of the expanded terminal.

Through use of the measures discussed above, we believe impacts from spills on surface 

water resources at the Terminal Expansion would be minimized to the extent practicable. 

Pipeline Expansion

Cameron Interstate would construct across waterbodies using several different methods, 

depending primarily on the size of the waterbody and the presence or absence of water at the 

time of construction. In addition, waterbody crossings would be designed and constructed in 

compliance with COE and state permitting requirements and the procedures presented in the 

Cameron Interstate Procedures included in the Cameron Interstate Environmental Plan

(Appendix C). Appendix F lists the waterbodies that would be crossed by the Pipeline 

Expansion along with Cameron Interstate’s proposed waterbody crossing methods and schematic 

drawings of typical crossing methods. 

Cameron Interstate would cross all perennial waterbodies, including the two major 

waterbodies, using the HDD method. Because Cameron Interstate would use the HDD crossing 

method at all perennial waterbody crossings, the pipeline would be buried below the maximum 

scour depth calculated to occur during the 100-year flood event. As a result, we conclude 

scouring would not impact the pipeline. 

Cameron Interstate would use the HDD crossing method for constructing the crossings of 

the Hickory Branch (MP10.3) and Beckwith Creek (MP 8.8), both of which are listed as Natural

& Scenic Rivers by LDWF. On March August 30 and September 16, 2013, Cameron Interstate 

received Natural & Scenic River permits from the LDWF for the crossings of Hickory Branch 

and Beckwith Creek, respectively. As a result, we conclude that water resources of these two 

waterbodies would not be affected by construction of the pipeline.

Open-cut crossing methods, which use methods similar to conventional upland open-cut 

trenching, would be used to cross intermittent and ephemeral waterbodies that are not designated 

as scenic rivers, including waterbodies with flows that cannot be flumed or pumped around the 

construction zone using the dry-ditch crossing techniques (see section 2.6.3 for additional details 

on crossing methods). This method open-cut crossing method would typically include streams 

not considered significant by the state, intermittent drainage ditches and streams, and ephemeral 

streams and ditches. Where Cameron Interstate would use a dry-ditch crossing method (i.e., 

flume or dam-and-pump), it would maintain downstream flow at all times and isolate the 

construction zone from the stream. Cameron Interstate would use the dry-ditch crossing method 

for waterbodies state-designated as significant warmwater fisheries, unless the open-cut method 

is approved by the appropriate state agency. 
Water Resources 4-26

The greatest potential impact on surface waters would result from the temporary 

suspension of sediments during open-cut crossings of flowing streams. The extent of the impact 

would depend on sediment load, stream velocity, turbidity, bank composition, and sediment 

particle size. These factors would determine the density and downstream extent of sediment 

migration. In-stream construction could cause the dislodging and transport of channel bed 

sediments and the alteration of stream contours. Changes in bottom contours could alter stream 

dynamics and increase downstream erosion or deposition, depending on circumstances. 

Turbidity resulting from resuspension of sediments from in-stream construction or erosion of 

cleared stream bank right-of-way areas could reduce light penetration and photosynthetic oxygen 

production. In-stream work could also introduce chemical and nutrient pollutants from 

sediments, if present. Resuspension of deposited organic material and inorganic sediments could 

cause an increase in biological and chemical use of oxygen, potentially resulting in a decrease of 

dissolved oxygen concentrations in the affected area. Lower dissolved oxygen concentrations 

could cause temporary displacement of motile organisms and non-motile organisms could suffer 

mortality within the affected area.

To reduce potential turbidity during open-cut crossings, Cameron Interstate would limit 

instream equipment to only the equipment necessary to complete a successful crossing. Further, 

Cameron Interstate would install equipment bridges for passage of all other construction 

equipment at flowing waterbodies, including minor crossings. Cameron Interstate would also 

require that waterbodies be crossed as quickly as practical and within the timing windows 

specified in the Cameron Interstate Procedures. Instream construction activities, including pipe 

installation and streambed restoration, would be completed within 24 hours for minor 

waterbodies and within 48 hours for intermediate waterbodies. 

The clearing and grading of stream banks would expose soil to erosion and would reduce 

riparian vegetation along the cleared sections of the affected waterbodies. The use of heavy 

equipment for construction could cause compaction of near-surface soils, an effect that could 

result in increased runoff into surface waters. The increased runoff could transport additional 

sediment into the waterbodies, resulting in increased turbidity levels and sedimentation rates in 

the receiving waterbody. The flume and dam-and-pump waterbody crossing methods would 

also disturb stream banks and could result in minor, temporary increases in turbidity when flow 

is restored to the waterbodies; however, this impact would be minimal.

Dust generated from vehicular and equipment traffic could increase sedimentation of 

adjacent waterbodies. To mitigate this effect, Cameron Interstate proposes to use approximately 

200,000 gallons of water from commercially available sources for dust control during 

construction of the Pipeline Expansion, which would minimize the movement of soil due to 

wind.

Cameron Interstate would follow its Procedures for waterbody crossings to ensure 

adequate water flow rates are maintained at all crossing locations and interruption of downstream 

uses are prevented. Cameron Interstate’s Plan and Procedures include requirements for preconstruction planning, environmental inspection, construction methods, sediment and erosion 

control, restoration, decompaction, and post-construction maintenance.

Where waterbodies are an integral part of a wetland ecosystem, Cameron Interstate 

would ensure the hydrologic regime of the waterbody and associated wetland complex are
4-27 Water Resources

maintained. Where installation of the pipeline has the potential to drain a waterbody and 

associated wetland complex, Cameron Interstate would install trench breakers or seal the trench 

bottom to maintain the original wetland hydrology.

Horizontal Directional Drilling Method

HDD is a trenchless crossing method that would be used to avoid direct impacts on nine 

waterbodies and associated wetlands, by directionally drilling well beneath them as described in 

section 2.6.3. Commercially available sources would truck a total of about 6,000 gallons of 

water to the drill sites to create drilling fluid. Drilling fluid, consisting of non-toxic bentonite (a 

natural clay product) and water, is used to lubricate the drill bit during drilling. A successful 

HDD would result in little or no impact on the waterbody being crossed. However, impacts on

surface waters could occur if an inadvertent release of drilling fluids reaches the surface. Such 

releases are more likely to occur in the vicinity of the HDD entry or exit hole. If unfavorable 

ground conditions exist, inadvertent releases could travel along fractures in the geology and 

reach the sensitive resource that is intended to be avoided by the use of HDD. 

Cameron Interstate prepared site-specific HDD Plans and an HDD Contingency Plan to 

address and plan for the possibility of an inadvertent release; these plans are included in the 

Cameron Interstate Environmental Plan (Appendix C). As required by the HDD Contingency 

Plan, containment equipment and material would be stored at each drill site to respond 

appropriately if an inadvertent release were to occur. In addition to impacts from an inadvertent 

release, placement of HDD guide wires may require minor hand clearing of woody vegetation 

and/or branches. 

Hydrostatic Testing

Cameron Interstate would hydrostatically test the integrity of the pipeline before 

initiating operation in accordance with the pipeline safety regulations identified in 49 CFR 192. 

Hydrostatic testing of the pipeline would require about 8.8 million gallons of water, which 

Cameron Interstate would withdrawal from the Houston River Canal. Another 20,000 gallons of 

water would be trucked from commercial or municipal sources to test the piping at the Holbrook 

Compressor Station. Cameron Interstate would not add chemicals to the test water. Cameron 

Interstate’s mitigation measures to minimize potential impacts from water withdrawal and 

discharge include, but are not limited to, the following:

• obtain and comply with all applicable water withdrawal permits (including 

LDNR’s Office of Coastal Management permit) and provide proper notifications 

prior to construction;

• screen hydrostatic test water withdrawal intakes to minimize the potential for

entrainment of fish and aquatic organisms; and

• regulate the discharge of hydrostatic test waters using energy dissipation devices 

to prevent erosion, scour, turbidity, or excessive streamflow.

Cameron Interstate would return hydrostatic test water to vegetated upland areas though 

energy dissipation devices to reduce the velocity of the discharge and minimize erosion. As 

result, we believe that the withdrawal, use, and discharge of hydrostatic test water would not 
Wetlands 4-28

result in a significant impact on surface waters. In addition, Cameron Interstate would comply 

with the stipulations regarding hydrostatic test water discharge included in its LDEQ discharge 

permit (including sampling and testing prior to discharge), which may further reduce the 

potential for impacts. 

Inadvertent Spills 

To avoid or minimize the potential impacts of inadvertent spills from refueling of 

vehicles and the storage of fuel, oil, or other hazardous materials near surface waters, Cameron 

Interstate would implement the measures provided in its Environmental Plan (Appendix C). 

These measures include restricting refueling and storage of potentially hazardous materials to 

upland areas at least 100 feet from waterbodies and provisions to handle stormwater that may 

carry spilled materials. If a spill were to occur, immediate downstream users of the water could 

experience degradation in water quality, and acute and chronic toxic effects on aquatic organisms 

could occur. However, Cameron Interstate would not store large volumes of fuel, oil, or other 

hazardous materials and it is not likely that significant long-term impacts would result if a spill 

during construction were to reach a waterbody.

Impact Summary

Through use of the measures discussed above and the proposed mitigation measures, we 

believe impacts on surface waters along the proposed pipeline route would be minimized to the 

extent practicable. 

4.4 WETLANDS

Wetlands are areas that are inundated or saturated by surface or groundwater at a 

frequency and duration sufficient to support, and under normal circumstances do support, a 

prevalence of vegetation typically adapted for life in saturated soil conditions, commonly known 

as hydrophytic vegetation (Environmental Laboratory 1987). Wetlands can be a source of 

substantial biodiversity and serve a variety of functions that include providing wildlife habitat, 

recreational opportunities, flood control, and naturally improving water quality.

Section 404 of the CWA establishes standards to evaluate and reduce total and net 

impacts on wetlands under the regulatory jurisdiction of the COE. These standards require 

avoidance of wetlands where possible and minimization of disturbance where impacts are 

unavoidable, to the degree practicable. Cameron must also demonstrate that it has taken 

appropriate and practicable steps to minimize wetland impacts in compliance with the COE’s 

Section 404(b)1 guidelines that restrict discharges of dredged or fill material where less 

environmentally damaging alternatives exist. 

In Louisiana, coastal wetlands are defined as wetlands less than 5 feet above MSL that 

occur within the designated coastal zone of the state. These wetlands are under the jurisdiction 

of LDNR, Office of Coastal Management and the COE.

4.4.1 Affected Wetlands

Wetlands that would be affected by Project facilities are regulated at the federal and state 

levels. On the federal level, the New Orleans District of the COE has authority under Section 
4-29 Wetlands

404 of the CWA to review and issue permits for activities that would result in the discharge of 

dredged or fill material into waters of the United States, including wetlands. Section 401 of the 

CWA requires that proposed dredge and fill activities under Section 404 be reviewed and 

certified by the LDEQ to ensure that the proposed Project would meet state water quality 

standards. On the state level, the LDNR, Office of Coastal Management is responsible for the 

implementation of the Louisiana Coastal Resources Program, which issues CUPs and sets 

mitigation requirements for unavoidable losses of coastal wetland function and value due to 

permitted activities. 

Cameron must comply with all Clean Water Act conditions of applicable permits issued 

by the COE, LDEQ, and LNDR, including the provisions of required compensatory wetland 

mitigation. Cameron reviewed available NWI maps and soil surveys, and conducted wetland 

field surveys within the proposed Project footprint in 2012, including the proposed Terminal 

Expansion facilities, the construction right-of-way, proposed access roads, ATWS, and pipeline 

aboveground facilities to delineate wetland boundaries in accordance with the requirements of 

the Corps of Engineers Wetland Delineation Manual (Environmental Laboratory 1987). In 

addition, Cameron conducted qualitative assessments for each identified wetland based on the 

COE’s five ecological parameters that include quality of wetland vegetation, soils, hydrology,

presence of plant and animal species of concern, and level of disturbance within the wetland and 

adjacent areas. Wetland types identified were classified into one of the following three types 

according to Cowardin et al. (1979):

• palustrine emergent (PEM) wetlands;

• palustrine scrub-shrub (PSS) wetlands; and

• PFO wetlands.

PEM wetlands are the most common in the vicinity of the proposed Project and are 

dominated by erect, rooted herbaceous hydrophytes. PSS wetlands are dominated by woody 

vegetation less than 6 meters tall and generally occur where land is no longer managed or where 

invasive species have entered marshlands. Cameron identified PSS wetlands in the vicinity of 

the proposed Project in abandoned fields and pastures and in marsh areas with higher elevation. 

PFO wetlands are dominated by tree species at least 6 meters tall and include bottomland 

hardwood, mixed pine/hardwood, and pine plantation. PFO wetlands occur in the floodplains of

waterbodies and in depressions within pine plantations and mixed pine/hardwood forests. 

Details regarding impacts on individual wetlands, including wetland classification, are provided 

in Appendix H.

4.4.2 Wetland Construction Procedures and Mitigation 

In general, wetland impacts need to be avoided first; if avoidance is not possible, impacts 

are to be minimized, rectified, reduced, and mitigated in accordance with federal and state 

regulations, including our Procedures and the COE’s Section 404(b)1 guidelines, which restrict 

discharges of dredged or fill material where a less environmentally damaging and practicable 

alternative exists. COE jurisdictional wetlands potentially affected by the Project are subject to 

review by the COE to ensure that wetland impacts are fully identified and that appropriate 

wetland restoration and mitigation measures are identified. Additionally, wetlands within 5 feet 

of MSL were reviewed by the LDNR. Cameron would comply with all conditions of its 
Wetlands 4-30

amended CUP and DA (Section 404 and Section 10) permit authorizations issued by the LDNR 

and COE. 

4.4.3 Compensatory Mitigation

The COE requires all unavoidable wetland impacts be offset by the creation, restoration, 

enhancement, or preservation of at least equal amounts of wetlands, depending on the quality of 

the wetlands affected and the type of wetlands created, restored, enhanced, or preserved. There 

are three mechanisms for providing compensatory mitigation: permittee-responsible 

compensatory mitigation, mitigation banks, and in-lieu fee mitigation. Through use of the 

measures discussed above, collocation of the majority of the proposed Pipeline Expansion rightof-way with existing rights-of-way, and the proposed mitigation measures, we believe impacts 

on wetlands due to construction and operation of the proposed Project would be minimized to the 

extent practicable. 

4.4.4 Terminal Expansion

Construction and operation of the Terminal Expansion would permanently fill a total of 

213.5 acres of wetlands. Of this total, approximately 119.4 acres are PEM, 69.8 acres are PSS, 

and 24.5 acres are PFO. Wetland vegetation includes emergent herbaceous species comprised of 

saltmeadow cord grass, narrowleaf cattail, common reed, Canada goldenrod, and bulrush; scrubshrub or woody species including eastern baccharis and Jesuit’s bark; and tree species, including 

Chinese tallow tree, wax myrtle, and yaupon. 

After construction, the Terminal Expansion would be maintained in an industrial state 

with concrete and gravel ground cover. Cameron LNG would conduct all activities impacting 

wetlands in accordance with its amended CUP and its Section 4 and Section 10 permits.

Cameron LNG would complete mitigation for all jurisdictional wetland impacts from 

construction and operation of the Terminal Expansion as required by the permits issued by the 

LDNR and COE. Mitigation is discussed in section 4.4.4.2. The COE issued a Jurisdictional 

Determination for the wetland impacts associated with the Terminal Expansion stating that 213.5 

acres of wetlands are considered jurisdictional; therefore, Cameron LNG would be required to 

mitigate for 213.5 acres of wetland impacts.

4.4.4.1 Wetland Construction Measures and Mitigation

Because Cameron LNG would convert the entire site of the expanded terminal to 

industrial use during operation, all of the wetlands on the proposed Terminal Expansion site 

would be permanently eliminated through either removal or filling. As a result, Cameron LNG

would mitigate impacts using mitigation methods approved by the COE, and LDNR as discussed 

in section 4.4.3.

4.4.4.2 Compensatory Mitigation

Cameron LNG proposes permittee-responsible compensatory mitigation to create tidal 

fresh/intermediate marsh wetland habitat adjacent to the Project site (west of LA-27) at a ratio of 

1.2 acres created for each acre of wetland impacted by the Terminal Expansion. Cameron LNG 

would beneficially reuse dredged material from construction of the work dock to convert about 
4-31 Wetlands

256 acres of open water areas to marsh habitat. The mitigation area would be adjacent to the 220 

acres of marsh habitat previously created during construction of the existing LNG terminal, thus 

contributing to a larger area of contiguous marsh habitat. Should additional dredged material be 

needed to achieve the elevation necessary within the mitigation area to meet the acreage 

requirement, dredged material from maintenance dredging at the existing Cameron LNG 

Terminal berthing area and the work dock would be used. Created marsh habitat would vegetate 

naturally and Cameron LNG would monitor it for quality and functionality for a period of 20 

years. 

In addition to the marsh creation area proposed as mitigation for the wetland impacts for 

construction of the Terminal Expansion, Cameron LNG proposes to create another marsh area 

for beneficial use of maintenance dredge material as part of its current CUP. Cameron LNG 

would implement its Mitigation Plan for the Cameron LNG Terminal Expansion, which includes 

post construction monitoring.

4.4.5 Pipeline Expansion 

Cameron Interstate would affect about 56.7 acres of wetlands by construction of the 

pipeline and associated aboveground facilities. Of this total, 16.0 acres would be within the 

operational right-of-way. Table 4.4.5-1 provides a summary of the impacts on each type of 

wetland during construction and operation of the pipeline and associated facilities.

Wetland delineations were not completed between MP 2.8 to MP 4.7 due to lack of 

access, although wetlands are present within this portion of the route. Impacts on wetlands for 

this 1.9-mile-long portion of right-of-way were estimated based on the Jurisdictional 

Determination issued by the COE. Therefore, we are recommending that:

• Prior to construction, Cameron Interstate should complete wetland surveys 

of the right-of-way from MP 2.8 to MP 4.7 and file the results of the surveys

with the Secretary for review by the Director of OEP. 

PEM wetlands are the most common wetlands along the proposed pipeline right-of-way. 

Most of these wetlands would remain as herbaceous because they are currently maintained along 

the existing utility corridors or are grazed by cattle. Common plant species representative of this 

vegetative community include: common rush, maidencane, horned beakrush, and needlegrass. 

Dominant species in PSS wetlands include: black willow, buttonbush, lamp rush, and 

honeysuckle. PFO wetlands occur along the proposed right-of-way in the floodplain of major 

tributaries associated with the Houston River, Little River, Beckwith Creek, and Hickory Branch 

Creek. Typical species composition in PFO wetlands and riparian areas along the proposed 

pipeline route include: loblolly pine, water oak, red maple, sweetgum, Chinese tallow, and black 

willow.
Wetlands 4-32

TABLE 4.4.5-1

Wetlands Affected by the Pipeline Expansion a

Wetland Classification b

Acres of Wetland Type Affected

PEM PSS PFO Total

Temp c Perm d Temp Perm d Temp Perm e Temp Perm

Pipeline 32.7 9.5 4.4 1.2 9.0 1.3 46.1 12.0

Holbrook Compressor Station 1.0 1.0 0.0 0.0 3.5 2.1 4.5 3.1

FGT Interconnection 0.4 0.4 0.0 0.0 0.0 0.0 0.4 0.4

Access Roads 0.5 <0.1 0.5 0.5 0.0 0.0 1.1 0.6

ATWS Areas 3.2 0.0 0.5 0.0 0.9 0.0 4.6 0.0

Pipeline Expansion Totals 37.7 10.9 5.4 1.7 13.4 3.4 56.7 16.0

< = Less than

a The numbers in this table have been rounded for presentation purposes. As a result, the totals may not reflect the sum of the 

addends.

b Wetland Classification:

PEM = Palustrine Emergent

PSS = Palustrine Scrub-Shrub

PFO = Palustrine Forested

c Temp = Temporary. Impact based on a 100-foot-wide construction right-of-way in wetlands.

d Perm = Permanent. Impact based on new 25-foot-wide maintained permanent right-of-way through PEM and PSS wetlands 

in collocated areas and new 50-foot-wide maintained permanent right-of-way through PEM and PSS in non-collocated areas.

e Perm = Permanent. Impact based on new 15-foot-wide maintained permanent right-of-way through PFO wetlands in 

collocated areas and new 30-foot-wide maintained permanent right-of-way through PFO wetlands.

Impacts on wetlands would occur along the construction right-of-way, at the compressor 

station site, and at 22 ATWS areas, which Cameron Interstate would restore following 

construction. The effects of construction would be greatest during and immediately after

construction. Generally, once the pipeline is in place, wetland vegetation communities would 

transition back into a community with a function similar to that of the wetland prior to 

construction. In PEM wetlands, the impact of construction would be relatively minor and shortterm, because the herbaceous vegetation would regenerate quickly (generally within 1 to 2 

years). PSS wetland impacts would also be minor and short-term, but these wetlands could take 

2 to 4 years to reach functionality similar to preconstruction conditions depending on the age and 

complexity of the wetland system. In PFO wetlands, the impact of construction would be longterm due to the long regeneration period of these vegetative types (30 years or more).

Excavation of the pipeline trench during open-cut construction, installation of the pipe, 

and backfill of the trench could affect the rate and direction of water movement within wetlands. 

This could adversely affect wetland hydrology and revegetation by creating soil conditions that 

may not support wetland communities and hydrophytic vegetation at preconstruction levels. 

Failure to properly segregate soils during construction could result in mixed soil layers, which 

could alter biological components of the wetland and affect the reestablishment of native wetland 

vegetation. Temporary stockpiling of soil and movement of heavy machinery across wetlands 
4-33 Wetlands

could lead to inadvertent compaction and furrowing of soils, which would alter natural 

hydrologic patterns, inhibit seed germination, and increase seedling mortality. Heavy equipment 

could also introduce non-native and invasive species to the disturbed soil. Altered surface 

drainage patterns, storm water runoff, runoff from the trench, accidental spills, and discharge of 

hydrostatic test water could also negatively affect wetland regeneration. 

Cameron Interstate would minimize wetland impacts by collocating and overlapping 74

percent of the proposed 21-mile-long pipeline route with existing pipeline rights-of-way, which 

would minimize impacts on previously undisturbed wetlands. Further, 100 percent of the route 

would follow existing corridors. Six HDDs are proposed to cross nine waterbodies and are 

designed to encompass wetland complexes adjacent to the waterbodies, where possible. This 

would reduce wetland clearing. A total of about 5.9 acres of wetland would be crossed by HDD, 

of which about 5.4 acres is PFO wetland.

Permanent impacts on wetlands would also occur during operation of the pipeline, 

compressor station, and at the FGT Interconnection. Construction of the Holbrook Compressor 

Station would permanently impact 2.1 acres of PFO wetland and 1.0 acre of PEM wetland. 

Construction of the permanent access road to the Holbrook Compressor Station would result 

in permanent impacts on 0.6 acre of wetlands, including less than 0.1 acre of PEM wetlands, 

and 0.5 acre of PSS wetlands. The FGT Interconnection would permanently impact 0.4 acre of 

PEM wetland. Permanent impacts would include the installation of permanent facilities, gravel, 

and paved areas. 

Operation would require clearing of a 10-foot-wide corridor centered over the proposed 

pipeline at a frequency necessary to maintain an herbaceous state to facilitate periodic pipeline 

corrosion/leak surveys. Additionally, Cameron Interstate would cut and remove trees within 

about 15 feet of the pipeline and greater than about 15 feet in height to ensure root systems do 

not interfere with operation of the pipeline. This would prevent the growth of woody vegetation 

and forested species within 15 feet of the centerline, resulting in a permanent conversion of PFO 

wetland to PEM wetland. Therefore, about 1.3 acres of PFO wetland would be permanently 

converted to PEM wetland. The conversion of vegetation would permanently modify the 

function of the wetland area including wildlife habitat. While the conversion of PFO to PEM 

wetlands would not constitute a total wetland loss, it does represent a permanent conversion of 

wetland function.

4.4.5.1 Wetland Construction Measures and Mitigation

Wetland impacts would be minimized by collocating approximately 74 percent of the 

proposed 21-mile pipeline route with existing pipeline rights-of-way. Section 2.6.3 provides 

additional details and typical drawings of right-of-way cross-sections in both collocated and noncollocated areas.

Six HDDs are proposed to cross nine waterbodies and 10 associated wetland complexes. 

This would avoid impacts on 5.9 acres of wetlands. No trees would be removed between the 

entry and exit points of the HDD; however, minor hand clearing of woody vegetation and/or 

branches may be required along the HDD guide wire. Section 2.6.3 describes the specialized 

pipeline construction that Cameron Interstate would use for construction through wetlands. 
Wetlands 4-34

Cameron Interstate would implement its Procedures to minimize impacts on wetlands, which 

include:

• limiting the operation of construction equipment within wetlands to equipment 

essential for clearing, excavation, pipe installation, backfilling, and restoration;

• limiting removal of stumps and grading in wetlands to directly over the trench, 

except where necessary to ensure safety;

• minimizing the length of time that topsoil is segregated and the trench is open;

• installing trench breakers at the boundaries of wetlands as needed to prevent 

draining of a wetland and maintain original wetland hydrology;

• prohibiting storage of hazardous materials, chemicals, fuels, and lubricating oils 

within a wetland or within 100 feet of a wetland boundary; and

• limiting post-construction maintenance of vegetation within herbaceous wetlands 

to a 10-foot-wide strip of vegetation centered over the pipeline, and in forested 

areas, limiting tree removal to those that are within 15 feet of the pipeline 

centerline.

During clearing, Cameron Interstate would install temporary erosion control measures to 

prevent sedimentation of wetlands. 

In unsaturated wetlands, Cameron Interstate would segregate up to 12 inches of topsoil 

from the trench from subsoil. Topsoil would be stabilized to minimize loss due to water or wind 

erosion with use of sediment barriers, mulch, temporary seeding, tackifiers, or functional 

equivalents, where necessary. Topsoil would not be stripped in saturated wetlands, at locations 

where no topsoil layer is evident, or in areas where the topsoil depth exceeds the depth of the 

trench. In accordance with the Cameron Interstate Procedures, Cameron would not trench within 

the wetland boundaries until the pipeline has been assembled and is ready for lowering-in. In 

saturated wetlands, Cameron Interstate would use special construction techniques, such as the 

use of low ground-pressure equipment or timber construction mats. Concrete-coated pipe or 

weights would be used during construction to ensure that the pipe does not float in saturated 

conditions. After construction, Cameron Interstate would remove timber mats and restore the 

contours as close to pre-existing conditions as possible. Non-forested wetlands within the 

construction right-of-way and forested wetlands outside of the permanent right-of-way that are 

affected by construction would be allowed to revegetate naturally, or as required by applicable 

permits. 

4.4.5.2 Alternative Measures to FERC’s Procedures

Cameron Interstate proposes alternative measures to the measures described in Section 

VI.A.3, VI.B.1, and VI.A.6 of our Procedures, which relate to the construction right-of-way 

width, the location of extra workspaces in wetlands, and locating aboveground facilities in 

wetlands. 

Section VI.A.3 of the FERC Procedures states the width of the construction right-of-way 

should be 75 feet or less in wetlands. Cameron Interstate has proposed a right-of-way width of 
4-35 Wetlands

100 feet for 66 wetland crossings due to unstable sandy soil conditions that require a greater 

trench width to maintain slope stability. 

Section VI.B.1 of the FERC Procedures states all extra work areas, such as staging areas 

and access roads, should be at least 50 feet outside of identified wetland boundaries, except 

where the adjacent upland consists of actively cultivated or rotated cropland or other disturbed 

land. Cameron Interstate proposed 33 locations where ATWS areas would be within 50 feet of a 

wetland including ATWS for road bores and HDD pullbacks.

Additionally, Cameron Interstate has proposed an alternative measure to our Procedures 

relating to the location of both the Holbrook Compressor Station and the FGT Interconnection. 

Section VI.A.6 of our Procedures state aboveground facilities should be outside of wetlands, 

except where the location of such facilities outside of wetlands would prohibit compliance with 

DOT regulations. To achieve the required natural gas flow rate at the terminal, the compressor 

station would need to be between MP 3.5 and MP 9.0. Alternative locations within the 5.5-milelong corridor were evaluated; however, wetlands comprise much of the area and could not be 

avoided (see section 3.7.1). The site of the Holbrook Compressor Station was chosen to avoid 

high quality PFO wetlands along the Little River. The FGT Interconnection would be adjacent

to the existing FGT Interconnection between the FGT pipeline and the existing Cameron 

Interstate Pipeline. Alternative locations would increase overall wetland impacts by requiring a 

new interconnection facility and reducing the percent of right-of-way collocated with existing 

rights-of-way.

Cameron Interstate would also complete all wetland permitting and compensatory 

mitigation consultations with the COE, LNDR, and LDEQ before commencing construction at 

any extra workspaces, ATWS areas, access roads, and aboveground facilities within wetlands, as 

discussed above. In addition, Cameron Interstate would implement all applicable wetland 

protective measures included in its Procedures. 

Based on our review, we determined that the proposed alternative measures to our 

Procedures (including those that would affect PFO wetlands), are reasonable and are adequately 

justified. Impacts at the specified locations would occur in PEM, PSS, and low-quality (pine 

plantation) PFO wetlands, with the exception of the four locations where impacts on bottomland 

hardwood communities would occur. In addition, the crossing of three wetlands where the 

wetland is not crossed at the centerline would impact bottomland hardwood communities. 

Additional justification and/or mitigation is warranted for Cameron Interstate’s requested 

alternative measure to increase the right-of-way width within these seven bottomland hardwood 

wetlands. As a result, the draft EIS included a recommendation that Cameron Interstate should 

provide an assessment of the feasibility of a reduced construction right-of-way width, expansion 

of nearby HDDs, or other alternative construction methods to minimize impacts on PFO 

wetlands containing bottomland hardwood species at MP 1.55, MP 2.25, MP 15.98, MP 18.46, 

MP 18.79, MP 20.11, and MP 20.36. In response to that recommendation (Recommendation No. 

18 in the draft EIS), Cameron Interstate agreed to reduce the width of the construction right-ofway at these areas of concern.

30 As a result, the width of the construction right-of-way would be 

 30 See Cameron LNG and Cameron Interstate comment letter on the draft EIS dated February 20, 2014, which is 

included in Appendix L as comment letter AP1.
Vegetation 4-36

reduced as follows: (1) from 125 feet to 100 feet at MPs 1.55 and 2.25, (2) from 100 feet to 75 

feet at MPs 15.98, 18.46, 18.79, 20.11, and 20.36. These changes would avoid impacts to a total 

of 1.25 acres of wetlands. Therefore, we are recommending that:

• Prior to construction, Cameron Interstate should file with the Secretary for 

review and written approval by the Director of the OEP revised photoalignment sheets depicting the reduced right-of-way widths at MP 1.55, MP 

2.25, MP 15.98, MP 18.46, MP 18.79, MP 20.11, and MP 20.36.

4.4.5.3 Compensatory Mitigation

Cameron Interstate, as part of the wetlands permitting process, filed its Section 404 

permit application with the COE, New Orleans District and is continuing consultations with the 

COE regarding appropriate mitigation for wetland impacts. 

To mitigate the permanent loss of about 4.1 acres of wetlands along the proposed pipeline 

right-of-way and the conversion of about 12.0 acres of wetlands to PEM wetlands, Cameron 

Interstate proposed to purchase mitigation credits from a COE-approved mitigation bank 

servicing the area. Details regarding the number and type(s) of credits that would be purchased 

would be decided by the COE upon review of the Section 404 permit application. Cameron 

Interstate stated that the COE indicated it would not require mitigation for the permanent impacts 

on the PEM wetland at the FGT Interconnection. Through use of the measures discussed above, 

collocation of the majority of the proposed pipeline right-of way, and the proposed mitigation 

measures, we believe impacts on wetlands along the proposed pipeline route would be 

minimized to the extent practicable. 

4.5 VEGETATION

4.5.1 Vegetation Resources

4.5.1.1 Terminal Expansion

The Terminal Expansion would be constructed on 424.7 acres of vegetated land,

including 52.9 acres within the existing terminal boundary and 371.6 acres on property directly 

north of the existing terminal. Vegetation types that would be affected during construction and 

operation of the Terminal Expansion include 211.2 acres of upland open land and 213.5 acres of 

wetlands. Section 4.4.4 provides additional information on wetland types, vegetation, and 

impacts.

About 93 percent of the Terminal Expansion site was previously disturbed through use as 

a COE disposal site for dredged material from maintenance of the Calcasieu Ship Channel. 

About 70.0 acres were also disturbed during construction of the existing Cameron LNG 

Terminal. As a result, vegetative communities contain low species diversity and are not 

productive as agricultural land, grazing land, or high-quality wildlife habitat. Much of the 

property is comprised of vegetation indicative of disturbed sites, such as groundsel tree, curly 

dock, goldenrod, and dewberry. 

All impacts on vegetation would be permanent, as Cameron LNG would convert the 

entire Terminal Expansion site to industrial use with concrete and gravel ground cover during 
4-37 Vegetation

operation. Cameron LNG would implement erosion control and other mitigation methods in our

Plan and Procedures to minimize indirect effects on vegetative communities during construction. 

To offset proposed permanent wetland impacts, Cameron LNG proposes to complete 

compensatory wetland mitigation, as discussed in section 4.4.4.3. Due to the presence of lowquality vegetation and proposed mitigation measures, we believe impacts from construction and 

operation of the Terminal Expansion on vegetation communities would not be significant, 

although the impacts would be permanent.

4.5.1.2 Pipeline Expansion 

Construction of the pipeline and associated facilities would disturb about 9.9 acres of 

upland forest, 40.2 acres of pine plantation, 152.4 acres of upland open land, 24.1 acres of 

agricultural land, and 56.7 acres of wetlands. Refer to section 4.4.5 for details on wetland types, 

vegetation, and impacts. Table 4.5.1-1 lists the vegetation communities affected by the proposed 

pipeline and associated facilities, including vegetation type and acreage affected.

Common canopy trees present in upland forests along the proposed pipeline route and 

associated facilities are: loblolly and slash pine, live and post oak, sweet gum, southern 

magnolia, and Chinese tallow tree. Pine plantations are typically comprised of a single species 

(either slash or loblolly pine) and are exclusively used for timber or paper production. Two 

types of critically imperiled longleaf pine savannahs, western acidic and saline, potentially occur

within the proposed Pipeline Expansion area in Beauregard and Calcasieu Parishes. LNHP 

requested that Cameron Interstate minimize impacts on these two forest habitats as discussed in 

section 4.7. Typically, the understory in pine plantations is sparse and is often controlled 

through maintenance activities. Understory species present along the proposed pipeline include:

yaupon, wax myrtle, Chinese tallow, and various species of Smilax. Open lands are upland areas 

typically vegetated with grasses, forbs, and shrubs. Common open land species include: 

Bermuda, Bahia, and vasey grass, goldenrod, ragweed, yaupon, American holly, groundsel tree, 

and wax myrtle. Un-vegetated land cover types, such as agricultural, industrial, and residential 

lands, are discussed in more detail in section 4.8.

Cameron Interstate would typically construct its pipeline within a 100-foot-wide 

construction right-of-way and ATWS areas, except in the four bottomland hardwood wetland 

areas where the right-of-way would be reduced as described in section 4.4.5.2. The construction 

right-of-way, ATWS areas, and aboveground facilities would be mechanically cleared of all 

vegetation and graded, with tree stumps removed as necessary. Cameron Interstate would 

dispose of cleared and removed timber and vegetation by one or more of the following methods 

as approved by landowners and/or state and local agencies: chipping/shredding and dispersing 

along the right-of-way; off-site disposal; or burning by permit. Construction crews would stack 

the timber along the disturbed right-of-way for landowner removal and use, upon landowner 

request and approval. Timber would be stacked where landowners can access it and would be 

stacked no more than 4 feet in height. A minimal gap of 30 feet would be maintained between 

stacks to allow for wildlife movement.
Vegetation

4-38

TABLE 4.5.1-1

Acreages of Vegetation Cover Types Impacted by the Pipeline Expansion a

Project Component Agriculture Pine Plantation Wetlands b Upland Forest Upland Open 

Land Total

Cons c Oper d Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper

Holbrook Compressor Station 0.0 0.0 12.4 11.6 4.5 3.1 0.0 0.0 0.4 0.4 17.3 15.1

Other Aboveground Facilities 

(Interconnections & Metering) 0.0 0.0 0.0 0.0 0.4 0.4 0.1 0.1 3.1 3.1 3.6 3.6

Pipeline e 24.1 8.1 27.2 5.7 50.8 12.0 9.8 1.4 138.6 40.4 250.5 67.6

Access Roads 0.0 0.0 0.6 0.6 1.1 0.6 0.0 0.0 0.0 0.0 1.7 1.2

Contractor Yard 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 10.3 0.0 10.3 0.0

Pipeline Project Totals 24.1 8.1 40.2 17.9 56.8 16.1 9.9 1.5 152.4 43.9 283.4 87.5

a The numbers in this table have been rounded for presentation purposes. As a result, the totals may not reflect the sum of the addends,

b Includes PFO, PSS, and PEM types

c Cons = impacts from construction

d Oper = portion of construction impacts that would be permanently maintained following construction

e Includes vegetation cover type acreage for ATWS areas 
4-39 Vegetation

The permanent right-of-way would vary between 25 and 50 feet wide, depending on the 

amount of permanent right-of-way overlap with existing rights-of-way. Cameron Interstate 

would collocate 15.5 miles of pipeline to overlap with existing rights-of-way and the permanent 

right-of-way would generally be 25 feet wide. Approximately 4.1 miles of pipeline would be 

offset from Cameron Interstate’s existing permanent right-of-way and would require a 50-footwide permanent easement. The remaining 1.4 miles are associated with HDD waterbody 

crossings where the right-of-way would not be maintained. Within upland forest, pine 

plantation, and forested wetland areas, the maintained easement would be 15 feet wide in 

collocated areas and 30 feet wide in non-collocated areas, as trees within 15 feet of the pipeline 

and greater than about 15 feet tall would be removed to ensure root systems do not interfere with 

operations of the pipeline. Routine vegetation mowing or clearing would occur not more than 

every 3 years across the entire permanent right-of-way. However, to facilitate periodic corrosion 

and leak surveys, Cameron Interstate would maintain a corridor not exceeding 10 feet in width 

centered over the pipeline in an herbaceous state.

The primary impacts on vegetation from construction of the pipeline and associated 

facilities would be the cutting, clearing, and/or removal of existing vegetation within the 

construction work areas. The duration and magnitude of impacts would depend on the type and 

amount of vegetation affected, the rate at which vegetation regenerates after construction, and 

the frequency of vegetation maintenance conducted on the right-of-way during pipeline 

operation. In addition, right-of-way revegetation would depend on factors such as local climate, 

soil types, right-of-way maintenance practices, and land use. There would be minor and shortterm changes on agricultural, scrub-shrub and herbaceous wetland, and open upland areas 

because we would expect these areas to revegetate to a cover similar to pre-construction 

conditions within 1 to 4 years. In areas where forest regeneration would occur, re-establishment 

to pre-construction conditions could take 10 to 30 years, depending on the species type. In 

addition, blowdowns may become more frequent for a time as trees newly exposed on the edge 

of forested habitats would not be acclimated to windy conditions often present in edge habitats.

Of the 152.4 acres of open land that would be disturbed for all aspects of the Pipeline 

Expansion during construction, 43.9 acres would be permanently affected within the Holbrook 

Compressor Station site, the pipeline right-of-way, and the interconnections (table 4.5.1-1). 

Cameron Interstate would re-seed the remaining 108.5 acres after pipeline installation and recontouring the right-of-way. Cameron Interstate would consult the local NRCS regarding 

seeding mixes, application rates, and times for the pipeline and associated facilities. Impacts on 

upland open land cover would be minor and short-term because the grass and shrub vegetation 

present in the majority of the Pipeline Expansion areas would revegetate to pre-construction 

conditions within one to two growing seasons following construction. 

In forested areas, including upland forest, pine plantation, and forested wetland, the 

removal of trees would constitute a conversion of the forest to herbaceous cover. In areas 

outside the permanent right-of-way, the impact would be long-term, but those areas would be 

allowed to recover to pre-construction conditions over time. Within the permanent right-of-way, 

the conversion of wetland forest to PEM or PSS wetland would be permanent, as Cameron 

Interstate would preclude trees from growing within 15 feet of the pipeline. As discussed above, 

the permanent easement within forested wetland areas would be 30 feet wide in non-overlapping 

areas and 15 feet wide in areas that overlap with existing rights-of-way. Of the 14.8 acres of 
Vegetation 4-40

forested wetland that Cameron Interstate would clear during construction, 3.4 acres would be 

permanently maintained in an herbaceous state. Of the 50.1 acres of upland forest and pine 

plantation that would be cleared during construction of the Pipeline Expansion, Cameron 

Interstate would permanently maintain 19.4 acres in an herbaceous state. The remaining 10.0

acres of forested wetland and 30.7 acres of forested upland would be allowed to revert back to 

forest cover. 

Cameron Interstate’s use of one contractor yard would temporarily affect 10.6 acres of 

upland open land. ATWS areas would impact 33.5 acres of agriculture, upland forest, upland 

open land, wetland, and pine plantation during construction. Impacts associated with agricultural 

land, upland open land, and herbaceous and scrub-shrub wetlands would be short-term, while 

impacts on forest would be long-term. No permanent impacts on vegetation would result from 

the use of these sites.

To minimize direct and indirect impacts on vegetative cover types along the proposed 

pipeline route and associated ATWS areas, Cameron Interstate would follow the requirements of 

its Plan. Some of the restoration and best management practices identified in the Cameron 

Interstate Plan include:

• use of at least one EI who would ensure compliance with Cameron Interstate’s 

Plan, Procedures, and other required conditions as provided in its Environmental 

Plan (Appendix D);

• stripping and segregating up to 12 inches of available topsoil over the ditch and 

working side of the right-of-way in agricultural land, residential areas, and where 

required by the landowner to preserve the native seed bank;

• installation of temporary and permanent erosion control measures, such as slope 

breakers, sediment barriers, and mulch; 

• commencement of cleanup, including restoring contours, immediately after 

backfilling and completion of restoration within 20 days (weather permitting);

• testing and mitigation for soil compaction;

• revegetation in accordance with the recommendations of the local soil 

conservation authority (NRCS) or the affected landowner;

• use of barriers to control off-road vehicle activities; and

• post-construction monitoring and maintenance of revegetated areas.

Where implemented, the use of HDD methods would also avoid and/or minimize impacts 

on vegetated communities, riparian vegetation, and high-quality forested wetlands (see section

4.3.2). Cameron Interstate proposes to use the HDD method in six areas along the proposed 

pipeline route that contain mature trees. Cameron Interstate would not clear trees between the 

entry and exit points of the HDD; however, minor hand clearing of woody vegetation and/or 

branches would be required along the HDD guide wire. 

Through use of the measures discussed above and collocation of the majority of the 

proposed right-of way to overlap with existing rights-of-way, we believe impacts on vegetation 
4-41 Vegetation

would be minimized to the extent practicable. In addition, the vegetative cover types within the 

Pipeline Expansion area represent a small percentage of the total available land of similar types 

in the surrounding area, and a large proportion of the affected area has been previously disturbed.

Therefore, we do not consider construction and operation of the proposed Pipeline Expansion, 

including associated facilities, to be a significant impact.

4.5.2 Exotic or Invasive Plant Communities and Noxious Weeds

Exotic plant communities, invasive species, and noxious weeds can out-compete and 

displace native plant species, thereby negatively altering the appearance, composition, and 

habitat value of affected areas. Chinese tallow trees are the only noxious weed of concern 

present along portions of the proposed pipeline route, at the proposed compressor station site, 

and at the Terminal Expansion site (NRCS 2013). 

Chinese tallow trees establish easily, grow quickly, and produce large quantities of seeds 

that are long-lived and are spread by water, birds, and mammals. This species can re-sprout 

quickly from crown and root buds when top growth is mechanically removed. As a result of this 

species already being present within the Project area, it is only possible for Cameron to manage 

this species rather than control its spread. No management of Chinese tallow trees would be 

needed at the Terminal Expansion, as the entire area would be permanently maintained as an 

industrial site.

Cameron Interstate would control the spread of Chinese tallow trees by managing the 

growth and distribution of tallow trees using the methods recommended by the NRCS: the leaf 

spraying and the stem spraying method. Prior to construction, Cameron Interstate would consult 

with the NRCS to determine acceptable application rates and spray times suitable for control of 

tallow trees along the pipeline route. In addition, Cameron Interstate’s Plan and Procedures 

include procedures designed to minimize the opportunity for noxious weeds from areas outside

of the Project to be introduced into the soil during construction. As stated in these documents, 

Cameron Interstate would develop specific procedures in coordination with NRCS to prevent the 

introduction or spread of noxious weeds and soil pests resulting from construction and 

restoration activities. Cameron Interstate’s EIs would verify that the soils imported for 

agricultural or residential use have been certified as free of noxious weeds and soil pests. Preconstruction surveys, specifically for noxious weeds, are not proposed; however, Cameron 

Interstate would provide pre-construction training to construction crews for the identification and 

reporting of noxious weeds to EIs. Based on the proposed control measures, we conclude that 

impacts from noxious weeds on native plant communities would not be significant. 

4.5.3 Vegetation Communities of Special Concern

No vegetative communities of special concern have been identified within the proposed 

Terminal Expansion site, along the proposed pipeline route, or within associated aboveground 

facility areas. Potential habitat for special-status plant species is discussed in section 4.7.
Wildlife And Aquatic Resources 4-42

4.6 WILDLIFE AND AQUATIC RESOURCES

4.6.1 Wildlife Resources

Wildlife species inhabiting the Project area are characteristic of the vegetative habitats 

that occur in the vicinity of the Project. We identified habitats based on interpretation of aerial 

photography and Cameron’s field reconnaissance.

4.6.1.1 Terminal Expansion

Existing Wildlife Habitat

The wildlife habitat types at the proposed Terminal Expansion site include wetlands, 

open water, and open land. Fisheries are discussed in section 4.6.3. Industrial or developed 

lands are not included in this section.

Wetland habitats, including PEM, PSS, and PFO wetland types, provide habitat for 

waterfowl, wading birds, raptors, mammals, reptiles, and amphibians. Typical wildlife 

associated with these habitats include: wood and mottled ducks; belted kingfisher; seaside 

sparrow; snowy, great, and cattle egrets; great blue heron; Virginia and king rails; red-shouldered 

hawk; barred owl; red-headed woodpecker; white-tailed deer; raccoon; nutria; eastern woodrat; 

swamp rabbit; beaver; eastern cottonmouth; diamond-backed water snake; and southern leopard 

frog.

Open water habitat within the Terminal Expansion site includes two freshwater ponds. 

Similar to wetland habitat, open water habitat provides food and water sources, in addition to 

habitat for species such as wading birds, waterfowl, beavers, nutria, snakes, and other wildlife 

species dependent on an aquatic environment. 

Open land consists primarily of grasses, forbs, and shrubs. Wildlife associated with these 

areas includes mammals, such as the white-tailed deer, coyote, striped skunk, cotton and whitefooted mice, eastern mole, and eastern cottontail rabbit. Bird species include mourning dove, 

American crow, common grackle, red-winged blackbird, American kestrel, and red-tailed and 

red-shouldered hawks. Reptiles and amphibians include common garter snake, southern black 

racer, copperhead, green anole, Gulf Coast toad, and box turtle. 

Much of the area proposed for the Terminal Expansion has been previously disturbed. 

Approximately 64.8 acres of habitat, including open water and upland open land, in the proposed 

Terminal Expansion area are within the existing LNG terminal footprint and were disturbed 

during construction of the original LNG terminal. Nearly all of the 424.7 additional acres of 

habitat outside the existing terminal footprint, including wetlands, open water, and upland open 

land, were previously disturbed from the COE’s Calcasieu Ship Channel dredge material 

disposal. These previous activities resulted in the degradation of wildlife habitat at the proposed 

Terminal Expansion site, which has reduced both the number of species found on the site and 

habitat diversity. 
4-43 Wildlife And Aquatic Resources

Impacts and Mitigation 

Construction and operation of the Terminal Expansion would result in permanent 

alteration of the various wildlife habitat types listed above. Construction of the Terminal 

Expansion facilities would permanently affect 502.2 acres, of which about 70 acres are within 

the existing terminal area. Approximately 213.5 acres of the Terminal Expansion site are 

wetlands and 211.2 acres are upland open land. Open water habitat comprises 70.1 acres, of 

which 9.4 acres are estuarine and 60.7 acres are freshwater man-made ponds. Land uses at the 

Terminal Expansion site are discussed in section 4.8 and listed in table 4.8.1-1.

Terminal Expansion construction would require vegetation clearing, grading, and fill to 

level the site. This would reduce cover, nesting, and foraging habitat for some species and may 

result in mortality of less mobile forms of wildlife, such as small rodents and reptiles. Other 

wildlife, such as birds and larger mammals, would leave the Terminal Expansion area as 

construction activities approach. These animals may relocate into similar habitats nearby; 

however, if a lack of adequate territorial space were to exist adjacent to the site, this could force 

these animals into suboptimal habitat and/or increased densities, which could lower reproductive 

success and survival. 

Cameron LNG would permanently remove all habitats at the Terminal Expansion site and 

convert them to industrial land. However, these habitats have been previously disturbed and 

offer limited productive wildlife habitat within the Terminal Expansion site, and a large amount 

of similar and/or higher quality habitat exists adjacent to and near the Terminal Expansion site 

for wildlife use. In addition, due to current industrial activities within and around the proposed 

Terminal Expansion area, most wildlife species in the area are acclimated to these activities, thus 

impacts due to noise, light, and human activity would be negligible. Given Cameron LNG’s 

recent successful creation of marsh habitat out of similar shallow open water areas during 

construction of the existing terminal, we believe the overall impact on wildlife using wetland 

habitat would be mitigated, as species would relocate to adjacent wetlands and the proposed 

marsh creation areas. These areas would provide higher quality habitat for wildlife currently 

using the Terminal Expansion area (refer to section 4.4.4). Therefore, we do not expect 

significant impacts on wildlife due to construction and operation of the Terminal Expansion. 

4.6.1.2 Pipeline Expansion 

Existing Wildlife Habitat

Vegetation types providing wildlife habitat within and around the Pipeline Expansion 

area include upland forest, agriculture, wetlands, landscaping on developed land (industrial and 

residential), pine plantation, and upland open land. About 74 percent of the right-of-way would 

overlap with existing rights-of-way; therefore, the majority of the Pipeline Expansion right-ofway would impact vegetated open land. 

Open land along the proposed Pipeline Expansion route consists primarily of grasses, 

forbs, and shrubs. Wildlife associated with these areas include mammals, such as white-tailed 

deer, coyote, striped skunk, cotton mouse, white-footed mouse, eastern mole, and eastern 

cottontail rabbit. Bird species include mourning dove, American crow, common grackle, redwinged blackbird, American kestrel, and red-tailed and red-shouldered hawks. Reptiles and 
Wildlife And Aquatic Resources 4-44

amphibians include common garter snake, southern black racer, copperhead, green anole, Gulf 

Coast toad, southern leopard frog, and box turtle. 

The upland forest and pine plantation habitats crossed by the proposed Pipeline 

Expansion provide habitat for mammals, including white-tailed deer, gray fox, bobcat, coyote, 

eastern cottontail rabbit, cotton mouse, fox squirrel, raccoon, and opossum. Resident and 

migratory non-game bird species that use these habitats include barred owl, northern cardinal, 

wood thrush, pine warbler, and eastern towhee. Avian game species include wild turkey, 

bobwhite quail, and mourning dove. Small songbirds utilize the forests, thickets, and cut-over 

areas of the upland forests and pine plantations to rest and feed during migration and, in some 

cases, breed. Amphibians and reptiles found in forest habitat include box turtle, black rat snake, 

spotted salamander, southeastern five-lined skink, and spring peeper. 

Wetland habitats provide habitat for waterfowl, wading birds, raptors, mammals, reptiles, 

and amphibians. Typical wildlife associated with these habitats includes wood and mottled 

ducks; white, great and cattle egrets; great blue heron; red-shouldered hawk; barred owl; redheaded woodpecker; white-tailed deer; nutria; eastern woodrat; swamp rabbit; raccoon; beaver; 

eastern cottonmouth; diamond-backed water snake; and southern leopard frog.

Riparian habitats include vegetation along banks of waterbodies, both natural and manmade. Similar to wetland habitat types, riparian habitats provide food and water sources, in 

addition to habitat, for species such as wading birds, waterfowl, beavers, otters, snakes, and other 

wildlife species dependent on aquatic environments. Waterbodies are addressed in section 4.3.2, 

while fisheries and other aquatic resources within these waterbodies are discussed in section 

4.6.3. 

Agricultural lands are frequently disturbed and provide habitat for edge-dwelling species 

that can either tolerate or thrive on disturbance. Edge habitats are transition zones where two 

ecosystems come together, such as forested and non-forested cover types. Certain species prefer 

these transition zones, as they provide certain types of food and cover in one area. Typical 

wildlife species that use agricultural lands are white-tailed deer, raccoon, striped skunk, coyote, 

and small mammals such as eastern harvest, cotton, and white-footed mice. 

Developed lands provide limited wildlife habitats for species that utilize wooded yards 

and landscape shrubbery for forage and shelter. Some of these species include songbirds, 

squirrel, raccoon, and white-tailed deer.

Impacts and Mitigation 

Construction of the proposed Pipeline Expansion would temporarily disturb about 284.6

acres of wildlife habitat during construction and permanently affect about 87.5 acres during

maintenance of the pipeline right-of-way and aboveground facilities, including the Holbrook 

Compressor Station, interconnections, and access roads (see table 4.5.1-1). Cameron Interstate 

would avoid or minimize impacts on riparian habitat by use of the HDD method at all perennial 

waterbody crossings and use of its Procedures where wet or dry waterbody crossing techniques 

are proposed.

The impact of construction on wildlife species and their habitats would vary depending 

on the resource requirements of each species and the existing habitat present along the pipeline 
4-45 Wildlife And Aquatic Resources

route and at aboveground facilities. The greatest effect to wildlife would occur during cutting, 

clearing, and/or removal of existing vegetation, which would reduce the amount of available 

habitat within the construction right-of-way and temporary workspaces. The degree of 

temporary impact would depend on the rate at which vegetation regenerates after construction. 

Herbaceous and scrub habitats generally revegetate within 4 years of disturbance, while forested 

areas can take up to 30 years to completely recover. 

Clearing of the temporary construction right-of-way would reduce cover, nesting, and 

foraging habitat for some species and may result in direct mortality for less mobile forms of 

wildlife, such as small rodents and reptiles. Larger or more mobile wildlife, such as birds and 

large mammals, would vacate the right-of-way as construction activities approach. Most species

would relocate into similar habitats in the vicinity of the proposed Pipeline Expansion facilities. 

However, if a lack of adequate territorial space exists, some individuals could be forced into 

suboptimal habitats. This could increase inter- and intra-specific competition and lower 

reproductive success and survival. That influx and increased density of species in some 

undisturbed areas could reduce reproductive success of animals that are not displaced by 

construction. These effects would cease after completion of construction and wildlife could 

return to the newly disturbed areas and adjacent, undisturbed habitats after right-of-way 

restoration is completed. Species that use early successional shrub or forest communities may 

benefit from the clearing and revegetation process, as additional habitat of this type would be 

created by construction of the proposed Pipeline Expansion. Additionally, non-woody, early 

successional vegetation may provide seeds and foliage as food for small mammals and birds, as 

well as habitat for ground-nesting birds, mammals, and reptiles.

In forested areas, construction of the Pipeline Expansion would relocate the edge habitat, 

as the entire route is adjacent to or near existing cleared rights-of-way, and the frequency of tree 

blowdowns may increase due the exposure of trees to windier conditions than they are 

acclimated to. These habitats are used by several wildlife species, such as white-tailed deer and 

various small mammals. Many species adapt well to this habitat shift and could take advantage 

of the edge habitats. Predatory species such as red-tailed hawk and coyote commonly use utility 

rights-of-way for hunting, and other species, such as eastern cottontail, northern bobwhite, 

mourning dove, eastern meadowlark, white-eyed vireo, white-tailed deer, and American crow, 

would benefit from the transition to early successional habitat for foraging. During construction,

Cameron Interstate would stack cleared timber along the right-of-way at intervals at least 30 feet 

apart and no more than 4 feet in height to ensure wildlife movement is not impeded. 

Although impacts may be advantageous for some species, construction and operation of 

the Pipeline Expansion would widen existing cleared rights-of-way, which may affect some 

interior forest species or species that prefer large tracts of unbroken forest. Species that use tree 

cavities for either roosting or nesting may suffer direct mortality during right-of-way clearing. 

Additionally, nesting success may be denied or diminished for one annual breeding cycle for 

adult birds that normally breed in the area but would avoid it during construction activities. The 

slow regeneration of forested communities within the temporary right-of-way would result in the 

long-term reduction in forested habitat for species that use these communities; however, 

abundant similar habitats are available for wildlife adjacent to the proposed Pipeline Expansion 

corridor. To further reduce impacts on nesting birds during pipeline operation, routine 

vegetation mowing or clearing would not occur along the entire width of the permanent right-of-
Wildlife And Aquatic Resources 4-46

way more frequently than every 3 years and routine vegetation mowing or clearing would not 

occur during the migratory bird nesting season between April 15 and August 1 unless 

specifically approved in writing by the responsible land management agency or the FWS, in 

accordance with Cameron Interstate’s Plan. 

Agricultural lands are areas that are regularly disturbed and would be available for

replanting during the next growing season following installation of the pipeline. Therefore, we 

believe impacts on wildlife that use agricultural lands would be short-term and negligible. 

Because Cameron Interstate would collocate the pipeline to overlap with existing rightsof-way as much as possible and would adhere to its Plan and Procedures and other measures 

discussed in this EIS, we believe construction and operation of the Pipeline Expansion would not 

substantially affect local wildlife populations. Furthermore, due to the amount of collocation, we 

do not expect habitat fragmentation to have a significant impact on wildlife populations. 

Therefore, impacts on wildlife due to construction and operation of the Pipeline Expansion 

would not be significant. 

4.6.1.3 Unique and Sensitive Wildlife Species

Unique or sensitive wildlife species, such as colonial nesting waterbirds and migratory 

songbirds and waterbirds, may be present in the vicinity of the proposed Project. Federally and 

state listed threatened and endangered species and other species of concern are discussed in 

section 4.7.

Migratory Birds

Migratory birds are protected under the Migratory Bird Treaty Act (MBTA) and 

Executive Order 13186, including bald and golden eagles, which are also protected under the 

Bald and Golden Eagle Protection Act. Bald eagles are further discussed in section 4.7. The 

executive order was enacted, in part, to ensure that environmental analyses of federal actions 

evaluate the impacts of actions and agency plans on migratory birds. It also states that emphasis 

should be placed on species of concern, priority habitats, and key risk factors, and it prohibits the 

take of any migratory bird without authorization from the FWS. The destruction or disturbance 

of a migratory bird nest that results in the loss of eggs or young is also a violation of the MBTA. 

Numerous migratory bird species, including colonial nesting waterbirds, waterfowl, and 

neotropical songbirds, could potentially occupy areas of the proposed Project facilities. 

Migratory birds follow broad routes called flyways between breeding grounds in Canada 

and the United States and wintering grounds in Central and South America, and the Caribbean. 

Additionally, several species migrate from breeding areas in the north to winter along the Gulf 

Coast and remain throughout the non-breeding season. The proposed Project is at the western 

edge of the Mississippi Flyway and the eastern edge of the Central Flyway. 

The Central and Mississippi Flyways both terminate at the Gulf Coast, making it one of 

the most important waterfowl areas in North America. Of the 650 species of birds known to 

occur in the United States, nearly 400 species occur in the Gulf Coast Migratory Bird Joint 

Venture area, which is discussed below. The Gulf Coast provides wintering and migration 

habitat for significant numbers of continental duck and goose populations that use both the 

Central and Mississippi Flyways. The coastal marshes of Louisiana, Alabama, and Mississippi 
4-47 Wildlife And Aquatic Resources

regularly hold half of the wintering duck population of the Mississippi Flyway (Esslinger and 

Wilson 2001).

The proposed Project is within the Cheniere Plain portion of the Gulf Coast Migratory 

Bird Joint Venture initiative area. The goal of the Cheniere Plain Initiative is to provide 

wintering and migration habitat for significant numbers of dabbling ducks, diving ducks, and 

geese, as well as year-round habitat for mottled ducks (Esslinger and Wilson 2001). The Project 

is also within the Partners in Flight – North American Landbird Plan – Gulf Coastal Plain. The 

area in the vicinity of the proposed Project provides important breeding habitat for resident birds 

of conservation concern, such as reddish egret, loggerhead shrike, sandwich tern, and dickcissel, 

as well as important wintering and stop-over habitat for migratory priority species, such as red 

knot and prothonotary and Swainson’s warblers (FWS 2008). No critical habitat for bald eagles 

is present in the vicinity of the proposed Project according to FWS element occurrence records, 

and it is unlikely that a transient bald eagle would use habitat within that area.

The Terminal Expansion site contains marginal habitat for migratory birds, as much of 

the vegetation has been previously disturbed. The primary migratory birds using the wetland and 

open water habitats within the proposed Terminal Expansion site are various species of 

waterfowl and water birds; species are predominantly gadwall, mallard, blue-winged teal, 

American coot, and various species of egrets and herons. Although wetland habitats in the 

Terminal Expansion area provide habitat for migratory waterfowl and waterbirds, use of this site 

is likely limited due to the proximity to and activity associated with LA-27, the Calcasieu Ship 

Channel, and the existing LNG Terminal. To mitigate this loss, Cameron LNG proposes to 

create tidal brackish marsh west of the Terminal Expansion site, which would provide additional 

habitat for migratory waterfowl and various wading/water bird species nearby. Impacts on 

migratory birds and their habitat within the Terminal Expansion site due to construction and 

operation would be similar to impacts on general wildlife resources, discussed in section 4.6.1. 

Therefore, impacts on the abundance of migratory waterfowl and other water birds due to the 

permanent conversion of these habitats would not be significant.

During startup, which may require up to 2 months for each train, flaring would be 

required. During operation, flaring would only occur occasionally. However, there is also 

occasional flaring throughout the general area, including at the existing Cameron LNG Terminal; 

the FWS has not raised this as an issue of concern in the area and we are not aware of any 

reported significant impacts of flaring on migratory birds in the area. As a result, we believe that 

the temporary flaring during construction and the occasional flaring during operation do not 

represent a significant impact on migratory birds passing through the area.

A variety of migratory bird species, including songbirds and raptors, use the vegetation 

communities in the vicinity of the Pipeline Expansion route. Representative species are similar 

to the species that inhabit the area in the vicinity of the Terminal Expansion site. Impacts on 

migratory birds and their habitat would be similar to impacts on general wildlife resources due to 

construction and operation of the Pipeline Expansion, as previously discussed. To further reduce 

impacts on nesting birds during pipeline operation, Cameron Interstate would not conduct 

routine vegetation mowing or clearing more frequently than every 3 years. However, to facilitate 

periodic corrosion and leak surveys, a corridor not exceeding 10 feet in width centered on the 

pipeline would be cleared at a frequency necessary to maintain an herbaceous state. Cameron 
Wildlife And Aquatic Resources 4-48

Interstate would not conduct routine vegetation mowing or clearing during the nesting season 

between April 15 and August 1, in accordance with its Procedures. 

FWS stated Cameron LNG would not be required to perform migratory bird surveys prior 

to construction of the Terminal Expansion due to the marginal nature of the habitat 

(correspondence with FWS dated February 11, 2013). However, Cameron LNG stated it would 

continue to consult with the FWS regarding potential impacts on migratory birds within the 

Terminal Expansion site during construction. Prior to construction, Cameron Interstate proposes 

to perform surveys throughout the Pipeline Expansion right-of-way and other facility workspaces 

during the nesting season to identify unavoidable migratory bird habitat, such as rookeries and/or 

nesting colonies. Surveys were conducted by Cameron Interstate in 2012, and no potential or 

existing rookery sites were identified. Cameron Interstate filed a Migratory Bird Conservation 

Plan with FWS, which the agency approved as stated in its comment letter on the draft EIS 

(comment letter FG1 in Appendix L). This plan describes mitigation measures and calculations 

regarding compensatory mitigation for unavoidable impacts on migratory birds or their habitat. 

If unavoidable impacts are discovered during pre-construction surveys, Cameron Interstate 

committed to take appropriate measures to avoid impacts in the form of altering construction 

time windows to ensure active rookeries and nesting sites are not affected and would conduct 

nesting surveys prior to clearing, should clearing be necessary during the nesting season. Based 

on Cameron Interstate’s commitment to conduct surveys and implement mitigation measures 

(such as timing of activities) to avoid impacts on migratory birds, we believe net adverse impacts 

on migratory birds would not be significant. In addition, as part of the Migratory Bird 

Conservation Plan, Cameron Interstate agreed to purchase 17.43 credits of mitigation from The 

Conservation Fund. Cameron Interstate and The Conservation Fund signed a letter of intent, 

indicating that The Conservation Fund has approved the mitigation and the Migratory Bird 

Conservation Plan. 

Managed and Sensitive Wildlife Areas

No national wildlife refuges or state wildlife management areas are within or adjacent to 

the proposed Project. The Sabine National Wildlife Refuge (NWR) and Cameron Prairie NWR 

are about 6 and 12 miles, respectively, from the Terminal Expansion and no impacts would occur 

on either of these two refuges. Section 4.8.5 provides further information on these refuges.

The pipeline route would cross private property managed for hunting from MP 10.45 to 

MP 12.12. This property is owned by Goldsmith Farms and is managed in cooperation with the 

LDWF for a number of wild game species, including white-tailed deer, feral hogs, wild turkey, 

and pheasant. Hunting is designated by season for each species and limits are based on surveys 

conducted by LDWF personnel. In addition to hunting, the property is actively managed for 

pulp wood production. Given the current management practices, we do not believe construction 

or operation of the proposed pipeline would adversely affect hunting activities. 
4-49 Wildlife And Aquatic Resources

4.6.2 Aquatic Resources

4.6.2.1 Terminal Expansion

Existing Aquatic Resources

Surface waters that would be affected by construction of the proposed Terminal 

Expansion facilities include intertidal estuarine environments that support an estuarine fishery 

and freshwater ponds that support warm, freshwater fish. Typical recreational fish species that 

may exist on or near the proposed Terminal Expansion site are listed in table 4.6.3-1. No known 

commercial fisheries occur within the proposed Terminal Expansion site. Impacts on sensitive 

fisheries, such as penaeid shrimp and red drum, and EFH are described in section 4.6.4. Impacts 

on surface waters due to construction and operation of the Terminal Expansion are discussed in 

section 4.3.2.3.

TABLE 4.6.3-1

Fish Species Occurring in Waterbodies Affected by the Project a

Common Name Project Occurrence Classification

Alligator gar Pipeline Freshwater/Recreational

Red shiner Pipeline Freshwater

Blue catfish Pipeline Freshwater/Recreational

Channel catfish Pipeline Freshwater/Recreational

Flathead catfish Pipeline Freshwater/Recreational

Spotted bass Pipeline Freshwater/Recreational

Largemouth bass Pipeline Freshwater/Recreational

Yellow bass Pipeline Freshwater/Recreational

White crappie Pipeline Freshwater/Recreational

Black crappie Pipeline Freshwater/Recreational

Bowfin Pipeline and Terminal Freshwater/Recreational

Western mosquitofish Pipeline and Terminal Freshwater

Bluegill Pipeline and Terminal Freshwater/Recreational

Blue crab Terminal Estuarine/Recreational

Spotted seatrout Terminal Estuarine/Recreational

White shrimp Terminal Estuarine/Recreational

Brown shrimp Terminal Estuarine/Recreational

Red drum Terminal Estuarine/Recreational

a All waterbodies and fisheries classified as warmwater.
Wildlife And Aquatic Resources 4-50

The aquatic habitat near the proposed work dock is comprised mainly of shallow 

estuarine bottom, such as unconsolidated subtidal sediment and unconsolidated intertidal flats. 

Subtidal soft sediments provide feeding habitat for demersal fish, worms, and mollusks living on 

and in the sediments. Unconsolidated subtidal habitat has been designated as EFH for penaeid 

shrimp and the snapper/grouper complex of species, which is described in section 4.6.4. All 

unconsolidated sediments, including subtidal and intertidal areas, in the Calcasieu Ship Channel 

are considered early successional due to the constant disturbance from maintenance dredging, 

propeller wash, vessel traffic, and natural sedimentation. 

The depth of water near the bank of the ship channel where Cameron LNG would dredge

for the work dock is approximately 3.5 feet below MSL. During and after construction,

Cameron LNG would maintain the depth between 15 and 16 feet below MSL to facilitate the 

loading and unloading of barges. Cameron LNG would impact approximately 60.7 acres of open 

water (two freshwater man-made ponds); one pond would be drained and filled during 

construction and the other would be used as a stormwater retention basin and may be filled in the 

future.

Impacts and Mitigation 

We assessed impacts associated with the export of LNG, the use of LNG carriers 

(including traffic, transit, and ballast water discharges), and LNG spills in our previous EIS and 

two EAs for the existing Cameron LNG Terminal (see section 2.1.1). Cameron LNG is not 

proposing to increase its authorized number or size of LNG carriers, and the associated impacts 

would not change; therefore, these activities are not addressed in this EIS. However, we note 

that ballast water management requirements have changed since those reviews were conducted. 

LNG captains would be required to comply with 33 CFR 151.2025 (Ballast Water Management 

Requirements), which offer more options than previous requirements and are more stringent than 

previous requirements. As a result, our earlier assessments of potential impacts due to ballast 

water exchange remain appropriate. 

Work Dock

Construction of the proposed Terminal Expansion requires dredging of approximately 

205,000 cubic yards of material from a 9.4-acre area and sheet piling/pile driving activities to 

construct a work dock near the existing LNG terminal berthing area. Cameron LNG would 

construct the work dock approximately 375 feet from the edge of the maintained portion of the 

Calcasieu Ship Channel. 

Cameron LNG would use a vibratory hammer to install sheet piling and dock piles on 

land near the bank of the Calcasieu Ship Channel. Once the dock sheet piling and piles are 

installed, the berthing area would be dredged to attain the desired water depth of 15 to 16 feet

below MSL. Therefore, no sheet piling or pile driving activities would be conducted within the 

water column. However, the occurrence of these activities near the water could generate 

underwater sound pressure waves that can adversely affect nearby marine organisms, including 

fish. Dredging and the installation of the pilings for the dock could cause rapid concussive noise 

underwater. Depending on the sound frequency and intensity associated with this activity, it 

could cause a change in aquatic species behavior in proximity to the work dock area or could 

cause species to avoid the area. Underwater noise levels are commonly referred to as a ratio of 
4-51 Wildlife And Aquatic Resources

the underwater sound pressure to a common reference pressure of 1 micropascal (μPa) root 

mean-square pressure, which is expressed in decibels (dB) of sound intensity as dB re: 1 μPa. 

There are insufficient peer reviewed reliable data available for the onset of behavior disturbance 

in fish; however, as a conservative measure, NMFS generally uses 150 dB re: 1 μPa as the 

threshold for behavior effects to fish species of particular concern, citing that noise levels in 

excess of 150 dB re: 1 μPa can cause temporary behavior changes (startle and stress) that could 

decrease a fish’s ability to avoid predators. The current interim thresholds protective of injury to 

fish are 206 dB re: 1 μPa (peak) and 187 dB re: 1 μPa (cumulative) sound exposure levels 

(SELs) for fish 2 grams or greater, and 183 dB re: 1 μPa (cumulative) SEL for fish of less than 2 

grams (ICF 2009).

Construction noise levels underwater would be greatest during dredging activities which 

are estimated to be between 172 and 185 underwater dB re: 1 μPa at 1 meter and would attenuate 

rapidly with distance (Central Dredging Association [CEDA] 2011). Although noise levels 

would be above the threshold for changes in fish behavior, these levels would not exceed the 

threshold for injury or mortality on species. Additionally, installing the pilings on land would 

reduce noise impacts because the ground would dissipate the sound generated from the hammer 

to noise levels well below 150 dB re: 1 μPa. Based on Cameron LNG’s proposed construction 

methods, aquatic species behavior may be impacted, but these species would likely move out of 

the area temporarily during dredging and return once construction activities have ceased. 

Therefore, we believe that impacts on aquatic species from noise would be temporary, localized, 

and not significant.

During construction of the work dock, additional lighting and noise would be present at 

the construction site. However, aquatic species in the area are likely acclimated to the current 

ambient noise and light, due to the industrial nature of the Calcasieu Ship Channel. Therefore, 

impacts on aquatic species due to nighttime lighting and industrial noise during construction and 

operation would be negligible when taking into account the proximity of the existing LNG 

terminal to the work dock and the existing environment of the area. Furthermore, Cameron LNG 

would direct any nighttime lighting on the activity being conducted to ensure the safety of 

workers and minimize impacts on aquatic species.

Cameron LNG proposes to use a hydraulic suction dredge during construction of the

work dock facilities. The construction activities related to these facilities could result in siltation 

at the water’s edge and temporarily increase turbidity and suspension of solids within the water 

column. Increases in turbidity can affect fish physiology and behavior. Potential physiological 

effects include mechanical abrasion of surface membranes, delayed larval and embryonic 

development, reduced bivalve pumping rates, and interference with respiratory functions. 

Possible behavioral effects from increased turbidity include interference with feeding for sightforaging fish and area avoidance. Alternately, the reduced visibility of predatory fish could 

lower vulnerability to predation for prey species. Turbidity also interferes with light penetration 

and thus reduces photosynthetic activity by phytoplankton. Such reductions in primary 

production would be localized around the immediate area of the work dock and would be limited 

to the duration of the sedimentation plume at the dock. Because the Calcasieu Ship Channel has 

a naturally high suspended sediment load, we believe the increase in suspended sediments 

typically created by a hydraulic suction dredge would not be significant. Because Cameron LNG 

would be using a type of suction dredge, the amount of suspended sediment would be less than 
Wildlife And Aquatic Resources 4-52

that resulting from use of a traditional clam shell dredge. Therefore, the potential effects of 

increased suspended sediments to aquatic species would be minor due to the condition of the 

existing environment and the methods used for dredging. Further, construction of the work dock 

would require only 4 weeks of active dredging. Therefore, we conclude that the impacts on 

aquatic species would be temporary, and species could return to the area following construction.

Excessive nutrient loading from sediment resuspension could have an adverse impact on 

the Calcasieu Ship Channel because it could cause dramatic increases in the productivity of 

planktonic algal populations. The particles that would resuspend as a result of dredging are fine 

silt and clay. Cameron LNG would comply with all requirements of its joint CWA 404 permit 

and CUP to minimize the suspension of sediments. In addition, Cameron LNG proposes to 

implement the BMPs in its Environmental Plan to mitigate increases in turbidity, such as using 

containment and diversion dikes and turbidity curtains. Cameron LNG would also conduct water 

sampling before and throughout dredging operations to ensure that standards specified in the

previous COE permit would not be exceeded for total suspended solids or dissolved oxygen. In 

general, the impacts of dredging on turbidity are expected to be localized, temporary, and minor. 

Furthermore, impacts would be similar to those that result from the current maintenance 

dredging conducted by the COE in the Calcasieu Ship Channel. Based on previous dredging 

activities conducted during the construction of the berthing slip for the existing LNG terminal, 

the temporary increase in turbidity and total suspended solids would have limited adverse 

impacts on aquatic species near the work dock construction area.

Dredging activities would affect the shallow estuarine bottom, in addition to the water 

column. Benthic organisms, such as mollusks and crustaceans, may experience direct mortality 

during these activities, while other more mobile species, such as blue crab, may experience 

temporary displacement. While the construction-related impacts would be greatest on the 

benthic community within the dredging area, impacts on saltwater fish species, such as red drum 

and spotted seatrout, would also occur, but would be localized and temporary. Due to the 

relatively small area of direct impact (9.4 acres) and the short duration of dredging, these species 

and other similar species would be temporarily displaced and could return upon completion of 

construction of the work dock. Although the benthic community would be directly affected, 

these communities generally re-populate within 1 year (Minerals Management Service [MMS] 

2004); therefore, the impacts from dredging for construction of the work dock on the benthic 

community would be short-term and minor.

The Sierra Club comment letter expressed concern about the proposed change in water 

depth at the work dock berthing area (comment IP2-57). Specifically, the letter stated “the 

Project plans to increase the water depth from about 3.5 feet to about 15 feet below. Yet, the 

draft EIS does not address how this alteration will affect indigenous fish and wildlife. For 

example, FERC does not discuss how the depth change will disrupt habitat formation and 

migration patterns of fish and wildlife.” The following text addresses that concern.

Baseline habitat conditions in the proposed dredge area consist of fine-grained softbottom sub-tidal open water ranging from -3.5 to -15 feet below MSL. The Project proposes to 

deepen this area to a consistent -15 feet below MSL. COE core sampling in the adjacent channel 

found 37 percent silt, 53 percent clay, and 10 percent sand, and noted that their lab studies 

showed that “amphipods that rely on burrowing into the sediment had a low level of survival in 

the cohesive DMMU [dredged material management units] 5 sediments ... the amphipods fail to 
4-53 Wildlife And Aquatic Resources

burrow because they are unable to penetrate the sediment due to its cohesive nature and not 

because of a classic sediment avoidance response to contamination.” In contrast, the same study 

found that “polychaete worm, which is tolerant of cohesive sediments, had a high level of 

survival in DMMU 5 sediment” (COE 2010a). This indicates that current bottom habitat grain 

sizes may limit the diversity of the benthic community that supports local fish and wildlife. 

These sediment core results were consistent with other studies of Calcasieu channel sediments 

from Mile 11 to Mile 20.5 (Applied Coastal Research And Engineering, Inc. 2007).

The proposed change in local open water depths is not expected to affect juvenile brown 

or white shrimp, which prefer vegetated shallows, but the deepening of the band between -3.5 

feet and -4.3 feet below MSL would reduce the amount of area that falls within the preferred 

depth range of juvenile red drum (less than 4.3 feet; Matlock 1987). However, the low 

abundance of amphipods may indicate that these areas do not offer prime nursery areas for 

juvenile fishes that prey on benthic invertebrates (COE 2010a). After dredging, the newly 

exposed bottom surface is expected to be similar in composition to the present bottom, and is 

expected to be covered in new deposits from upstream sediment transport. Post-dredging habitat 

conditions, although deeper in some areas, would therefore resemble baseline conditions, albeit 

with a different disturbance regime due to regular maintenance dredging. 

The Project is not expected to significantly alter major habitat-forming processes, 

specifically discharge, tides, wind, flooding, nutrient inputs, or sediment deposition/scour in the 

vicinity of the proposed Terminal Expansion site. However, expected regular (2-year interval) 

maintenance dredging of subtidal estuarine bottom habitats would be an alteration of local 

disturbance regimes from current conditions, which are artificially stabilized due to navigation 

improvements dating back to 1874. Similar maintenance dredging occurs within the channel and 

at the berthing area and turning basin of the existing Cameron LNG Terminal. Historically, delta 

channel changes would have been determined by recurrence intervals of natural events such as 

floods, hurricanes, bar formation, and channel migration. Modern baseline conditions are far 

more stabilized in order to maintain energy and transportation infrastructure and operations. 

Benthic invertebrate communities in estuarine mud substrates, such as those in and near the 

Terminal Expansion site, are thought to recolonize and recruit faster than sand- and graveldominated habitats, typically recovering to pre-dredging abundance and diversity in less than 1 

year. However, dominant species and their relative abundance may differ from pre-dredging 

conditions (Newell and Seiderer 2003 in U.S. Department of the Interior, Minerals Management 

Service 2004). Therefore, although changes in disturbance regime may alter invertebrate 

community structure, species presence and overall biomass are expected to be similar, and 

habitat type and availability would not significantly change as a result of the Project. Because the 

Project would not block passage or substantially alter water discharge or velocity patterns, 

migration patterns of local fauna are unlikely to be significantly affected.

Potential impacts from introduction of invasive species due to barges and support vessels 

using the work dock could affect aquatic species in the area. However, vessels calling on the 

work dock during construction and operation would be barges and tugs that would not discharge 

ballast water. In addition, mostly local vessels would be used during construction of the 

Terminal Expansion and the potential for invasive species introduction via hull attachment on 

these vessels would be negligible. Therefore, we do not anticipate impacts associated with the 

introduction of invasive species during construction of the Terminal Expansion. During 
Wildlife And Aquatic Resources 4-54

operation, barges would only deliver supplies when necessary or to facilitate maintenance 

dredging in the berthing and work dock areas and perform maintenance activities associated with 

the expanded terminal. 

Barge movements and the movements of support vessels and other supply vessels during 

construction and operation of the Terminal Expansion are not expected to substantially increase 

shoreline erosion, benthic sediment disturbance, or prop scouring in the immediate area. These 

occurrences are not expected primarily because the vessels are slow moving and do not create 

substantial wakes. Some benthic sediment disturbance could occur when the barges are 

offloading at the work dock; however, the major increase in barge traffic would be short-term, 

lasting for about the first 14 months of construction. In addition, vessel groundings are not likely 

due to the slow movement of the barges. We conclude that impacts associated with increased 

barge traffic on aquatic species would not be significant.

Operational impacts would occur during maintenance dredging of the work dock. These 

impacts would be similar to those discussed for construction dredging of the work dock, such as 

increased turbidity and decreased water quality during dredging. Cameron LNG would comply 

with all state and federal requirements to minimize the suspension of sediments according to its

CUP. In addition, Cameron LNG would perform maintenance dredging at the same time the 

COE performs maintenance dredging in the Calcasieu Ship Channel. This would reduce the 

number of times that aquatic species would be affected by increased suspended sediment loads. 

Because turbidity that would occur during maintenance dredging for the work dock would be 

localized and temporary, we believe impacts on fisheries in or near the work dock area would not 

be significant.

Freshwater Pond Fill

Construction of the Terminal Expansion facilities would involve draining and filling of 

one of the freshwater pond basins and use of the second pond as a stormwater retention basin 

that may be filled in the future. The impacts associated with filling these ponds during 

construction or operation of the proposed Terminal Expansion would be permanent. The 

freshwater ponds are man-made and were stocked with warmwater fish species for recreational 

purposes by the former landowner. Fish within these ponds would suffer mortality. However, 

because these freshwater ponds are not naturally occurring and the fish present are not endemic 

to the basins, we do not believe these impacts would be significant. 

Hydrostatic Testing

Cameron LNG would hydrostatically test the facility piping and the new LNG storage 

tank, which would require water from an on-site well and discharge into the Calcasieu Ship 

Channel upon completion. Hydrostatic testing is discussed in more detail in section 4.3.2.3. The 

discharge of hydrostatic test water could cause localized turbidity at the end of the discharge 

hose or pipe. However, to minimize the potential impacts related to this activity, Cameron LNG 

would sample, test, and discharge all hydrostatic test water in accordance with its discharge 

permit and the Cameron LNG Environmental Procedures. In addition, Cameron LNG would not 

add chemicals to the water, and energy dissipation devices would be used. We conclude that

impacts on aquatic resources from hydrostatic testing would be temporary and negligible with 

the use of these preventative measures. 
4-55 Wildlife And Aquatic Resources

Inadvertent Spills

To minimize the potential for petroleum or hazardous materials spills from land

equipment or vessels berthed at the work dock during construction and operation, Cameron LNG 

would implement its spill procedures, which include spill prevention and response guidelines, in 

accordance with its Environmental Plan. Cameron LNG would revise its existing Terminal 

SPPC plan to include the expanded terminal facilities and would implement the procedures in the 

revised plan during operation. Both the Environmental Plan and the Terminal SPCC plans 

include guidelines to reduce response time in the event of a release and expedite an efficient 

cleanup. Based on the implementation of these procedures by Cameron LNG, we believe 

impacts on aquatic species due to inadvertent releases would be minimized.

LDWF Permitting

LDWF stated in its comment letter on the draft EIS regarding the Terminal Expansion 

(comment letter SG2 in Appendix L, dated February 24, 2014) that it has assisted Cameron LNG

in past years to create marsh from spoil material resulting from the dredge activities of the LNG 

berthing slip. LDWF also stated that the spoil disposal areas have resulted in appropriate marsh 

elevations and successful revegetation and therefore, the agency continues to support such 

efforts. 

LDWF requested that Cameron LNG develop a mitigation plan designed to off-set 

impacts on fish and wildlife resources and that the mitigation plan be approved by the resource 

and regulatory agencies. The approved mitigation plan is part of the conditions of the LDWF

permit. Cameron LNG filed a letter dated March 12, 2014, with the FERC31 stating that it would 

comply with the mitigation plan approved in the CUP and the COE Section 404 and Section 10 

permits. Additionally, Cameron LNG would use its Environmental Plan and the FERC’s Plans 

and Procedures during construction to further mitigate any potential impacts on fish and wildlife 

resources.

In its comment letter, LDWF also noted concerns with invasive species. The LDWF 

stated that construction equipment and water extracted from water bodies should be inspected for 

the presence of invasive aquatic weeds, including but not limited to giant salvinia (Salvinia 

molesta), water hyacinth (Eichhornia spp), and Esthwaite Waterweed (Hydrilla verticallata), or 

aquatic animals, such as apple snails (Family Ampulariidae), before being brought to the site and 

before being moved from the site to prevent the transport and spread of such species. 

In its March 12, 2014 response to the LDWF comment letter, Cameron LNG stated that it 

had revised its Environmental Plan to include the information requested. We note that the 

version currently filed with the FERC does not address this issue and that LDWF made the same 

comments pertaining to the Pipeline Expansion. Therefore, we are recommending that:

• Prior to construction, Cameron should file revised Environmental Plans with 

the Secretary for review and written approval by the Director of the OEP 

that include measures to prevent the transport and spread of invasive 

 31 Available on the FERC docket at http://ferc.gov/docs-filing/elibrary.asp, Docket No. CP13-25, Accession No. 

20140312-5275.
Wildlife And Aquatic Resources 4-56

aquatic weeds and animals. Cameron should then submit the FERC 

approved plan to LDFW.

4.6.2.2 Pipeline Expansion 

Existing Aquatic Resources 

The Pipeline Expansion would cross 27 waterbodies (with one waterbody crossed twice) 

and one pond, for a total of 29 waterbody crossings. Appendix F provides a list of the 

waterbodies crossed, the proposed crossing method, and the fishery classification for each. All 

the waterbodies crossed by the proposed route may support warm, freshwater fisheries. The 

representative fish species present in the waterbodies that would be crossed by the pipeline route 

are presented in table 4.6.3-1. 

No known commercial fisheries occur within the vicinity of the pipeline route. The 

majority of recreational fishing along the proposed route occurs in the Houston and Little Rivers, 

Beckwith Creek, and Hickory Branch. The smaller intermittent and ephemeral streams along the 

pipeline route do not support warmwater fisheries. Some of the larger intermittent waterbodies

could support fish during the periodic inundation that occurs seasonally or after large 

precipitation events. However, due to the sporadic periods of inundation, the intermittent and 

ephemeral waterbodies crossed by the proposed pipeline are unlikely to sustain fishery resources. 

No sensitive fish species, fisheries of concern, or EFH have been identified within the 

waterbodies crossed by the route. 

Impacts and Mitigation

Waterbody Crossings

Impacts on fisheries resulting from pipeline construction activities at waterbody crossings 

could include sedimentation and turbidity, alteration or removal of instream and stream bank 

cover, introduction of water pollutants, or entrainment of small organisms during withdrawal of 

hydrostatic test water. Studies generally indicate that pipeline construction through waterbodies 

results in temporary impacts on streams and rivers, and that there are no long-term effects on 

water temperature, pH, dissolved oxygen, benthic invertebrate populations, or fish populations 

(Vinkour and Shubert 1987; Blais and Simpson 1997).

Cameron Interstate proposes to cross 14 waterbodies using the open-cut method, five

using the dry-ditch method (dam-and-pump or flume crossing), one by a conventional bore in

conjunction with a road crossing, and nine waterbodies using the HDD method (see section 2.6.3

and Appendix F). Cameron Interstate proposes to cross all perennial waterbodies by the HDD 

method, thereby minimizing construction impacts on fisheries. Using the HDD method would 

minimize vegetation clearing adjacent to the waterbody, as well as eliminate trenching directly in 

the stream or river bed. The use of the HDD method would avoid impacts on fisheries during 

construction unless an instream inadvertent return occurred. An instream inadvertent return

would impact water quality and could impede fish movement due to the release of drilling fluid

into the waterbody, potentially increasing the rates of stress, injury, and/or direct mortality 

experienced by fish. If an inadvertent return occurs, Cameron Interstate would implement the 

cleanup and mitigation measures outlined in its HDD Contingency Plan (Appendix C), such as 

the use of hay bales, silt fencing, and other containment materials to prevent the fluid from 
4-57 Wildlife And Aquatic Resources

reaching a waterbody, and the construction of pits and berms around the borehole entry to 

contain any inadvertent releases. 

An open-cut crossing would result in short-term increases in turbidity and siltation 

downstream of the pipeline crossing sites. The concentration of suspended solids would 

decrease rapidly after the completion of instream work, but the increased siltation may cause 

degradation of benthic and spawning habitat and decreased flow of oxygenated water to benthic 

organisms and fish eggs. Direct loss of spawning habitat, benthic invertebrates, and protective 

cover may occur at the pipeline crossing location due to trenching and backfilling within the 

stream or river bed. However, any sedimentation and turbidity resulting from construction 

would be temporary. Where feasible, waterbody crossings would occur during periods of low or 

no flow. Cameron Interstate would construct all waterbody crossings in accordance with the 

construction and mitigation measures in its Procedures, which requires completion of most 

instream work within 24 hours for waterbodies 10 feet wide or less, and within 48 hours for 

streams between 10 and 100 feet in width (Appendix C).

Cameron Interstate’s open-cut construction would require clearing of streamside 

vegetation, which may result in reduced shading and possible increased water temperatures in 

localized areas of the stream. However, stream bank clearing would be adjacent to existing 

rights-of-way, which would minimize changes in water temperature because much of the 

vegetation adjacent to the waterbodies is already being maintained in a low-growing, herbaceous 

state and is not providing shade over the waterbodies. Cameron Interstate would adhere to its 

Plan and Procedures to restore vegetation post-construction to minimize potential stream bank 

erosion and siltation of the waterbody. To provide greater protection for warmwater fisheries, 

the Cameron Interstate Procedures also require that construction activities within waterbodies 

take place between June 1 and November 30 unless expressly permitted by the appropriate state 

agencies in writing on a site-specific basis. 

Using the dry-ditch method (either flume or dam-and-pump) rather than an open-cut 

crossing reduces turbidity and downstream sedimentation during construction; however, minor 

aquatic habitat alteration could occur. Temporary impediments to flow, such as the dam 

structures or flume pipes, as well as loss of habitat, water temperature increases from removal of 

riparian vegetation, and/or the alteration of water quality could increase the rates of stress, injury, 

and/or mortality experienced by fish. 

Use of the Cameron Interstate Procedures would reduce impacts on fisheries from 

construction-related sedimentation and turbidity (Appendix C). For all crossing methods, 

excavated material would be stored within the right-of-way on or above the stream banks at least 

10 feet from the water’s edge. Cameron Interstate would install temporary erosion control 

devices around piles of excavated material to minimize the potential for sediment-laden water to 

enter the stream. Additionally, all staging and temporary workspace areas would be at least 50 

feet from the water’s edge where topographic conditions permit (unless otherwise permitted), 

thus minimizing the potential for erosion and sedimentation along the stream banks. Impacts on 

water quality from open-cut and dry-ditch crossings would be temporary and suspended 

sediment concentrations would return to pre-construction levels soon after crossings are 

completed. With implementation of the Cameron Interstate Procedures, we believe these 

temporary and localized impacts on fish and other freshwater aquatic organisms would be 

minimal.
Wildlife And Aquatic Resources 4-58

Hydrostatic Testing 

Hydrostatic testing of the pipeline would be conducted to ensure the integrity of the 

installed pipe. All hydrostatic test water for the pipeline would be withdrawn from the Houston 

River. The water withdrawal process could entrain fish eggs and juvenile fish. To minimize the 

potential for this impact, Cameron Interstate would cover the intake hose with an adequatelysized mesh screen. During withdrawal, Cameron Interstate would maintain flow rates in the 

river that are adequate to protect aquatic life, provide for all waterbody uses, and provide for 

downstream withdrawals of water by existing users. Cameron Interstate would also sample, test, 

and discharge all hydrostatic test water in accordance with its state discharge permit and its

Procedures. Therefore, impacts on fish species due to hydrostatic testing would be temporary 

and negligible. Hydrostatic testing is discussed in further detail in section 4.3.2.3.

Inadvertent Spills 

Water quality could be adversely affected by an accidental spill of hazardous material 

into or near a waterbody. Adherence to the spill prevention measures in the Cameron Interstate 

Environmental Plan, such as prohibiting refueling or storage of hazardous materials within 100 

feet of waterbodies, would minimize the potential for releases to occur. Should a spill occur, 

implementation of the response measures in the Cameron Interstate Environmental Plan would 

reduce response time and ensure appropriate cleanup, therefore minimizing impacts on aquatic 

species.

LDWF Permitting 

In its comment letter on the draft EIS regarding the Pipeline Expansion (comment letter 

SG1 in Appendix L, dated February 24, 2014), LDWF provided comments that were similar to 

those provided in the LDWF comment letter regarding the Terminal Expansion. Those 

comments are addressed above under LDWF permitting for the Terminal Expansion.

4.6.3 Essential Fish Habitat 

The MSFCMA, as amended in 1996, was established, along with other goals, to promote 

the protection of EFH in the review of projects conducted under federal permits, licenses, or 

other authorities that affect or have the potential to affect such habitat. EFH is defined in the 

MSFCMA as those waters and substrate necessary to fish for spawning, breeding, feeding, or 

growth to maturity. All estuaries and estuarine habitats in the northern Gulf of Mexico are 

considered EFH (Gulf of Mexico Fisheries Management Council [GMFMC] 1998).

Federal agencies that authorize, fund, or undertake activities that may adversely impact 

EFH must consult with NMFS. Although absolute criteria have not been established for 

conducting EFH consultations, NMFS recommends consolidated EFH consultations with

interagency coordination procedures required by other statutes, such as NEPA and the ESA, to 

reduce duplication and improve efficiency. Generally, the EFH consultation process includes the 

following steps:

• Notification – The action agency should clearly state the process being used for 

EFH consultations (e.g., incorporating EFH consultation into the EIS).
4-59 Wildlife And Aquatic Resources

• EFH Assessment – The action agency should prepare an EFH Assessment that 

includes both identification of affected EFH and an assessment of impacts. 

Specifically, the EFH should include: a description of the proposed action; an 

analysis of the effects (including cumulative effects) of the proposed action on 

EFH, the managed fish species, and major prey species; the Federal agency’s 

views regarding the effects of the action on EFH; and proposed mitigation, if 

applicable.

• EFH Conservation Recommendations – After reviewing the EFH Assessment, 

NMFS would provide recommendations to the action agency regarding measures 

that can be taken by that agency to conserve EFH.

• Agency Response – The action agency must respond to NMFS within 30 days of 

receiving recommendations from NMFS. The response must include a 

description of measures proposed by the agency for avoiding, mitigating, or 

offsetting the impact of the activity on EFH.

The FERC proposes to incorporate EFH consultations for the Terminal Expansion 

facilities with the interagency coordination procedures required under NEPA. As such, we are

requesting that NMFS consider the EIS as initiation of EFH consultation.

Only impacts associated with the proposed construction and operation of the Terminal 

Expansion are discussed in this section. The FERC previously prepared an EIS and two EAs to 

assess construct and operation impacts from the existing Cameron LNG Terminal on EFH and 

EFH species (see section 2.1.1). As a part of those environmental assessments, in 2003 the 

FERC consulted with NMFS regarding EFH for construction of the original LNG Terminal on 

dredging the berthing area, loss of estuarine emergent wetlands within the terminal footprint, 

filling of tidal creeks and marsh ponds, accidental releases of LNG, and the number of LNG 

carriers and transit routes. We determined and NMFS agreed that based on the implementation 

of conservation measures and the compensatory mitigation plan developed by Cameron LNG, no 

substantial adverse impacts on EFH or EFH species would occur due to the construction and 

operation of the Cameron LNG Terminal. The FERC then consulted with NMFS on the 2006 

expansion of the existing terminal which included additional dredging, additional LNG carrier 

traffic, loss of estuarine emergent wetland, and accidental releases of LNG. We determined and 

NMFS agreed that based on the compensatory mitigation proposed by Cameron LNG, no net 

uncompensated impacts would occur on EFH and, therefore, no significant long-term impacts 

would occur. In 2010, the FERC consulted with NMFS regarding EFH for approval to export 

LNG from the existing terminal, which included ballast water discharges from LNG carriers 

while loading. We determined and NMFS agreed that no impacts on EFH would occur due to 

ballast water discharge, as all LNG carriers would adhere to Coast Guard regulations requiring 

an open ocean ballast water exchange. The impacts of LNG spills are not addressed in this EIS 

for the following reasons: (1) LNG spills were fully assessed in our previous consultations, 

assessments, authorizations for export of LNG, and (2) Cameron LNG is not requesting to 

increase its authorized number or size of LNG carriers (including traffic, transit, and ballast 

water discharges).
Wildlife And Aquatic Resources 4-60

4.6.3.1 EFH Characterization

NMFS and the GMFMC have identified the Calcasieu Ship Channel and adjacent coastal 

marsh as EFH for multiple recreational and commercial marine species. The EFH that may be 

affected by the proposed Terminal Expansion includes estuarine water bottoms (soft bottom 

sediment) and estuarine water column. The estuarine water bottom habitat in and near the work 

dock area is comprised of sub-tidal unconsolidated sediments. This EFH type serves as 

important nursery and feeding areas for many fish and invertebrates, including demersal fish that 

eat worms and mollusks living on and in the sediments. The community composition of the 

estuarine water bottom and column habitat within the Calcasieu Ship Channel remains in an 

early successional stage due to regular disturbance from the COE’s 2-year maintenance dredging 

program, Cameron LNG’s maintenance dredging at the berthing facilities of its existing terminal, 

propeller wash from passing vessels, and natural sedimentation. Estuarine water column habitat 

serves as EFH for several species and their prey at various life stages by providing habitat for 

spawning, breeding, and foraging. Fish communities within the water column are determined by 

factors such as salinity, temperature, dissolved oxygen, and are acclimated to the level of 

disturbance activity within the Calcasieu Ship Channel.

EFH species listed for the Project area include brown shrimp, white shrimp, red drum, the 

snapper/grouper complex, coastal migratory species, and highly migratory species. Although 

certain life stages for each of these species inhabit estuaries and some of the prey species are 

estuarine dependent, there are many other estuaries in the area to provide alternative habitat that 

contain appropriate prey species. In addition, the species are all mobile and could avoid most 

direct impacts during construction and operation and use other habitat nearby. Based on review 

of available literature and previous and on-going projects conducted in and near the Terminal 

Expansion area, we believe the proposed Terminal Expansion would have no adverse impacts on 

species within the snapper/grouper species complex, the coastal migratory species in the area, 

such as cobia and mackerel, or the highly migratory species in the area. All highly migratory 

species (which include 5 species of tuna, 5 species of billfish, and 25 species of shark) are 

considered pelagic and would not be present within or near the project area with the exception of 

the bull shark. Although the bull shark could be present in the area because the species uses 

estuarine habitat as a nursery for juveniles, bull sharks are very mobile and would likely avoid 

the area during construction. Therefore, their presence in the vicinity of the Project during 

construction is not likely, and we believe there would be no adverse effects to these species. 

These species/complexes are not addressed further in this EIS. 

Species and life-stages which may be present within the Terminal Expansion area during 

construction and/or operation due to their use of EFH in the area are listed in table 4.6.4-1.
4-61 Wildlife And Aquatic Resources

TABLE 4.6.4-1

EFH Species In Waterbodies Affected by the Terminal Expansion

Common Name Scientific Name Life Stages in Estuarine Habitat Comment

Brown shrimp Penaeus aztecus Post-larval, juvenile EFH present within project vicinity

White shrimp Penaeus setiferus Post-larval, juvenile EFH present within project vicinity

Red drum Sciaenops ocellatus Larval, juvenile, sub-adult EFH present within project vicinity

4.6.3.2 EFH Species Descriptions

Brown Shrimp

Brown shrimp eggs and larvae inhabit offshore marine environments where spawning 

takes place. The eggs are demersal and the larvae are planktonic. Brown shrimp begin to 

migrate to estuarine habitats as post-larvae, migrating on flood tides at night from February 

through April. The juvenile stage occurs within estuarine habitats and post-larval and juvenile 

brown shrimp are common to highly abundant in all Gulf of Mexico estuaries from Apalachicola 

Bay in Florida to the Mexican border, although they are generally not present between December 

and February. They are typically associated with shallow vegetated habitats, silty sand, and nonvegetated mud bottom where salinities range from 0 to 70 parts per thousand. The densities of 

post-larval and juvenile brown shrimp are highest in marsh edge habitat and submerged 

vegetation. At maturity, the juveniles migrate back to ocean waters. Larval brown shrimp feed 

on phytoplankton and zooplankton; post-larvae feed on epiphytes, phytoplankton, and detritus; 

and juveniles and adults prey on polychaetes, amphipods, chironomid larvae, algae, and detritus 

(GMFMC 1998).

White Shrimp 

White shrimp eggs and larvae inhabit nearshore marine waters. The eggs are demersal 

and the larvae are planktonic. Post-larvae migrate into estuarine habitats from May through 

November, with peaks occurring June through September. After entering the estuaries, postlarval white shrimp become benthic and typically inhabit shallow water estuarine habitats on 

muddy-sandy substrates with high organic detritus content or estuarine marsh habitats and they 

are generally present year-round. Densities of post-larval and juvenile white shrimp are usually 

highest in marsh edge and submerged aquatic vegetation habitats. Juveniles are common to 

highly abundant in all Gulf of Mexico estuaries from Texas to the Suwannee River in Florida. 

When they reach maturity, they migrate from estuarine habitats back to marine habitats in late 

August and September. Larval white shrimp feed on phytoplankton and zooplankton; postlarvae feed on epiphytes, phytoplankton, and detritus; and juveniles and adults prey on 

polychaetes, amphipods, chironomid larvae, algae, and detritus (GMFMC 1998).

Red Drum

In the Gulf of Mexico, red drum occur in a variety of habitats, ranging from water depths 

of about 130 feet (40 meters) offshore to very shallow estuarine waters. Red drum can tolerate 

salinities ranging from freshwater to highly saline. They commonly occur in nearly all estuaries 

of the Gulf of Mexico year-round where they are present over a variety of substrates, including 
Wildlife And Aquatic Resources 4-62

sand, mud, and oyster reefs. Estuarine wetlands are especially important as nursery habitat for

larval, juvenile, and sub-adult red drum, and are also important habitat for the prey species of all 

life stages. Larval red drum prey on mysids, amphipods, and shrimp, whereas larger juveniles 

feed on crabs and fish. Crustaceans, including shrimp and crabs, and fish are the most important 

prey items in the adult red drum diet (GMFMC 1998).

4.6.3.3 Project Activities Potentially Affecting EFH 

The Pipeline Expansion would not impact EFH. Cameron LNG would conduct the 

majority of the construction activities for the Terminal Expansion on land as discussed in section 

2.3. With implementation of Cameron LNG’s Plan and revised SPCC Plan, we believe the 

potential for land-based activities to affect EFH or EFH species would be negligible; therefore, 

this EFH assessment focuses on activities associated with the work dock and vessels calling on 

the dock. 

During construction of the work dock, Cameron LNG would drive sheet piling and dock 

piles on land prior to dredging the work dock area up to the location of the sheet pilings. No 

sheet pilings or dock piles would be driven directly into the water. After installation of the piles, 

Cameron LNG would dredge and maintain the area underneath and around the work dock to a 

depth of 15 to 16 feet below MSL. Approximately 205,000 yd3 of sediment would be removed 

from a 9.4-acre area during construction (figure 2.2-1). Up to about 275 barges per month (about 

9 or 10 per day) would use the work dock during the first 7 months of construction of the 

Terminal Expansion, decreasing to about 125 per month (about 4 per day) in months 10 through 

14 of construction, and further decreasing after that to about 1 barge every 3 days through the 

end of construction of the Terminal Expansion in 2018. During operation of the expanded 

terminal, barge deliveries would be made at the work dock for various maintenance activities. 

Other Project-related activities with the potential to affect EFH include: runoff from the 

expanded terminal (see section 4.3.2.2); discharge of hydrostatic test water into the channel (see 

sections 4.3.2.2 and 4.6.3); an accidental release of petroleum products during construction (see 

sections 4.3.2.2 and 4.6.3); exacerbation of shoreline erosion due to vessel wakes (see section 

4.1.3.6); and increased sound levels and lighting at the work dock area (addressed below). The 

potential effects of these activities on EFH or EFH species are discussed below. 

4.6.3.4 Impact and Mitigation

As shown in table 4.6.4-1, life stages were identified for the three EFH species that could 

potentially be affected by aspects of construction and operation of the proposed Terminal 

Expansion. No spawning occurrences or habitat, egg stage, or habitat for adults for any of the 

three species would be affected by the Terminal Expansion, as those life stages take place farther 

offshore than the construction or operation area.

All phases of construction and operation of the work dock could affect EFH or EFH 

species, but dredging would present the greatest potential impact. Dredging would cause 

sediment suspension and turbidity temporarily, lowering the water quality within a localized area 

surrounding dredging activities. As discussed in section 4.6.3, increases in turbidity can 

adversely affect fish physiology and behavior, resulting in less healthy individuals, reductions in 

fecundity, and reduced foraging. However, Cameron LNG would minimize sedimentation 
4-63 Wildlife And Aquatic Resources

through the use of a cutterhead dredge, as discussed in section 4.6.2. Furthermore, the Calcasieu 

Ship Channel has naturally high suspended sediment loads and active dredging at the work dock 

would take approximately 4 weeks. Therefore, the increase in turbidity due to dredging of the 

work dock area would be minor compared to the existing environment. Increased turbidity 

would also be temporary during active dredging and localized to the immediate area surrounding 

the work dock. Habitat would revert back to normal conditions after construction. All three 

managed EFH species could be present during the 4 weeks of active dredging; however, based 

on the mitigation measures proposed (i.e., use of a cutterhead dredge and limited duration of 

dredging), the existing environment, and the timing of construction of the work dock, the 

impacts of dredging on EFH or EFH species in the water column would be temporary and minor. 

In addition, Cameron LNG would place dredge material in its mitigation site at an elevation 

sufficient to create tidal freshwater/intermediate marsh, providing additional habitat for EFH 

species. 

Another aspect of dredging activities that could affect EFH or EFH species is disturbance 

of the estuarine water bottom habitat within the proposed work dock area. Within the first few 

days after completion of dredging operations, the benthic community would be reduced in 

species richness, species abundance, and biomass through direct mortality. This would reduce 

the amount of prey available for all three EFH species within the proposed work dock area; 

however, polychaetes, oligochaetes, and other similar species would quickly re-colonize 

disturbed areas following dredging. Through natural processes and rapid population growth, 

these species take advantage of unoccupied space in newly exposed sediments (MMS 2004). We 

anticipate that, based on published data, dredging would result in a negligible temporary impact 

on the benthic community. Therefore, impacts on EFH species would also be negligible, as the 

species could forage in other nearby EFH areas and return to the work dock area after 

repopulation of the prey base.

Dredging and the installation of the pilings for the dock could cause rapid concussive 

noise underwater. Depending on the sound frequency and intensity associated with this activity, 

it could cause a change in aquatic species behavior in proximity to the work dock area or could 

cause species to avoid the area. Underwater noise levels are commonly referred to as a ratio of 

the underwater sound pressure to a common reference dB re: 1 μPa as discussed in section 4.6.3. 

Construction noise levels underwater would be greatest during dredging activities which are 

estimated to be between 172 underwater dB and 185 underwater dB re: 1 μPa at 1 meter and 

would attenuate rapidly with distance (CEDA 2011). Although noise levels would be above the 

threshold for changes in fish behavior, these levels would not exceed the threshold for injury or 

mortality on species. Additionally, installing the pilings on land would reduce noise impacts 

because the ground would dissipate the sound generated from the hammer to noise levels well 

below 150 dB re: 1 μPa. Based on Cameron LNG’s proposed construction methods, EFH 

species behavior may be impacted, but these species would likely move out of the area 

temporarily during dredging and return once construction activities have ceased. Therefore, we 

believe that impacts on EFH species from noise would be temporary, localized, and not 

significant.

During construction of the work dock, additional lighting would be installed and used at 

the construction site. However, aquatic species in the area are likely acclimated to the current 

ambient light from the existing Cameron LNG Terminal and the industrial nature of the 
Wildlife And Aquatic Resources 4-64

Calcasieu Ship Channel. Therefore, impacts on EFH species due to nighttime lighting during 

construction would be minor when taking into account the proximity of the existing LNG 

terminal to the work dock, and the existing environment. Certain EFH species may be drawn to 

light that bleeds outside the immediate construction area and may be subject to increased 

predation. However, we do not believe impacts at the population level would occur. 

Furthermore, Cameron LNG would direct any nighttime lighting on the activity being conducted 

to ensure the safety of workers and minimize impacts on FEH species. 

The increase in barge traffic at and near the work dock during construction would result 

in a short-term increase in vessel traffic and noise in the area. During operation, barges would 

only deliver supplies when necessary or to facilitate maintenance dredging in the berthing and 

work dock areas. Barge movements and the movements of support vessels and other supply 

vessels are not expected to substantially increase shoreline erosion, benthic sediment 

disturbance, or prop scarring in the immediate area, primarily because the vessels are slow 

moving and do not create substantial wakes. Some benthic sediment disturbance could occur 

when the barges are offloading at the work dock; however, the major increase in barge traffic 

would be short-term, lasting for about the first 14 months of construction. Underwater noise 

generated by large vessels calling on the work dock is estimated to be between 180 and 190 dB 

re: 1 μPa at 1 meter and would attenuate rapidly with distance (CEDA 2011). Noise would be 

greatest during vessel transport to the work dock. However, noise would attenuate at a faster rate 

during vessel movement, and species would be subjected to the noise for a short period of time 

as the vessels pass. Vessels moored at the dock would produce noise during engine start up and 

if idling. Idling noise would be lower as the propeller would not be in use. Noise levels of 

vessels calling on the work dock would be similar to the noise currently generated by vessels 

transiting the Calcasieu Ship Channel. Based on these considerations, we conclude that impacts 

associated with increased barge traffic and noise on EFH and EFH species would be consistent 

with current vessel traffic noise occurring in proximity to the Terminal Expansion and would not 

be significant.

Hydrostatic testing of the Terminal Expansion piping and the storage tank would require 

water to be withdrawn from an on-site well and not directly from the channel; therefore, no 

impacts on EFH would result from water intake for this purpose. Discharge of the freshwater 

hydrostatic test water could cause localized turbidity and minor changes of the salinity and 

temperature. Cameron LNG would not add any chemicals to the test water. Cameron LNG 

would conduct discharges in accordance with its discharge permit and the FERC Procedures 

through the use of energy dissipation devices onto land prior to entering the ship channel. Use of 

these measures would result in temporary and negligible impacts on EFH and EFH species in the 

form of minimal water and sediment disturbance during discharge, and the impact would 

dissipate shortly after completion of hydrostatic discharge activities. Section 4.3.2 provides 

additional information on hydrostatic testing for the proposed Terminal Expansion. 

During and after construction, the conversion of land to impervious surface areas at the 

Terminal Expansion site would result in an increased volume of stormwater runoff, which could 

create changes in salinity, temperature, and/or dissolved oxygen in the area surrounding 

discharges. Cameron LNG would modify the existing stormwater management system to 

accommodate runoff from the expanded terminal, and update its existing LPDES Industrial 

Discharge Permit. All stormwater leaving the expanded site would be directed to and discharged 
4-65 Wildlife And Aquatic Resources

through permitted outfalls or leave the site as sheetflow. Cameron LNG would also maintain a 

150- to 200-foot-wide vegetation buffer between the work dock and the northern boundary of the 

Terminal Expansion along the Calcasieu Ship Channel during construction and operation, which 

would dissipate and filter stormwater runoff. Impacts from increased stormwater runoff are 

expected to occur only during storm events and have a negligible impact on water quality.

To minimize the potential for petroleum product spills during construction and operation, 

Cameron LNG would implement spill prevention procedures and clean-up measures in its 

Environmental Plan, which includes spill prevention and response guidelines. The 

implementation of these procedures would minimize response time and ensure appropriate 

cleanup actions are taken in the event of a spill. Therefore, we believe impacts from a spill 

would be minimized

In its comment letter on the draft EIS, NMFS requested that information related to the 

beneficial use of the dredge material and mitigation plan be included in the EIS and that the

mitigation plan be updated to reflect the latest COE Jurisdictional Determination and

mitigation requirements. Much of the information requested was not available at the time the 

draft EIS was in production and some of it was not available until after the draft EIS was issued. 

Cameron LNG received an amended CUP and a Modified Maintenance Dredge Permit from 

LDNR which includes dredging the work dock berthing area, on January 21, 2014 and 

November 20, 2013, respectively. Cameron LNG also received a DA permit from the COE on 

February 12, 2014. Both the amended CUP and the DA permit included a compensatory 

mitigation plan designed to mitigate impacts of the proposed Terminal Expansion. The DA 

permit is provided as Appendix K of the EIS and includes information on the mitigation plan, 

which is briefly summarized below. 

The mitigation plan consists of creation of a tidal brackish marsh wetland habitat adjacent 

to the Project site (west of LA-27) at a ratio of 1.2 acres of created marsh for each acre of 

wetland impacted by the Terminal Expansion. Dredged material would be placed at an initial fill 

height such that the settled fill height would not exceed +2.0 feet NAVD88 (North American 

Vertical Datum of 1988) and would be as close to the surrounding natural marsh elevations as 

possible. Dredged material from construction of the work dock and from maintenance dredging

of the existing berthing area of the Cameron LNG Terminal would be used for creating the 

brackish marsh habitat. The marsh would vegetate naturally, and the containment dikes used for 

the dredged material disposal would be breached after compaction to allow access for fishery

resources no later than 3 years after initiation of the mitigation work. Cameron LNG would 

coordinate work on the mitigation plan with the COE and LDNR and other natural resource 

agencies as directed in the DA permit. The agencies would be notified prior to commencement 

of these activities and would have the final authority as to the breach timing and locations. 

Cameron LNG would monitor the mitigation area for quality and functionality and 

submit monitoring reports to the COE and LDNR the first, third, fifth, and tenth year after 

placement as required by the permits. Cameron LNG would also establish a 0.01-acre 

monitoring station for every 10 acres of marsh created. Monitoring surveys would be conducted 

between the months of September and October, and the monitoring reports submitted in 

December of the same year. The monitoring reports would include digital images taken from 

ground level at each monitoring station and consist of five sections as outlined in COE 

Regulatory Guidance Letter No. 08-03, dated October 10, 2008. Although an adaptive 
Wildlife And Aquatic Resources 4-66

management plan was not required by the permitting agencies, Cameron LNG agreed to work 

with the regulatory agencies to adapt the mitigation plan as needed throughout the life of the 

Project.

4.6.3.5 EFH Conclusions

Although construction of the work dock would involve permanent conversion of 

estuarine sub-tidal bottom habitat to deep water habitat and direct mortality to benthic organisms, 

the deepened area would recolonize with soft-bottom benthic organisms soon after completion of 

dredging, providing a prey base for EFH species (MMS 2004). This temporary impact would reoccur with regular maintenance dredging along with elevated turbidity events associated with 

maintenance dredging scheduled to occur every 2 years in conjunction with the COE dredging 

schedule. These events represent a minor increase in the already periodic nature of elevated 

turbidity due to ongoing maintenance dredging throughout the Calcasieu Ship Channel. The area 

temporarily affected for construction and operation of the work dock would be negligible in 

terms of the two types of EFH in the area when taking into account the amount of similar subtidal and deep water habitat available in the immediate vicinity. 

To minimize impacts from dredging on EFH and EFH species, Cameron LNG would use 

a cutterhead dredge for initial and maintenance dredging. Dredged materials would be used to 

create a tidal brackish marsh wetland area west of the Terminal Expansion site at rather than 

place it back into the estuary in the vicinity of the Terminal Expansion site. This mitigation area 

would provide additional habitat for EFH species affected by the proposed Project. Cameron 

LNG would also adhere to its Environmental Plan, which includes spill prevention and response 

procedures to reduce response and clean-up time in the event of an accidental release.

Impacts on brown shrimp and white shrimp would be limited to the post-larval and 

juvenile stages, as both stages occur in estuaries similar to the habitat present at the work dock 

site. Brown shrimp are present year-round, while white shrimp are present in the estuary 

between March and November. Direct mortality could occur during active dredging; however, 

individuals are mobile and many could avoid the construction area. After dredging, and until 

conditions are conducive for repopulation, individuals would use areas with suitable EFH. 

Impacts from each of the construction activities discussed above are expected to be temporary. 

Impacts on the prey species of white and brown shrimp and EFH would also be temporary and 

localized due to Cameron LNG’s construction methods and mitigation measures. We do not 

anticipate any substantial adverse effects on white or brown shrimp.

Red drum, at any life stage, occur year-round in estuaries associated with the Gulf of 

Mexico. Larval, juvenile, and sub-adult red drum are likely to be present in the Calcasieu Ship 

Channel throughout construction and operation of the Terminal Expansion. Direct mortality 

could occur during active dredging; although individuals would likely avoid the area during 

construction of the work dock and use other EFH areas nearby. Operation of the Terminal 

Expansion would not likely impede population growth of red drum in the area. As discussed 

above, prey species for red drum would re-colonize quickly after construction and dredging are 

completed. In addition, impacts from each of the construction activities discussed above and 

potential operational impacts are expected to be temporary. Therefore, we do not anticipate any 

substantial adverse effects to the red drum. Based on this information, we believe effects on 

EFH and EFH species in and near the construction area of the Terminal Expansion would be 
4-67 Threatened And Endangered Species

localized and temporary especially when compared to the everyday industrial use of the 

Calcasieu Ship Channel. In addition, the tidal brackish marsh created by Cameron, in 

compliance with the mitigation plan requirements of its DA permit and amended CUP, would

provide additional habitat for EFH species. Therefore, the Project would not have a substantial 

adverse impact on EFH or EFH species in the area.

4.7 THREATENED, ENDANGERED AND OTHER SPECIAL STATUS SPECIES

Special status species are those species for which state or federal agencies afford an 

additional level of protection by law, regulation, or policy. Included in this category are 

federally listed and federally proposed species that are protected under the ESA, as amended, or 

are considered as candidates for such listing by the FWS or NMFS, and those species that are 

state-listed as threatened, endangered, or other special status.

Federal agencies, in consultation with the FWS, are required by Section 7(a)(2) of the 

ESA to ensure that any action authorized, funded, or carried out by the agency would not 

jeopardize the continued existence of a federally listed threatened or endangered species or 

species proposed for listing, or result in the destruction or adverse modification of the designated 

critical habitat of a federally listed species. As the lead federal agency, the FERC is responsible 

for the Section 7 consultation process with the FWS. The lead agency is required to consult with 

the FWS and/or NMFS to determine whether any federally listed endangered or threatened 

species or any of their designated critical habitats are in the vicinity of the Project, and to 

determine the proposed action’s potential effects on those species or critical habitats.

For actions involving major construction activities with the potential to affect listed 

species or critical habitats, the federal agency must prepare a BA for those species that may be 

affected. As lead, the FERC must submit its BA to the FWS and/or NMFS and, if it is 

determined that the action may adversely affect a federally listed species, the FERC must submit 

a request for formal consultation to comply with Section 7 of the ESA. In response, the FWS 

and NMFS would issue a Biological Opinion as to whether or not the federal action would likely 

adversely affect or jeopardize the continued existence of a listed species, or result in the 

destruction or adverse modification of designated critical habitat. To comply with Section 7 of 

the ESA, we submitted our draft EIS and the various survey reports prepared by Cameron 

(submitted separately on February 15, 2014), as our BA for the proposed Project. As Cameron 

LNG does not propose to change the authorized number or size of LNG carriers, and no ballast 

water would be needed for construction barges, these items are not discussed further in this 

section of the EIS. 

To assist in compliance with Section 7 of the ESA, Cameron, acting as the FERC’s nonfederal representative, initiated informal consultation with the FWS-Louisiana Field Office and 

NMFS-Baton Rouge Field Office on September 12, 2012, regarding federally listed and other 

special status species. Cameron also consulted with the Louisiana Natural Heritage Program 

(LNHP) regarding state-listed or other special status species or habitat with the potential to be 

affected by construction and operation of the Project.

Cameron reviewed the FWS database, the LDWF Species by Parish List, and conducted 

surveys in May, June, and July 2012, and January 2013, for federal and state-listed threatened or 

endangered species and their critical habitats in the Project area. Agency consultations, together 
Threatened And Endangered Species 4-68

with previous studies and a review of updated lists of threatened and endangered species, 

initially identified 13 federally listed or candidate species that potentially occur within or near 

the proposed Project (tables 4.7-1 and 4.7-2). Cameron also requested a data review from LNHP 

within 1 mile of the proposed Project to determine the presence of state-listed threatened or 

endangered species and other special status species and habitats of special status species in the 

vicinity of the Project. Sixteen species were identified that potentially occur within or near the 

proposed Project, of which seven are also federally listed (tables 4.7-1 and 4.7-2). No federal or 

state-listed threatened, endangered, candidate, or special status species were observed during 

surveys. In addition, no known critical habitats for federally listed species or potential habitats 

for other special status species were observed. Cameron submitted the results of its field surveys 

to the FWS and NMFS.

We have reviewed the information submitted by Cameron, performed our own research, 

and consulted directly with the FWS and NMFS. Based on our review, we believe that the 

proposed Project would have no effect on seven federally listed, candidate, and state-listed 

species in Beauregard, Calcasieu, and Cameron Parishes because the Project would not be within 

the known range of the species or because the Project would not affect habitat for the species 

(table 4.7-1). Therefore, these seven species are not addressed further in this EIS, of which one 

is under the jurisdiction of NMFS, four are under the jurisdiction of the FWS, and two are under 

the jurisdiction of LDWF. The remaining 15 species are listed in table 4.7-2 and discussed in 

this section.

4.7.1 Federally Listed Threatened and Endangered Species

A total of 11 species listed as federally threatened or endangered occur in Beauregard, 

Calcasieu, and Cameron Parishes. However, only four would be within the area of the proposed 

Project. Three are under the jurisdiction of the FWS (piping plover, red-cockaded woodpecker, 

and West Indian manatee) and one is under the jurisdiction of NMFS (Kemp’s ridley sea turtle). 

These species are evaluated below. An additional four species under NMFS jurisdiction could 

be within the waterway for barge traffic (green, hawksbill, leatherback, and loggerhead sea 

turtles).
4-69 Threatened And Endangered Species

TABLE 4.7-1

Federal, Candidate, and State-Listed Species Eliminated From Further Review

Common Name Scientific Name Listing Parish Project 

Component

Federal 

Status a State 

Status a Determination and Comments

Sprague’s pipit b Anthus spragueii Cameron, 

Calcasieu

Terminal, 

Pipeline C –

Would not cause a trend toward federal 

listing. Suitable habitat is not present

within the Project area

Gulf sturgeon b Acipenser oxyrinchus 

desotoi Cameron Terminal T –

No effect. Suitable foraging habitat is 

present near the work dock site, but the 

species is not known to inhabit the area.

Louisiana black bear b, c Ursus americanus 

luteolus

Cameron, 

Calcasieu, 

Beauregard

Terminal, 

Pipeline T – No effect. Suitable habitat is not present within the Project area

Louisiana pine snake d Pituophis ruthveni Beauregard Pipeline C –

Would not cause a trend toward federal 

listing. Suitable habitat is not present 

within the Project area

American chaffseed d Schwalbea americanus Beauregard Pipeline E – No effect. Suitable habitat is not present 

within the Project area

Diamondback terrapin Malaclemys terrapin Cameron Terminal – RH No effect. Suitable habitat is not present 

within the Project area

Ornate box turtle Terrapene ornata Cameron Terminal – RH No effect. Suitable habitat is not present 

within the Project area

Species lists from FWS Species List by County and LDWF Species List by County.

a E: endangered, T: threatened, C: candidate, RH: restricted harvest

b Species listed by the FWS for Cameron Parish, but not shown by LDWF as federally listed for Cameron Parish.

c Species listed by the FWS for Beauregard and Calcasieu Parishes, but not shown by LDWF as federally listed for either Beauregard or Calcasieu Parishes.

d Species shown by LDWF as federally listed for Beauregard Parish, but not listed by the FWS in Beauregard Parish.
Threatened And Endangered Species

4-70

TABLE 4.7-2

Federal, State, and Special Status Species Potentially Occurring in the Project Area

Common Name Scientific Name Listing Parish Project 

Component

Federal 

Status a State 

Status a Determination and Comments

Piping plover Charadrius melodus Cameron Terminal T T

Not likely to adversely affect. Suitable 

habitat may be present within the Project 

area

Red-cockaded 

woodpecker b Picoides borealis Beauregard, 

Calcasieu Pipeline E E

Not likely to adversely affect. Suitable 

habitat may be present within the Project 

area

West Indian manatee Trichechus manatus Cameron Terminal E E

Not likely to adversely affect. Suitable 

foraging habitat is present near the work 

dock site and construction barge 

pathways.

Green sea turtle Chelonia mydas Cameron Terminal T T

Not likely to adversely affect. Suitable 

habitat is not present in the project area, 

but construction barge traffic could 

encounter this species.

Hawksbill sea turtle Eretmochelys imbricata Cameron Terminal E E

Not likely to adversely affect. Suitable 

habitat is not present in the project area, 

but construction barge traffic could 

encounter this species.

Kemp’s ridley sea turtle Lepidochelys kempii Cameron Terminal E E

Not likely to adversely affect. Suitable 

foraging habitat is present near the work 

dock site

Leatherback sea turtle Dermochelys coriacea Cameron Terminal E E

Not likely to adversely affect. Suitable 

habitat is not present in the project area, 

but construction barge traffic could 

encounter this species.

Loggerhead sea turtle Caretta Caretta Cameron Terminal E E

Not likely to adversely affect. Suitable 

habitat is not present in the project area, 

but construction barge traffic could 

encounter this species.

Bald eagle Haliaeetus leucocephalus

Beauregard, 

Calcasieu, 

Cameron

Terminal, 

Pipeline – E Impacts would not be significant. Suitable 

habitat is present within the Project area
4-71 Threatened And Endangered Species

TABLE 4.7-2

Federal, State, and Special Status Species Potentially Occurring in the Project Area - Continued

Common Name Scientific Name Listing Parish Project 

Component

Federal 

Status a State 

Status a Determination and Comments

Brown pelican Pelicanus occidentalis Cameron Terminal – E Impacts would not be significant. Suitable 

habitat is present within the Project area

Alligator snapping turtle Macrochelys temminckii Beauregard Pipeline – RH Impacts would not be significant. Suitable 

habitat is present within the Project area

Old prairie crawfish Fallicambarus macneesei Cameron Terminal – I Impacts would not be significant. Suitable 

habitat is present within the Project area

Dotted gay-feather Liatris punctata Beauregard, 

Calcasieu Pipeline – CI

Impacts would not be significant. Suitable 

habitat may be present within the Project 

area

Long-sepaled false 

dragon head Physostegia longisepala Cameron Terminal – I Impacts would not be significant. Suitable habitat is present within the Project area

Silveus dropseed Sporobolous silveanus Beauregard, 

Calcasieu Pipeline – I

Impacts would not be significant. Suitable 

habitat may be present within the Project 

area

a E: endangered, T: threatened, RH: restricted harvest, I: imperiled in state of Louisiana; CI: critically imperiled in state of Louisiana

b Red-cockaded woodpecker is listed by the FWS for both Beauregard and Calcasieu Parishes, but LDWF only shows this species as federally listed under Beauregard Parish.
Threatened And Endangered Species 4-72

4.7.1.1 Piping Plover

The piping plover is federally listed as threatened in the state of Louisiana, although in 

the Great Lakes region it is listed as endangered (FWS 2012b). It is a migratory species that 

winters in Atlantic and Gulf coastal regions of the United States and several Caribbean islands, 

and breeds in the northern United States and Canada (FWS 2012c). This species mainly uses 

wide, flat, open, sandy beaches to forage. Nesting territories occur on open beaches near small 

creeks or wetlands. Piping plovers eat mostly insects, spiders, and crustaceans that occur on 

open beaches or mudflats (FWS 2012c; LDWF 2012a). In Louisiana, the piping plover has been 

observed in the Calcasieu River Basin (LDWF 2012a). Threats to this species include habitat 

loss and degradation, particularly of coastal beaches, and nest disturbance and predation (FWS 

2012c).

During winter, this species could be present along the shoreline near the Terminal 

Expansion, should open mudflats or beaches exist. However, based on Cameron LNG’s survey 

information and aerial imagery interpretation, those preferred shoreline types are not currently 

present in the vicinity of the Terminal Expansion. Further, the industrialized nature near the 

Terminal Expansion would limit the likelihood that the species would use the small amount of 

existing shoreline. Piping plover could transit through the area during construction of the 

Terminal Expansion; however, it is likely they would avoid the area due to the high level of 

activity. As such, we believe the proposed Terminal Expansion is not likely to adversely affect

the piping plover.

4.7.1.2 Red-cockaded Woodpecker

The red-cockaded woodpecker is federally listed as endangered and is known to occur in 

both Beauregard and Calcasieu Parishes. It is generally a non-migratory species that inhabits 

mature pine forests. The species has been known to inhabit longleaf, loblolly, shortleaf, slash, 

and pond pine stands, but seems to prefer longleaf pine stands over other tree species. Redcockaded woodpeckers forage, nest, and roost in tree cavities and prefer mature stands between 

60 and 150 years old, depending on the species (NatureServe 2012a). They are not tolerant of 

dense understories. Red-cockaded woodpeckers eat mostly insects from tree cavities and 

beneath bark, but also eat fruit from shrubs and vines. Primary threats to this species include 

loss and fragmentation of habitat due to development, use of shorter rotations in pine plantations 

and forests, and fire suppression, which results in thicker understories (LDWF 2012b).

This species requires mature pine forests, which are not present within or around the 

Terminal Expansion site, Pipeline Expansion route, or within associated aboveground facility 

sites with the exception of a small portion of the pipeline right-of-way between MP 13.9 and MP 

14.5. The FWS identified this area as potential habitat for the red-cockaded woodpecker and 

requested Cameron Interstate perform additional surveys within a 0.5-mile radius of the potential 

habitat. Cameron Interstate, with FWS personnel, conducted an additional survey in accordance 

with the 2003 Red-cockaded Woodpecker Recovery Plan survey protocols on January 24, 2013.

No red-cockaded woodpeckers or nest clusters were identified within the proposed Pipeline 

Expansion right-of-way. Therefore, due to the small amount of available habitat and the lack of 

observations of individuals or nest cavities, we believe the proposed Pipeline Expansion is not 

likely to adversely affect the red-cockaded woodpecker. On March 11, 2013, the FWS provided 

concurrence with this determination and indicated no further consultation would be required for 
4-73 Threatened And Endangered Species

the Pipeline Expansion. However, because pipeline construction would not commence within a 

year of this survey, we are recommending that:

• Prior to construction Cameron Interstate should complete and file the results 

of an updated survey for the red-cockaded woodpecker between MP 13.9 and 

14.5 where designated habitat exists. Specifically, Cameron Interstate should 

ensure that the FERC staff receives the updated survey report for the redcockaded woodpecker completed within 1 year of the construction start date, 

as well as any comments received from the FWS regarding impacts on this 

species.

4.7.1.3 West Indian Manatee

The West Indian manatee is federally listed as endangered and can be found in marine, 

estuarine, and freshwater environments. Manatees generally seek out natural warm water sites to 

forage, drink, and rest, including areas where industrial facilities discharge warm water. Most of 

their time is spent in freshwater and estuarine environments, but manatees will venture into salt 

water to travel to different locations. Manatees are herbivores that feed on a large variety of 

plants, including submerged, emergent, and floating vegetation. Mating can occur at any time of 

year and, while calving peaks in the spring months, calves may be present in any area at any time 

of the year and usually remain with the mother for 2 years. Major threats to this species include 

boat collisions, habitat loss, and forage species loss (FWS 2012d).

Manatees are present in the Calcasieu River Basin; however, given the level of industrial 

activity, their presence near the Terminal Expansion site is unlikely (LDWF 2012c). The LNHP

database shows a historical sighting near the Terminal Expansion site in 1929, but none since 

then. Although their presence is unlikely, manatees may be present in the Calcasieu Ship 

Channel and increased vessel strikes may potentially occur with an increase in vessel traffic 

during Cameron LNG’s construction and use of the work dock. As the manatee has not been 

observed in the vicinity of the Terminal Expansion site in over 80 years and appropriate habitat 

for foraging is minimal, we believe the Project is not likely to adversely affect the West Indian 

manatee.

4.7.1.4 Sea Turtles

Five species of federally-listed endangered and threatened sea turtles possibly occur in 

the waters near the Terminal Expansion in Cameron and Calcasieu Parishes, Louisiana, and are 

described below.

Green Sea Turtle

The green sea turtle is federally-listed as threatened. Green sea turtles inhabit shallow 

habitats with an abundance of marine algae and seagrass, such as lagoons, bays, inlets, shoals, 

and estuaries. They use coral reefs and rocky outcrops near feeding areas to rest, and they feed 

on marine plants, mollusks, sponges, crustaceans, and jellyfish. They tend to nest on their natal 

beach (NOAA 2006). Suitable nesting habitat for this species is not available in the vicinity of 

the Project.
Threatened And Endangered Species 4-74

Hawksbill Sea Turtle

The hawksbill sea turtle is federally-listed as endangered. This species inhabits coastal 

reefs, bays, rocky areas, estuaries, and lagoons at depths of 70 feet or less. Hawksbill sea turtle 

hatchlings may occur in the open sea floating on masses of marine plants, while juveniles, 

subadults, and adults may occur near their primary foraging area along coral reefs. Hawksbill 

sea turtles are omnivorous; however, they prefer to feed on invertebrates such as sponges,

mollusks, and sea urchins. In contrast to all other sea turtle species, hawksbills nest in low 

densities on scattered small beaches. About 15,000 females are estimated to nest each year 

throughout the world with the Caribbean accounting for 20 to 30 percent of the world’s 

hawksbill population. Panama, which used to support the single most important nesting 

population in the Caribbean, is only a remnant population. Mexico and Cuba now support the 

largest nesting populations in the Caribbean (FWS, no date). The hawksbill sea turtle is one of 

the most infrequently encountered sea turtles in offshore Louisiana. However, a hawksbill was 

reported near Calcasieu Lake in 1986 (COE 2010b). This species is not listed for Calcasieu 

Parish. Due to the lack of suitable foraging and nesting habitats, there is a low probability of this 

species occurring within the project area.

Kemp’s Ridley

The Kemp’s ridley sea turtle is the smallest of the sea turtles found in the Gulf of Mexico 

and is federally listed as endangered. It occurs mainly in the coastal areas of the Gulf of Mexico 

and the U.S. Atlantic seaboard. Nesting occurs mainly in Mexico from May to July, but Kemp’s 

ridley sea turtles also nest in small numbers along the Gulf coast, mostly in southern Texas 

(NMFS 2011). Kemp’s ridley sea turtles have not been known to nest on the Louisiana coast 

(LDWF 2012d). Juveniles and sub-adults occupy shallow, coastal regions and are commonly 

associated with crab-laden, sandy or muddy water bottoms; young turtles often float on mats of 

Sargassum seaweed. Kemp’s ridley sea turtles feed mostly on swimming crabs, but their diet 

also includes fish, jellyfish, and mollusks. The primary threat to this species is capture and 

entanglement in fishing gear, such as shrimp trawls, gill nets, and longlines. Egg collection has 

also historically been a threat to the population (NMFS 2011).

Nesting areas for the Kemp’s ridley sea turtle are not present in or near the Terminal 

Expansion site and no Kemp’s ridley sea turtles have been known to nest in Louisiana.

Leatherback Sea Turtle

The leatherback sea turtle is federally-listed as endangered. Leatherback sea turtles 

spend most of their time in the open sea and come to land to nest. They may be present in 

coastal waters only when nesting or following jellyfish concentrations. They feed mainly on 

jellyfish and sea squirts as well as sea urchins, crustaceans, fish, and floating seaweed and prefer 

sandy beaches with deepwater approach for nesting. Suitable nesting habitat for this species is 

not available in the vicinity of the Project.

Loggerhead Sea Turtle

The loggerhead sea turtle is federally-listed as threatened. The greatest threats to this sea 

turtle are coastal development, commercial fisheries, and pollution. Loggerhead sea turtles 

inhabit continental shelves, bays, estuaries, and lagoons in temperate, subtropical, and tropical 
4-75 Threatened And Endangered Species

waters. Loggerheads were named for their relatively large heads, which support powerful jaws 

and enable them to feed on hard-shelled prey, such as whelks and conch. The carapace (top shell) 

is slightly heart-shaped and reddish-brown in adults and sub-adults, while the plastron (bottom 

shell) is generally a pale yellowish color. The neck and flippers are usually dull brown to reddish 

brown on top and medium to pale yellow on the sides and bottom. Loggerhead sea turtles nest 

within the coastal United States from Louisiana to Virginia, with major nesting concentrations 

occurring on the coastal islands of North Carolina, South Carolina, and Georgia, and on the

Atlantic and Gulf coasts of Florida. In Louisiana, loggerheads are known to nest on the 

Chandeleur Islands, which is over 200 miles east of the Terminal Expansion. This species is not 

listed for Calcasieu Parish. 

Sea Turtle Impacts and Mitigation

Although sea turtles are not likely to inhabit the area in the immediate vicinity of the 

Terminal Expansion, foraging and transit habitat for the Kemp’s ridley sea turtle does exist near 

the site of the proposed work dock. Given the level of industrial activity in the Calcasieu Ship 

Channel, it is highly unlikely that the Kemp’s ridley sea turtle would use any habitat near the 

proposed Terminal Expansion. If, however, sea turtles were present on occasion, they could 

avoid any sheet piling or pile driving activities and sedimentation from dredging activities. 

Sheet piling and pile driving activities for the proposed work would not occur in the 

water; all piling and piles would be driven on land prior to dredging. These activities would 

generate noise because it would occur close to the water’s edge. It is anticipated that in-water 

construction of the work dock would take 3 months. In addition, dredging activity would 

generate noise because it occurs within the water column. However, dredging is a common 

activity in the vicinity of the Terminal Expansion, and it is likely that most aquatic species are 

accustomed to the level of noise generated by dredging. Therefore, impacts due to noise would 

be minor due to the size of the work dock, the short duration of construction, and the current 

frequency of dredging in the area. During construction of the work dock, Cameron LNG would 

conduct all in-water work during daylight hours with lighting only minimally used for safety and 

security reasons after dark (1- to 5-foot candles). Minimal lighting (1- to 5-foot candles) would 

also be required during operation of the work dock for safety and security reasons after dark. 

Therefore, impacts from lighting during construction and operation of the work dock would be 

temporary and minor. Dredging activities within the Calcasieu Ship Channel occur every 2 years 

according to the COE schedule, and dredging also occurs for maintenance of the berthing area of 

the existing terminal. Dredging activities associated with the proposed work dock would be 

minimal in comparison to the regular maintenance dredging within the channel. Due to the lack 

of available habitat and avoidance of the area due to current industrial activities, including 

dredging, sea turtles would likely continue to avoid the area. To minimize dredging impacts, 

Cameron LNG proposes to use a hydraulic cutterhead dredge which NMFS has confirmed would 

pose no risk to sea turtles32. 

During site surveys, Cameron LNG did not observe any suitable sea turtle habitat or 

individuals. In addition, foraging and transit habitats for the sea turtles are limited near the 

 32 The construction work dock, associated dredging, and construction barge traffic was previously analyzed in 

Docket No. CP06-422-000. While moderate additional dredge volume and construction barge traffic would be 

necessary, the likely impacts on listed species would be the same as Docket No. CP06-422-000.
Threatened And Endangered Species 4-76

Terminal Expansion site. Construction barges delivering material to the site could come from 

the direction of the Gulf of Mexico. Therefore, sea turtle impacts with construction shipping 

traffic could occur. However, these barges would typically be very slow moving and easy for 

sea turtles to avoid. Therefore, based on the limited foraging and transit habitat and Cameron’s 

measures to minimize impacts from dredging, lighting, and pile driving, we conclude the 

proposed Project is not likely to adversely affect any sea turtle species. 

4.7.1.5 Federally Listed Species Conclusion

In its comments on the draft EIS dated February 14, 2014 (comment letter FG1 in 

Appendix L), FWS concurred with our not likely to adversely affect determination and stated that 

no further consultation regarding threatened and endangered species would be necessary unless 

there are significant changes in the scope or location of the Project. Therefore, consultation under 

Section 7(a)(2) of the ESA for species under the jurisdiction of the FWS is complete. 

Additionally, we and NMFS concluded that the impacts from the Terminal Expansion have not 

substantially changed from the impacts discussed in Docket No. CP06-422-000. Because NMFS 

has already concurred with our determination that these impacts are not likely to adversely affect 

listed species, NMFS stated that re-initiation of consultation is not necessary and consultation is 

complete.

33

Should any listed species be identified in the vicinity of the Project or any additional 

species be listed, we would re-open consultation at that time.

4.7.2 State-Listed and Special Status Species

Cameron conducted consultations with LNHP and determined that, in addition to the 

federally listed species above, two state endangered species, three state imperiled species, one 

critically imperiled species, and one restricted harvest species could be affected by the proposed 

Project. The life histories and potential impacts on these seven species are discussed in this 

section.

4.7.2.1 State-Listed and Special Status Species 

Bald Eagle

The bald eagle is state-listed in Louisiana as endangered. It was federally listed as 

endangered in 1967 primarily because the use of dichlorodiphenyltrichloroethane (DDT) caused 

thinning of eggshells and a decrease in survivorship of the eggs. A recovery plan was put in 

place and the use of DDT was curtailed, which allowed the bald eagle population to increase

significantly. It was subsequently delisted in 2007, but is still federally protected by the Bald 

and Golden Eagle Protection Act, which prohibits the “taking” of bald eagles, including their 

parts, nests, or eggs. In addition, “taking” includes disturbance, which means to bother or agitate 

a bald eagle to the point of injury, decrease in productivity, or nest abandonment (FWS 2010; 

FWS 2012e). It winters and breeds throughout the United States along river systems, next to 

large lakes, and along coastal areas. In Louisiana, bald eagles winter along the coast and near 

some lakes in the northern part of the state, and nest in winter and early spring. Bald eagles tend 

to use the same nest year after year and, in southern Louisiana, nests are usually constructed in 

 33 See Docket No. CP13-25, Accession Number 20140409-4005
4-77 Threatened And Endangered Species

large cypress trees. Bald eagles generally feed on fish, but their diet also includes waterfowl, 

carrion, muskrats, and nutria. Current threats to this species include loss of nesting habitat and 

disturbance to nesting pairs from humans during the nesting season (LDWF 2012e).

The bald eagle could winter or breed in areas near the Terminal Expansion site and 

Pipeline Expansion route; however, little suitable habitat is available and the area has a high 

level of industrial activity, which could cause eagles to avoid the area. Potential foraging habitat 

does exist near the Terminal Expansion site; however, it is unlikely that many eagles use this 

area due to the level of industrial activity. In the vicinity of the Pipeline Expansion route, the 

majority of the forest cover is managed pine plantation, which is not preferred bald eagle habitat. 

Additionally, Cameron Interstate would HDD all perennial waterbodies, where bald eagles are 

most likely to occur. This would further minimize the likelihood of pipeline construction related 

impacts on the bald eagle. Further, Cameron conducted surveys in May, June, and July 2012 and 

no nesting sites were found within 0.5 mile of the proposed Terminal Expansion site or the 

proposed Pipeline Expansion route. 

Because no nesting sites were observed during surveys and little suitable habitat for 

either nesting or foraging can be found nearby, we believe the Project would not significantly 

impact the bald eagle. Should a bald eagle be observed, Cameron LNG would stop all work and 

would immediately notify the FWS and LDWF to determine appropriate protection actions.

Brown Pelican

The brown pelican is state-listed as endangered. It was federally listed as endangered in 

1970 for the same reason as the bald eagle: the use of DDT thinned eggshells of the brown 

pelican to the point that survivorship of eggs was severely decreased. Pelicans usually occur in 

small flocks in bays, estuaries, and along the coast. The brown pelican generally nests in small 

thickets in the dune line of barrier islands between November and July. Often if a pair is 

unsuccessful with the first nest, the pair will re-nest within the same season. They feed mainly 

on fish and some marine invertebrates in deep and shallow coastal waters. Current threats to this 

species include a decrease in nesting habitat due to erosion of barrier islands, illegal take of the 

eggs by humans, and coastal land loss throughout its range (FWS 2012f; LDWF 2012f).

No potential brown pelican habitat exists near the Pipeline Expansion site. Potential 

foraging areas for the brown pelican exist near the Terminal Expansion site, but no high quality 

nesting habitat exists in the vicinity. Although foraging habitat exists near the Terminal 

Expansion site, it is unlikely that brown pelicans would use the area often due to the level of 

industrial activity. As no nesting sites and little suitable habitat are found nearby, we believe the 

Project would have minimal impact on the brown pelican.

Alligator Snapping Turtle

The alligator snapping turtle is under restricted harvest in Beauregard Parish. Alligator 

snapping turtles can become very large animals and are usually found in slow moving rivers, 

lakes, or oxbows, but can also be found in freshwater marsh areas with rivers close by (LDWF 

2012g). Because the proposed Pipeline Expansion route contains several large waterbodies, 

construction could affect the alligator snapping turtle. However, Cameron Interstate proposes to 

use the HDD method to cross all perennial waterbodies, which would most likely contain 
Threatened And Endangered Species 4-78

alligator snapping turtles. The use of the HDD method would minimize or avoid direct impacts 

on this species. If an inadvertent release occurs, drilling mud could enter the waterbody, which 

would cause localized turbidity. The alligator snapping turtles would likely leave or avoid the 

area if this occurs. Furthermore, Cameron Interstate would perform drilling under the guidance 

of their HDD Contingency Plan (Appendix C). The use of this plan and associated mitigation 

measures would minimize impacts on the alligator snapping turtle. Therefore, we believe the 

impact on the alligator snapping turtle would be minimized.

Old Prairie Crawfish and Long-Sepaled False Dragon-Head 

The old prairie crawfish and long-sepaled false-dragon head are designated as imperiled 

in Louisiana. All historical observations were made between 1966 and 1988; no observations 

have been made since. The long-sepaled false dragon-head prefers bottomland hardwood forests 

and slightly disturbed wet areas, such as roadside ditches (LDWF 2012h). Although habitat 

exists for the long-sepaled false dragon-head in the vicinity of the Terminal Expansion site, no 

individuals or populations have been observed and recorded near the area since 1988. Therefore, 

the presence of the species is not expected within the area and we conclude the proposed 

expansion would have no impact on the long-sepaled false dragon-head. 

The old prairie crawfish, also known as the old prairie digger, lives in burrows in areas

where the water table is close to the ground surface and that experience frequent flooding. They 

mainly inhabit herbaceous areas and can be found in roadside ditches (NatureServe 2012b). The 

species was last recorded in the area in 1966. Although habitat exists for the old prairie crawfish 

in the vicinity of the Terminal Expansion site, no individuals or populations have been observed 

or recorded near the area since 1966. Therefore, the presence of the species is not expected 

within the area and we conclude the Project would have no impact on the old prairie crawfish.

Dotted Gay-Feather and Silveus Dropseed

LNHP provided information that indicates the dotted gay-feather and silveus dropseed 

occur within longleaf pine savannahs; therefore, they could be present in the vicinity of the 

Pipeline Expansion right-of-way. The dotted gay-feather is critically imperiled in Louisiana and 

the silveus dropseed is imperiled in Louisiana. These species, as described by LNHP, are 

associated with two types of critically imperiled longleaf pine savannahs, western acidic and 

saline, that potentially occur in the vicinity of the proposed Pipeline Expansion right-of-way in 

Beauregard and Calcasieu Parishes. LNHP requested that Cameron Interstate minimize impacts 

on these two forest habitats. LNHP also requested in an October 24, 2012 letter that caution be 

used when working in or near these areas to avoid impacts on these two species and the two 

longleaf pine savannah habitats. During wetland delineations conducted in July 2012, no 

longleaf pine savannahs were documented by Cameron Interstate. However, a field visit was 

conducted with LNHP on February 13, 2013 and a portion of the proposed Pipeline Expansion 

route was found to include saline longleaf pine savannah. The savannah sites are between 

Beckwith Creek and Hickory Branch, both of which Cameron Interstate would cross using the 

HDD method. Cameron Interstate indicated it would work with LNHP to develop a site-specific 

construction management plan for this area prior to construction, which would include best 

management practices and restoration methods. If either the dotted gay-feather or silveus 

dropseed are observed during construction, Cameron Interstate has committed to ceasing 
4-79 Threatened And Endangered Species

construction activities in the immediate area and notifying the LNHP to determine the 

appropriate protection actions.

In an effort to reduce impacts on western acidic and western saline longleaf pine 

savannahs, we included a recommendation in the draft EIS that Cameron Interstate develop sitespecific construction management plans for areas where the pipeline would cross western saline 

longleaf pine savannahs. In response to that recommendation, Cameron Interstate filed a copy of 

a May 16, 2013 letter from the LNHP that included mitigation measures in those areas. Cameron 

Interstate agreed to those recommendations, which included soil stockpiling, use of native seeds 

for reclamation, soil rutting and compaction avoidance, and cleaning equipment before mowing. 

In addition, Cameron Interstate filed a copy of its August 22, 2013 letter to LNHP in which 

Cameron Interstate agreed to extend the HDD more than 1,000 feet east of the originally 

proposed end point to avoid the saline pine savannah that is east of Beckwith Creek. Cameron 

Interstate also agreed to make that change on photo-based alignment sheets prior to the start of 

construction of the pipeline as part of its Implementation Plan. Because Cameron LNG has not 

yet filed these photo-alignment sheets, we are recommending that:

• Prior to construction, Cameron Interstate should file with the Secretary for 

review and written approval by the Director of the OEP revised photoalignment sheets that include the proposed extension of the HDD crossing of 

Beckwith Creek to avoid the saline pine savannah that is east of Beckwith 

Creek.

Based on the avoidance by HDD and the establishment and implementation of measures 

to minimize impacts on the saline longleaf pine savannah as committed to by Cameron Interstate, 

we conclude that no significant impacts would occur on longleaf pine savannah habitat or on the 

dotted gay-feather and silveus dropseed species. 

4.7.2.2 Threatened, Endangered, and other Special Status Species Conclusion

Based on review of available literature, results of field surveys, and coordination with 

agency personnel, it is not likely that any of the state-listed or special status species for 

Beauregard, Calcasieu, or Cameron Parishes would frequently inhabit the Terminal Expansion 

site or the Pipeline Expansion right-of-way or in the immediate vicinity of those areas. Based on 

the limited amount of available habitat in the area for listed or other special status species, the 

temporary nature of the impacts for the Pipeline Expansion, alignment along and overlap with 

existing rights-of-way, and mitigation measures proposed, we believe the Project would either 

have no impact on special status species or the impact would be adequately minimized.

4.8 LAND USE, RECREATION, AND VISUAL RESOURCES 

4.8.1 Land Use

Cameron would construct its Project in Cameron, Calcasieu, and Beauregard Parishes. 

Land use in the vicinity of the Project is generally classified into the following categories: 

forested, planted pine, open space, open water, agricultural, residential, and 

industrial/commercial lands. Installation of facilities for the Terminal Expansion and Pipeline 

Expansion would require temporary disturbance of about 823.6 acres of land. After construction, 
Threatened And Endangered Species 4-80

the permanent rights-of-way would encompass about 590.3 acres. The remaining 233.3 acres 

would return to pre-construction conditions and uses. Table 4.8.1-1 summarizes the acreages of 

each land use type that Cameron would affect during construction and operation of the Project. 

The definitions of each land use type are as follows:

• forested – includes upland and wetland forests;

• pine plantation – includes planted pine land used for silviculture;

• open space – includes non-forested open lands, such as: existing utility rights-ofway; grassland/rangeland; emergent and scrub-shrub34 wetlands and uplands; and 

grazing land; 

• open water – includes water crossings greater than 100 feet; 

• agricultural – includes active cropland or hay fields; 

• residential – includes residential yards, subdivisions, and planned new residential 

developments; and

• industrial/commercial – includes all developed areas, such as roads railroads, and 

industrial areas. 

4.8.1.1 Terminal Expansion 

The proposed Terminal Expansion site is on the west side of the Calcasieu Ship Channel. 

Most of the site was previously disturbed by the placement of dredged material from 

maintenance of the Calcasieu Ship Channel and construction of the existing LNG Terminal. 

Land uses surrounding and within the proposed expansion site are primarily industrial, forested 

and non-forested wetlands, roads, open space, and open water. Cameron LNG would construct 

the Terminal Expansion within and adjacent to its existing LNG Terminal, which abuts the 

southern end of the Terminal Expansion site. Construction of the facilities would require 

approximately 502.2 acres, including 400.2 acres of open land (which includes emergent and 

scrub-shrub wetlands), 24.5 acres of forested land, 7.5 acres of industrial land, and 70.1 acres of 

open water. Approximately 70.0 acres of these impacts are within the existing terminal 

boundaries. Cameron LNG would convert all lands used for construction of the Terminal 

Expansion to industrial use.

 34 Scrub-shrub lands are dominated by woody vegetation less than 20 feet tall, such as sage brush, young trees, 

and small or stunted trees or shrubs.
4-81 Land Use, Recreation, And Visual Resources

TABLE 4.8.1-1

Land Uses Affected by the Liquefaction Project a

Acres

Parish

Forest b Pine 

Plantation Open Space c Open Water Agriculture Residential Industrial/Commercial Total

Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper

Terminal Expansion

Calcasieu 18.5 18.5 0.0 0.0 170.1 170.1 < 0.1 d < 0.1 d 0.0 0.0 0.0 0.0 0.0 0.0 188.6 188.6

Cameron 6.1 6.1 0.0 0.0 230.1 230.1 70.0 70.0 0.0 0.0 0.0 0.0 7.5 7.5 313.6 313.6

Terminal 

Expansion 

Project Total

24.5 24.5 0.0 0.0 400.2 400.2 70.1 70.1 0.0 0.0 0.0 0.0 7.5 7.5 502.2 502.2

Pipeline Expansion

Calcasieu 11.6 3.0 26.1 5.7 85.8 24.7 0.0 0.0 0.0 0.0 0.0 0.0 0.9 0.2 124.4 33.6

Beauregard 2.7 0.0 0.3 0.0 72.1 26.0 0.0 0.0 18.5 8.1 0.0 0. 0 0.3 0.1 93.9 34.2

Pipeline 

Expansion 

Total

4.3 3.0 26.4 5.7 157.9 50.7 0. 0 0.0 18.5 8.1 0.0 0.0 1.2 0.3 218.3 67.8

Holbrook Compressor Station

Calcasieu 0.0 0.0 16.0 13.7 1.3 1.3 0.0 0.0 0.0 0.0 0.0 0.0 0.3 0.2 17. 6 15.3

ATWS

Calcasieu 1.1 0.0 0.0 0.0 10.4 0.0 0.0 0.0 5.6 0.0 0.0 0.0 0.1 0.0 17.3 0.0

Beauregard 3.0 0.0 2.2 0.0 11.2 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.0 16.5 0.0

ATWS Total 4.1 0.0 2.2 0. 0 21.6 0.0 0.0 0.0 5.6 0.0 0.0 0.0 0.2 0.0 33.7 0.0

FGT Interconnection

Calcasieu 0.0 0.0 0.0 0.0 1.5 1.45 0.0 0.0 0.0 0.0 0. 0 0.0 0.1 0.1 1.5 1.5
Land Use, Recreation, And Visual Resources

4-82

TABLE 4.8.1-1

Land Uses Affected by the Liquefaction Project a - Continued

Acres

Parish

Forest b Pine 

Plantation Open Space c Open Water Agriculture Residential Industrial/Commercial Total

Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper

TGP Interconnection

Calcasieu 0.1 0.1 0.0 0.0 1.2 1.2 0.0 0.0 0.0 0.0 0.0 0.0 0.1 0.17 1.4 1.4

TETCO and Transco Interconnections d

Beauregard 0.0 0.0 0.0 0.0 0.7 0.7 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.7 0.7

Trunkline Interconnection

Beauregard 0.0 0.0 0.0 0.0 0.2 0.2 0.0 0.0 0.0 0.0 0.0 0.0 < 0.1 <0.1 0.2 0.2

Contractor Yard

Calcasieu 0.0 0.0 0.0 0.0 10.3 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.4 0.0 10.6 0.0

Access Roads

Calcasieu 0.0 0.0 1.2 1.2 0.6 < 0.1 0.0 0.0 0.0 0.0 0.0 0.0 22.9 0.0 24.7 1.2

Beauregard 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 12.8 0.0 12.8 0.0

Access Roads 

Total 0.0 0.0 1.2 1.2 0.6 < 0.1 0.0 0.0 0.0 0.0 0.0 0.0 35.7 0.0 37.4 1.2

Pipeline 

Expansion 

Project Total

18.5 3.1 45.8 20.6 195.2 55.6 0.0 0.0 24.0 8.1 0.0 0.0 37.9 0.7 321.4 88.1

Liquefaction 

Project Total 43.0 27.7 45.8 20.6 595.4 455.8 70.1 70.1 24.0 8.1 0.0 0.0 45.4 8.2 823.6 590.3
4-83 Land Use, Recreation, And Visual Resources

TABLE 4.8.1-1

Land Uses Affected by the Liquefaction Project a - Continued

Acres

Parish

Forest b Pine 

Plantation Open Space c Open Water Agriculture Residential Industrial/Commercial Total

Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper Cons Oper

< = Less than

Cons = Construction

Oper = Operation

a The numbers in this table have been rounded for presentation purposes. As a result, the totals may not reflect the sum of the addends. 

b Forested acreages include upland forests and forested wetlands.

c Open Space acreages include emergent and scrub-shrub wetlands.

d The TETCO and Transco Interconnections would occupy the same workspace.
Land Use, Recreation, And Visual Resources 4-84

4.8.1.2 Pipeline Expansion

Pipeline

During construction, Cameron Interstate would typically use a 100-foot-wide right-ofway in uplands and wetlands (see figure 2.3.1), except in the four bottomland hardwood wetland 

areas where the right-of-way would be reduced as described in section 4.4.5.2. Cameron 

Interstate would require about 289.4 acres for construction of its pipeline (which includes area 

for the ATWSs and access roads). Of this amount, approximately 140.0 acres (48 percent) was 

previously disturbed during construction of the Cameron Interstate and LA Storage Pipelines. 

Cameron Interstate would construct the entire 20.9 miles of pipeline parallel to existing rights-ofway. Cameron Interstate would collocate about 15.5 miles with its existing pipeline right-ofway. In these areas, the construction right-of-way would overlap the existing rights-of-way, with 

the width of the overlap dependent upon the configuration of the existing rights-of-way (see table 

4.8.1-1). During operation, Cameron Interstate would maintain an additional 25-foot-wide 

permanent easement adjacent to its existing 50-foot-wide permanent rights-of-way. Cameron 

Interstate would extend its pipeline about 4.1 miles northeast from its existing permanent rightsof-way (see table 4.8.1-1), and would acquire and maintain an additional 50 feet of permanent 

easement in this area. The remaining 1.3 miles of the pipeline would be installed using the HDD 

method. Cameron Interstate would maintain about 67.8 acres during operation of the pipeline.

Aboveground Facilities

The Pipeline Expansion would include one new compressor station, a new 

interconnection with Trunkline, metering stations and modifications at four existing 

interconnections, and installation of a metering station at the existing Cameron LNG Terminal. 

Cameron Interstate would construct the new Holbrook Compressor Station on about 25 acres of 

land in Calcasieu Parish at MP 8.4. Of that area, about 5 acres would be within the construction 

right-of-way of the pipeline and are addressed with the pipeline impacts discussed above. For 

the remaining 20 acres, about 17.6 acres would be cleared and graded during construction, while 

2.4 acres would not be impacted. Cameron Interstate would maintain about 15.3 acres for 

operation of the station. Cameron Interstate would seed and maintain as grass the remaining 2.3 

acres.

The new Trunkline interconnection would impact about 0.2 acre of land in Beauregard 

Parish near MP 20.8. The new interconnection and metering facilities at Trunkline would use 

portions of the existing LA Storage interconnection site. Additionally, Cameron Interstate would 

use all of the 0.2 acre during operation. 

Cameron Interstate would install new metering facilities at its four existing 

interconnections: FGT, TGP, TETCO, and Transco. Cameron Interstate would expand and 

relocate the existing fence lines at these interconnections to accommodate the new facilities. The 

FGT interconnection would require 1.5 acres during construction and operation. The TETCO 

and Transco interconnections would be at one site and would require 0.7 acre of land during both 

construction and operation. The TGP interconnection would require 1.4 acres for construction 

and operation.
4-85 Land Use, Recreation, And Visual Resources

Contractor and Storage Yard

The Pipeline Expansion would require temporary use of one warehouse/storage yard to 

store pipe and equipment for the Pipeline Expansion, as well as for contractor office space, on 

about 10.6 acres adjacent to the Ragley Compressor Station in Calcasieu Parish (see figure 2.0-

3). This area was previously used as a storage yard during construction of the existing Cameron 

Interstate Pipeline. 

Additional Temporary Work Space/Staging Areas

Cameron Interstate would need 33.7 acres of ATWSs adjacent to the construction rightof-way. The majority of ATWSs would be within open land and agricultural land. In the event 

that Cameron Interstate requires new ATWSs in some areas and for reasons approved by its Plan 

(i.e., non-wetland areas to accommodate full right-of-way topsoil segregation or for truck turnarounds where no reasonable alternative exists), they would be identified and approved by the EI 

prior to use by the construction workforce and identified in the construction status reports. 

Access Roads

Cameron Interstate would use 28 public and private roads that intersect or parallel the 

proposed pipeline route to access the right-of-way during construction (the access roads are 

depicted on the alignment sheets in Appendix B; Appendix H provides a table that lists the 

access roads along with their lengths and locations by milepost). Cameron Interstate would also 

construct a new 1,500-foot-long access road to the Holbrook Compressor Station, which would 

impact about 1.2 acres. No other new access roads to the pipeline right-of-way are proposed and 

the existing roadways would not require major modifications, such as widening. Additionally, 

Cameron Interstate does not propose any new permanent access roads (other than to provide 

access to the Holbrook Compressor Station). However, Cameron Interstate may require minor 

modifications to some of the existing access roads, such as grading and replacement of gravel. 

Access roads and anticipated improvements are discussed in section 2.3.2.

4.8.1.3 Land Use Impacts and Mitigation

Impacts and mitigation on forest and open space are described in sections 4.4 (wetlands) 

and 4.5 (vegetation) of this EIS. The sections below focus on land uses not discussed in detail

elsewhere in this EIS.

Planted Pine 

Cameron LNG would not impact any pine plantation. Cameron Interstate would clear 

about 45.8 acres of pine plantation during construction of the Pipeline Expansion. After

construction, 25.2 acres would be available for planting and use in timber production. This 

would be a long-term impact due to the relatively long growth period required for marketable 

timber. Cameron Interstate would prohibit timber production within the permanent right-of-way, 

resulting in permanent removal of 20.6 acres of timber production. However, Cameron Interstate 

would compensate the landowner for the loss of timber production in accordance with the terms 

of individual easement negotiations. 
Land Use, Recreation, And Visual Resources 4-86

Existing Rights-of-Way

Terminal Expansion

About 70.0 acres of the expansion would be within the existing Cameron LNG Terminal.

Pipeline Expansion

About 15.5 miles of the proposed pipeline right-of-way would overlap existing rights-ofway, limiting the amount of newly disturbed right-of-way. This would result in impacts on 140.0 

acres of land that was previously disturbed during construction of the Cameron Interstate and LA 

Storage pipelines. The proposed route crosses eight paved public roads, 21 unpaved and/or 

private roads, and one railroad. Cameron Interstate would bore the railroad and paved road 

crossings to avoid impacts on rail traffic, adverse effects to the roadways, and traffic on the 

roadways. Cameron Interstate would cross non-paved roads using the open-cut method. Where 

open-cut construction is proposed on roads that provide access to private residences or 

businesses with no alternate entrance, Cameron Interstate would maintain passage during 

construction. In addition, Cameron Interstate would attempt to avoid peak traffic times during 

construction of roadway crossings that could temporarily close roads, use signage to minimize 

impacts, and follow local regulations regarding maintaining the flow of traffic. 

Cameron Interstate would keep roads free of mud left by its construction equipment. 

Track-driven equipment would cross paved roads on tires or equipment pads to minimize 

damage to the road surface. To further minimize road damage, Cameron Interstate would 

enforce local weight limitations and restrictions. Cameron Interstate would repair roadways 

damaged by its construction to pre-construction conditions. We believe that use of these 

construction methods would not have a significant impact on roadways or railroads. 

Open Water 

Terminal Expansion

Open water is considered to be perennial waterbodies greater than 100 feet wide. 

Construction of the Terminal Expansion would include filling about 70.1 acres of open water. 

Two manmade freshwater ponds are present on the Terminal Expansion site. One seasonally dry 

pond that Cameron LNG would fill was created as a result of the onsite disposal of dredged 

material from COE maintenance dredging in the Calcasieu Ship Channel. Cameron LNG would 

use the second pond as a temporary construction stormwater basin and may fill it later. The 

smaller pond is deeper, does not dry up seasonally, and supports some of the typical species for 

fresh water ponds in the area. It was previously used for recreational fishing, but after Cameron 

LNG purchased the land for the Terminal Expansion, including the fish camp, access to that area 

has been limited to Cameron LNG employees. This pond could be filled during construction, 

resulting in converting all open water within the facility to industrial land. 

As part of the Terminal Expansion, Cameron LNG would construct and use a work dock 

along the western bank of the Calcasieu Ship Channel. The work dock would require dredging 

of about 9.4 acres and would result in a permanent impact on open water at the terminal. 
4-87 Land Use, Recreation, And Visual Resources

We believe impacts from construction and operation of the Terminal Expansion would 

not be significant for several reasons. The existing ponds were manmade, with the larger pond 

used for industrial purposes that would not be necessary for continued operation of the existing 

Cameron LNG Terminal. The smaller pond is no longer used for recreational fishing because 

that area is limited to employee use. Open water adjacent to the work dock would remain as 

open water although public use of the water would be prohibited. In addition, there is a large 

amount of open water in all directions from the Terminal Expansion site. 

Pipeline Expansion

Cameron Interstate would use the HDD method to cross all perennial and sensitive 

waterways (six HDD crossings along the approximately 21-mile-long route), with the result that 

those waterbodies would not be impacted by construction. Operation of the pipeline would 

result in no permanent impacts on open water. Waterbody crossings are discussed further in 

section 4.3

Agricultural 

Terminal Expansion

The Terminal Expansion would not impact any agricultural lands during construction or 

operation. 

Pipeline Expansion

Cameron Interstate would impact about 18.5 acres of agricultural lands within the 100-

foot-wide pipeline construction right-of-way and 5.6 acres within the ATWS areas. To minimize 

impacts on agricultural lands, Cameron Interstate would implement the measures provided in its 

Plan, including topsoil segregation, erosion control, and soil compaction mitigation. 

The pipeline would also extend through about 15.2 miles of lands with soils classified as 

prime farmland. Cameron Interstate would implement its Plan, which includes mitigation 

measures to limit impacts, such as topsoil segregation and soil compaction mitigation in annually 

cultivated prime farmland. In addition, construction of the Holbrook Compressor Station would 

affect approximately 5.2 acres of prime farmland, currently used for silviculture and classified as 

pine plantation. 

The Pipeline Expansion would impact about 24 acres of agricultural lands, with a loss of 

production during and shortly after construction is completed. After construction, Cameron 

Interstate would allow all cultivated agricultural land impacted by the Project to return to 

preconstruction conditions. There would be no permanent impacts on cultivated land by the 

Project. As a result, we believe the impact on cultivated agricultural land would be temporary to 

short-term and would not be significant. 

Residential Lands

No active businesses occur within 50 feet of the Project.
Land Use, Recreation, And Visual Resources 4-88

Terminal Expansion

Cameron LNG executed an option to purchase the one residence that was within 50 feet 

of the boundary of the proposed site of the Terminal Expansion and would exercise that right 

prior to construction if the Project is authorized and receives all other required certifications and 

permits. The next closest residence is about 1.2 miles northwest of the property boundary. The 

nearest residence may observe an increase in traffic along LA-27 during construction as well as a 

change in the viewshed from the residence. Visual impacts on residential areas are discussed in 

section 4.8.6, transportation impacts are discussed in section 4.9.7.2, and noise and dust impacts 

on nearby residences are discussed in section 4.11. 

Pipeline Expansion

There is one residence within 50 feet of the proposed construction right-of-way and one 

unoccupied trailer and one shed within 20 feet of the right-of-way. The nearest residence to the 

proposed Holbrook Compressor Station is about 0.6 mile from the site. In residential areas, the 

two most significant impacts associated with construction and operation of natural gas facilities 

are disturbance during construction and hindrance of property future uses due to the presence of 

Project facilities. Temporary construction impacts on residential areas can include 

inconveniences caused by noise and dust generated by construction equipment, personnel, and 

trenching through roads or driveways; ground disturbance of lawns; removal of trees, landscaped 

shrubs, or other vegetative screening between residences and the right-of-way; potential damage 

to septic systems or wells; and removal of aboveground structures, such as sheds or trailers, from 

the right-of-way. Additionally, during typical overland pipeline construction, the trench is 

sometimes excavated before the pipe is strung and welded. This could result in open trenches for 

extended periods of time, which could pose a safety hazard to nearby residents.

To minimize residential impacts of the construction right-of-way, Cameron Interstate 

would implement the following mitigation measures:

• notify the residents of the approximate time that construction would take place on 

their property;

• minimize noise within 1 mile of residences;

• employ water trucks or sprinklers as necessary to reduce dust;

• place curtains of suitable material, as necessary, to prevent windblown sand 

blasting particles from reaching residences; 

• repair or replace any damaged septic tanks or drain fields; 

• only remove mature trees if necessary for safe operation of construction vehicles;

• restore all lawn areas and landscaping immediately after construction or as 

specified in landowner agreements; 

• reduce the width of the construction right-of-way near the residences to maintain 

at least 15 feet of undisturbed land between the right-of-way and the residence; 

• fence the edge of the construction work area for 100 feet on either side of the 

residence; and 
4-89 Land Use, Recreation, And Visual Resources

• maintain safety fencing throughout construction. 

After construction, landowners may use the right-of-way, provided they do not interfere 

with the rights granted to Cameron Interstate. No trees would be permitted on the permanent 

right-of-way, as they may impair access to the pipeline, and roots could damage the pipeline 

coating. No structures, including houses, tool sheds, garages, poles, swimming pools, or other 

objects not easily removed would be permitted on the permanent right-of-way.

Three other residences are within 135 feet of the proposed construction right-of-way 

(table 4.8.1-2). Cameron Interstate developed site-specific construction plans for each of these 

residences (Appendix D). We reviewed these site-specific plans, and believe Cameron 

Interstate’s proposed mitigation measures would lessen impacts on the affected residences.

TABLE 4.8.1-2

Residences and Structures Within 135 feet of the Pipeline Expansion Construction Right-of-Way

Facility Parish Milepost

Distance to 

Construction Work Area 

(feet)

House Calcasieu 0.3 15

House Calcasieu 1.3 93

House Calcasieu 1.4 67

Unoccupied Trailer Calcasieu 1.5 20

House Beauregard 20.9 135

Shed Beauregard 20.9 19

Construction would not affect the residence nearest the compressor station site, but 

compressor station noise during operation would result in a minor impact at that residence (see 

section 4.11). In addition to the residence closest to the compressor station, there is one other 

residence within 1 mile of the Holbrook Compressor Station (about 0.9 mile from the site). Due 

to the distance from the compressor station site, we would not expect any impacts at that 

residence.

The proposed route is adjacent to existing rights-of-way. Overall, we believe 

construction of the Project would have a moderate, temporary impact on residential land use. 

There would be a permanent and minor noise impact on residential land use in the vicinity of the 

Holbrook Compressor Station during operation of the Project due to an increase in sound levels 

(see section 4.11).

4.8.2 Landowner and Easement Requirements 

4.8.2.1 Terminal Expansion

The 502.2 acres required for construction of the Terminal Expansion are all under the 

ownership of Cameron LNG, with approximately 70.1 acres within the existing Cameron LNG 

Terminal property. As a result, Cameron LNG would not acquire additional land or easements 

for the Terminal Expansion. 
Land Use, Recreation, And Visual Resources 4-90

4.8.2.2 Pipeline Expansion

Cameron Interstate would install all facilities associated with the Pipeline Expansion on 

private lands. Cameron Interstate executed an option to purchase the proposed site of the 

Holbrook Compressor Station and would exercise that right prior to construction if the Project is 

authorized and receives all other required certifications and permits. 

For privately owned land along the proposed pipeline route, Cameron Interstate would 

secure an easement to convey both temporary and permanent rights-of-way prior to construction. 

The easement acquisition process is designed to provide fair compensation to the landowners for 

the right of Cameron Interstate to use the property during construction and operation of the 

pipeline. 

If an easement cannot be negotiated with a landowner and the Project has been 

Certificated by the FERC, Cameron Interstate could use the right to eminent domain granted to it 

under Section 7(h) of the NGA and the procedure set forth under the Federal Rules of Civil 

Procedure (Rule 71A) to obtain the right-of-way and ATWS areas. Cameron Interstate must

compensate the landowner for the right-of-way and any damages incurred during construction.

However, a court would determine the level of compensation. In either case, Cameron Interstate 

would compensate the landowner for the use of the land.

4.8.3 Planned Developments

4.8.3.1 Terminal Expansion

There are no existing or known planned developments at or near the proposed site of the 

Terminal Expansion. 

4.8.3.2 Pipeline Expansion 

The proposed pipeline route does not cross and is not near any area recorded planned 

development. The previous landowner of the compressor station site indicated he may develop 

parcels along Holbrook Park Road, approximately 1,500 feet from the proposed compressor 

station. However, no development plans have been submitted to the parish. 

4.8.4 Recreation and Special Interest Areas

4.8.4.1 Terminal Expansion

Cameron LNG’s Terminal Expansion would not directly affect designated recreational or 

special interest areas by construction or operation. 

There are two wildlife refuges in the vicinity of the Terminal Expansion site (figure 4.8-

1) and 36 miles of accessible coastal beaches in Cameron Parish. In addition, the Creole Nature 

Trail All American Road (Creole Nature Trail) is a roadway system approximately 180 miles 

long that extends through Calcasieu and Cameron Parishes. It includes the portion of LA-27 that 

extends from Sulphur to the Gulf Coast, including the highway in the vicinity of the Terminal 

Expansion. During the approximately 4-year construction period for the Terminal Expansion, 

there would be a substantial increase in traffic on LA-27 between Sulphur and the Terminal 
4-91 Land Use, Recreation, And Visual Resources

Figure 4.8-1 Recreational Facilities Near the Terminal Expansion
Land Use, Recreation, And Visual Resources 4-92

Expansion site. Our recommendations for mitigating the impact of the additional traffic are 

discussed in section 4.9.7. In addition, the majority of the traffic would be from construction 

workers commuting to and from the site during early morning or evening hours, times when 

many tourists and recreational users of the roadway would not be affected. Impacts on this 

portion of the Creole Nature Trail could also include visual impacts (see section 4.8.6) and noise 

and dust impacts (see section 4.11). We believe that the impacts of construction and operation of 

the Project on the Creole Nature Trail would be minor to moderate with incorporation of the 

mitigation measures identified in section 4.9.7. 

Portions of two NWRs are in the vicinity of the Calcasieu Ship Channel and offer a 

variety of recreational activities. The Sabine NWR is 8 miles south of Hackberry, Louisiana, and 

the refuge extends to the ship channel between river miles 9 and 12. Users of the Sabine NWR 

adjacent to the channel may observe an increase in barge traffic during construction, and may 

also observe LNG carrier traffic through the channel (see section 4.8.6). The East Cove Unit of 

the Cameron Prairie NWR extends along a portion of the southeastern shore of Calcasieu Lake. 

The Cameron Prairie NWR is distant from the Calcasieu Ship Channel, and there is a strip of 

land on the eastern side of the channel that blocks views from the refuge. As a result, we believe 

East Cove Unit users would not likely be affected by traffic in the channel due to construction 

and operation of the Project. In addition, Cameron LNG has not requested an increase in the 

number of LNG carriers currently authorized to call on the terminal, and the impacts to the 

NWRs would not increase beyond those assessed on our previous EIS and EAs.35 As a result, 

the Terminal Expansion would not impact land uses of the NWRs. 

The closest marina to the Terminal Expansion is near Hackberry, more than 2 miles south 

of the terminal site. The marina is on a tributary to the channel and would not be directly 

affected by the increase in barge traffic during construction or operation of the Terminal 

Expansion.

Construction of the Terminal Expansion would require dredging in the waters of the 

Calcasieu Ship Channel adjacent to land and would increase barge and support vessel traffic in 

the channel (also see section 4.9.7.1). However, Cameron LNG would not construct in the 

channel, and there would be at least 300 feet between vessels berthed at the work dock and the 

edge of the maintained ship channel. 

During construction of the Terminal Expansion, barge traffic in both the Gulf Intracoastal 

Waterway and in the Calcasieu Ship Channel would increase. In each of the first 7 months of 

Terminal Expansion construction there would be about 275 barges per month, or about 9 barges 

per day. Barge deliveries would decrease to 150 per month (about 5 per day) during months 8 

through 10, and 125 barges per month (about 4 per day) from months 11 through 14. After that 

there would be about 10 barges per month (about 1 barge every 3 days) for the duration of 

construction. Although recreational boat traffic uses the Calcasieu Ship Channel in transit to 

Calcasieu Lake, we believe the impacts on that traffic during construction would be minor. 

Similarly, the impacts of barge traffic on fishing in the channel would be minor. Barge traffic 

would also increase in the Gulf Intrastate Waterway during construction, although the impacts 

would be similar to those of barge traffic in the channel. Overall, construction of the Terminal 

 35 Hackberry EIS (Docket No. CP02-374), Cameron LNG Terminal Expansion EA (Docket No. CP06-422), and 

Environmental Assessment, Cameron LNG Export Project (Docket No. CP10-496).
4-93 Land Use, Recreation, And Visual Resources

Expansion would result in minor, short-term impacts on recreational boating and fishing in the 

channel and the waterway, with most of the impacts occurring during the first 10 months of 

construction.

As described above, Cameron has not requested an increase in LNG carrier traffic or a 

change in the size or quantity of ships that are currently authorized at the existing LNG 

Terminal. During operation, the potential impacts on recreational boating and fishing would not 

increase above the impacts addressed in our previous EIS and EAs for the existing Cameron 

LNG Terminal.

4.8.4.2 Pipeline Expansion

Cameron Interstate would construct its Pipeline Expansion near several recreation areas, 

including U.S. Highway 171 (a scenic highway), two Louisiana Natural and Scenic Rivers, Sam 

Houston Jones State Park, Holbrook Park, and private hunting areas (figure 4.8-2). Potential 

visual impacts on these areas are discussed in section 4.8.6.

U.S. Highway 171 is a scenic highway that follows the western border of Louisiana from 

north to south. The pipeline would cross U.S. Highway 171 in Beauregard Parish at MP 15.5. 

Cameron Interstate would cross the highway using the conventional bore construction method to 

avoid direct impacts on the highway and transportation. 

The pipeline route would cross two Louisiana Natural and Scenic Rivers in Calcasieu

Parish (Beckwith Creek at MP 9.0 and Hickory Branch at MP 10.3). Cameron Interstate would 

cross both waterbodies by the HDD construction method to avoid impacts on the bed and banks 

of the waterbodies. 

Sam Houston Jones State Park is approximately 5 miles southeast of the proposed 

pipeline in Calcasieu Parish. Recreational activities at this park include boating, fishing, birding, 

hiking, and camping. Holbrook Park is in Sulphur, Louisiana, approximately 1.5 miles southeast 

of MP 8.4. Holbrook Park has a public boat ramp, tent and RV camp sites, playground, picnic 

area, and a pavilion. Because of the distance between the construction right-of-way and these 

parks, we believe Cameron Interstate would avoid direct park impacts.

There are hunting lands managed in cooperation with the LDWF for deer, goose, turkey 

and pheasant near the proposed compressor station site, and the proposed pipeline route extends 

through private hunting lands between MP 10.4 and MP 12.1. To limit impacts on hunters, 

Cameron Interstate would schedule pipeline construction through these areas to avoid the 

hunting season where practicable.
Land Use, Recreation, And Visual Resources 4-94

Figure 4.8-2 Recreational Facilities Near the Pipeline Expansion
4-95 Land Use, Recreation, And Visual Resources

4.8.4.3 Indirect Project Impacts on Public Parks

During construction of the pipeline and the Terminal Expansion, most non-local workers, 

and in some cases their families, would reside primarily in Calcasieu and Beauregard Parishes 

(see section 4.9.5). Cameron LNG anticipates that up to 130 permanent employees would be 

hired to operate the Terminal Expansion facilities, and the Pipeline Expansion would require 5 

new permanent employees. It is likely that some workers and/or their families would visit 

nearby parks in those parishes, or visit parks in Cameron Parish, resulting in indirect impacts. 

However, there is a large inventory of recreation areas in the three parishes spread over a large 

geographic area, and although some facilities may be stressed due to use by workers and/or their 

families, we believe that the overall impact on these facilities would not be significant. 

4.8.5 Visual Resources

4.8.5.1 Terminal Expansion

The primary existing structures in the viewshed of the proposed terminal site include the 

existing Cameron LNG Terminal, oil and gas production facilities, electric transmission line 

towers, and storage tanks. The viewshed also includes the Calcasieu Ship Channel east of the 

proposed site; open land and wetlands to the north, west, and south; and LA-27, which is part of 

the Creole Nature Trail. 

Construction of the Terminal Expansion would increase traffic on LA-27, which would 

affect the views of those using the highway. These changes to the visual character of the area 

during construction that highway users could observe include increased equipment, vehicles, 

workers, and structures on the Terminal Expansion site. The portion of the Creole Nature Trail 

that borders the proposed Terminal Expansion site represents only a small portion of the 180 

miles of the Creole Nature Trail, and those traveling along the highway would have a short time 

to view the site during construction. In addition, Cameron LNG would construct its expansion 

adjacent to the existing Cameron LNG Terminal, and views would be consistent with the 

existing industrial area. The impact on visual resources during construction would be short term 

due to the presence of workers and equipment for the approximately 4-year construction period, 

but the impacts of the facilities would be permanent as discussed below. 

The expanded terminal would include many aboveground structures that could result in a 

visual resource impact. These include three liquefaction trains, a new LNG storage tank, an 

NGL storage and truck loading area, a work dock, a vapor fence, and flare structures. In 

addition, most of these structures would require lighting. Cameron LNG would site about 13 

percent of the Terminal Expansion within the existing Cameron LNG Terminal site, while 

constructing the remaining portions north of and adjacent to the existing terminal. Table 4.8.5-1 

lists the primary equipment and structure of the Terminal Expansion along with the heights 

above ground level. 
Land Use, Recreation, And Visual Resources 4-96

TABLE 4.8.5-1

Major Structures of the Terminal Expansion

Structure Number Length (feet) Width (feet) Height (feet)

Storage Tanks

LNG Tank 1 260.0 (dia) - 170.0

Condensate Storage Tanks 2 90.0 (dia) - 55.0

Piperacks

Main Piperack w/ air coolers 1/train 700.0 100.0 80.0

Turbines

Frame 7 Turbine Enclosure 2/train 60.0 40.0 60.0

Frame 7 Exhaust Stacks 2/train 15.0 (dia) - 250.0

Flares

Flare Derrick Structure 1 45.0 45.0 420.0

Flare (Operational) 1 2.0 - 200.0

Other

Amine Absorber 1/train 17.0 (dia) - 95.0

Amine Regenerator 1/train 15.0 (dia) - 110.0

Main Cryogenic Heat Exchanger 1/train 17.0 (dia) 150.0

Dia = diameter

The proposed Terminal Expansion site is surrounded primarily by open land, wetlands, 

and industrial lands. Gresham et al. (2002) conducted an Aesthetic Viewshed Study prior to 

Cameron LNG’s construction of the existing LNG Terminal. The study assessed potential visual 

impacts from three viewpoints: a residence 0.5 mile north of the LNG Terminal, a residence 

approximately 1.5 miles south of the terminal, and a residential area 4.0 miles to the east, on the 

opposite side of Lake Calcasieu. The residence 0.5 mile from the existing Cameron LNG 

Terminal was acquired by Cameron and is within the proposed Terminal Expansion boundary. 

Therefore, we did not consider the reported potential impacts from that viewpoint in our 

assessment. 

Gresham et al. (2002) noted that the LNG Terminal facilities would be visible from the 

residential viewpoints 1.5 miles away and 4.0 miles away, which suggests that the proposed 

facilities would also be visible from those viewpoints. The existing LNG storage tanks range in 

height from 168 feet to 192 feet. Cameron LNG would construct the new LNG storage tank 

within the existing terminal and adjacent to existing LNG storage tanks. The new tank would 

have a height of 170 feet, which is within the range of the existing tanks and would limit the 

observable overall change to the viewshed. All other facilities would result in enlarging the 

industrial viewshed of an area that is currently forest, wetlands, open land, and open water. The 

proposed facilities range in height from 18 feet to a maximum of 420 feet for a flare structure 

(table 4.8.5-1). However, we believe the proximity of the proposed structures to the existing 

industrialized area would lessen the overall impact, as would the existing oil and gas production 
4-97 Land Use, Recreation, And Visual Resources

facilities, electric transmission line towers, and storage tanks. In the previous viewshed analysis, 

Graham et al. (2002) stated that the viewers at the residence across the ship channel, 4.0 miles 

away, could see the LNG storage tanks, but that the gray color of the tanks would lessen their 

visual impact, and soil piles along the ship channel would partially screen the tanks and project 

facilities as would passing ships. Those conditions would also lessen the visual impact of the 

proposed Terminal Expansion on viewers in that area. 

As stated in the draft EIS, Cameron LNG planned to install a 20-foot-high vapor fence

along the Terminal Expansion property boundary adjacent to LA-27. However, Cameron LNG

and its engineering contractor re-evaluated the requirement for vapor fences and Cameron LNG 

provided a revision to the design in its February 20, 2014 filing on the draft EIS (comment letter 

AP1 in Appendix L). The redesign reduced the length of the fences from about 9,000 feet to 

about 1,500 feet, eliminating over 80 percent of the fencing, and the fences would be adjacent to 

the existing Cameron LNG Terminal (see figures 2.0-2 and 4.12-1). Views from LA-27 in that 

area are dominated by the existing LNG storage tanks and other facilities of the terminal, and the 

change in the design of the vapor fences substantially decreased the visual impact of the fence. 

In the draft EIS we recommended that Cameron LNG provide a plan to install and 

maintain vegetative screening between LA-27 and the vapor fence. Cameron LNG provided 

several reasons why a vegetative barrier would not be appropriate within the existing terminal or 

in the area adjacent to the property boundary along the fence line. Specifically, Cameron LNG 

stated the following:

• it does not want trees, shrubs, or other combustible vegetation planted within the 

terminal;

• any vegetative screening would have to be installed at the base of the storm surge 

barrier which could interfere with security fencing and/or surveillance; and

• it would be difficult to install and maintain effective vegetative screening between 

LA-27 and the vapor fence due to the low elevation in this area that is tidally 

influenced. This environment generally supports scrub/shrub or marsh vegetation 

which would have limited use as screening. This is further compounded by the 

fact the terminal’s storm surge barrier is elevated and is 9 feet higher than the area 

adjacent to LA-27.

However, Cameron LNG proposed to construct aesthetically pleasing vapor fences, 

similar to the concrete sound barriers used along highways near residential areas, We believe that 

Cameron LNG’s justification for not using a vegetative buffer, use of its proposed mitigation 

measure, and the greatly reduced length of the fence would reduce visual impacts of the vapor 

fence to the extent practicable and would not be significant. Therefore, we eliminated the 

recommendation from this EIS.

Operation of the Terminal Expansion would also result in visual impacts on those 

traveling along LA-27, which is the Creole Nature Trial. As for construction, those traveling 

along the highway would have a short time to view the site, and views of the expanded terminal 

would be consistent with views of the existing adjacent Cameron LNG Terminal. 
Land Use, Recreation, And Visual Resources 4-98

Overall, we believe the expanded terminal would result in minor impacts on the viewshed 

during construction and operation. LA-27 travelers would have the greatest visual impacts. 

However, those viewers would only be impacted for the brief time they are driving in the vicinity 

of the site and the views would be similar to those of the existing Cameron LNG Terminal. As a 

result, we believe that operation of the Terminal Expansion would not result in a significant 

impact on visual resources. 

The existing Cameron LNG Terminal includes outdoor lighting that consists primarily of 

downlighting for safety and lights on tall structures for aircraft warnings. Cameron LNG would 

operate similar lighting on the expanded terminal during operation. In addition, viewers of the 

existing terminal are occasionally able to see flares at night, and that would also be the case for 

the expanded terminal. The viewshed for the expanded terminal extends as far as 4.0 miles from 

the site. Most of the viewers of night lights in that area would consist of motorists along LA-27 

and other roadways, boaters in the channel, residents at their homes, and viewers from a variety 

of locations in the viewshed. However, the lighting of the expanded terminal would appear 

similar to the existing terminal, although across a greater area. Viewers familiar with the 

nighttime appearance of the existing terminal may notice a larger lit area. Although the lighting 

would be obvious throughout the viewshed and slightly different in size than the currently lit 

area, it would be similar to the lighting of oil and gas facilities throughout the area. We believe 

the impact of night lighting on visual resources would not be significant. 

4.8.5.2 Pipeline Expansion

Cameron Interstate’s right-of-way vegetation clearing would cause the primary impact on 

visual resources during construction and operation of the pipeline and associated facilities. To 

minimize visual impacts, the entire proposed right-of-way would parallel existing permanent 

rights-of-way, which avoids development of a new corridor. This would limit the extent of 

changes in the viewshed. However, clearing of forested lands within the construction right-ofway, and maintaining the permanent right-of-way as herbaceous and scrub/shrub vegetation 

types would change the viewscape for viewers in the area. We believe the impact would not be 

significant because the increase in width of the right-of-way would be difficult to discern, and 

there would be few observers of the change. Cameron Interstate would allow all other forested 

lands to revert to pre-construction conditions, although it could require 20 to 40 years to reach 

that stage, resulting in long-term visual impacts in those areas. 

In addition to clearing of vegetation, construction of the pipeline and associated facilities 

would require the presence of personnel, large construction equipment, and vehicles, all of which 

could be visible in areas accessible to the public, such as at roadways crossed by the route and 

near residences. Cameron Interstate identified one residence and one unoccupied trailer within 

50 feet of the construction right-of-way. In addition, three other residences are within 135 feet of 

the construction right-of-way. Visual impacts in these areas due to the presence of construction 

equipment and personnel would be temporary. Therefore, we believe those visual impacts would 

not be significant. 

U.S. Highway 171 is a scenic highway that Cameron Interstate would cross using a 

conventional bore to avoid impacts on the highway and traffic. The land use in this area is open 

land, and the construction equipment and personnel would be visible to motorists on the highway 
4-99 Land Use, Recreation, And Visual Resources

in the vicinity of the right-of-way. These impacts would be temporary and minor due to the brief 

period of potential observation by motorists. 

The pipeline route would cross two Louisiana Natural and Scenic Rivers in Calcasieu 

Parish. Cameron Interstate would cross both waterbodies by the HDD method to avoid impacts 

on the bed or banks. Additionally, Cameron Interstate would set the HDD entry and exit 

workspaces back at least 400 feet from each waterbody. Although most viewers would not see 

the right-of-way from the waterbodies or the construction equipment on the right-of-way, it is 

possible that portions of the drilling equipment would be visible from some locations. We 

believe this temporary visual impact would not be significant due to the small change in 

viewscape. 

The proposed Holbrook Compressor Station is on an undeveloped pine plantation parcel 

of land. The major structure at the compressor station would be the compressor buildings, which 

would be about 40 feet tall. The area surrounding the proposed compressor station site is mainly 

forested and currently being used for silviculture. The closest roadway to the proposed 

compressor station is Holbrook Park Road, approximately 1,500 feet from the site. The area 

surrounding the proposed compressor station is largely forested and would provide visual 

screening of the compressor station from the roadway. We believe the visual impacts from

construction would be temporary and minor. 

Cameron Interstate would limit outdoor lighting for the compressor station to 

downlighting for safety during normal operation. The area surrounding the compressor station is 

largely forested and the closest residence is 0.6 mile from the site and only one other residence is 

within 1 mile of the site. Therefore visual receptors would be limited. In addition, the low level 

of light produced by downlighting would not be visible from long distances. As a result, the 

nighttime appearance of the compressor station would not have a significant impact on visual 

resources. Although the visual impacts during operation would be permanent, we believe they 

would not be significant due to the rural nature of the compressor station’s location, distance 

from the roadway, downlighting, and forested screening. 

4.8.6 Coastal Zone Management

The Louisiana CZMP is administered by the LDNR. The inland extent of the coastal 

zone boundary is defined by the Gulf Intracoastal Waterway. Within the coastal zone, areas are 

divided into Environmental Management Units by the LDNR. The LDNR evaluates activities or 

development affecting land within Louisiana’s coastal zone for compliance with the CZMA 

through a process called “federal consistency.” Almost half of the proposed Terminal Expansion 

site is within the designated coastal zone. 

The dredging for and building of a work dock for the existing terminal was approved by 

the Commission as part of a previously proposed expansion of the Cameron LNG Terminal.36 

Although the dock was not constructed, LDNR had issued a CUP and a dredge permit for that

portion of the project, and the dock could have been constructed under the previous consistency 

determination. LDNR issued a Modified Maintenance Dredge Permit for the proposed Project 

on November 20, 2013, and an amended CUP and consistency determination for the currently 

 36 Cameron LNG Terminal Expansion EA (docket no. CP06-422)
Socioeconomics 4-100

proposed Project January 21, 2014 (see table 1.5-1). In addition to the work dock, the CUP 

includes the remainder of the Terminal Expansion within the coastal zone. The proposed 

Pipeline Expansion is not within the jurisdiction of the CZMP. 

The Project would not impact either wetland reserve program or conservation reserve 

program lands.

4.9 SOCIOECONOMICS

Construction of the Project could impact socioeconomic conditions, either adversely or 

positively, in the general vicinity of the Project. These potential impacts include alteration of 

population levels or local demographics, increased employment opportunities, increased demand 

for housing and public services, transportation impacts, and an increase in government revenue 

associated with sales and payroll taxes. The potential socioeconomic impacts of Project 

operation include employment opportunities, ongoing local expenditures by the operator, an 

increased tax base, and an increase in the demand for public services. 

The Project would include facilities in three parishes: the Terminal Expansion in 

Cameron and Calcasieu Parishes; and the Pipeline Expansion in Calcasieu, and Beauregard 

Parishes. For the purposes of our socioeconomic analysis, these three parishes are defined as the 

“Project area.”

In accordance with Executive Order 12898 on Environmental Justice, all public 

documents, notices, and meetings were made readily available to the public throughout the 

Cameron Liquefaction Project area during our review of the Project. The mailing list for the 

Project has been continuously updated during the EIS process. The public has been notified of 

all official proceedings regarding the Project with the issuance of the NOI and the scoping 

meeting we held in the Project area. Section 1.3 of this EIS further describes the public 

participation and notification process. 

Cameron Interstate would collocate the majority of the Pipeline Expansion with existing 

linear and facility infrastructure, with the remaining portion of the pipeline route parallel and 

close to other existing linear facilities. Therefore, routing was not selected to disproportionately 

impact low income or minority populations. Further, the Project would not significantly impact 

urban or residential areas nor would there be disproportionately high and adverse human health 

or environmental effects on minority, low-income communities, or Native American tribes 

because none have been identified. 

4.9.1 Population

Table 4.9.1-1 provides a summary of selected population and demographic information

for the Project area. 
4-101 Socioeconomics

TABLE 4.9.1-1

Existing Socioeconomic Conditions in the Project Area

State/ Parish

Population Population Density

(per square mile)

Per Capita 

Income

Civilian 

Labor Force

Unemployment 

Rate (percent)

Top Two Major 

Industries a

2000b 2010c 2000 b 2010c 2010 c July 2013d July 2013 d 2010e

Cameron 9,991 6,839 7.6 5.3 $24,634 3,214 6.2

1. Management, 

Business, and Science

2. Retail Trade

Calcasieu 183,577 192,768 171.4 181.2 $23,591 95,953 6.4

1. Entertainmentf

2. Retail Trade

Beauregard 32,986 35,654 28.4 30.8 $21,543 14,632 8.4 1. Manufacturing

2. Retail Trade

Louisiana 4,468,976 4,533,372 102.6 104.9 $23,094 2,123,336 7.1

1. Retail Trade

2. Entertainmentf

a Excludes Education and Health Service industry. b From U.S. Census Bureau (2000) c From U.S. Census Bureau (2010a) d From Louisiana Workforce Commission (2013) e From U.S. Census Bureau (2010b) f Entertainment refers to the Entertainment Accommodation and Food Services industry.
Socioeconomics 4-102

4.9.1.1 Terminal Expansion

The U.S. Census Bureau (2010a) reported that in 2010, the population of Cameron Parish 

was 6,839, with a population density of 5.3 persons per square mile. Calcasieu Parish was 

considerably more populated, with a 2010 population of 192,768 and a population density of 

181.2 persons per square mile. The average population density for Louisiana in 2010 was 104.9 

persons per square mile.

Cameron LNG anticipates full construction of the Terminal Expansion to begin in 2014, 

and be completed in 2018. Cameron LNG estimates a peak construction workforce of about 

3,500 workers over a time span of about 6 months, with an average workforce of about 2,300 

workers per month. Cameron LNG anticipates hiring many of these workers locally; non-local 

personnel are expected to be highly skilled tradesmen. However, to present a worst-case 

assessment for this EIS, we have assumed all workers would be non-local. 

The peak construction workforce could represent a sizeable increase to the local 

population if all 3,500 workers were housed within Cameron Parish. However, non-local 

workers would likely find housing in Cameron and Calcasieu Parishes. As discussed in section 

4.9.5, the majority of available transient housing is in Calcasieu Parish, with most of the housing 

within 15 to 25 miles of the proposed Terminal Expansion site. 

The 2010 Census data for Louisiana indicate that the average family size in the state is 

2.6 persons (U.S. Census Bureau 2010a). If all non-local workers move to the Terminal 

Expansion area with their families, up to 9,135 people may relocate to Cameron and Calcasieu 

Parishes during construction of the Terminal Expansion. Although it is not likely that all 

workers would be non-local, and it is unlikely that all workers would bring families, an increase 

of 9,135 people would result in a 4.7 percent increase in the population of Calcasieu Parish for 

the peak 6 months of construction. For the remainder of the construction period, the population 

could increase by about 6,000 people if all workers were non-local and brought families. 

Cameron LNG anticipates hiring up to 130 permanent employees to operate the expanded 

terminal. This workforce and their families would represent a minor but permanent increase in 

the population in the vicinity of the Terminal Expansion. 

4.9.1.2 Pipeline Expansion

The proposed pipeline route traverses two Parishes: Calcasieu and Beauregard. Calcasieu 

Parish is described above. Beauregard Parish is more populated than Cameron, but less 

developed than Calcasieu, with a population of 32,986 and a population density of 30.8 persons 

per square mile (U.S. Census Bureau 2010a). 

Cameron Interstate anticipates construction activities for the Pipeline Expansion to begin 

in 2014, with an in-service date of 2017. The construction workforce would consist of 

approximately 270 workers for the compressor station and 200 workers for the pipeline. 

Cameron Interstate estimates a local workforce of 20 to 40 percent who would commute to the 

work sites daily. However, if all workers are non-local and if each worker brings 2.6 family 

members, the temporary population would increase by about 1,230 individuals. As described in 

section 4.9.5, those workers would likely reside in Calcasieu and Beauregard Parishes, a 0.5 
4-103 Socioeconomics

percent increase in the combined population of the parishes. That would represent a minor 

population increase in the vicinity of the Pipeline Expansion. 

Cameron Interstate anticipates hiring five new permanent employees to operate the 

Pipeline Expansion. This would represent a negligible increase in the local population in the 

vicinity of the Pipeline Expansion. 

4.9.1.3 Combined Terminal and Pipeline Expansion Impacts 

Construction of the Terminal Expansion and Pipeline Expansion would coincide for a 

period of 12 to 18 months. For this period, the combined construction workforces would range 

from 2,700 to 3,900 workers, depending on when the workforce for the Terminal Expansion 

peaks. The total population for the three parishes in the Project area is approximately 235,000. 

Assuming all workers are non-local and would be accompanied by 2.6 family members, the 

population increase could be between 7,047 and 10,179 for a 6-month period. This would 

represent a potential 3.0 to 4.3 percent increase in the population of the Project area, which is a 

minor increase. 

Operation of the Project would require a permanent workforce of 135 new employees. 

This would represent a minor permanent impact on the local population. 

4.9.2 Economy and Employment

Table 4.9.2-1 provides selected employment and income statistics for the Project area. 

The main employment sectors in Cameron Parish are management, business, scientific, 

administrative, and retail trade. In Calcasieu Parish the main employment sectors are 

entertainment and retail trade (U.S. Census Bureau 2010b). 

TABLE 4.9.2-1

Employment and Income Characteristics of the Project Area

Major Industry (2010) a, b

Louisiana Cameron Parish Calcasieu Parish Beauregard Parish

Retail Trade

Management, 

Business, Scientific, 

and Administrative

Entertainment, 

Accommodation 

and Food services

Manufacturing

2006-2010 Civilian Labor 

Force c 2,116,794 3,632 92,007 15,123

2006-2010 Per Capita 

Income (dollars) a 23,094 24,634 23,591 21,543

2006 - 2010 Population 

below poverty level 

(percent) a 18.1 11.6 16.2 13.2

July 2013 Unemployment 

Rate (percent) c 7.1 6.2 6.4 8.4

a From U.S. Census Bureau (2010a)

b Excludes Education and Health Service industry.

c Louisiana Workforce Commission (2013)
Socioeconomics 4-104

4.9.2.1 Terminal Expansion

The civilian labor force is defined as the sum of employed persons and those searching 

for work. As of July 2013, the civilian labor force numbered 3,214 persons in Cameron Parish 

and 95,953 in Calcasieu Parish. Per capita income is roughly the same for both parishes 

($24,634 in Cameron Parish - and $23,591 in Calcasieu Parish), and both are above the state’s 

average per capita income of $23,094. 

Cameron Parish has an unemployment rate of 6.2 percent, with 11.6 percent of the 

population below the poverty line. Calcasieu Parish has an unemployment rate of 6.4 percent, 

and 16.2 percent of the population is below the poverty line. Both parishes have lower 

unemployment rates than the state of Louisiana, which has an unemployment rate of 7.1 percent. 

In addition, both parishes have a smaller percentage of the population that is below the poverty 

level compared to Louisiana’s 18.1 percent.

During the proposed construction, Cameron estimates a total payroll for the Terminal 

Expansion of about $657 million. Construction of the Terminal Expansion would increase 

economic activity within the area in several ways: 

• a direct effect – hiring of local construction workers and purchases of goods and 

services from local businesses; 

• an indirect effect – the additional demand for goods and services, such as 

replacing inventory from the firms that sell goods and services directly to the 

project or to workers and their families; and 

• an induced effect – the spending of disposable income by the construction 

workers at local businesses, which in turn order new inventory from their 

suppliers. 

The increase in economic activity resulting from the sum of these three effects would 

result in a temporary positive economic impact in the Terminal Expansion area.

Anticipated operational expenditures include $10.4 million per year in salaries, or 

approximately $80,000 per worker per year. As this is well above the average income for the 

area, we conclude that the permanent workforce associated with the Terminal Expansion would 

result in a minor, but positive permanent impact on the local economy.

4.9.2.2 Pipeline Expansion

The manufacturing and retail trade sectors are the major employers in Beauregard Parish 

(U.S. Census Bureau 2010b). Employment and income information for Calcasieu Parish is 

described above.

As of July 2013, the civilian labor force was 14,632 persons in Beauregard Parish 

(Louisiana Workforce Commission 2013). Beauregard Parish has a per capita income of 

$21,543, which is lower than the other parishes in the Project area (U.S. Census Bureau 2010a). 

Beauregard Parish had an unemployment rate of 8.4 percent in of July 2013, with 13.2 

percent of the population below the poverty line. All three parishes have a smaller percentage of 
4-105 Socioeconomics

their population below the poverty line than Louisiana, but only Cameron and Calcasieu have a 

lower unemployment rate as well.

As with the Terminal Expansion, in addition to the direct employment and payroll 

impacts generated by the Pipeline Expansion, dollars spent on goods and services would have 

minor, positive direct, indirect, and induced economic impacts on the Project area during the 

construction period.

Operation of the pipeline would require five new permanent employees. These 

permanent positions would result in a negligible positive impact on the local economy. 

4.9.3 Local Taxes and Government Revenue

4.9.3.1 Terminal Expansion

Cameron LNG estimates spending $637 million on construction goods and services in the 

Terminal Expansion area during construction of the Terminal Expansion. This would generate 

increased local, state, and federal sales tax revenue in Cameron, Calcasieu, and Beauregard 

Parishes. The expenditures on goods and services by the construction workforce and the families 

of the workers would also generate increased tax revenues. In addition, local, state, and federal 

governments would tax the $657 million in total workforce payroll. This increase in tax revenue 

would be a minor, temporary, positive impact on the tax revenue in the Terminal Expansion area. 

After construction, Cameron LNG would pay parish property taxes on its Terminal 

Expansion facilities and equipment. There also would be long-term increases in sales tax 

revenue from expenditures on materials, goods, and services by Cameron LNG and the 

operational workforce. 

Based on the present tax laws and Cameron LNG’s assumed Terminal Expansion life of 

20 years, Cameron LNG estimated that the total property tax paid to Cameron and Calcasieu 

Parishes would be $1.5 billion.

4.9.3.2 Pipeline Expansion

As for the Terminal Expansion, expenditures by Cameron Interstate, workers, and the 

families of workers during construction would increase tax revenues in the Pipeline Expansion 

area. This would be a minor, temporary, positive impact on the tax revenue in the Pipeline 

Expansion area. 

Operation of the pipeline would also have a positive effect on local property tax revenue 

based on Cameron’s tax projections of about $86.5 million over the life of the pipeline. 

4.9.4 Housing

Table 4.9.4-1 provides data on the local rental and other temporary housing options in the 

Project area. According to the U.S. Census Bureau (2010c), vacant housing units in Cameron 

Parish totaled 1,018 units; of these, 62 units were rentals and 779 were for seasonal, recreational, 

or occasional use. In Calcasieu Parish, vacant housing units totaled 8,062 units; of these, 3,015

units were rentals and 726 were for seasonal, recreational, or occasional use. There are also 85 

hotels/motels in Calcasieu Parish that could be used by any of the short-term workforce 
Socioeconomics 4-106

(HotelMotels 2013). In 2010, there were approximately 9,080 total vacant housing units in the 

Terminal Expansion area. In Beauregard Parish, vacant housing units totaled 1,881 units. Of 

these, 250 were rentals and 514 were for seasonal, recreational, or occasional use (U.S. Census 

Bureau 2010c). There are about 8 recreational vehicle (RV) parks in Calcasieu Parish, which 

contain over 470 RV spaces. There are no RV parks in Beauregard Parish, and there are two RV 

parks located in Cameron Parish, which contain over 19 spaces (Louisiana RV Parks 2013; 

Hidden Ponds RV Park 2013). 

TABLE 4.9.4-1

2010 Housing Characteristics of the Project Area 

State/Parish

Total

Housing

Units a

Vacant 

Housing 

Units a,b

Vacant 

Housing 

Units for 

Rent a,b,c

Other 

Vacant 

Units a,c

For Seasonal, 

Recreational, or 

Occasional Use a,b

Hotels/

Motels c

Rental 

Vacancy 

Rate 

(percent) a

Cameron 3,593 1,018 62 139 779 7 16.3

Calcasieu 82,058 8,062 3,015 3,187 724 85 11.8

Beauregard 15,040 1,881 251 883 513 10 8.0

Louisiana 1,964,981 236,621 66,857 95,464 42,253 1,875 10.5

a U.S. Census Bureau (2010c)

b Housing Definitions (US Census Bureau 2010c)

Vacant Housing Unit – A housing unit is vacant if no one is living in it at the time of enumeration

Vacant Units for Rent – Vacant units offered “for rent” and vacant units offered either “for rent or for sale”

For Seasonal, Recreational, or Occasional Use – Vacant units used or intended for use only in certain seasons or for 

weekends or other occasional use throughout the year.

Other Vacant Units – If a vacant unit does not fall into any of the classified categories, it is classified as “other vacant”. For 

example, this category includes units held for occupancy by a caretaker or janitor, for migrant workers, and for personal 

reasons of the owner. 

c HotelsMotels 2013

4.9.4.1 Terminal Expansion

As stated previously, Cameron LNG anticipates local residents would comprise a portion 

of the workers hired for construction of the Terminal Expansion. However, for the purpose of 

this analysis, we have assumed all 3,500 workers in the peak construction workforce would be 

non-local. The proposed Terminal Expansion site extends into southern Calcasieu Parish and 

much of the parish would be easily accessible to workers. Calcasieu Parish has the most vacant 

transient housing units that would be available to the workforce, including vacant units for rent 

and those for seasonal, recreational, and occasional use (about 3,700 units) as well as rooms at 

85 hotels and motels (table 4.9.4-1), and it is likely that the majority of the workforce would be 

housed there. In addition, a portion of the 3,187 “other vacant” units in Calcasieu Parish may 

also be available for use by the workforce. Overall the three parishes have 3,328 vacant units for 

rent, along with 2,016 “seasonal” units, 4,209 “other vacant” units, and 102 hotels and motels. 

The currently available transient housing in Cameron, Calcasieu, and Beauregard Parishes is 

sufficient to accommodate the maximum peak workforce for the terminal along with families of 

the workers who chose to bring their families. Housing of those workers and family members 

would result in a moderate, temporary impact on housing availability in the Project area that 
4-107 Socioeconomics

would last about 6 months. Outside of the time when the workforce peaks, the impact on 

transient housing would be minor, even assuming all 2,300 workers bring their families. Overall, 

we believe construction of the proposed Terminal Expansion would not result in significant 

impacts on transient housing availability in the area.

We believe the addition of 130 permanent staff required to operate the expanded terminal 

would have, at most, a minor permanent impact on local housing markets.

4.9.4.2 Pipeline Expansion

Cameron Interstate anticipates local hires would comprise 20 to 40 percent of the peak of 

470 workers for the Pipeline Expansion. Those workers would commute daily from their homes 

to the construction right-of-way or the compressor station site. However, for the purposes of this 

assessment, we considered the worst-case scenario, with all 470 workers being non-local and 

requiring temporary housing. Based on the number of available rental housing units and 

hotels/motels in Calcasieu and Beauregard Parishes as discussed above, adequate housing exists 

to accommodate those workers and their families. Use of 470 housing units in Calcasieu and 

Beauregard Parishes would result in a minor, temporary impact on transient housing in those 

parishes. Overall, construction of the proposed Pipeline Expansion would not result in 

significant impacts on transient housing in the area.

Operation of the pipeline would require five new permanent employees who would 

relocate to the Pipeline Expansion area. These new employees would represent a negligible 

decrease in available permanent housing. 

4.9.4.3 Combined Terminal and Pipeline Expansion Impacts 

Construction of the Terminal Expansion and Pipeline Expansion may coincide for a 

period of 12 to 18 months. For this period, the combined construction workforces would range 

from 2,700 to 3,900 workers, depending on when the workforce for the Terminal Expansion 

peaks. As noted above, there is sufficient vacant transient housing in Cameron, Calcasieu, and 

Beauregard Parishes (about 9,500 units, including all categories, plus rooms in 102 hotels and 

motels) to accommodate the construction workforce peak, assuming some workers would be 

housed in the vacant “seasonal” and “other” units (as defined in table 4.9.4-1) and in the rooms 

available in the 102 hotels and motels in the parishes. The impact on transient housing 

availability would last no more than 6 months and would not be significant. 

Operation of the Project would require 135 permanent employees who would relocate to 

the area. These new employees would represent at most a minor impact on housing. 

4.9.5 Public Services

Table 4.9.5-1 summarizes local community public services in the Project area. 
Socioeconomics 4-108

TABLE 4.9.5-1

Public Service Data for the Project Area

Parish

Education Public Safety Healthcare

Number of 

Public 

Schools a

Total 

Enrollment 

2011-2012 a

Number of 

Police 

Departments b

Number of 

Fire 

Departments c

Number of 

Hospitals d

Number of 

Hospital 

Beds d

Cameron 4 1,313 1 6 1 49

Calcasieu 60 32,612 8 18 9 904

Beauregard 12 6,043 3 5 1 60

a From Louisiana Department of Education 2013

b From Capital Impact Government Gateway 2013

c From Louisiana Office of State Fire Marshal 2013

d From Louisiana Hospital Association 2013

Note: Hospitals do not include rehabilitation, long term, and psychiatric hospitals.

4.9.5.1 Terminal Expansion

Cameron and Calcasieu Parishes have 64 public schools with a 2011 to 2012 enrollment 

of 33,925 students. There are eight hospitals in Cameron and Calcasieu Parishes with a total of 

771 beds. Cameron Parish has one sheriff’s department and six fire departments. Calcasieu 

Parish has eight police departments, and 18 fire departments.

The peak construction workforce of 3,500 workers is anticipated to last 6 months. If all 

of these workers relocate to the Pipeline Expansion area with two children each, local school 

system enrollment would increase by 7,000 students, or an increase of 20.6 percent. However, 

Cameron would not employ many of the workers for the full duration of construction, and it is 

unlikely that those workers would relocate with their children. For the average workforce of

2,300 and assuming two children per worker, school enrollment could increase by 4,600 

students, or 13.6 percent. We believe this represents the worst-case scenario, resulting in 

moderate, temporary impacts on the schools. However, many construction workers do not have 

families or would not relocate their families while they work on the Terminal Expansion. 

Additionally, Cameron LNG estimated local workers would account for about 20 percent of the 

workforce based on construction of the existing terminal. As a result, the impacts on schools in 

the Project area would likely be much less than estimated.

During operation of the expanded terminal, the 130 permanent workers would not likely 

cause any adverse impact on local schools. If all 130 permanent workers have two children, this 

would result in 260 additional children in local parish school systems. Combined, this addition

would represent less than a 0.1 percent increase in total enrollment across these school districts,

with students spread out over many grade levels. As a result, we believe no adverse impacts 

from operation of the expanded terminal would occur on the parish’s school districts.

During construction, enforcement and support activities associated with permitted large 

vehicle loads and widths could increase, workplace injuries may require emergency medical 

services, and periodic police services could be required. Local fire departments participate in a 
4-109 Socioeconomics

regional mutual aid program that provides emergency assistance to many petro-chemical 

facilities in the area, are experienced with industrial incidents, and could assist in emergencies 

during construction. In addition, Cameron LNG would expand its existing LNG Terminal first 

responder group that supports local services, to respond to incidents at the expanded terminal, 

thus reducing the need for local public service assistance. Therefore, we believe impacts on 

public services during construction of the Terminal Expansion would be temporary and minor.

We believe Cameron LNG’s first responder group for the expanded LNG Terminal 

would minimize operation impacts on public services from the Terminal Expansion to less than 

significant levels. The 130 new permanent employees would represent a negligible impact on 

public services. 

4.9.5.2 Pipeline Expansion

Beauregard Parish has 12 public schools with a total of 6,043 students enrolled for the 

2011 to 2012 academic year. The Parish also has one hospital with 60 beds, three police 

departments, and five fire departments. Data on public services in Cameron and Calcasieu 

Parishes are provided above. 

We believe Cameron Interstate’s 470 construction workers would not likely bring family 

members to the area due to the pipeline’s relatively short construction period. Further, the 

temporary increase in population due to construction would be negligible compared to the 

current population in the area. As a result, we believe the Pipeline Expansion would minimally 

impact schools in the Pipeline Expansion area. Although it is likely that there would be some 

need for increased police, fire, and medical services during construction, those public services 

would experience only minor impacts during construction. 

Cameron Interstate’s five new permanent positions would represent a negligible increase 

in the local population. Therefore, we believe local services would not be impacted. 

4.9.6 Transportation

4.9.6.1 Terminal Expansion

Ground access to the existing Cameron LNG Terminal for deliveries of equipment and

materials, as well as for personnel, is provided by existing roads. The entrance to the existing 

terminal is situated off LA-27, which is a two-lane highway with a posted speed limit of 55 miles 

per hour. Based on Cameron LNG’s traffic studies (Neel-Schaffer 2012 and 2013), there are 

about 1,867 vehicles per day along the portion of LA-27 adjacent to the proposed site, with the 

roadway operating at a U.S. Department of Transportation (USDOT) Level of Service (LOS)-

A.

37

Construction would increase traffic substantially in the vicinity of the proposed Terminal 

Expansion site due to the presence of worker vehicles, construction vehicles, and trucks taking 

materials and equipment to and from the site. According to the 2013 traffic study (Neel-Schaffer 

 37 LOS is a letter designation that indicates a qualitative assessment of a road’s operating conditions and refers to 

a standard measurement used by transportation officials which reflects the relative ease of traffic flow on a 

scale of A to F, with free-flow being rated LOS-A and congested conditions rated as LOS-F (U.S. Department 

of Transportation 2013).
Socioeconomics 4-110

2013), construction work would likely occur during two work shifts, one from 6:00 a.m. until 

4:00 p.m. and the second between 5:00 p.m. and 3:00 a.m. There are two driveways at the 

Terminal Expansion Site that would be used to access the Terminal Expansion site. Cameron 

LNG would use the northern driveway for material deliveries and the driveway to the south for

employee access. During the peak of construction, approximately 3,500 employees would travel 

to the worksite. This would result in up to 1,750 commuter vehicles entering or exiting the site 

per shift. Material deliveries would also add vehicle traffic to LA-27. Neel-Schaffer (2013) 

indicated that there would be excessive delays of traffic at both driveway intersections during 

construction (USDOT LOS-E). That would result in a significant impact to traffic flow along 

LA-27 in the Terminal Expansion Area during peak shift hours. Neel-Schaffer (2013) 

recommended that uniformed traffic control be used during commuting times to reduce the 

impact, the same mitigation employed during construction of the existing Cameron LNG 

Terminal. Cameron LNG stated that it had not received complaints regarding traffic disruption 

during construction of the existing terminal. However, other measures may also be effective in 

reducing the impacts on traffic along LA-27 in the vicinity of the Terminal Expansion site. 

Therefore, we are recommending that:

• Prior to construction, Cameron LNG should file a traffic plan with the 

Secretary, for review and written approval by the Director of OEP, that 

includes the following:

a. uniformed traffic control at the access driveways of the Terminal 

Expansion site during construction commuting times; 

b. mass transportation to and from the Terminal Expansion site for 

construction workers, including the identification of locations for 

park-and-ride lots, and a schedule for plan implementation; and

c. a traffic study during construction to assess the DOT’s LOS. If the 

traffic study indicates a USDOT LOS of D or worse, Cameron LNG 

should implement additional mitigation measures to reduce traffic 

impacts.

Barges would deliver the majority of large equipment and materials, such as soil and rock 

fill, to the work dock during construction. This would reduce the number of truck trips to and 

from the Terminal Expansion site as well as the potential for damage to local roadways and 

traffic congestion. Cameron LNG would attempt to schedule deliveries outside of peak traffic 

hours, when possible, to reduce congestion. The greatest traffic congestion would occur in the 

vicinity of the site access points on LA-27, resulting in moderate delays over many months for 

local drivers. Because the majority of this increase would occur outside of commuting times for 

the construction workforce, it would not add substantially to the impact of the workforce 

traveling to and from the site each day. In addition, trucks and heavy construction equipment 

could damage local roadways. However, Cameron would repair any roadway damage that it 

causes.

Operation of the Cameron LNG Terminal would require a permanent workforce of 130 

employees who would commute to the site on a daily basis. This would result in a maximum of 

130 commuter vehicles entering the site and 130 commuter vehicles exiting the site per day, 

distributed over two work shifts. Therefore, up to 65 commuter vehicles would enter the site 
4-111 Socioeconomics

during the morning peak commuting hours and up to 65 commuter vehicles would exit the site 

during the evening peak commuting hours. Based on Cameron’s 2012 traffic impact study 

(Neel-Schaffer 2012), we believe this would not result in a significant impact on the existing 

traffic conditions along LA-27 in the vicinity of the Terminal Expansion site. 

Operation of the expanded terminal would increase truck traffic, including deliveries of 

refrigerant and other supplies and materials, as well as removal of condensate derived from the 

liquefaction process. However, it is not likely that the increase in traffic would be substantial, 

and we believe there would be a minor impact on local roads for the life of the Project. 

Marine Traffic Impacts

During construction of the Terminal Expansion, Cameron LNG would receive large 

equipment, bulk materials, and other supplies by barge at the proposed work dock on the 

Calcasieu Ship Channel. Barges would also use the existing dock on the Gulf Intracoastal 

Waterway near Old Highway 27. Most barges would likely travel the Gulf Intracoastal 

Waterway from the Port Arthur area to either the existing dock or to the confluence of the 

waterway with the channel and to the proposed work dock. Some barges may transit the channel 

from the Port of Port Charles and others travel up the channel from the Gulf of Mexico. The 

largest number of deliveries would occur at the beginning of construction (between months 2 and 

7) when about 275 barges per month, or about 9 barges per day assuming 30 delivery days per 

month, are anticipated. Barge deliveries would decrease to 150 per month (about 5 per day) 

during months 8 through 10, and there would be 125 barges per month (about 4 per day) from 

months 11 through 14. After that there would be about 10 barges per month (about 1 barge 

every 3 days) for the duration of construction. 

About 10 barges would stage in a common area on the Gulf Intracoastal Waterway every 

second day. That area is currently used as a barge staging area and Cameron LNG’s use of the 

area would not result in an increase in disruption to vessel traffic along the waterway. Full 

barges would be moved to the construction dock and empty barges moved back to the staging 

area.

Cameron LNG would construct the work dock about 375 feet from the western edge of 

the Calcasieu Ship Channel, and barges tied up at the work dock would not affect commercial or 

recreational vessel traffic in the channel. In the initial phases of construction, the additional 9 

barges per day may affect some recreational and commercial users of the channel, resulting in a 

minor, temporary, and we believe not significant, impact that would last for about 5 months. 

About 7 months after construction begins, barge traffic related to construction would represent a 

small increase in traffic in the channel, and we believe the impact would be minor and 

temporary. 

Because the size and number of LNG carriers would not change from those currently 

authorized, we do not anticipate any additional impacts from LNG carriers beyond the impacts 

identified in our previous EIS and EAs for the existing Cameron LNG Terminal.38 

 38 Hackberry EIS (Docket No. CP02-374), Cameron LNG Terminal Expansion EA (docket no. CP06-422), and 

Cameron LNG Export Project EA (docket no. CP10-496).
Cultural Resources 4-112

During operation of the expanded terminal, Cameron LNG would use the work dock to 

receive some deliveries for maintenance and operation, although most deliveries would be made 

by truck. This would result in a minimal increase in barge traffic and a minor impact on marine 

traffic in the channel.

4.9.6.2 Pipeline Expansion

Cameron Interstate would conventionally bore all paved public roads to prevent impacts 

on roadways and traffic during road crossings as discussed in section 2.6.3. Cameron Interstate 

would attempt to schedule construction activities to avoid traffic flow interruptions on dirt and 

gravel roads, which it proposes to open-cut. Delivery of pipe and other materials to the 

construction right-of-way, the storage yard, and the compressor station site, may result in some 

disruption of traffic; however, this temporary impact would occur primarily in the early stages of 

construction. 

The workforce of 270 personnel at the compressor station would access the work site 

from an existing access road off of Holbrook Park Road. Workers on the pipeline would 

commute to the construction right-of-way, and Cameron Interstate anticipates that most 

personnel would travel to and from the construction site outside of peak commuting hours. 

Therefore, we expect construction of the Pipeline Expansion to result in minor, temporary 

impacts on traffic flow by the construction workforce. 

Operation of the pipeline would not result in any significant impacts on traffic or 

roadways within the Project area.

4.10 CULTURAL RESOURCES

Section 106 of the NHPA, as amended, requires the FERC to take into account the effect 

of its undertakings on properties listed, or eligible for listing, on the NRHP and to afford the 

ACHP an opportunity to comment on the undertaking. Cameron LNG and Cameron Interstate, 

as non-federal parties, are assisting the FERC in meeting our obligations under Section 106 and 

the implementing regulations in 36 CFR 800 by preparing the necessary information, analyses, 

and recommendations, as authorized by 36 CFR 800.2(a)(3). 

Construction and operation of the Project could affect historic properties (that is, cultural 

resources listed or eligible for listing on the NRHP). Historic properties include prehistoric or 

historic archaeological sites, districts, buildings, structures, and objects, as well as locations with 

traditional value to Native Americans or other groups. Such historic properties generally must 

possess integrity of location, design, setting, materials, workmanship, feeling, and association, 

and must meet one or more of the criteria specified in 36 CFR 60.4.

4.10.1 Terminal Expansion

Cameron LNG completed a records review and a Phase I cultural resources survey of the 

proposed Terminal Expansion (Thomas and Holland 2012). The investigations covered both 

archaeological and architectural resources. The resulting report was provided to the FERC and 

the Louisiana State Historic Preservation Office (SHPO).
4-113 Cultural Resources

The records review did not identify any known archaeological resources within the 

survey area, or any known historic architectural resources within or near the proposed site of the 

Terminal Expansion. 

The Phase I cultural resources survey examined a 566-acre area that had not been 

previously surveyed, and re-examined a 69-acre portion that had been previously surveyed. The 

survey consisted of pedestrian surface inspection of areas with greater than 25 percent surface 

visibility, and systematic subsurface shovel testing of areas that were not inundated, obviously 

disturbed past the depth of potential archaeological deposits, or used for dredge spoil disposal. A 

total of 317 shovel tests were excavated. No archaeological resources were identified.

Cameron LNG also examined a 0.5-mile-wide area adjacent to the boundaries of the 

Terminal Expansion area and existing terminal for historic architectural resources, except in 

some areas where vegetation limited line of sight to shorter distances. No historic architectural 

resources were identified.

The Louisiana SHPO reviewed the Phase I cultural resources survey report, and in letters 

dated September 24 and December 5, 2012, concurred that no historic properties would be 

impacted and indicated that it had no further concerns regarding the Terminal Expansion. On 

April 24, 2013, the Louisiana SHPO concurred that a cultural resource survey was not required 

for the associated wetland mitigation and dredge disposal areas since these areas consisted of 

open water, marsh, and existing dredge disposal areas.

4.10.1.1 Unanticipated Discovery Plan

Cameron LNG prepared an Unanticipated Discovery Plan which it would implement in 

the event that cultural resources or human remains are encountered during construction. We 

requested revisions to the plan, and Cameron LNG provided a revised plan that we find 

acceptable. 

4.10.1.2 Compliance with the National Historic Preservation Act

Cultural resource surveys have been completed for the Terminal Expansion. The 

Louisiana SHPO and the FERC agree that no historic properties would be affected. Therefore, 

the process of complying with Section 106 of the NHPA has been completed for the Terminal 

Expansion.

4.10.2 Pipeline Expansion

Cameron Interstate completed a records review and a Phase I cultural resources survey of 

the proposed Pipeline Expansion and related facilities (Thomas et al. 2012). The investigations 

covered both archaeological and architectural resources for the proposed pipeline right-of-way, 

Holbrook Compressor Station, contractor storage yard, access roads, the new interconnection to 

Trunkline, and modified interconnections with Transco, TETCO, TGP, and FGT pipelines. The 

resulting report was provided to the FERC and SHPO. A new metering facility at the existing 

LNG Terminal would be installed within an area previously surveyed, with no cultural resources 

identified (Ryan et al. 2002). Therefore, it was not included in the investigations for the Pipeline 

Expansion.
Cultural Resources 4-114

The records review identified three known archaeological sites previously documented 

within or near the survey area. One site (16BE47) mapped within the survey area was described 

as a ca. 1882 through 1963 artifact scatter associated with an abandoned bed of the Southern 

Pacific Railroad. This site was determined not eligible for the NRHP. The other two sites 

(16BE1690 and 16BE1691) were mapped outside of the survey area. No historic architectural 

resources were identified within the study area. In addition, the records review identified the 

Swires Family Cemetery (06-00001-A) 0.6 mile from the proposed route.

The Phase I cultural resources survey examined a 200-foot-wide to 400-foot-wide 

corridor encompassing the proposed pipeline right-of-way and associated extra work spaces, 50-

foot-wide corridors along the access roads, a 25-acre parcel for the compressor station, a 21-acre 

parcel for the contractor storage yard, and parcels for the Trunkline interconnection and modified 

interconnections. In total, approximately 1,097 acres were surveyed.

The survey consisted of pedestrian surface inspection of areas with greater than 25 

percent surface visibility, and systematic subsurface shovel testing of areas that were not 

inundated or obviously disturbed past the depth of potential archaeological deposits. The area 

examined through surface inspection and subsurface testing included the proposed pipeline rightof-way, the compressor station and contractor storage yard parcels, and the interconnections. 

The access roads, all existing, were examined through surface inspection. One approximately 

1.7-mile-long segment along the pipeline route was denied access by the landowner. In this area, 

shovel tests were excavated (all negative) along the edge of the survey corridor where it 

occupied the existing pipeline right-of-way, and from there, visual inspection of the adjoining 

no-access property was carried out. Because of disturbances due to silviculture and the swampy 

nature of the land, no further work was recommended for this segment. 

Cameron Interstate did not identify any archaeological resources within the survey area,

including any cultural remains associated with previously recorded Site 16BE47, which was not 

re-located.

Cameron Interstate also examined the areas around the proposed compressor station, new 

interconnection, and four interconnection modifications for architectural resources that could be 

visually impacted by those facilities. It defined the area of potential visual impact as the visual 

horizon from each proposed facility to the adjacent tree line. Cameron Interstate did not identify 

any architectural resources within those areas. 

The Louisiana SHPO reviewed the Phase I cultural resources survey report, and in letters 

dated September 24 and December 5, 2012, concurred that no historic properties would be 

impacted and indicated that it had no further concerns regarding the Pipeline Expansion.

4.10.2.1 Unanticipated Discovery Plan

Cameron Interstate prepared an Unanticipated Discovery Plan which it would implement 

in the event that cultural resources or human remains are encountered during construction. We 

requested revisions to the plan, and Cameron Interstate provided a revised plan that we find 

acceptable.
4-115 Air Quality And Noise

4.10.2.2 Compliance with the National Historic Preservation Act

Cultural resource surveys have been completed for the Pipeline Expansion. The 

Louisiana SHPO and the FERC agree that no historic properties would be affected. Therefore, 

the process of complying with Section 106 of the NHPA has been completed for the Pipeline 

Expansion.

4.10.3 Native American Consultation

We mailed our NOI to six federally recognized Native American tribes: the Jena Band of 

Choctaw Indians, the Caddo Nation, the Chitimacha Tribe of Louisiana, the Coushatta Tribe of 

Louisiana, the Alabama Coushatta Tribe of Texas, and the Tunica-Biloxi Indian Tribe of 

Louisiana. The NOI requested comments on the proposed Project and encouraged attendance at 

the FERC’s public scoping meeting. We did not receive responses to our NOI from any of the 

tribes.

We sent a follow-up letter to each of the tribes on October 19, 2012. The letters 

requested comments from the tribes and assistance in identifying properties of traditional, 

religious, or cultural importance that may be affected by the proposed Project. We received a 

letter from the Coushatta Tribe of Louisiana expressing thanks “for the opportunity to review this 

report.” To date no other responses have been received.

Cameron sent letters to the tribes on July 20 and August 1, 2012. The letters requested

the tribes communicate any concerns about potential impacts the proposed Project may have on 

archaeological sites, burials, or traditional cultural properties. Cameron also sent follow-up 

letters to the tribes on October 31, 2012. In a response dated December 12, 2012, the Jena Band 

of Choctaw Indians requested that Cameron provide the cultural resource survey reports for 

review. Cameron provided the reports to the tribe on February 8, 2013. In a letter dated April 

11, 2013, the tribe concurred with the findings and recommendations in the reports, and 

requested to be contacted immediately in the event of a significant unanticipated discovery. No 

other responses have been received to date to the original or follow-up letters.

4.11 AIR QUALITY AND NOISE

4.11.1 Air Quality

4.11.1.1 Regional Climate

The general area in the vicinity of the proposed Project area has a modified marine 

climate which can be influenced by a predominant onshore flow of tropical marine air from the 

Gulf of Mexico. During onshore flow events, the area experiences a subtropical humid climate. 

In summer, sea breezes help decrease temperatures. Based on data from the National Climatic 

Data Center’s (NCDC) Climatology of the United States No. 20 (NCDC 2010), which provides 

data from 1971 to 2000, maximum and minimum temperatures at the Port Arthur Airport in 

Beaumont, Texas (the data collection point that is closest to the proposed Project) usually occur 

in July and January, respectively. 
Air Quality And Noise 4-116

Mean annual precipitation falling at the Port Arthur Airport is 59.9 inches, while monthly 

average precipitation is from 3.35 inches in February to 6.58 inches in June. Thunderstorms 

occur in the area approximately 60 days per year and the average annual snowfall is 0.3 inch.

Winds in the area are generally from the south, with average wind speeds around 9 miles 

per hour. Winds from the southwest through north-northwest are quite rare. Wind direction can 

vary by season; spring winds are from the south through southeast, summer winds are from the 

south and west-southwest; fall winds are from the north clockwise through south; and in winter, 

winds are from the north.

4.11.1.2 Existing Air Quality

Ambient Air Quality Standards

Air quality would be affected by construction activities and operation of the proposed 

facilities. With authority granted by the CAA, the EPA established NAAQS to protect human 

health (primary standards) and public welfare (secondary standards). EPA set NAAQS for the 

following air contaminants designated as “criteria pollutants:” nitrogen oxides (NOX) including 

nitrogen dioxide (NO2), carbon monoxide (CO), ozone (O3), sulfur dioxide (SO2), lead (Pb), 

particulate matter with an aerodynamic diameter less than or equal to 10 microns (PM10), and 

particulate matter with an aerodynamic diameter less than or equal to 2.5 microns (PM2.5). These 

NAAQS reflect the relationship between pollutant concentrations and health and welfare effects. 

The NAAQS are codified in 40 CFR 50 and are summarized in table 4.11.1-1. The LDEQ

adopted the NAAQS.

In December 2009, EPA updated the definition of air pollution to include six greenhouse 

gases (GHGs) after determining that GHGs in the atmosphere can endanger public health and 

welfare. The GHGs include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), 

hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. GHGs can be ranked by their 

global warming potential (GWP), which is a relative measure of a GHG’s ability to absorb solar 

radiation and its residence time in the atmosphere in comparison to that of CO2. Thus, CO2 has a 

GWP of 1. On November 29, 2013, the EPA revised GWPs for GHGs to reflect more accurate 

GWPs from the Intergovernmental Panel for Climate Change Fourth Assessment Report, to 

better characterize the climate impacts of individual GHGs, and to ensure continued consistency 

with other U.S. climate programs, including the Inventory U.S. Greenhouse Gas Emissions and 

Sinks. More information is available in Volume 78 of the Federal Register, Issue 230. 

Therefore, the GWP for CH4 changed from 21 to 25, and the GWP for N2O changed from 310 to 

298. As a result of these changes, we updated the estimated GHG emissions for construction and 

operation of the Terminal Expansion and the Pipeline Expansion. 
4-117 Air Quality And Noise

TABLE 4.11.1-1

National and Louisiana Ambient Air Quality Standards

Pollutant Time Frame Primary Secondary

PM10

Annuala Revoked Revoked

24-hourb 150 μg/m3 150 μg/m3

PM2.5

Annualc 12 μg/m3 15 μg/m3

24-hourd 35 μg/m3 35 μg/m3

SO2

Annual 0.030 ppm (80 μg/m3) NA

24-hourb 0.14 ppm (365 μg/m3) NA

3-hourb NA 0.5 ppm (1,300 μg/m3)

1-hour e 75 ppb (196 μg/m3) NA

CO

8-hourb 9 ppm (10,000 μg/m3) NA

1-hourb 35 ppm (40,000 μg/m3) NA

NO2

Annual 0.053 ppm (100 μg/m3) 0.053 ppm (100 μg/m3)

1-hourf 0.100 ppm NA

O3

8-hourg 0.075 ppm (147 μg/m3) 0.075 ppm (147 μg/m3)

1-hourh Revoked Revoked

Pb

3-month rollingi 0.15 μg/m3 0.15 μg/m3

Quarterly 1.5 μg/m3 1.5 μg/m3

Source: EPA 2010

Abbreviations:

PM10 = particulate matter less than 10 microns PM2.5 = particulate matter less than 2.5 microns

SO2 = sulfur dioxide CO = carbon monoxide

NO2 = nitrogen dioxide O3 = ozone

Pb = lead mg = milligram(s)

μg = microgram(s) m3 = cubic meter(s)

NA = not applicable ppm = part(s) per million

ppb = part(s) per billion

Air Quality Control Regions and Attainment Status

An Air Quality Control Region (AQCR), as defined in the CAA (42 USC 7407), is a 

contiguous area considered to have relatively uniform ambient air quality, and is treated as a 

single unit for reducing air emissions and determining compliance with the NAAQS. Each 

AQCR, or smaller portion within an AQCR, is designated as attainment, unclassifiable, 

maintenance, or nonattainment. Areas where ambient air pollutant concentrations are below the 

NAAQS are designated as attainment, while areas where ambient air concentrations are greater 

than the NAAQS are designated as nonattainment. Areas previously designated as 

nonattainment that have subsequently demonstrated compliance with the NAAQS are designated 
Air Quality And Noise 4-118

as maintenance. Areas without data available are designated unclassifiable, and are treated as 

attainment areas for the purpose of stationary source air permitting. 

The proposed Project would be constructed in Cameron, Calcasieu, and Beauregard 

Parishes, which are within the Southern Louisiana-Southeast Texas Interstate AQCR. All of 

these parishes are in attainment for all criteria pollutants. Calcasieu Parish is classified as a 

maintenance parish for O3 and Cameron Parish is classified as an “adjoining” parish. To 

maintain a status of attainment, measures must be taken in both parishes to track emissions data 

for all criteria pollutants. Currently, there are no provisions or emissions thresholds associated 

with Calcasieu Parish’s maintenance designation with which the Pipeline Expansion must 

comply. Both Calcasieu and Cameron Parish are in attainment for the current 8-hour O3

NAAQS.

Air Quality Monitoring and Existing Air Quality

EPA, along with state and local agencies, created a network of ambient air quality 

monitoring stations that collect data on background concentrations of priority pollutants across 

the U.S. To characterize the existing ambient air quality for the proposed Project, data were 

gathered from three air quality monitoring stations in Calcasieu Parish: Carlyss, Vinton, and 

Westlake. Outside of Calcasieu Parish, the next closest air monitoring station is about 80 miles 

from the proposed Project. 

The monitors at Carlyss, Vinton, and Westlake measure O3. The Westlake monitor also 

measures NOX and SO2, and the Vinton monitor also measures PM2.5. In 2005, the nearest PM10

monitoring location was in Lafayette, approximately 80 miles from the Project. The nearest 

monitoring location for CO is in Baton Rouge, which is approximately 135 miles from the 

Project.

The most recent validated data from these monitoring sites are presented in table 4.11.1-

2, which compares monitored data with the appropriate NAAQS standard for each criteria 

pollutant. All monitored values were below the NAAQS. 
4-119 Air Quality And Noise

TABLE 4.11.1-2

Ambient Air Quality and Ambient Air Quality Standardsa

Air Pollutant Averaging 

Period

Highest 

Monitored 

Value

Monitoring 

Site Year NAAQS

Ozone (O3) 8-hour NAb Carlyss, Vinton, 

Westlake

2010-2011 75 ppb

Sulfur Dioxide (SO2) 1-hour 3 ppb Westlake 2008-2010 75 ppb

Carbon Monoxide (CO) 1-hour 3.11 ppm Baton Rouge 2008-2010 35 ppm

Nitrogen Dioxide (NO2) Annual 7.5 ppb Westlake 2008-2010 53 ppb

Particulate Matter of 10 microns in 

diameter or less (PM10) 24-hour 88 μg/m3 Port Allen 2008-2010 150 μg/m3

Particulate Matter of less than 2.5 

microns in diameter (PM2.5) Annual 9 μg/m3 Vinton 2008-2010 15 μg/m3

Abbreviations:

NA= not available ppb = parts per billion ppm = parts per million

μg/m3 = micrograms per cubic meter NAAQS = National Ambient Air Quality Standards a

 Data collected from monitoring stations closest to Project. b

 The 2010 and 2011 data from Carlyss, Vinton, and Westlake included three O3 exceedance days in 2011 but 

none in 2010.
Air Quality And Noise 4-120

Emissions from the Existing Cameron LNG Terminal

Table 4.11.1-3 lists emissions from the Cameron LNG Terminal as previously permitted 

under Part 70 Permit No. 0560-00184-V4. 

TABLE 4.11.1-3

Emissions Summary for the Existing Cameron LNG Terminal

Emission Unit

Annual Pollutant Emissions (tons)

NOX CO SO2 PM10/PM2.5 VOC HAPs GHG

Submerged Combustion Vaporizer CAP 230.0 182.65 3.16 33.60 24.32 0.36 528,092

Fuel Gas Heater CAP 1.40 0.88 0.01 0.12 0.09 <0.001 1,949

Emergency Generators (3) 4.59 2.43 0.27 0.15 4.59 0.003 477

Emergency Fire Water Pumps (3) 0.72 0.24 0.03 0.03 0.72 0.001 47

Emergency River Water Pumps (2) 0.24 0.12 0.02 0.02 0.24 0.0004 16

Diesel Storage Tank -- -- -- -- 0.01 -- --

Fugitives -- -- -- -- 0.04 -- 158

Flare 0.19 1.06 <0.01 0.01 0.01 0.005 333

TOTAL 237.14 187.38 3.50 33.93 30.02 0.37 531,072

Abbreviations:

NOX = oxides of nitrogen CO = carbon monoxide SO2 = sulfur dioxide

VOC = volatile organic compounds HAPs = hazardous air pollutants GHG = greenhouse gas

PM10 = particulate matter less than 10 microns

4.11.1.3 Regulatory Requirements for Air Quality

Terminal Expansion

Federal Air Quality Requirements

New Source Review/Prevention of Significant Deterioration

Federal preconstruction review of certain large proposed projects varies for attainment 

and nonattainment areas. Federal preconstruction review for sources in nonattainment areas is 

referred to as Nonattainment New Source Review (NNSR), while federal preconstruction review 

for sources in attainment areas is formally referred to as Prevention of Significant Deterioration 

(PSD). The review process aids in preventing new sources from causing existing air quality to 

deteriorate beyond acceptable levels. The PSD regulations under 40 CFR 52.21 consider a major 

source as any source that (1) is in one or more of 28 listed source categories that emits or has the 

potential to emit 100 tons per year (tpy) or more of any pollutant regulated under the CAA, or (2) 

is in an unlisted source category and emits or has the potential to emit those pollutants in 
4-121 Air Quality And Noise

amounts greater than 250 tpy [40 CFR 52.21(b)]. The Terminal Expansion does not fall under a 

listed source category, but it is considered a major source because it has the potential to emit 

more than 250 tpy of a pollutant regulated under the CAA. Table 4.11.1-4 lists major source 

emission thresholds, and table 4.11.1-5 summarizes the potential-to-emit based on new 

equipment that would be used for the Terminal Expansion.

TABLE 4.11.1-4

Major Stationary Source/Major Modification Emission Thresholds

Pollutant Major Stationary Source Threshold 

Level (tpy)

Major Modification Significant Net 

Increase (tpy)

O3/VOC/NOX 250 40

CO 250 100

SO2 250 40

PM 250 25

PM10 250 15

PM2.5 250 10

Pb 250 0.6

GHG 100,000 tpy CO2-eq/250 tpy GHGsa 75,000 tpy CO2-eq />0 tpy GHGsb

Abbreviations:

O3 = ozone VOC = volatile organic compounds

NOX = oxides of nitrogen CO = carbon monoxide

SO2 = sulfur dioxide PM = particulate matter

PM10 = particulate matter less than 10 microns PM2.5 = particulate matter less than 2.5 microns

Pb = lead tpy = tons per year

GHG = greenhouse gas CO2-eq = carbon dioxide equivalents a A facility is considered a major stationary source if the potential-to-emit is greater than 100,000 tpy of CO2-

eq and greater than 250 tpy of GHG (sum of 6 six GHGs on a mass basis). b A major modification must meet 2 emission conditions: must be greater than 75,000 tpy of CO2-eq and 

exceed 0 tpy of GHG (sum of 6 GHGs on a mass basis).
Air Quality And Noise 4-122

TABLE 4.11.1-5

Terminal Expansion Project Potential-to-Emit

Emission Unit (Quantity)

Pollutant Emissions (tpy)

NOX CO SO2 PM10/PM2.5 VOC HAPs GHG

Refrigeration Compressor 

Turbines (6) 2,312.64 814.68 1.56 131.40 47.10 22.21 2,939,770

Thermal Oxidizer 

(1 with spare) 0.01 0.01 6.98 0.001 0.004 <0.001 462,939

Flares (5) 13.66 74.40 0.11 1.49 1.09 0.04 23,462

Emergency Generators 

(4 with spare) 7.65 4.05 0.45 0.25 7.65 0.008 795

Emergency Fire Water 

Pumps (3) 0.27 0.27 0.03 0.015 0.27 0.001 47

Emergency River Water 

Pumps (2) 0.10 0.10 0.01 0.004 0.10 0.0004 16

Condensate Storage Tanks 

(2) -- -- -- -- 3.58 -- --

Condensate loading -- -- -- -- 1.22 -- --

Fugitive emissions -- -- -- -- 36.68 -- 2,395

TOTAL 2,333.84 890.82 9.14 133.11 97.65 22.26 3,429,424

Abbreviations:

NOX = oxides of nitrogen CO = carbon monoxide

SO2 = sulfur dioxide PM10 = particulate matter less than 10 microns

VOC = volatile organic compounds HAPs = hazardous air pollutants

GHG = greenhouse gas (rounded to nearest whole number) tpy = tons per year

-- = no emissions

There are three air quality classifications within each of the Air Quality Control Regions 

of the U.S.: Class I areas are designated as pristine natural areas or areas of natural significance 

and receive special protections under the CAA based on good air quality. Class III areas are 

heavily-industrialized zones that are established only on request and must meet all requirements 

outlined in 40 CFR 51.166. The remainder of the U.S. is designated as Class II. If a new source 

or major modification of an existing source is subject to the PSD program requirements and is 

within 62 miles (100 kilometers [km]) of a Class I area, the facility is required to notify the 

appropriate federal officials and assess the impacts of the proposed project on the Class I area. 

The closest designated Class I area to the Terminal Expansion is Breton National Wildlife 

Refuge, approximately 238 miles from the proposed site, and therefore a PSD Class I analysis is 

not required.

In May 2010, EPA issued the PSD GHG Tailoring Rule, designed to account for facilities

that represent approximately 70 percent of GHG emissions from stationary sources while 

protecting smaller sources. Beginning in January 2011, a new industrial facility that is a major 

source for at least one non-GHG pollutant and which emits or has the potential to emit at least 
4-123 Air Quality And Noise

75,000 tpy of CO2-equivalent (CO2-eq)39 would also be subject to GHG permitting requirements 

under PSD. Any existing industrial facility that is already considered a major source of a nonGHG pollutant and which would increase its GHG emissions by more than 75,000 tpy CO2-eq 

would also be subject to GHG permitting requirements under PSD. Beginning in July 2011, the 

new PSD major source threshold of 100,000 tpy of CO2-eq became effective for new sources. 

For existing PSD major sources, the threshold for a modification is 75,000 tpy CO2-eq. The 

Terminal Expansion would be a PSD major source, have projected CO2-eq emissions above 

75,000 tpy, and be subject to the PSD GHG Tailoring Rule.

Cameron LNG submitted a PSD air quality permit application for the proposed Terminal 

Expansion to LDEQ. The LDEQ issued a PSD permit (PSD-LA-766) on October 1, 2013.

New Source Performance Standards

The New Source Performance Standards (NSPS), codified in 40 CFR 60, regulate 

emission rates and provide requirements for new or significantly modified sources. NSPS 

requirements include emission limits, monitoring, reporting, and record keeping. 

The standards in 40 CFR 60 Subpart KKKK apply to stationary combustion turbines that 

commenced construction, modification, or reconstruction after February 18, 2005 and have a 

heat input at peak load equal to or greater than 10.7 gigajoules per hour (10 million British 

thermal units [Btu] per hour). Cameron LNG would operate the refrigeration turbines of the 

Terminal Expansion in compliance with the applicable requirements of Subpart KKKK by 

accomplishing the following:

• operating within emission limits, with recorded source and use of sulfur fuel at or 

below 0.060 pounds per million Btu; 

• operating and maintaining the turbines and associated control and monitoring 

equipment using good air pollution control procedures to minimize emissions at 

all times;

• reporting excess emissions (4-hour rolling unit operating hour average where the 

target value is outside acceptable range) for all periods of unit operation; 

• conducting initial and annual performance tests to demonstrate emissions at least 

75 percent of peak load;

• submitting results within 60 days of testing; and 

• submitting fuel for analysis. 

The emergency generators, emergency fire water pumps and emergency river water 

pumps would be subject to NSPS Subpart IIII – Standards of Performance for Stationary 

Compression Ignition Internal Combustion Engines. Cameron LNG would comply with the 

standards for these pumps by accomplishing the following:

• operating below required emission limits; 

 39 CO2-eq is a measure used to compare GHGs based on their GWP. The carbon dioxide equivalent for a gas is 

calculated by multiplying tons of the gas by the associated GWP.
Air Quality And Noise 4-124

• operating, maintaining, and altering the pumps in accordance with the 

manufacturer’s instructions; 

• using the required non-road diesel fuel; 

• operating for maintenance as required for no more than 100 hours per year;

• undergoing the required performance tests; and 

• timing operations on a non-resettable meter installed prior to initial startup of the 

engine. 

Cameron LNG would comply with the standards for the emergency generators by 

accomplishing the following:

• using certified engines for the required emission limits for new non-road engines; 

• using the required non-road diesel fuel; 

• installing and configuring the generators in accordance with the manufacturer’s 

requirements; and

• timing operations on a non-resettable meter installed prior to initial startup of the 

engine. 

The two new condensate storage tanks would be subject to NSPS Subpart Kb – Standards 

of Performance for Volatile Organic Liquid Storage Vessels (including petroleum liquid storage 

vessels) for which construction, reconstruction, or modification commenced after July 23, 1984. 

Cameron LNG would comply with the standards by accomplishing the following:

• installing the required closed-vent system and control device;

• keeping records for the life of the source, including vessel dimension and 

capacity; 

• obtaining the necessary data to calculate the true vapor pressure; 

• preparing an operating plan for the facility;

• providing measured monitoring values for all operations without the flare pilot 

flame; and 

• providing required reports on time.

National Emissions Standards for Hazardous Air Pollutants

The National Emissions Standards for Hazardous Air Pollutants (NESHAPs), codified in 

40 CFR Parts 61 and 63, regulate the emissions of Hazardous Air Pollutants (HAPs) from new 

and existing sources. Part 61, promulgated before the 1990 CAA Amendments, regulates eight 

hazardous substances: asbestos, benzene, beryllium, coke oven emissions, inorganic arsenic, 

mercury, radionuclides, and vinyl chloride. 

The 1990 CAA Amendments established a list of 189 HAPs, resulting in the 

promulgation of Part 63, also known as the Maximum Achievable Control Technology (MACT) 
4-125 Air Quality And Noise

standards. Part 63 regulates HAPs from major sources of HAPs and specific source categories 

emitting HAPs. Some NESHAPs may apply to non-major sources (area sources) of HAPs. 

Major source thresholds for NESHAPs are 10 tpy of any single HAP or 25 tpy of total HAPs. 

The Terminal Expansion is not expected to include processes that are regulated by Part 

61.

Title V Operating Permit

A Title V major source, as defined in 40 CFR 70.2, is a source or group of stationary 

sources (including new and existing sources) within a contiguous area and under common 

control, emitting or with the potential to emit criteria pollutants or HAPs above the criteria 

pollutant threshold values (100 tpy for criteria pollutants). Cameron LNG currently operates the 

existing LNG Terminal under a Title V permit and the proposed expansion would be considered 

a major modification under the Title V program. Therefore, the current Title V permit must be 

modified for construction and operation of the Terminal Expansion. An air quality permit 

application for the proposed expansion was submitted to LDEQ and considered a modification to 

the existing LNG Terminal Air Permit. The LDEQ issued the Title V Permit (0560-00184-V5) 

for the Terminal Expansion on October 1, 2013.

General Conformity

The General Conformity Rule was designed to require federal agencies to ensure that 

federally-funded or federally-approved projects conform to the applicable State Implementation 

Plan (SIP). Section 176(c) of the CAA prohibits federal actions in nonattainment or PSD 

maintenance areas that do not conform to the SIP for the attainment and maintenance of 

NAAQS. General Conformity regulations apply to project-wide emissions of pollutants for 

which the project areas are designated as nonattainment (or, for ozone, its precursors NOX and 

VOC) that are not subject to NSR and that are greater than the significance thresholds 

established in the General Conformity regulations or 10 percent of the total emissions budget for 

the entire nonattainment area. Federal agencies are able to make a positive conformity 

determination for a proposed project if any of several criteria in the General Conformity Rule are 

met. These criteria include:

• emissions from the project that are specifically identified and accounted for in the 

SIP attainment or maintenance demonstration; or

• emissions from the action that are fully offset within the same area through a 

revision to the SIP, or a similarly enforceable measure that creates emissions 

reductions so there is no net increase in emissions of that pollutant.

The existing LNG Terminal and the proposed expansion would be entirely within an 

attainment area and would be subject to PSD permitting and, therefore, not subject to General 

Conformity. 

GHG Reporting Rule

In September 2009, EPA issued the final Mandatory Reporting of Greenhouse Gases 

Rule, requiring reporting of GHG emissions from suppliers of fossil fuels and facilities that emit 
Air Quality And Noise 4-126

greater than or equal to 25,000 metric tpy of GHG (reported as CO2-eq). In November 2010, 

EPA signed a rule finalizing GHG reporting requirements for the petroleum and natural gas 

industry in 40 CFR Part 98, Subpart W. The industry separates LNG storage facilities from LNG 

import and export equipment because the former are considered part of the source category 

regulated by Subpart W. The rule does not apply to construction emissions. 

New LNG facilities associated with the Terminal Expansion would potentially be subject 

to the GHG Mandatory Reporting Rule. The rule establishes reporting requirements based on 

actual emissions; however it does not require emission controls. Cameron LNG would monitor 

emissions in accordance with the reporting rule. If actual emissions exceed the 25,000 tpy CO2-

eq reporting threshold, Cameron LNG would be required to report its GHG emissions to EPA. 

Applicable State Air Quality Requirements

The Terminal Expansion facilities would be subject to state standards, codified in LAC 

Title 33, Part III. The regulations listed below would apply to the new facilities associated with 

the Terminal Expansion, including governing turbines, flares, generators, fire water pumps, 

condensate loading, amine units with incinerator, and fugitive emissions:.

• Section 1101 - Control of Air Pollution from Smoke;

• Section 1103 – Impairment of Visibility on Public Roads Prohibited;

• Section 1105 - Smoke from Flaring;

• Section 1109 - Outdoor Burning (smoke);

• Section 1305 - Control of Fugitive Emission (particulate matter);

• Section 1311 – Emission Limits (particulate matter);

• Section 1313 - Fuel Burning Equipment (particulate matter);

• Section 2103 – Storage of Volatile Organic Compounds;

• Section 2111 – Pumps and Compressors; and

• Section 2113 - Housekeeping.

Cameron LNG would comply with all applicable state requirements.

Pipeline Expansion 

Federal Air Quality Requirements

New Source Review/Prevention of Significant Deterioration

Neither the pipeline nor the Holbrook Compressor Station would be a listed source 

category, but the Holbrook Compressor Station would be considered a major PSD source 

because it would exceed the 250 tpy threshold during operation. Table 4.11.1-4 lists major 

source emission thresholds, and table 4.11.1-6 summarizes the potential-to-emit from the 

equipment proposed for the Holbrook Compressor Station.
4-127 Air Quality And Noise

TABLE 4.11.1-6

Pipeline Expansion Project Potential-to-Emit

Emission Unit (Quantity)

Pollutant Emissions (tpy)

NOX CO SO2 PM10/PM 2.5 VOC HAPs GHG

Natural Gas-Fired Compressors

(12) 273.72 20.52 0.96 0.12 199.68 9.46 241,273

Emergency Generator 1.04 0.22 0.20 0.03 0.06 0.004 113

Fugitive Emissions -- -- -- -- 0.10 0.02 94

TOTAL 274.76 20.74 1.16 0.15 199.86 9.48 241,480

Abbreviations:

NOX = oxides of nitrogen CO = carbon monoxide

SO2 = sulfur dioxide PM10 = particulate matter less than 10 microns

VOC = volatile organic compounds HAPs = hazardous air pollutants

tpy = tons per year -- = no emissions

GHG = greenhouse gas (as CO2-eq, rounded to whole numbers)

The closest designated Class I area to the pipeline route, the Breton National Wildlife 

Refuge, is approximately 256 miles away; therefore a PSD Class I analysis is not required.

The Holbrook Compressor Station would be a PSD major source and would have 

projected CO2-eq emissions above 75,000 tpy. Therefore, the Pipeline Expansion would be 

subject to the PSD GHG Tailoring Rule. Cameron Interstate filed its PSD application with the 

LDEQ and LDEQ issued a PSD permit (PSD-LA-769) on December 20, 2013.

New Source Performance Standards

Subpart IIII of 40 CFR 60 applies to each stationary compression ignition internal 

combustion engine that commenced construction after July 11, 2005. The new emergency 

generator at the compressor station would be constructed and operated in compliance with those 

requirements. Cameron Interstate would comply with those standards by accomplishing the 

following:

• certifying the generators for the required emission standards;

• operating, maintaining, and altering the equipment in accordance with the 

manufacturer’s recommendations;

• using approved non-road diesel fuel;

• conducting the required maintenance and readiness activities for no more than 

100 hours per year and for no more than 50 hours per year for non-emergency 

testing; and

• timing operations on a non-resettable meter installed prior to initial startup of the 

engine. 
Air Quality And Noise 4-128

Subpart JJJJ of 40 CFR 60 applies to each stationary compression ignition internal 

combustion engine that commenced construction after July 11, 2005. Cameron Interstate would 

operate the compressors in compliance with those requirements by accomplishing the following:

• certifying the equipment for the required emission standards;

• using propane as an alternative fuel for no more than 100 hours per year; and 

• conducting recordkeeping at the required frequency.

National Emissions Standards for Hazardous Air Pollutants

The proposed pipeline and compressor station are not expected to include processes 

regulated by 40 CFR 61. The Holbrook Compressor Station would be a minor source of HAPs 

subject to 40 CFR 63, Subpart ZZZZ - NESHAPS for Stationary Reciprocating Internal 

Combustion Engines. Cameron Interstate would operate the compressors and emergency 

generator in compliance with the applicable requirements of Subpart ZZZZ by accomplishing the 

following:

• complying with Subpart JJJJ (see above New Source Performance Standards) for 

compressor operation; and 

• complying with Subpart IIII for the emergency generator (see above New Source 

Performance Standards).

Title V Operating Permit

The Holbrook Compressor Station would be considered a major source and a Title V 

permit would be required for construction and operation of the facility. Cameron Interstate 

submitted a draft Title V permit application to LDEQ on October 16, 2012 and LDEQ issued the 

Title V Permit (0520-00464-V0) on December 20, 2013.

General Conformity

Because the proposed pipeline route is in an attainment area, general conformity does not 

apply. A portion of the Pipeline Expansion is in Calcasieu Parish, which is designated as a 

maintenance area for the 1-hour ozone standard. The Pipeline Expansion would conform to the 

Louisiana SIP, but emissions from the expanded system would be excluded from a conformity 

determination because it is subject to NSR. 

GHG Reporting Rule

The Holbrook Compressor Station would be subject to the GHG Mandatory Reporting 

Rule. The rule establishes reporting requirements based on actual emissions; however it does not 

require emission controls. Cameron Interstate would monitor emissions in accordance with the 

reporting rule. If actual emissions exceed the 25,000 tpy CO2-eq reporting threshold, Cameron 

Interstate would be required to report its GHG emissions to EPA.
4-129 Air Quality And Noise

Applicable State Air Quality Requirements

As discussed for the Terminal Expansion, construction and operation of the pipeline 

would be subject to the state air quality standards codified in LAC Title 33, Part III. The 

regulations that would apply to the pipeline and associated equipment and facilities are listed 

below:

• Section 1101 - Control of Air Pollution from Smoke;

• Section 1103 – Impairment of Visibility on Public Roads Prohibited;

• Section 1109 - Outdoor Burning (smoke);

• Section 1311 – Emission Limits (particulate matter);

• Section 2111 – Pumps and Compressors; and

• Section 2113 – Housekeeping.

Cameron Interstate would comply with all applicable state requirements.

4.11.1.4 Construction Air Emissions and Impacts

Terminal Expansion

Emissions

Potential impacts to ambient air quality for construction projects typically include 

generation of fugitive dust and combustion emissions from construction equipment operation. 

Fugitive dust results from construction activities such as land clearing, grading, excavation, and 

concrete work, as well as from vehicles traveling on paved and unpaved roads. Fugitive dust 

generation depends on the area of construction, silt and moisture contents of the soil, wind speed, 

frequency of precipitation, amount of vehicle traffic, and vehicle and roadway type. Fugitive 

dust may be produced during all phases of construction. Emissions are typically greatest during 

drier winter months and in areas of fine-textured soils. The control of fugitive particulate 

emissions is typically addressed through compliance with state or local nuisance regulations such 

as Louisiana state regulations Section 1305 - Control of Fugitive Emission of Particulate Matter

and Section 1311 – Emission Limits (particulate matter). Cameron LNG would use dust 

suppression techniques, such as watering the construction areas to minimize fugitive dust during 

construction, in addition to the requirements in Louisiana state regulations Section 1305.

Construction-related air quality impacts are also associated with the operation of 

gasoline- or diesel-fueled engines in on-road, off-road, stationary and mobile equipment. A 

summary of expected construction emissions is provided in table 4.11.1-7. 

As with any fossil fuel-fired activity, construction equipment used for the Terminal 

Expansion would also contribute GHG emissions, including CH4, CO2, and N2O. Emissions of 

GHGs are typically estimated as CO2-eq. Although EPA’s reporting rule does not apply to 

construction emissions, we have included these GHG emissions in table 4.11.1-7 for accounting 

and disclosure purposes.
Air Quality And Noise 4-130

TABLE 4.11.1-7

Summary of Terminal Expansion Construction Emissions

Year

Annual Pollutant Emissions (tons)

NOX CO SO2 PM10 PM2.5 VOC GHG

2014 398.88 214.80 28.82 109.25 25.58 24.50 36,715

2015 190.14 336.37 6.32 104.66 21.00 32.15 38,102

2016 120.04 315.47 3.62 100.71 17.04 24.95 29,992

2017 13.53 47.89 1.05 93.66 9.99 3.13 4,434

TOTAL 722.59 944.53 39.81 408.27 73.62 84.74 109,243

Abbreviations:

NOX = oxides of nitrogen CO = carbon monoxide

SO2 = sulfur dioxide PM10 = particulate matter less than 10 microns

PM2.5 = particulate matter less than 2.5 microns VOC = volatile organic compounds

HAPs = hazardous air pollutants

GHG = greenhouse gas (as CO2-eq, rounded to whole numbers)

Mitigation Measures

Once the construction phase is completed, the fugitive dust and emissions would subside;

thus, the length of time the area near the site would be exposed to dust and emissions from 

construction activities would be limited. Cameron LNG would incorporate the following 

mitigation measures into the Terminal Expansion to minimize impacts on air quality during 

construction: 

• use of modern, well-maintained machinery and vehicles meeting applicable 

emission performance standards to minimize combustion related emissions, 

including GHGs;

• shutting down idling fossil-fueled equipment when not in use, if practicable (i.e., 

during summer operations), to minimize combustion-related emissions, including 

GHGs; 

• maintenance of tire pressures to manufacturer’s specifications of on-road and offroad vehicles to minimize combustion related emissions, including GHGs;

• use of dust abatement techniques during construction, such as applying water or 

dust retardant chemicals, to control fugitive dust emissions;

• reduction of the amount of the disturbed land area where possible to control 

fugitive dust emissions; 

• covering or maintaining at least 2 feet of freeboard in the beds of trucks hauling 

dirt, sand, soil, or other loose materials to control fugitive dust emissions; 
4-131 Air Quality And Noise

• reuse of construction debris and use of locally made construction materials to the 

extent feasible to reduce associated GHG emissions; and

• minimization of tree removal during construction to the extent feasible, and 

replacement of landscaping (trees, shrubs, and grasses) to offset the loss of carbon 

sequestration associated with tree removal to reduce GHG emissions.

The mitigation measures employed by Cameron LNG would meet all LDEQ

requirements for construction-related vehicle exhaust emissions. Vehicular exhaust and 

crankcase emissions from gasoline and diesel engines would comply with applicable EPA 

mobile source emission regulations (40 CFR 85) by using equipment manufactured to meet these 

specifications.

Cameron LNG’s control measures to minimize fugitive dust due to vehicle travel would 

meet all LDEQ requirements for fugitive dust mitigation. These measures may include watering 

the disturbed construction area, washing construction equipment, and minimizing the area being 

disturbed to the extent possible during each phase of construction. With incorporation of 

Cameron LNG’s proposed mitigation measures, we believe that fugitive dust emissions 

associated with vehicle travel in and around the construction area would not result in a 

significant impact on regional air quality.

The air emissions and fugitive dust that would occur during construction of the Terminal 

Expansion would be primarily limited to the existing terminal site. These emissions would 

represent a small portion of the parishes’ yearly emissions inventories and would subside once 

construction has been completed. Further, Cameron LNG’s proposed mitigation measures and

its commitment to comply with applicable state and local regulations would minimize 

construction-related air emissions. Therefore, we believe the construction-related impact on 

local air quality during construction would not be significant.

Pipeline Expansion

Emissions

Construction of the Pipeline Expansion would impact air quality due to fugitive dust and 

combustion emissions from operation of gasoline- or diesel-fueled engines in on-road, off-road, 

stationary, and mobile equipment during construction of the pipeline and associated facilities. A 

summary of expected construction emissions is provided in table 4.11.1-8.

Construction of the Pipeline Expansion would also contribute GHG emissions, including 

CH4, CO2, and N2O. Although EPA’s reporting rule does not apply to construction emissions, 

we have included these GHG emissions in table 4.11.1-8 for accounting and disclosure purposes. 
Air Quality And Noise 4-132

TABLE 4.11.1-8

Summary of Pipeline Expansion Construction Emissions

Year

Annual Pollutant Emissions (tons)

NOX CO SO2 PM10 PM2.5 VOC GHG

2015 34.03 67.99 6.7E‐02 56.79 8.66 7.15 7,649

2016 12.05 25.83 2.7E‐02 29.28 3.98 1.84 3,205

TOTAL 46.08 93.82 9.4E‐02 86.07 12.64 8.99 10,854

Abbreviations:

NOX = oxides of nitrogen CO = carbon monoxide

SO2 = sulfur dioxide PM10 = particulate matter less than 10 microns

PM2.5 = particulate matter less than 2.5 microns VOC = volatile organic compounds

HAPs = hazardous air pollutants

GHG = greenhouse gas (as CO2-eq, rounded to whole numbers)

Mitigation Measures

Because pipeline construction moves through an area relatively quickly, air emissions are 

typically intermittent and short-term. Cameron Interstate would employ the same mitigation 

measures for construction of the pipeline and compressor station as described for the Terminal 

Expansion. Air emissions resulting from construction of the Pipeline Expansion facilities would 

subside once construction is completed and would represent a small portion of the parishes’ 

yearly emissions inventories. Therefore, the construction-related impact on local air quality 

would be temporary and would not be significant. 

4.11.1.5 Operation Air Emissions Impacts and Mitigations

Terminal Expansion

Emissions

Emissions during operation of the terminal would be primarily from the following:

• six refrigeration turbines;

• three amine units controlled by a thermal oxidizer;

• three emergency generators;

• three firewater pumps;

• two river water pumps; and

• condensate loading and storage. 

In addition, there would be emissions from mobile sources operating within the moored 

safety zone (mobile sources in and outside of the berthing area are addressed in section 

4.13.2.11, Cumulative Impacts). Pollutants that would be emitted include NOX, CO, GHG, SO2, 
4-133 Air Quality And Noise

PM2.5, PM10, and VOCs. Table 4.11.1-5 lists a facility-wide emission summary based on its

potential-to-emit.

Cameron LNG conducted air dispersion modeling for compliance with PSD and the 

NAAQS for CO, PM2.5, and NO2 for the Terminal Expansion stationary sources. Results of the 

modeling conducted are listed in table 4.11.1-9. The modeling was conducted in accordance 

with the LDEQ guidelines and procedures, as well as the June 28 and 29, 2010 and March 1, 

2011 EPA memoranda for the new 1-hour NO2 standard. Modeling was also conducted for 

mobile sources of air emissions, which include LNG ships and support vehicles; however, these 

mobile source emissions are authorized under Cameron LNG’s existing operations and could 

occur independently of the proposed Terminal Expansion. Further, there would not be an 

increase in LNG carrier traffic for the Terminal Expansion Project beyond that currently 

authorized and the mobile source emissions are not considered in the air permitting process. 

Therefore, the mobile source emissions were not included in the analysis here. Mobile source 

emissions and modeling results are discussed in section 4.13.2.11, Cumulative Impacts. 

TABLE 4.11.1-9

Screening, Modeling, and Increment Consumption Analysis 

for Operation of the Terminal Expansion

Screening Results

Pollutant and 

Averaging Period Year of Highest Levela Modeled Concentration 

(μg/m3

)

Significant Impact 

Level (μg/m3)

CO 1-hour 2007 162.80 2,000

CO 8-hour 2010 51.26 500

PM 2.5 24-hour 2007-2011 5-yr avg 0.69 1.2

PM 2.5 Annual 2011 0.05 0.3

NO2 1-hour All years equal 35.36 7.5

NO2 Annual 2011 0.83 1

Refined Modeling Analysis – 1-hour Average NO2

Averaging Period Year of Highest Level Total Concentration (μg/m3

) 

[Modeled+ Backgroundb

] NAAQS (μg/m3

)

1-hour All years equal 3,113 188

Culpability Analysis – 1-hour Average NO2

Averaging Period Year of Highest Level

Project Contribution to 

Modeled Maximum 

Concentration (μg/m3

)

Significant Impact 

Level (μg/m3

)

1-hour All years equal 0.00014 7.5

Abbreviations:

μg/m3 = micrograms per cubic meter a Meteorological years used were 2007 to 2011. b Background data used most appropriate air pollutant monitoring station, which would have included any 

emissions from existing terminal during 2007 to 2011.
Air Quality And Noise 4-134

The model used was the American Meteorological Society/EPA Regulatory Model 

(AERMOD) version 12060. AERMOD incorporated data from AERMAP (version 11103), the 

terrain preprocessor, AERMET (version 11059), the meteorological preprocessor, and 

AERSURFACE (version 08009), which is used to estimate surface characteristics required for 

input to AERMET. A screening analysis was conducted to determine if emissions from the 

equipment listed above would cause a significant impact. The screening results (table 4.11.1-9) 

indicate that CO and PM2.5 are below their respective PSD modeling significant impact levels 

(SILs). Therefore, further modeling was not required. 

The screening results for the 1-hour average NO2 indicated an exceedance of the SIL, and 

a refined analysis of NO2 emissions was conducted. The results of the refined analysis for the 1-

hour NO2 NAAQS had exceedances of the standard at multiple locations (see table 4.11.1-9). 

The NO2 1-hour NAAQS modeling also included a cumulative assessment of NO2 emissions for 

existing major sources of air emissions in the area of impact for the Terminal Expansion. The 

area of impact for the Terminal Expansion was 6.2 miles (10 km) and included a total of 116 

industrial emissions sources from 26 entities. A culpability analysis was conducted using the 

MAXDCONT post processor to determine if operation of the Terminal Expansion contributed 

significantly (7.5 μg/m3) to any of the exceedances when combined in both time and space. The 

results listed in table 4.11.1-9 indicate that operation of the expanded terminal would not 

contribute significantly to exceedances of the 1-hour NAAQS for NO2. 

We received a comment on the draft EIS from the Sierra Club (comment letter IP2 in 

Appendix L) regarding the Terminal Expansion’s large potential NOX and VOC emissions and 

the potential for ozone formation as a result. In April 2013, Cameron LNG performed 

photochemical grid modeling to determine the impact on ozone concentrations for the 8-hour 

time period due to emissions from the Terminal Expansion. Currently, no standard approach 

exists for modeling ozone impacts from discrete sources. Unlike for other regulatory modeling 

studies for PSD purposes, 40 CFR 51, Appendix W does not identify a preferred model for 

evaluation of ozone impacts from discrete sources. Furthermore, no de minimis levels have been 

established for ozone below which the impacts are deemed not to be significant. Thus, the 

analysis and interpretation of the modeling results is handled on a case-by-case basis. Given that 

the EPA has not issued formal guidance for conducting ozone modeling or interpretation of the 

results, Cameron LNG used methodology provided by EPA Region 6. In addition, the modeling 

protocol incorporated updates suggested by EPA Region 6 subsequent to the environmental 

review of the Sabine Pass Liquefaction Project. Those updates included lowering of the 

threshold from 80 parts per billion (ppb) to 75 ppb to better reflect the current 8-hour ozone 

NAAQS, lowering the screening threshold for grid cell day increase metric from 0.3 to 0.2 ppb, 

and showing daily ozone impact graphics for all days where the Terminal Expansion impacted 

areas were simulated to be above 70 ppb. 

The potential 8-hour ozone impact of the proposed Terminal Expansion emissions was 

quantified using the regional photochemical model, Comprehensive Air Quality Model with 

Extensions (CAMx) in conjunction with the May 26 through July 1, 2006 ozone episode 

prepared for the LDEQ for the Baton Rouge ozone redesignation submittal. The May 26 through

July 1, 2006 episode was used because the episode encompasses nearly two-thirds of the high 

ozone days in the Beaumont/Port Arthur Region.
4-135 Air Quality And Noise

EPA guidance for projecting future 8-hour ozone concentrations recommends using the 

photochemical grid model in a relative sense to scale current observed 8-hour design values 

(EPA 2007). A design value is defined as a 3-year average of the fourth highest daily maximum 

8-hour ozone concentrations at a monitor. Model scaling factors, referred to as relative response 

factors, are used to scale the observed design values in order to predict future year design values.

The project impacts are the differences in the future design values between the project emissions 

simulations and the Future Year Base case simulation. The analysis addresses impacts at known 

monitor locations and unmonitored locations.

Monitors throughout the 8-hour ozone nonattainment Baton Rouge Metropolitan 

Statistical area, the Beaumont/Port Arthur area, and the Houston/Galveston/Brazoria area were 

considered in terms of the incremental ozone impacts due to the Terminal Expansion during the 

ozone episode. The Terminal Expansion impacts were evaluated both at the monitor locations 

and at areas removed from the monitors and an absolute basis, and using the EPA-preferred 

relative response factor basis.

In Louisiana, the Terminal Expansion emissions were estimated to increase the future 

year design value by 0.2 ppb at three monitors in Calcasieu Parish. In Texas, the Terminal 

Expansion emissions were estimated to increase the future year design value by 0.1 ppb at 13 

monitors, and by 0.2 ppb at 2 monitors in Jefferson County. On the relative basis at areas 

removed from the monitors, the primary impacts occur offshore and in Cameron Parish, with 

impacts of between 0.2 and 1.0 ppb. 

Using the absolute basis metrics suggested by EPA Region 6, the Terminal Expansion 

was estimated to impact on-land grid cells greater than 2.0 ppb at limited areas on a single 

episode day (June 29) with the majority of the impact restricted to a very limited area close to the 

terminal site on Lake Calcasieu in Cameron Parish. Depending on the metric, the Terminal 

Expansion emissions were estimated to increase the metric in the Beaumont/Port Arthur area 

between 0.0 percent and 2.7 percent. In the Houston/Galveston/Brazoria area, the Terminal 

Expansion emissions were estimated to increase the metrics by between 0.2 percent and 0.8

percent.

In September 2013, Cameron LNG updated its ozone impact analysis to include the 

authorized Sabine Pass Liquefaction Project. The modeling methodology and analysis was 

similar to Cameron LNG’s analysis summarized above with the exception that the Baton Rouge 

attainment demonstration base case emissions and the Terminal Expansion emissions were 

modified to include the estimated actual emissions from the Sabine Pass Liquefaction Project as 

presented in the Sabine Pass ozone impact analysis.

40 The results were quite similar, with no 

impact changing by more than 0.1 ppb. The inclusion of the Sabine Pass Liquefaction Project 

emissions had a very small impact on the modeling results, with some impact metrics increasing 

slightly and other impact metrics decreasing slightly.

Unlike air quality analyses conducted for other criteria pollutants, the EPA has not 

defined a significance threshold for ozone impacts, especially when evaluating a single facility’s 

contribution to ozone impacts. The CAMx modeling performed by Cameron LNG indicates that 

 40 The “Ozone Impact Analysis of the Proposed Cheniere Sabine Pass Liquefaction Facility” (Docket No. CP11-

72-000) can be accessed through the FERC website at http://ferc.gov/docs-filing/elibrary.asp.
Air Quality And Noise 4-136

the Terminal Expansion would result in small increases in ozone levels compared to existing 

(2006) and baseline 2009 future-case design-value concentrations at some monitoring sites and at 

some unmonitored locations. The potential impact on ozone levels in Louisiana would be 

minimal. The increase in the design value concentrations would be less than 1 percent of the 

baseline 2009 future-case design-value concentrations. The analysis does not show any new 

violations of the 8-hour ozone NAAQS and/or does not show an increase in the severity and/or 

frequency of violations. Therefore, we do not believe impacts on ozone from the Terminal 

Expansion would be significant.

Mitigation Measures

Cameron LNG would minimize potential impacts on air quality due to the operation of 

the Terminal Expansion by adhering to applicable federal and state regulations and installing

BACT to minimize emissions. As presented in Cameron LNG’s Title V Permit application 

modification, the BACT analysis includes identification of all applicable control technologies 

based on control effectiveness. The strictest controls are evaluated first and if those are 

technically or economically infeasible, or if environmental effects are significant, then the next

most stringent control technology is reviewed. The process continues until the BACT level 

being considered cannot be eliminated based on technical or economic considerations, energy or 

environmental impacts. BACT is required for NOX, CO, VOC, PM10, PM2.5, and GHG 

emissions for the proposed equipment.

BACT for Refrigeration Turbines 

For NOX, Dry Low-NOX (DLN) is proposed on the refrigeration compressor turbines 

with an emission rate of 15 parts per million, volumetric dry (ppmvd) at 15 percent oxygen (O2) 

(on an annual basis) as BACT, in addition to the use of good combustion practices. For VOC, 

good combustion practices and the use of natural gas are determined as BACT. For CO, good 

combustion practices to limit maximum CO emissions from the turbines to 0.040 pounds per 

million Btu are determined as BACT. For PM (encompassing both PM10 and PM2.5), good 

combustion practices and the use of natural gas are determined as BACT for turbine emissions.

BACT for Internal Combustion Engines

Internal combustions engines proposed for the Terminal Expansion include diesel-fired 

fire water pumps, river water pumps, and emergency generators, which are required to comply 

with NOX, CO, VOC, and PM10 standards in 40 CFR 60 Subpart IIII (NSPS). In complying with 

Subpart IIII, the equipment would be incompliance with the requirements of 40 CFR 63 Subpart 

ZZZZ (NESHAPS). Compliance with 40 CFR 60 Subpart IIII is determined as BACT for NOX, 

CO, VOC, PM10, and PM2.5 emissions.

BACT for Thermal Oxidizers

Two thermal oxidizers would be installed to control VOC and hydrogen sulfide (H2S) 

within the acid gas vent streams generated by the amine units. This equipment would be 

designed to maximize the destruction efficiency by maximizing the combustion temperature by 

emitting a maximum of less than 0.01 pounds per hour of NOX. Good equipment design, proper 

operating practices, and the use of natural gas are determined as BACT for NOX, CO, VOC, 

PM10, and PM2.5 emissions from the thermal oxidizers.
4-137 Air Quality And Noise

BACT for Flares

Five flares are proposed: two low-pressure flares (one wet flare and one dry flare) and 

three high-pressure flares (one wet flare, one main dry flare, and one spare dry flare). The wet 

and dry flares control vents from the pressure relief devices and depressurizing valves of the 

liquefaction trains. For complete combustion of the flare gas, a flame is maintained at the flare 

tip whenever vent gas is routed to the flare. This practice, along with proper plant operations, 

would minimize NOx, CO, VOC, PM10, and PM2.5 emissions and is determined as BACT for the 

flares.

The existing flare, which controls natural gas and VOC from warm ship cool downs, 

emergency emissions, and maintenance activities, would not generate increased emissions as a 

result of operation of the Terminal Expansion. Physical modifications would not be made to this 

flare and BACT analysis is not required.

BACT from Condensate Tanks, Loading Operations, and Fugitive Emissions

VOC emissions are highest during nighttime hours and tank loading. A closed-vent 

system routed to a control device would be used that meets the requirements of 40 CFR 60 

Subpart Kb (NSPS) and thus are determined to be BACT for the tanks. Good equipment design 

and proper operating practices are BACT for VOC emissions from loading. All rotary pumps 

and compressors handling VOC with a true vapor pressure of 1.5 pounds per square inch 

absolute or greater at handling conditions would be equipped with mechanical seals or other 

equivalent equipment which is determined as BACT for VOC emissions from fugitives.

BACT for Greenhouse Gas Emissions

Installing a leak detection and repair program to minimize methane emissions is 

determined as BACT for GHG emissions from fugitive sources, while proper plant operations to 

minimize flare gas are determined as BACT for GHG emissions for the flares. The use of 

natural gas fired high thermal efficiency turbines in combination with good combustion and 

operating practices are determined as BACT for GHG emissions from the turbines.

Pipeline Expansion

Emissions

The anticipated emissions during operation of the Pipeline Expansion would be from the 

Holbrook Compressor Station and from pipeline maintenance activities, including minor 

emissions from mowers and vehicles. Emissions from the Holbrook Compressor Station would 

be primarily from the 12 natural gas-fired compressor engines (totaling approximately 56,820

horsepower) and the emergency generator engine. Pollutants emitted from these units would 

include NOX, CO, GHG, SO2, VOC, PM2.5, and PM10. There would also be fugitive emissions 

during operation of the compressor station. Table 4.11.1-7 presents an emission summary for the 

compressor station based on its potential-to-emit. 

Cameron Interstate conducted air dispersion modeling for compliance with PSD and the 

NAAQS for both NOX and PM2.5. The modeling was conducted in accordance with the LDEQ 
Air Quality And Noise 4-138

guidelines and procedures, as well as the June 28 and 29, 2010 and March 1, 2011 EPA 

memoranda for the new 1-hour NO2 standard. 

The model used was the AERMOD version 12345. AERMOD incorporated data from 

AERMAP (version 11103), the terrain preprocessor and AERMET (version 11059), the 

meteorological preprocessor. A screening analysis was conducted to determine if emissions 

from the equipment listed above would cause a significant impact. The screening results (table 

4.11.1-10) indicate that PM2.5 is below PSD modeling SILs and preconstruction exemption 

levels. Therefore, further modeling was not required for PM2.5. 

The screening results for maximum offsite concentrations of NO2 were below 

preconstruction monitoring exemption levels. However, the annual and 1-hour averaging 

periods were exceeded for the SIL, and a refined analysis of NO2 emissions was conducted. The 

results of the refined analysis for annual NO2 NAAQS had no exceedances of the NAAQS, but 

the 1-hour NAAQS results had exceedances of the standard (see table 4.11.1-10). The 

culpability analysis conducted using the MAXDCONT post processor indicated that operation of 

the Holbrook Compressor Station would not contribute significantly to exceedances of the 1-

hour NAAQS (see table 4.11.1-10). 

An increment consumption analysis was also conducted to compare results to Class II 

allowable PSD increment consumption standards for the annual NO2 NAAQS. That analysis 

resulted in levels that were below Class II levels and indicated that the Holbrook Compressor 

Station was in compliance with the standard. 

This modeling included a total of 380 industrial emissions sources from 16 entities and 

represents a cumulative assessment of NO2 emissions for existing major sources of air emissions 

in the area of impact for the Holbrook Compressor Station (32 miles [52 km]).
4-139 Air Quality And Noise

TABLE 4.11.1-10

Screening, Modeling, and Increment Consumption Analysis 

for Operation of the Holbrook Compressor Stationa

Screening Results

Pollutant and 

Averaging Period

Year of Highest 

Level

Modeled 

Concentration 

(μg/m3

)

Significant Impact 

Level (μg/m3

)

Monitoring 

Exemption Level 

(μg/m3

)

PM2.5 24-hour 

(5-year) All years equal 0.96 1.2 4

PM2.5 Annual All years equal 0.004 0.3 NA

NO2 1-hour (5-year) All years equal 118 7.5 NA

NO2 Annual 2007 3.95 1 14

Refined Modeling Analysis – NO2

Averaging Period Year of Highest 

Level

Modeled 

Concentration 

(μg/m3

)

Project 

Contribution to 

Modeled Maximum 

Concentration 

(μg/m3)

NAAQS (μg/m3

)

1-hour (5-year) All years equal 257b 0.00347 188

Annual 2007 73.81c NR 100

Increment Consumption Analysis - NO2

Averaging Period Year of Highest Level

Modeled Maximum 

Concentration Annual 

Average All Sources 

(μg/m3)

Increment Consumption 

Standard (μg/m3

)

Annual 2007 9.63 25

Abbreviations:

μg/m3 = micrograms per cubic meter

NA = not applicable

NR = not required

a Meteorological years used were 2007 to 2011 b Maximum daily 8th high for all sources c Annual average plus 5-year background concentration

Mitigation Measures

Cameron Interstate has committed to comply with all applicable state and local air 

permitting requirements during construction and operation of the Holbrook Compressor Station. 

Under a new PSD permit for the Holbrook Compressor Station, a BACT analysis similar to that 

described above for the Terminal Expansion was performed. BACT would be implemented for 

the stationary gas compressor and emergency diesel generator and is required to control NOX, 

VOC, and PM2.5.
Air Quality And Noise 4-140

BACT for Compressors

For NOX, lean-burn combustion with an emission rate of 0.7 grams per brake 

horsepower-hour (BHP-hr) for the compressors, along with good combustion practices, is 

determined as BACT. 

For VOCs, CO oxidation catalyst control would be implemented, along with the use of 

good combustion practices which follow the manufacturer’s recommendations for maximum fuel 

efficiency and minimal emissions of 0.36 grams per BHP-hr for the compressors, which is 

determined as BACT.

For PM2.5, the use of natural gas, along with good combustion practices, is determined as 

BACT for the compressors, achieving emission limits of 7.7 x 10-5 pounds per million Btu.

BACT for Internal Combustion Engine

For NOX, the use of low sulfur fuel, good combustion practices, including operation and 

maintenance of the generator as recommended by the manufacturer for maximum fuel efficiency 

and minimal emissions, and compliance with 40 CFR 60 Subpart IIII (NSPS) for a combined 

limit of 4.8 grams per BHP-hr of non-methane hydrocarbons and NOx are determined as BACT 

for the emergency generator.

For VOC, good combustion practices including operation and maintenance of the 

generator as recommended by the manufacturer for maximum fuel efficiency and minimal 

emissions with a limit of 0.28 grams per BHP-hr is determined as BACT for the emergency 

generator.

For PM2.5, the use of low sulfur fuel and an emergency generator certified by the 

manufacturer, and a non-emergency operational limitation of 100 hours per year is determined as 

BACT.

As a result of incorporation of BACT, we believe that air quality impacts due to 

construction and operation of the proposed Pipeline Expansion would be minor. 

4.11.2 Noise

Sound is mechanical energy transmitted by pressure waves in media such as air or water

(FTA 2006). When sound becomes excessive, annoying, or unwanted, it is referred to as noise. 

Noise levels are quantified using units of decibels (dB). Noise may be continuous (constant 

noise with a steady decibel level), steady (constant noise with a fluctuating decibel level), 

impulsive (having a high peak of short duration), stationary (occurring from a fixed source), 

intermittent (at intervals of high and low sound levels), or transient (occurring at different rates). 

Ambient sound levels, or background sound levels, result from sound emanating from 

natural and artificial sources. The magnitude and frequency of background noise may vary 

considerably over the course of a day and throughout the year, caused in part by weather 

conditions, seasonal vegetative cover, and human activity. Two measures used by federal 

agencies to relate the time-varying quality of environmental sound levels to known effects on 

people are the 24-hour equivalent sound level (Leq(24)) and the day-night sound level (Ldn). The 
4-141 Air Quality And Noise

Leq(24) is the level of steady sound with the same total energy as the time-varying sound, averaged 

over a 24-hour period. The Ldn is the Leq(24) with 10 decibels on the A-weighted decibel scale 

(dBA) added to the nighttime sound levels between the hours of 10 p.m. and 7 a.m., to account 

for people’s greater sensitivity to sound during nighttime hours. 

The potential for noise impacts can be assessed by considering the sound level increase 

over existing levels at receptors, referred to as noise-sensitive areas (NSAs) such as residences, 

schools, or hospitals. In general, an increase of 3 dBA is barely detectable by the human ear and 

an increase of 5 dBA is considered clearly noticeable. Increases of 10 dBA are perceived as a 

doubling of noise or twice as loud.

During construction, sound levels would increase in the vicinity of the Terminal 

Expansion site and the Pipeline Expansion area. During operation, sound levels would increase 

in the vicinity of the Terminal Expansion site and the Holbrook Compressor Station. EPA

indicated that an Ldn of 55 dBA protects the public from indoor and outdoor activity interference. 

We have adopted this criterion and use it to evaluate the potential noise impacts from operation 

of new and modified natural gas pipeline facilities. An Ldn of 55 dBA is equivalent to a 

continuous sound level of 48.6 dBA for facilities that generate constant sound levels. 

The State of Louisiana, Cameron Parish, and Beauregard Parish do not have regulations 

that would limit noise from the Project. 

Calcasieu Parish has a noise ordinance (Code of Ordinances, Chapter 18, Article VIII –

Disturbing the Peace) that does not set specific sound level limits, but rather restricts excessive 

noise as follows: “No person shall make, continue, or cause to be made or continued any loud, 

unnecessary or excessive noise which unreasonably interferes with the comfort and repose of 

others within the jurisdiction of the parish.” (Sec 18-96) (Municipal Code Corporation, 2003).

Applicable exemptions include:

• Sec 18-99, paragraph (3) “Noises made by persons having obtained a permit.”;

• Sec 18-99, paragraph (4) “Any noise resulting from activities of temporary 

duration, for which a permit has been granted pursuant to this article, and which 

conforms to the conditions and limits stated thereon.”; and 

• Sec 18-100, paragraph (4) “Construction and demolition. The operating of any 

equipment used in construction work within 165 feet of any residential or noise 

sensitive area between sunset and sunrise on weekdays and Saturdays, and 9:00 

p.m. and 8:00 a.m. on Sundays and holidays, except for emergency work.”

4.11.2.1 Existing Sound Levels and Noise-Sensitive Areas

Cameron LNG and Cameron Interstate evaluated potential noise impacts during operation 

by conducting a background noise level survey and noise impact evaluation at the nearest NSAs,

during operation of the Project. The noise impact evaluations included development of estimated 

sound level increases during construction and operation and comparing those estimates to our 

standard for permissible sound levels at NSAs.
Air Quality And Noise 4-142

Terminal Expansion

The only NSA in the vicinity of the Terminal Expansion site is a rural residence about 1.2

miles northwest of the site boundary. The NSA is on the Gulf Intracoastal Waterway, near the 

Ellender Bridge, west of LA-27. Ambient sound levels were determined based on measurements 

recorded during a July 2009 the FERC noise compliance survey for the existing Cameron LNG 

Terminal. The measurements were recorded at a sound level measurement location 1.1 miles 

southeast of the NSA and closer to the existing LNG Terminal.41 However, both the NSA and 

sound level measurement location are within similar land use areas and have similar ambient 

sound levels. The next nearest NSA is 1.5 miles northwest of the acoustic center of the site and 

would not be affected by increases in sound levels at the site of the expanded terminal; therefore, 

this NSA was not included in our analysis. 

The primary sources of sound generation during the July 2009 measurements included 

distant traffic sounds from nearby LA-27, natural sounds from birds and insects, and sound from 

the existing LNG Terminal). Measurements were conducted between the hours of 10:15 pm and 

10:45 pm. The Leq(24) was 44.5 dBA and the Ldn was 50.9 dBA.

Pipeline Expansion 

Ambient sound levels in the vicinity of the proposed construction right-of-way and the 

Holbrook Compressor Station site were estimated based on typical sound levels by land use type. 

Land uses in those areas were determined through a review of aerial photography. This 

technique is consistent with estimates of ambient sound levels conducted by EPA (1978) and the 

American National Standards Institute (ANSI). The ANSI standard sound level estimation uses 

six land use categories and is generally consistent with the levels calculated by EPA (see table 

4.11.2-1). All NSAs identified for the pipeline and associated facilities are in Category 6, Very 

Quiet Sparse Suburban or Rural Areas. For those land use areas, the assumed Leq(24) is 43 dBA, 

with an Ldn of 45 dBA. Table 4.11.2-2 lists each proposed HDD entry or exit site along with the 

nearest NSA.

The NSA nearest the Holbrook Compressor Station site is a residence approximately 

3,200 feet (0.6 mile) from the proposed site. Other nearby residences range from 4,900 feet (0.9 

mile) to 7,500 feet (1.4 miles) from the site. Figure 4.11-1 depicts the NSAs within 1 mile of the 

proposed Holbrook Compressor Station. Land use Category 6 was also used to estimate the 

ambient sound levels at these NSAs.

 41 At the time the sound level measurements were recorded, the measurement location was a residence and 

considered an NSA. However, Cameron LNG purchased the property and it is no longer a residence. 
4-143 Air Quality And Noise

TABLE 4.11.2-1

American National Standards Institute Land Use Categories for Estimating Ambient Noise Levels

Category Land Use Description

Estimated

Existing

Daytime

Leq(24) (dBA)

Estimated

Existing Ldn

(dBA)

1

Noisy Commercial 

and Industrial 

Areas

Very heavy traffic conditions, such as in busy

downtown commercial areas, at intersections of

mass transportation and other vehicles, including

trains, heavy motor trucks and other heavy traffic,

and street corners where motor buses and heavy

trucks accelerate

69 70

2

Moderate 

Commercial and

Industrial Areas, 

and Noisy

Residential Areas

Heavy traffic areas with conditions similar to

Category 1 but with somewhat less traffic, routes of

relatively heavy or fast automobile traffic but where

heavy truck traffic is not extremely dense, and motor 

bus routes

64 65

3

Quiet Commercial,

Industrial Areas, 

and Normal Urban 

and Noisy

Residential Areas

Light traffic conditions where no mass transportation 

vehicles and relatively few automobiles and trucks 

pass, and where these vehicles generally travel at 

low speeds. Residential areas and commercial 

streets and intersections with little traffic comprise 

this category.

58 60

4 Quiet Urban and 

Normal

These areas are similar to Category 3 above but, for 

this group, the background is either distant traffic or 

is unidentifiable.

53 55

5 Quiet Suburban

Residential Areas Isolated areas, far from significant sources of sound 48 50

6

Very Quiet, 

Sparse Suburban 

or Rural Areas

These areas are similar to Category 5 above but are 

usually in unincorporated areas and, for this group, 

there are few if any near neighbors

43 45
Air Quality And Noise 4-144

TABLE 4.11.2-2

Noise Analysis for Daytime HDD Boring

Station

Distance

(feet)

/Direction

Land Use

Category

Existing

Daytime

Leq(24) (dBA) 

a

Calculated 

HDD Leq(24)

Noise Level

Combined 

Future Level

(Existing Plus

HDD)

Increase Over

Existing

Leq(24)

Houston River HDD Entry 850 / SE 5 48 58.4 58.8 10.8

Houston River HDD Exit 1700 / SW 5 48 46.0 50.1 2.1

Little River HDD Entry 3050 / SE 5 48 42.6 49.1 1.1

Little River HD Exit 2350 / NW 5 48 46.1 50.2 2.2

Beckwith Creek HDD 

Entry 1650 / SE 6 43 52.4 52.9 9.9

Beckwith Creek HDD Exit 2450 / S 6 43 42.5 45.8 2.8

Hickory Branch HDD Entry 6400 / SW 6 43 37.8 44.1 1.1

Hickory Branch HDD Exit 7900 SW 6 43 29.1 43.2 0.2

Indian Bayou HDD Entry 580 / N 5 48 61.5 61.7 13.7

Indian Bayou HDD Exit 1600 / E 5 48 46.9 50.5 2.5

Marsh Bayou HDD Entry 1200 / SW 6 43 55.5 55.7 12.7

Marsh Bayou HDD Exit 2000 / NW 6 43 44.4 46.8 3.8

a

Estimated Leq(24) based on land use as set forth in ANSI 12.9-1993/Part 3.
4-145 Air Quality And Noise

Figure 4.11-1 Noise Sensitive Areas within 1 mile of the Holbrook 

Compressor Station
Air Quality And Noise 4-146

4.11.2.2 Construction Noise Impacts and Mitigation

Terminal Expansion

The most prevalent sound generating equipment during construction of the Terminal 

Expansion would be internal combustion engines of construction equipment (up to 90 dBA at 50 

feet) and pile driving (up to 95 dBA at 50 feet). The sound levels experienced at the NSAs 

would depend on the type of equipment used, the mode of operation of the equipment, the length 

of time the equipment is in use, the amount of equipment used simultaneously, and the distance 

between the sound generation source and the receptor. Sheet and pile driving could produce 

peak sound levels that would be perceptible above the prevalent sound levels during 

construction. Cameron LNG would restrict sheet and pile driving activities to daylight hours to 

prevent nighttime noise impacts. Increased sound levels during construction would occur for the 

duration of the construction period. Sound levels would be reduced a minimum of 6 dBA for 

each doubling of distance between the source and the receiver. Based on the distance to the NSA 

(1.2 miles or 6,336 feet), sound levels from construction equipment could reach 48 dBA, which 

is less than our noise criteria of an Ldn of 55 dBA noise, and would not be expected to result in 

adverse impacts on the NSA. Sheet and pile driving could contribute sound levels of 53 dBA, 

which is also less than our noise criteria, and would also not be expected to result in significant 

impacts on the NSA. 

Increases in sound levels during construction activities would be intermittent and would 

generally occur during daylight hours. However, certain activities may need to be conducted 

during non-daylight hours to avoid construction schedule delays, including the unloading/staging 

of materials, barge unloading, and welding activities. Construction noise levels for these 

activities are minimal. If perceived noise levels cause a nuisance at the nearby NSAs and 

residents are inconvenienced, Cameron LNG would provide alternative accommodations for 

residents during the activity contributing to noise levels that are greater than expected.

Pipeline Expansion 

Sound level increases during pipeline construction would be intermittent and would 

generally occur during daylight hours, with the exception of some HDD activities. The most 

prevalent sound generating equipment would be internal combustion engines of construction 

equipment (up to 90 dBA at 50 feet). 

Based on the type of equipment proposed for construction, sound levels would not be 

expected to exceed 90 dBA at 50 feet from the edge of the construction right-of-way for the 

pipeline or from the edge of the Holbrook Compressor Station site. Beyond these points, sound 

levels would be reduced a minimum of 6 dBA for each doubling of distance. The NSA closest to 

the Holbrook Compressor Station is about 0.6 mile from the site, and sound levels from 

construction would reach 65 dBA. 

The HDD construction method is proposed at six waterbody crossings. The primary 

sound generation during HDD activities would be from the diesel engines that power the drilling

equipment. Sound levels measured at HDD sites using a 600-horsepower diesel engine at full 

load indicate that the sound level is approximately 85 dBA at 50 feet from the edge of the entry 

site. HDD exit locations, which require less equipment, typically generate a sound level of 
4-147 Air Quality And Noise

approximately 79 dBA at 50 feet from the site. Table 4.11.2-2 lists the estimated HDD noise 

impacts at the NSAs nearest to the HDD sites, the closest of which is 584 feet from an HDD 

entry site.

With the exception of NSAs near the Little River HDD exit site and the Hickory Branch 

HDD exit site, sound levels from the HDD equipment would exceed our noise criteria of 55 

dBA, including during nighttime hours. To ensure that noise level increases at the nearest 

residences are less than 10 dBA, with an Ldn of 55 dBA, due to HDD activities, Cameron 

Interstate committed to implement the following measures, as needed: 

• reconfiguration of equipment locations to take advantage of natural and artificial 

noise barriers; 

• installation of a partial noise barrier around the hydraulic power unit, including 

the engine and associated engine jacket-water cooler (for example covering two 

sides of the power unit with a plywood barrier system approximately 14 feet 

high); 

• use of residential-grade silencers or mufflers on engines;

• use of gear box noise blankets and other mechanical noise dampening blankets, 

acoustical tents, and acoustical barriers; and 

• use of “low noise” generators. 

During initial drilling of the HDD entry points at the Houston River, Indian Bayou, 

Beckwith Creek, and Marsh Bayou sites, which are nearest to the NSAs (see table 4.11-2-2),

Cameron Interstate would collect noise measurements to confirm that noise levels at the nearest 

NSAs are acceptable. Cameron Interstate would also reimburse nearby residents who may elect 

to use temporary housing at a local commercial hotel during HDD-related construction activities 

if the residents indicate that noise generated by the HDD activities are unacceptable. To ensure 

that HDD-related noise does not exceed an Ldn of 55 dBA and/or increase noise over ambient 

conditions greater than 10 dBA, we are recommending that:

• Cameron Interstate file in the weekly construction status reports the 

following for the entry points of the Houston River, Indian Bayou, Beckwith 

Creek, and Marsh Bayou HDD sites:

a. the noise measurements from the nearest NSA, obtained at the start of 

drilling operations;

b. the noise mitigation that Cameron implemented at the start of drilling 

operations; and

c. any additional mitigation measures that Cameron would implement if 

the initial noise measurements exceeded an Ldn of 55 dBA at the 

nearest NSA and/or increased noise is over ambient conditions greater 

than 10 dB. 

Cameron Interstate would comply with the requirements of the noise ordinance in

Calcasieu Parish and would limit construction to the daytime hours as listed above. With regard 
Air Quality And Noise 4-148

to Section 18-100, any HDD activities requiring 24-hour operations would not be exempt from 

noise restrictions in Calcasieu Parish. We believe that Cameron Interstate’s commitments would 

lessen impacts on residents to the extent practicable.

Noise associated with pipeline construction activities would be intermittent because of 

the transitory nature of the construction activities. Cameron Interstate would limit operation of 

construction equipment to only that necessary to perform the required activities. While the noise 

levels attributable to the construction equipment could noticeably increase ambient noise levels 

at the NSAs nearest the pipeline right-of-way and the Holbrook Compressor Station site, the 

noise increase during the construction phase would be temporary and localized. With 

construction mostly limited to daytime hours, incorporation of Cameron Interstate’s proposed 

mitigation, and implementation of our recommendation, we believe that the landowners and 

residents near the pipeline and compressor station site would not be significantly affected by 

construction-related noise.

4.11.2.3 Operation Noise Impacts and Mitigation

Terminal Expansion

Operation of the expanded terminal would generate sound levels that would occur 

throughout the life of the Project. Noise would generally be produced on a continuous basis at 

the liquefaction facility by a number of sources which would include various types of 

compressors and cooling fans. Operational noise levels were assessed based on all three 

liquefaction trains and associated equipment operating at full capacity concurrently. The 

estimated Ldn of the Terminal Expansion facilities would be 54.2 dBA at the nearest NSA and 

would increase the noise level by 3.3 dBA at the nearest NSA, from 50.9 dBA to 54.2 dBA, 

which is slightly above the “barely detectable” increase level of about 3 dBA above the current 

ambient noise level. This estimated noise level would be below our noise criteria of 55 dBA Ldn. 

Cameron LNG would house the compressors in acoustically-treated enclosures and install 

exhaust stack silencers on certain of the combustion turbines with specific noise design limits. 

Refrigeration turbine air intakes and exhausts would be fitted with appropriate silencers that 

would extend outside the buildings.

As discussed in sections 1.0 and 2.7.1, while liquefying natural gas and exporting LNG, 

the Terminal Expansion would retain the capability to regasify (vaporize) imported LNG. While 

the design of the facility would allow for simultaneous liquefaction and regasification, market 

conditions would make that an unrealistic scenario, and Cameron LNG’s commercial agreements

preclude simultaneous regasification and liquefaction. Therefore, at any point in time the 

expanded terminal would be operated exclusively as a liquefaction/ export facility or exclusively 

as an import/regasification facility, and there is no potential for noise levels to exceed 55 dBA 

under this scenario. 

Operation of the Terminal Expansion would occur in phases with the first liquefaction 

train and associated facilities to be completed and in service in 2017, followed by the second and 

third liquefaction trains in service in 2018. Therefore, to ensure that NSAs are not adversely 

impacted by the phased operation of the expanded Cameron LNG Terminal, we are 

recommending that: 
4-149 Air Quality And Noise

• Cameron LNG file a full load noise survey with the Secretary for the 

Terminal Expansion no later than 60 days after each liquefaction train is 

placed into service for the first and second liquefaction train. If the noise 

attributable to the operation of the equipment at the Terminal Expansion 

exceeds an Ldn of 55 dBA at the nearby NSA, Cameron LNG should reduce 

operation of the liquefaction facilities or install additional noise controls until 

a noise level below an Ldn of 55 dBA at the nearby NSA is achieved. 

Cameron LNG should confirm compliance with the above requirement by 

filing a second noise survey with the Secretary no later than 60 days after it 

installs the additional noise controls.

In compliance with the condition above, Cameron LNG would need to complete two 

noise surveys after the first and second liquefaction trains are placed in-service to ensure that the 

phased-in liquefaction trains are below 55 dBA Ldn at the nearest NSA. If the noise levels 

reported in any of the noise surveys are over 55 dBA Ldn, Cameron LNG would need to 

implement the required mitigation to reduce the noise impacts on the nearest NSAs within the 

time specified in the condition. Once the third liquefaction train is installed and placed into 

service, we are recommending that:

• Cameron LNG file a noise survey with the Secretary no later than 60 days

after placing the Terminal Expansion into service. If a full load noise survey 

is not possible, Cameron LNG should provide an interim survey at the 

maximum possible load and provide the full load survey within 6 months. If 

the noise attributable to the operation of all of the equipment at the Terminal 

Expansion under interim or full load conditions exceeds an Ldn of 55 dBA at 

the nearby NSA, Cameron LNG should file a report on what changes are 

needed and should install the additional noise controls to meet the level 

within 1 year of the in-service date. Cameron LNG should confirm 

compliance with the above requirement by filing a second noise survey with 

the Secretary no later than 60 days after it installs the additional noise 

controls.

Based on the results of the noise analysis and our recommendation, we believe that 

operational noise from the Terminal Expansion would have no significant impact on the noise 

environment in the vicinity of the Terminal Expansion. 

Pipeline Expansion 

There would be an increase in sound levels due to operation of the Holbrook Compressor 

Station and during maintenance activities. Those sound level increases would occur for the life 

of the Project. The major noise-generating equipment at the compressor station would be the 

reciprocating engines and the fin fan-type gas coolers. Table 4.11.2-3 summarizes the estimated 

ambient noise levels and the predicted operational noise levels at the nearby NSAs for the 

Holbrook Compressor Station. 
Air Quality And Noise 4-150

TABLE 4.11.2-3

Estimated Noise Levels at Noise Sensitive Areas Near the Holbrook Compressor Station

Noise 

Sensitive 

Location

Distance and 

Direction

Sound Levels (dBA) Change in 

Background Sound 

Background Level (dBA)

(Ldn)

Estimated Ldn During 

Operation [including 

background levels]

1 3,200 feet (E) 45 50.8 5.8

2 4,900 feet (ESE) 45 47.6 2.6

3 6,000 feet. (ESE) 45 46.9 1.9

4 6,100 feet (ESE) 45 46.8 1.8

5 6,600 feet (ESE) 45 46.5 1.5

6 7,500 feet (SE) 45 46.3 1.3

Abbreviations:

NSA= Noise Sensitive Area E = east

ESE = east-southeast SE = southeast

Ldn = day-night equivalent sound level dBA = decibels on the A-weighted scale

The estimated Ldn of the Holbrook Compressor Station would be 49.5 dBA and would 

increase the noise level at the nearest NSA from 45 dBA to 50.8 dBA. While overall noise levels 

at the nearest NSA would be below our criteria of 55 dBA Ldn, the potential increase would be 

about 5.8 dB, which would be a noticeable increase in noise at the NSA. Cameron Interstate 

would implement mitigation measures to reduce noise impacts, such as installing the compressor 

units in an acoustically-designed building. Cameron Interstate would also install exhaust stack 

silencers and combustion air intake silencers, as necessary to comply with our noise criteria.

Based on our noise analysis, noise levels attributable to operation of the Holbrook 

Compressor Station would be less than 55 dBA Ldn at all nearby NSAs. To ensure that the noise 

from the compressor station does not exceed an Ldn of 55 dBA at the nearest NSAs, we are 

recommending that:

• Cameron Interstate file a noise survey for the Holbrook Compressor Station 

no later than 60 days after placing the station into service. If a full power 

load condition noise survey is not possible, Cameron Interstate should file an 

interim survey at the maximum possible power load within 60 days of 

placing the station into service and file the full power load survey within 6 

months. If the noise attributable to operation of all equipment at the station 

under interim or full power load conditions exceeds an Ldn of 55 dBA at any 

nearby NSA, Cameron Interstate should:

a. file a report with the Secretary, for review and written approval by 

the Director of OEP, on what changes are needed;
4-151 Safety

b. install additional noise controls to meet that level within 1 year of the 

in-service date; and 

c. confirm compliance with this requirement by filing a second full 

power load noise survey with the Secretary for review and written 

approval by the Director of OEP no later than 60 days after it installs 

the additional noise controls.

The compressor station site is near several parcels on Holbrook Road for which the 

current landowner has indicated the potential desire for residential and/or commercial/business 

development. In its negotiations for acquiring the compressor station site, Cameron Interstate 

agreed to maintain the station property at a minimum distance of 1,500 feet north north-east of 

Holbrook Park Road. The land purchase option agreement also contains provision for noise 

requirements to which the landowner and Cameron Interstate have agreed. Specifically, 

Cameron Interstate would design the compressor station such that the noise level at 1,000 feet 

from the property site not exceed 55 dBA.

The only sound level increases associated with operation of the pipeline would be 

indirect noise resulting from vehicle and equipment use during maintenance and inspection 

activities. However, these activities would be transient, short-term, and would not be 

significantly more audible than normal vehicle traffic at the nearest NSAs along the pipeline 

right-of-way.

Based on the noise analysis and our recommendation, we believe that operation of the 

Pipeline Expansion would have no significant impact on the noise environment in the vicinity of 

the Pipeline Expansion.

4.12 SAFETY

4.12.1 Regulatory Agencies

Three federal agencies share regulatory authority over the siting, design, construction and 

operation of LNG import terminals: the Coast Guard, the DOT, and the FERC. The Coast Guard 

has authority over the safety of an LNG facility’s marine transfer area and LNG marine traffic, 

as well as over security plans for the entire LNG facility and LNG marine traffic. Those 

standards are codified in 33 CFR Parts 105 and 127. The DOT establishes federal safety 

standards for siting, construction, operation, and maintenance of onshore LNG facilities, as well 

as for the siting of marine cargo transfer systems at waterfront LNG plants. Those standards are 

codified in 49 CFR 193. Under the NGA and delegated authority from the DOE, the FERC 

authorizes the siting and construction of LNG import and export facilities.

In 1985, the FERC and DOT entered into a memorandum of understanding (MOU) 

regarding the execution of each agency’s respective statutory responsibilities to ensure the safe 

siting and operation of LNG facilities. In addition to the FERC’s existing ability to impose 

requirements to ensure or enhance the operational reliability of LNG facilities, the MOU 

specified that the FERC may, with appropriate consultation with DOT, impose more stringent 

safety requirements than those in Part 193.
Safety 4-152

In February 2004, the Coast Guard, DOT, and the FERC entered into an Interagency 

Agreement to ensure greater coordination among these three agencies in addressing the full 

range of safety and security issues at LNG terminals, including terminal facilities and tanker 

operations, and maximizing the exchange of information related to the safety and security 

aspects of the LNG facilities and related marine operations. Under the Interagency Agreement, 

the FERC is the lead federal agency responsible for the preparation of the analysis required 

under NEPA for impacts associated with terminal construction and operation. The DOT and 

Coast Guard, when necessary, participate as cooperating agencies.

As part of the review required for a FERC authorization, Commission staff must ensure 

that all proposed facilities would operate safely and securely. The design information that must 

be filed in the application to the Commission is specified by 18 CFR 380.12 (m) and (o). The 

level of detail necessary for this submittal requires the Project sponsor to perform substantial 

front-end engineering of the complete facility. The design information is required to be sitespecific and developed to the extent that further detailed design would not result in changes to 

the siting considerations, basis of design, operating conditions, major equipment selections, 

equipment design conditions, or safety system designs which we considered during our review 

process. 

The FERC’s filing regulations also require each applicant to identify how its proposed 

design would comply with DOT’s siting requirements in 49 CFR 193, Subpart B. As part of our 

NEPA review, we use this information from the applicant to assess whether or not a facility 

would have a public safety impact. As a cooperating agency, DOT assists FERC staff in 

evaluating whether an applicant’s proposed siting meets the DOT requirements. If a facility is 

constructed and becomes operational, the facility would be subject to DOT’s inspection program. 

Final determination of whether a facility is in compliance with the requirements of 49 CFR 193 

would be made by DOT staff.

In accordance with 33 CFR 127, the Coast Guard has reviewed the proposed liquefaction 

facilities and stated that a Letter of Intent (LOI) or a revision to the WSA is not required for the 

Terminal Expansion Project because the proposed modifications lie outside the Marine Transfer 

Area. A copy of the correspondence between Cameron LNG and the Coast Guard is included in 

Appendix A.11 of the application.42

Section 4.12.2 discusses the principal properties and hazards associated with LNG; 

section 4.12.3 discusses our technical review of the preliminary design; section 4.12.4 discusses 

siting requirements for the Terminal Expansion facilities; section 4.12.5 includes a siting analysis 

of hazards resulting from a land based LNG spill; section 4.12.6 discusses emergency response 

and evacuation planning, section 4.12.7 discusses the Terminal Expansion security, and section 

4.12.8 discusses pipeline safety.

4.12.2 Hazards

Before liquefaction, Cameron LNG would pre-treat the feed gas for the removal of 

mercury, hydrogen sulfide, and carbon dioxide. The hazards associated with the removal of 

these substances from the feed gas stream result from the physical and chemical properties, 

 42 Accession number: 20121207-5141.
4-153 Safety

flammability, and toxicity of mercury, hydrogen sulfide, and amine. Cameron LNG proposes a 

design capacity to handle up to 100 micrograms per normal cubic meter (μg/Nm3

) mercury, 4 

parts per million by volume hydrogen sulfide, and 3 percent by volume (%-vol) CO2. However, 

lower quantities and concentrations of these substances would be expected in the natural gas feed 

stream and would not pose a hazard to the public. Mercury in the feed gas would be removed by 

adsorption in the mercury removal units. Hydrogen sulfide would be removed by permanently 

bonding to scavenger beds, the equipment that contains absorbing materials to reduce hydrogen 

sulfide concentration in the feed stream. Cameron LNG would need to replace the mercury and

scavenger beds by the end of their service life. Maintenance and safety procedures would cover 

the proper replacement and disposal of these beds. The amine solution would be contained, as 

discussed under “Impoundment Sizing” in section 4.12.5, and handled at temperatures below the 

point at which it could produce enough vapors to form a flammable mixture. Therefore, the 

amine solution would not pose a significant hazard to the public, which would have no access to 

the on-site areas. 

Cameron LNG would install a heavy hydrocarbon removal system to remove pentane and 

heavier hydrocarbons that may be present in the feed gas. During this removal process, natural 

gas liquid (NGL) would be extracted and handled on-site at temperature and pressure conditions 

under which a loss of containment would result primarily in a vapor release and the ability to 

produce damaging overpressures. The resulting stabilized condensate, which includes pentane 

and heavier hydrocarbons, would be stored on-site at atmospheric pressure and temperature. 

Due to the temperature and pressure conditions under which the stabilized condensate would be 

stored and handled, a loss of containment would primarily result in a liquid release. The liquid 

spill would be contained in impoundments, as discussed under “Impoundment Sizing” in section 

4.12.5, and would not present an offsite hazard to the public. The principal hazards associated 

with the storage and sendout of condensate would result from loss of containment and the 

flammability and toxicity of the substances used or produced in the heavy hydrocarbon removal 

system.

The principal hazards associated with the liquefaction and storage of LNG and 

refrigerants result from loss of containment, vapor dispersion characteristics, flammability, and 

the ability to produce damaging overpressures. A loss of the containment provided by storage 

tanks or process piping would result in the formation of flammable vapor at the release location, 

as well as from any LNG or liquid flammable refrigerant that pooled. Releases occurring in the 

presence of an ignition source would most likely result in a fire at the vapor source. A spill 

without ignition would form a vapor cloud that would travel with the prevailing wind until it 

either dispersed below the flammable limits or encountered an ignition source. In some 

instances, ignition of a vapor cloud may produce damaging overpressures. These hazards are 

described in more detail below.

4.12.2.1 Loss of Containment

Cameron LNG would store the following on-site: LNG at atmospheric pressure and at a 

cryogenic temperature of approximately -260 °F; liquid ethylene at approximately 754 pounds 

per square inch gage and -26°F; liquid propane at ambient temperature and elevated pressures 

(similar to the conditions typically used in propane storage and distribution); and stabilized 

condensate at ambient temperature and pressure. 
Safety 4-154

The mixed refrigerant process stream would consist of methane, ethylene, propane, and 

nitrogen. Cryogenic temperatures as low as -260°F would occur within the mixed refrigerant 

process stream used to liquefy the feed gas. The temperature of NGL in the heavy hydrocarbon 

removal process stream would be as low as -137°F. Loss of containment of LNG, mixed 

refrigerant liquid (MRL), and NGL could lead to the release of both liquid and vapor into the 

immediate area. Exposure to either cold liquid or vapor could cause freeze burns and, depending 

on the length of exposure, more serious injury or death. However, spills would be contained to 

on-site areas and the cold state of these releases would be greatly limited due to the continuous 

mixing with the warmer air. The cold temperatures from the release would not present a hazard 

to the public, which would not have access to on-site areas. 

LNG and MRL are cryogenic liquids that would quickly cool any materials contacted by 

the liquid on release, causing extreme thermal stress in materials not specifically designed for 

such conditions. These thermal stresses could subsequently subject the material to brittleness, 

fracture, or other loss of tensile strength. These temperatures, however, would be accounted for 

in the design of equipment and structural supports, and would not be substantially different from 

the hazards associated with the storage and transportation of liquid oxygen (-296oF) or several 

other cryogenic liquids that have been routinely produced and transported in the United States. 

4.12.2.2 Vapor Dispersion

In the event of a loss of containment, LNG, ethylene, propane, and NGL would vaporize 

on release from any storage or process facilities. Depending on the size of the release, cryogenic 

liquids, such as LNG and MRL, as well as NGL may form a liquid pool and vaporize. 

Additional vaporization would result from exposure to ambient heat sources, such as water or 

soil. When released from a containment vessel or transfer system, LNG will generally produce

620 to 630 standard cubic feet (ft3

) of natural gas for each cubic foot of liquid. Ethylene will 

produce approximately 375 ft3 of gas for each cubic foot of liquid. Propane will produce 

approximately 250 ft3 of gas for each cubic foot of liquid. The composition of NGL would vary 

throughout the heavy hydrocarbon removal process and may produce up to 380 ft3 of gas for 

each cubic foot of liquid. In the event of a loss of containment of stabilized condensate, the 

stabilized condensate would spill primarily as a liquid and form a pool, but would vaporize much 

more slowly than NGL. 

If the loss of containment does not result in immediate ignition of the hydrocarbons, the 

vapor cloud would travel with the prevailing wind until it either encountered an ignition source 

or dispersed below its flammable limits. An LNG release would form a denser-than-air vapor 

cloud that would sink to the ground due to the cold temperature of the vapor. As the LNG vapor 

cloud disperses downwind and mixes with the warm surrounding air, the LNG vapor cloud may 

become buoyant. However, experimental observations and vapor dispersion modeling indicate 

the LNG vapor cloud would not typically be warm, or buoyant, enough to lift off from the 

ground before the LNG vapor cloud disperses below its lower flammability limit (LFL). A 

liquid ethylene release would form a denser-than-air vapor cloud that would sink to the ground 

due to the cold temperature of the vapor. As the ethylene vapor cloud disperses downwind and 

mixes with the warm surrounding air, the ethylene vapor would become neutrally buoyant. A 

propane release would form a denser-than-air vapor cloud that would sink to the ground; 

however, propane would remain denser than the surrounding air, even after warming to ambient 
4-155 Safety

temperatures. The concentration of NGL would vary throughout the heavy hydrocarbon removal 

process; however, a release at any point in the NGL stream would form a denser-than-air vapor 

cloud that would also sink to the ground, even after warming to ambient temperatures.

Methane and heavier hydrocarbons are classified as simple asphyxiates and may pose 

extreme health hazards, including death, if inhaled in significant quantities within a limited time. 

Very cold methane and heavier hydrocarbons vapors may also cause freeze burns. However, the 

locations of concentrations where cold temperatures and oxygen-deprivation effects could occur 

are greatly limited due to the continuous mixing with the warmer air surrounding the spill site. 

For that reason, exposure injuries from contact with releases of methane and heavier 

hydrocarbons normally represent negligible risks to the public.

4.12.2.3 Vapor Cloud Ignition

Flammability of the vapor cloud is dependent on the concentration of the vapor when 

mixed with the surrounding air. In general, higher concentrations within the vapor cloud would 

exist near the spill, and lower concentrations would exist near the edge of the cloud as it 

disperses downwind. Mixtures occurring between the LFL and the upper flammability limit 

(UFL) can be ignited. Concentrations above the UFL or below the LFL would not ignite.

The LFL and UFL for methane are approximately 5%-vol and 15%-vol in air, 

respectively. Propane has a narrower flammability range, with a LFL of approximately 2.1%-vol 

and a UFL of 9.5%-vol in air. Ethylene has a much wider flammability range and a LFL of 

approximately 2.7% vol and a UFL of 36%-vol in air. NGL has a LFL of approximately 2.3%-

vol and a UFL of approximately 11.1%-vol. Condensate has a LFL of approximately 1.3%-vol 

and a UFL of approximately 7.6%-vol.

If the flammable portion of a vapor cloud encounters an ignition source, a flame would 

propagate through the flammable portions of the cloud. In most circumstances, the flame would 

be driven by the heat it generates. This process is known as a deflagration. An LNG vapor 

cloud deflagration in an uncongested and unconfined area travels at slower speeds and does not 

produce significant pressure waves. However, exposure to this LNG vapor cloud fire can cause 

severe burns and death, and can ignite combustible materials within the cloud. Overpressures of 

LNG, NGL, and refrigerant vapor clouds are discussed later in this section under 

“Overpressures.”

A deflagration may propagate back to the spill site if the vapor concentration along this 

path is sufficiently high to support the combustion process. When the flame reaches vapor 

concentrations above the UFL, the deflagration could transition to a fireball and result in a pool 

or jet fire back at the source. A fireball would occur near the source of the release and would be 

of a relatively short duration compared to an ensuing jet or pool fire.

The extent of the affected area and the severity of the impacts on objects either within an 

ignited cloud or in the vicinity of a pool fire would primarily be dependent on the quantity and 

duration of the initial release, the surrounding terrain, and the environmental conditions present 

during the dispersion of the cloud. Radiant heat and dispersion modeling are discussed in section 

4.12.5.
Safety 4-156

Fires may also cause failures of nearby storage vessels, piping, and equipment. The 

failure of a pressurized vessel could cause fragments of material to fly through the air at high 

velocities, posing damage to surrounding structures and a hazard for operating staff, emergency 

personnel, or other individuals in proximity to the event. In addition, failure of a pressurized 

vessel when the liquid is at a temperature significantly above its normal boiling point could 

result in a boiling-liquid-expanding-vapor explosion (BLEVE). BLEVEs of flammable liquids 

can produce overpressures and a subsequent fireball when the superheated liquid rapidly changes 

from a liquid to a vapor upon the release from the vessel. 

4.12.2.4 Overpressures

If the deflagration in a flammable vapor cloud accelerates to a sufficiently high rate of 

speed, pressure waves that can cause damage would be generated. As a deflagration accelerates 

to super-sonic speeds, large pressure waves are produced, and a shock wave is created. This 

shock wave, rather than the heat, would begin to drive the flame, resulting in a detonation. 

Deflagrations or detonations are generally characterized as “explosions” as the rapid movement 

of the flame and pressure waves associated with them cause additional damage beyond that from 

the heat. The amount of damage an explosion causes is dependent on the amount the produced 

pressure wave is above atmospheric pressure (i.e., an overpressure) and its duration (i.e., pulse). 

For example, a 1 psi overpressure, often cited as a safety limit in U.S. regulations, is associated 

with glass shattering and traveling with velocities high enough to lacerate skin. 

Flame speeds and overpressures are primarily dependent on the reactivity of the fuel, the 

ignition strength and location, the degree of congestion and confinement of the area occupied by 

the vapor cloud, and the flame travel distance. 

The potential for unconfined LNG vapor cloud detonations was investigated by the Coast 

Guard in the late 1970s at the Naval Weapons Center in China Lake, California. Using methane, 

the primary component of natural gas, several experiments were conducted to determine whether 

unconfined LNG vapor clouds would detonate. Unconfined methane vapor clouds ignited with 

low-energy ignition sources (13.5 joules), produced flame speeds ranging from 12 to 20 mph. 

These flame speeds are much lower than the flame speeds associated with a deflagration with 

damaging overpressures or a detonation.

To examine the potential for detonation of an unconfined natural gas cloud containing 

heavier hydrocarbons that are more reactive, such as ethane and propane, the Coast Guard 

conducted further tests on ambient-temperature fuel mixtures of methane-ethane and methanepropane. The tests indicated that the addition of heavier hydrocarbons influenced the tendency 

of an unconfined natural gas vapor cloud to detonate. Less processed natural gas with greater 

amounts of heavier hydrocarbons would be more sensitive to detonation. 

Although it has been possible to produce damaging overpressures and detonations of 

unconfined LNG vapor clouds, the feed gas stream proposed for the Terminal Expansion would 

have lower ethane and propane concentrations than those that resulted in damaging overpressures 

and detonations. The substantial amount of initiating explosives needed to create the shock 

initiation during the limited range of vapor-air concentrations also renders the possibility of 

detonation of these vapors at an LNG plant as unrealistic. Ignition of a confined LNG vapor 

cloud could result in higher overpressures. In order to prevent such an occurrence, Cameron 
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LNG would take measures to mitigate the vapor dispersion and ignition into confined areas, such 

as buildings. Cameron LNG proposed to install hazard detection devices at all combustion and 

ventilation air intake equipment to enable isolation and deactivation of any combustion 

equipment whose continued operation could add to, or sustain, an emergency. In general, the 

primary hazards to the public from an LNG spill that disperses to an unconfined area, either on 

land or water, would be from dispersion of the flammable vapors or from radiant heat generated 

by a pool fire. 

In comparison with LNG vapor clouds, there is a higher potential for unconfined propane 

clouds to produce damaging overpressures, and an even higher potential for unconfined ethylene 

vapor clouds to produce damaging overpressures. Unconfined ethylene vapor clouds also have 

the potential to transition to a detonation much more readily than propane. This has been shown 

by multiple experiments conducted by the Explosion Research Cooperative to develop predictive 

blast wave models for low, medium, and high reactivity fuels and varying degrees of congestion 

and confinement (Pierorazio 2005). The experiments used methane, propane, and ethylene, as 

the respective low, medium, and high reactivity fuels. In addition, the tests showed that if 

methane, propane, or ethylene is ignited within a confined space, such as in a building, they all 

have the potential to produce damaging overpressures. The MRL and NGL process streams 

would contain a mixture of components such as the ones discussed above (i.e., ethylene and 

propane). Therefore, a potential exists for these process streams to produce unconfined vapor 

clouds that could produce damaging overpressures in the event of a release.

Discussion of these hazards and potential mitigation are in section 4.12.5 for the 

Terminal Expansion facilities.

4.12.2.5 Past LNG Facility Incidents

With the exception of the October 20, 1944, failure at an LNG facility in Cleveland, 

Ohio, the operating history of the U.S. LNG industry has been free of safety-related incidents 

resulting in adverse effects on the public or the environment. The 1944 incident in Cleveland led 

to a fire that killed 128 people and injured 200 to 400 more people.

43 The failure of the LNG 

storage tank was due to the use of materials inadequately suited for cryogenic temperatures. 

LNG migrating through streets and into underground sewers due to the lack of adequate spill 

impoundments at the site was also a contributing factor. Current regulatory requirements ensure 

that proper materials suited for cryogenic temperatures are used and that spill impoundments are 

designed and constructed properly to contain a spill at the site.

Another operational accident occurred in 1979 at the Cove Point LNG facility in Lusby, 

Maryland. A pump seal failure resulted in gas vapors entering an electrical conduit and settling 

in a confined space. When a worker switched off a circuit breaker, the gas ignited, causing 

heavy damage to the building and a worker fatality. With the participation of the FERC, lessons 

learned from the 1979 Cove Point accident resulted in changing the national fire codes to ensure 

that the situation would not occur again.

 43 For a description of the incident and the findings of the investigation, see “U.S. Bureau of Mines, Report on 

the Investigation of the Fire at the Liquefaction, Storage, and Regasification Plant of the East Ohio Gas Co., 

Cleveland, Ohio, October 20, 1944,” dated February 1946.
Safety 4-158

On January 19, 2004, a blast occurred at Sonatrach’s Skikda, Algeria, LNG liquefaction 

facility, which killed 27 and injured 56 workers. No members of the public were injured. 

Findings of the accident investigation suggested that a cold hydrocarbon leak occurred at 

Liquefaction Train 40 and was introduced to the high-pressure steam boiler by the combustion 

air fan. An explosion developed inside the boiler firebox, which subsequently triggered a larger 

explosion of the hydrocarbon vapors in the immediate vicinity. The resulting fire damaged the 

adjacent liquefaction process and liquid petroleum gas (LPG) separation equipment of Train 40, 

and spread to Trains 20 and 30. Although Trains 10, 20, and 30 had been modernized in 1998 

and 1999, Train 40 had been operating with its original equipment since start-up in 1981. To 

ensure that this potential hazard is addressed at the proposed Terminal Expansion, Cameron 

LNG proposed to install hazard detection devices at all combustion and ventilation air intake 

equipment to enable isolation and deactivation of any combustion equipment whose continued 

operation could add to, or sustain, an emergency.

On March 31, 2014, an explosion and fire occurred at Northwest Pipeline Corporation’s 

LNG peak-shaving facility in Plymouth, Washington. The facility was immediately shut down, 

and emergency procedures were activated, which included notifying local authorities and 

evacuating all plant personnel. No members of the public were injured. The accident 

investigation is still in progress. Once developed, measures to address any causal factors which 

led to this incident will be applied to all facilities under Commission jurisdiction.

4.12.3 Technical Review of the Preliminary Engineering Design

Operation of the proposed facility poses a potential hazard that could affect the public 

safety if strict design and operational measures to control potential accidents are not applied. 

The primary concerns are those events that could lead to an LNG spill of sufficient magnitude to 

create an off-site hazard as discussed in section 4.12.2. However, it is important to recognize the 

stringent requirements in place for the design, construction, operation, and maintenance of the 

facility, as well as the extensive safety systems proposed to detect and control potential hazards. 

As part of a project’s preliminary safety review, Cameron LNG conducted a hazard 

identification study of the process flow diagram (PFD) to identify potential risk scenarios. A 

more detailed and thorough hazard and operability review (HAZOP) analysis would be 

performed by Cameron LNG during the final design phase to identify the major hazards that may 

be encountered during the operation of facilities. The HAZOP study would be intended to 

address hazards of the process, engineering and administrative controls, and would provide a 

qualitative evaluation of a range of possible safety, health, and environmental effects which may 

result from the design or operation of the facility. Recommendations to prevent or minimize 

these hazards would be generated from the results of the HAZOP review. These studies help 

establish the required safety control levels and identify whether additional process and safety 

instrumentation, mitigation, and/or administrative controls would be needed. 

Once the design has been subjected to a HAZOP review, the design development team 

tracks changes in the facility design, operations, documentation, and personnel. Cameron LNG 

would evaluate these changes to ensure that the safety, health, and environmental risks arising 

from these changes are addressed and controlled. Resolutions of the recommendations generated 

by the HAZOP review would be monitored by the FERC staff. We have included a 
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recommendation that Cameron LNG should file a hazard and operability study on the completed 

final design. 

Based on these analyses, Cameron LNG would include various layers of protection or 

safeguards in the facility design to reduce the risk of a potentially hazardous scenario from 

developing into an event that could impact the off-site public. These layers of protection are 

independent of one another so that anyone would perform its function regardless of the action or 

failure of any other protection layer or initiating event. These layers of protection typically 

include:

• a facility design that prevents hazardous events through the use of suitable 

materials of construction; operating and design limits for process piping, process 

vessels, and storage tanks; adequate design for wind, flood, seismic, and other 

outside hazards;

• control systems, including monitoring systems and process alarms, remotelyoperated control and isolation valves, and operating procedures to ensure the 

facility stays within the established operating and design limits;

• safety-instrumented prevention systems, such as safety control valves and 

emergency shutdown systems, to prevent a release if operating and design limits 

are exceeded;

• physical protection systems, such as appropriate electrical area classification, 

proper equipment and building spacing, pressure relief valves, spill containment, 

and structural fire protection, to prevent escalation to a more severe event;

• site security measures for controlling access to the facility, including security 

inspections and patrols; response procedures to any breach of security and liaison 

with local law enforcement officials; and

• on-site and off-site emergency response, including hazard detection and control 

equipment, firewater systems, and coordination with local first responders to 

mitigate the consequences of a release and prevent it from escalating to an event 

that could impact the public.

The use of these protection layers would mitigate the potential for an initiating event to 

develop into an incident that could impact the safety of the off-site public. In addition, proper 

siting of the facility with regard to potential off-site consequences is required by DOT’s 

regulations in 49 CFR 193, Subpart B to ensure that impacts to the public would be minimized. 

These siting requirements are discussed in section 4.12.4.

As part of the application, Cameron LNG provided a front-end engineering design

(FEED) for the Project. The FEED and specifications submitted for the proposed facilities to 

date are preliminary, but would serve as the basis for any detailed design to follow. We have 

analyzed the information filed by Cameron LNG to determine the extent that layers of protection 

or safeguards to enhance the safety, operability, and reliability of the facility are included in the 

FEED. 
Safety 4-160

As a result of the technical review of the information provided by Cameron LNG in the 

submittal documents, we identified a number of concerns in an information data request letter 

issued on April 3, 2013 relating to the reliability, operability, and safety of the proposed design. 

Cameron LNG provided written responses to the information data request on April 29, 2013. 

However, some of these responses indicated that Cameron LNG would correct or modify its 

design in order to address issues raised in the information request. As a result, we are 

recommending that:

• Prior to construction of the final design, Cameron LNG should file 

information/revisions with the Secretary, for review and written approval by

the Director of OEP, pertaining to Cameron LNG’s response numbers 30 

and 71 of its April 29, 2013 filing, which indicated features to be included or 

considered in the final design. 

The objectives of our FEED review focused on the engineering design and safety 

concepts of the various protection layers, as well as the projected operational reliability of the 

proposed facilities. The design would use materials of construction suited to the pressure and 

temperature conditions of the process design. Piping would be designed in accordance with 

ASME B31.3. Pressure vessels would be designed in accordance with ASME Section VIII and 

the storage tanks would be designed in accordance with API Standard 620, per 49 CFR 193 and 

the NFPA’s Standard 59A (NFPA 59A). Valves and other equipment would be designed to 

recommended and generally accepted good engineering practices. As proposed in the Basic 

Engineering Data section located in appendix C.13 of the application, Cameron LNG would 

design the facility to withstand a design wind velocity of a 183 mph, 3-second gust. The 

proposed LNG storage tank and liquefaction process area would be at a height of 5 feet and 11.5 

feet, respectively, or greater above sea level (FEMA 2003) to minimize the risk of flooding. We 

also examined the seismic and structural design of the Terminal Expansion facility.

Cameron LNG would install process control valves and instrumentation to safely operate 

and monitor the facility. Alarms would have visual and audible notification in the control room 

to warn operators that process conditions may be approaching design limits. Operators would 

have the capability to take action from the control room to mitigate an upset. 

Cameron LNG would expand the existing facility operation procedures to include the 

Terminal Expansion after completion of the final design; this timing is fully consistent with 

accepted industry practice. We have made recommendations for Cameron LNG to provide more 

information on the operating and maintenance procedures as they are developed, including hot 

work procedures and permits and personnel training. In addition, we have recommended 

measures such as labeling of instrumentation and valves (i.e., car-seals, locks) to address human 

factor considerations and improve facility safety. An alarm management program would also be 

in place to ensure effectiveness of the alarms.

Safety valves and instrumentation would be installed to monitor, alarm, shutdown, and 

isolate equipment and piping during process upsets or emergency conditions. Safety 

instrumented systems would comply with International Society for Automation Standard 84.01 

and other recommended and generally accepted good engineering practices. We also made 

recommendations on the design, installation, and commissioning of instrumentation and 
4-161 Safety

emergency shutdown equipment to ensure appropriate cause and effect alarm or shutdown logic 

and enhanced representation of the emergency shutdown valves in the facility control system.

Safety relief valves and flares would be installed to protect the process equipment and

piping. The safety relief valves would be designed to handle process upsets and thermal 

expansion within piping, per NFPA 59A and ASME Section VIII, and would be designed based 

on API 520, 521, 527, and other recommended and generally accepted good engineering 

practices. In addition, we made recommendations to ensure appropriate discharge of pressure 

relief devices and to include pressure relieving protection for flammable liquid piping.

In order to minimize the risk of an intentional event, Cameron LNG would provide 

security fencing, lighting, camera systems, and intrusion detection to deter, monitor, and detect 

intruders into the facility. In addition, as discussed in section 4.12.5, Cameron LNG must update 

the existing Facility Security Plan in accordance with the Coast Guard’s regulations found in 33 

CFR 105, Subpart D. We also made recommendations to provide security and incident reporting 

during operation.

In the event of a release, drainage systems from LNG storage and liquefaction process 

facilities would direct a spill away from equipment in order to minimize flammable vapors from 

dispersing to confined, occupied, or public areas and to minimize heat from impacting adjacent 

equipment and public areas if ignition occurs. Impoundment systems are further discussed in 

4.12.5.

Cameron LNG performed a preliminary fire protection evaluation to ensure that adequate 

hazard detection, hazard control, and firewater coverage would be installed to detect and address 

any upset conditions. Structural fire protection, proposed to prevent failure of structural supports 

of equipment and pipe racks, would comply with NFPA 59A and other recommended and 

generally accepted good engineering practices. Cameron LNG would also install hazard 

detection systems to detect, alarm, and alert personnel in the area and control room to initiate an 

emergency shutdown and/or initiate appropriate procedures, and would meet NFPA 72, 

International Society for Automation 12.13, and other recommended and generally accepted 

good engineering practices. Hazard control devices would be installed to extinguish or control 

incipient fires and releases, and would meet NFPA 59A and NFPA 10, 11, 12, 17, and other 

recommended and generally accepted good engineering practices. Cameron LNG would provide 

automatic firewater systems and monitors for use during an emergency to cool the surface of 

storage vessels, piping, and equipment exposed to heat from a fire, and would meet NFPA 59A, 

20, 22, and 24 requirements. We have made recommendations for Cameron LNG to provide 

more information on the design, installation, and commissioning of hazard detection, hazard 

control, and firewater systems as Cameron LNG would further develop this information during 

the final design phase.

Cameron LNG would also update the existing emergency procedures to include the 

Terminal Expansion in accordance with 49 CFR 193 and 33 CFR 127. The emergency 

procedures would provide for protection of personnel and the public as well as the prevention of 

property damage that may occur as a result of incidents at the facility. 

If authorization is granted by the Commission, the next phase of the Terminal Expansion 

Project would include development of the final design, including final selection of equipment 
Safety 4-162

manufacturers, process conditions, and resolution of some safety-related issues. To ensure the 

final design would be consistent with the safety and operability characteristics identified in the 

FEED, information regarding the development of the final design, as detailed below, would need 

to be filed with the Secretary for review and written approval by the Director of the OEP before 

equipment construction at the site would be authorized.

In addition to the final design review, we would conduct inspections during construction 

and would review additional materials, including quality assurance and quality control plans, 

nonconformance reports, and cooldown and commissioning plans, to ensure that the installed 

design is consistent with the safety and operability characteristics of the FEED. We would also 

conduct inspections during operation to ensure that the facility is operated and maintained in 

accordance with the filed design throughout the life of the facility.

To ensure that the concerns we’ve identified relating to the reliability, operability, and 

safety of the proposed design are addressed by Cameron LNG, and to ensure that the facility is 

subject to the Commission’s construction and operational inspection program, we are 

recommending that the following measures should apply to the Cameron LNG Terminal 

Expansion. Information pertaining to these specific recommendations should be filed with 

the Secretary for review and written approval by the Director of OEP either: prior to 

initial site preparation; prior to construction of final design; prior to commissioning; prior 

to introduction of hazardous fluids; or prior to commencement of service, as indicated by 

each specific condition. Specific engineering, vulnerability, or detailed design information 

meeting the criteria specified in Order No. 683 (Docket No. RM06-24-000), including 

security information, should be submitted as critical energy infrastructure information 

pursuant to 18 CFR 388.112. See Critical Energy Infrastructure Information, Order No. 

683, 71 Fed. Reg. 58,273 (October 3, 2006), FERC Stats. & Regs. ¶31,228 (2006). 

Information pertaining to items such as: offsite emergency response; procedures for public 

notification and evacuation; and construction and operating reporting requirements,

would be subject to public disclosure. All information should be filed a minimum of 30 

days before approval to proceed is requested. 

• Prior to initial site preparation, Cameron LNG should provide procedures 

for controlling access during construction.

• Prior to initial site preparation, Cameron LNG should file the quality 

assurance and quality control procedures for construction activities.

• Prior to initial site preparation, Cameron LNG should file a plot plan of the 

final design showing all major equipment, structures, buildings, and 

impoundment systems.

• The final design should include change logs that list and explain any changes 

made from the Front-End Engineering Design provided in Cameron LNG’s 

application and filings. A list of all changes with an explanation for the 

design alteration should be provided and all changes should be clearly 

indicated on all diagrams and drawings.
4-163 Safety

• The final design should provide up-to-date Process Flow Diagrams with heat 

and material balances and Piping and Instrument Diagrams (P&IDs), which 

include the following information: 

a. equipment tag number, name, size, duty, capacity, and design 

conditions; 

b. equipment insulation type and thickness; 

c. storage tank pipe penetration size and nozzle schedule;

d. valve high pressure side and internal and external vent locations;

e. piping with line number, piping class specification, size, and 

insulation type and thickness;

f. piping specification breaks and insulation limits; 

g. all control and manual valves numbered; 

h. relief valves with set points; and

i. drawing revision number and date.

• The final design should provide P&IDs, specifications, and procedure that 

clearly show and specify the tie-in details required to safely connect the 

Terminal Expansion to the existing facility.

• The final design should provide an up-to-date complete equipment list, 

process and mechanical data sheets, and specifications.

• The final design should provide complete plan drawings and a list of the 

hazard detection equipment. The drawings should clearly show the location 

and elevation of all detection equipment. The list should include the 

instrument tag number, type and location, alarm locations, and shutdown 

functions of the proposed hazard detection equipment. 

• The final design should provide complete plan drawings and a list of the 

fixed and wheeled dry-chemical, hand-held fire extinguishers, and other 

hazard control equipment. Drawings should clearly show the location by tag 

number of all fixed, wheeled, and hand-held extinguishers. The list should 

include the equipment tag number, type, capacity, equipment covered, and 

automatic and manual remote signals initiating discharge of the units. 

• The final design should provide facility plans and drawings that show the 

location of the firewater and foam systems. Drawings should clearly show: 

firewater and foam piping; post indicator valves; and the location of and 

area covered by each monitor, hydrant, deluge system, foam system, watermist system, and sprinkler. The drawings should also include piping and 

instrumentation diagrams of the firewater and foam system.

• The final design should include an updated fire protection evaluation of the 

proposed facilities carried out in accordance with the requirements of NFPA 
Safety 4-164

59A 2001, chapter 9.1.2 as required by 49 CFR Part 193. A copy of the 

evaluation, a list of recommendations and supporting justifications, and 

actions taken on the recommendations should be filed. 

• The final design should ensure that the LNG storage tank piping supports 

are adequately designed for the higher rated in-tank pump flow rates.

• The final design should include a relief valve study to ensure the existing 

LNG storage tank vacuum relief valves provide adequate protection when 

the higher capacity in-tank pumps would be operating at full capacity. 

• The final design should specify that for hazardous fluids, the piping, and 

piping nipples 2 inches or less are to be no less than Schedule 160. 

• The final design of the electrical purge seal arrangement should include an 

alternate or additional detection method to the proposed nitrogen system 

pressure indicators, to detect and alarm flammable vapors at the vent 

discharge to atmosphere in order to account for small leaks that pressure 

indicators may not be able to detect. 

• The final design should provide an air gap or acceptable means downstream 

of the secondary seal to prevent the migration of flammable vapors from the 

secondary seal to the switchgear.

• The final design should provide electrical area classification drawings.

• The final design should provide spill containment system drawings with 

dimensions and slopes of curbing, trenches, and impoundments.

• The final design of the hazard detectors should account for the calibration 

gas when determining the Lower Flammability Limit (LFL) set points for 

methane, propane, and ethylene, and condensate.

• The final design should provide pressure relieving protection for flammable 

liquid piping segments (i.e., refrigerants, liquid hydrocarbons, condensate 

products) that can be isolated by valves.

• The final design should specify that the pressure of the shell side of Inlet Gas 

Preheater, H1-1001, should not exceed the allowable operating pressure 

during pressure relief conditions, and the relieving device should discharge 

to a safe location. 

• The final design should specify that the design temperature of the coil of the 

Hot Oil Heat Exchanger, H1-3013, is in accordance with Note 4 on page 5 of 

CAM1-PRC-DTS-H0035.

• The final design should specify that the C5+ Condensate Storage Tank fill 

connection is located above the maximum liquid level.
4-165 Safety

• The final design should address the potential for reverse flow through the 

Molecular Sieve Driers in the event that emergency vent valve XV1-10128 

opens.

• The final design should include a hazard and operability review of the 

completed design prior to issuing the P&IDs for construction. A copy of the 

review, a list of recommendations, and actions taken on the 

recommendations, should be filed.

• The final design should include the cause-and-effect matrices for the process 

instrumentation, fire and gas detection system, and emergency shutdown 

system. The cause-and-effect matrices should include alarms and shutdown 

functions, details of the voting and shutdown logic, and setpoints.

• The final design should include a drawing showing the location of the 

emergency shutdown (ESD) buttons. ESD buttons should be easily accessible, 

conspicuously labeled and located in an area which would be accessible 

during an emergency.

• The final design should include a pressure survey of the anticipated 

operating and design conditions for the wet and dry flares. The survey 

should include a report showing the stream analysis, flow rates, temperatures 

and operating pressures from the relief discharge to the flare inlet.

• The final design should include a plan for clean-out, dry-out, purging, and 

tightness testing. This plan should address the requirements of the American 

Gas Association’s Purging Principles and Practice required by 49 CFR Part 

193 and should provide justification if not using an inert or non-flammable 

gas for cleanout, dry-out, purging, and tightness testing. 

• The final design should include the sizing basis and capacity for the final 

design of pressure and vacuum relief valves for major process equipment, 

vessels, and storage tanks.

• The final design should provide the procedures for pressure/leak tests which 

address the requirements of ASME VIII and ASME B31.3, as required by 49 

CFR 193.

• Prior to commissioning, Cameron LNG should file plans and detailed 

procedures for: testing the integrity of onsite mechanical installation; 

functional tests; introduction of hazardous fluids; operational tests; and 

placing the equipment into service. 

• Prior to commissioning, Cameron LNG should provide a detailed schedule 

for commissioning through equipment startup. The schedule should include 

milestones for all procedures and tests to be completed: prior to introduction 

of hazardous fluids; and during commissioning and startup. Cameron LNG 

should file documentation certifying that each of these milestones has been 
Safety 4-166

completed before authorization to commence the next phase of 

commissioning and startup will be issued.

• Prior to commissioning, Cameron LNG should provide results of the LNG 

storage tank hydrostatic test and foundation settlement results.

• Prior to commissioning, Cameron LNG should tag all equipment, 

instrumentation, and valves in the field, including drain valves, vent valves, 

main valves, and car-sealed or locked valves.

• Prior to commissioning, Cameron LNG should file a tabulated list and 

drawings of the proposed hand-held fire extinguishers. The list should 

include the equipment tag number, extinguishing agent type, capacity, 

number, and location. The drawings should show the extinguishing agent 

type, capacity, and tag number of all hand-held fire extinguishers. 

• Prior to commissioning, Cameron LNG should file updates addressing the 

Terminal Expansion facilities in the operation and maintenance procedures 

and manuals, as well as safety procedures.

• Prior to commissioning, Cameron LNG should maintain a detailed training 

log to demonstrate that operating staff has completed the required training. 

• Prior to introduction of hazardous fluids, Cameron LNG should complete a 

firewater pump acceptance test and firewater monitor and hydrant coverage 

test. The actual coverage area from each monitor and hydrant should be 

shown on facility plot plan(s). 

• Prior to introduction of hazardous fluids, Cameron LNG should complete all 

pertinent tests (Factory Acceptance Tests, Site Acceptance Tests, Site 

Integration Tests) associated with the Distributed Control System and the 

Safety Instrumented System that demonstrates full functionality and 

operability of the system.

• Prior to commencement of service, Cameron LNG should label piping with 

fluid service and direction of flow in the field in addition to the pipe labeling 

requirements of NFPA 59A.

• Prior to commencement of service, progress on the construction of the 

proposed systems should be reported in monthly reports filed with the 

Secretary. Details should include a summary of activities, problems 

encountered, contractor non-conformance/deficiency logs, remedial actions 

taken, and current Project schedule. Problems of significant magnitude 

should be reported to the FERC within 24 hours.

In addition, we are recommending that the following measures should apply throughout 

the life of the facility:
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• The facility should be subject to regular FERC staff technical reviews and 

site inspections on at least an annual basis or more frequently as 

circumstances indicate. Prior to each FERC staff technical review and site 

inspection, Cameron LNG should respond to a specific data request, 

including information relating to possible design and operating conditions 

that may have been imposed by other agencies or organizations. Up-to-date 

detailed piping and instrumentation diagrams reflecting facility 

modifications and provision of other pertinent information not included in 

the semi-annual reports described below, including facility events that have 

taken place since the previously submitted semi-annual report, should be 

submitted.

• Semi-annual operational reports should be filed with the Secretary to 

identify changes in facility design and operating conditions, abnormal 

operating experiences, activities (including ship arrivals, quantity and 

composition of imported and exported LNG, liquefied and vaporized 

quantities, boil-off/flash gas, etc.), plant modifications, including future plans 

and progress thereof. Abnormalities should include, but not be limited to: 

unloading/loading/shipping problems, potential hazardous conditions from 

off-site vessels, storage tank stratification or rollover, geysering, storage tank 

pressure excursions, cold spots on the storage tanks, storage tank vibrations 

and/or vibrations in associated cryogenic piping, storage tank settlement, 

significant equipment or instrumentation malfunctions or failures, nonscheduled maintenance or repair (and reasons therefore), relative movement 

of storage tank inner vessels, hazardous fluid releases, fires involving 

hazardous fluids, negative pressure (vacuum) within a storage tank and 

higher than predicted boil-off rates. Adverse weather conditions and the 

effect on the facility also should be reported. Reports should be submitted 

within 45 days after each period ending June 30 and December 31. In 

addition to the above items, a section entitled "Significant Plant 

Modifications Proposed for the Next 12 Months (dates)” also should be 

included in the semi-annual operational reports. Such information would 

provide the FERC staff with early notice of anticipated future 

construction/maintenance projects at the LNG facility.

• Significant non-scheduled events, including safety-related incidents (e.g., 

hazardous fluid releases, fires, explosions, mechanical failures, unusual over 

pressurization, and major injuries) and security-related incidents (e.g., 

attempts to enter site, suspicious activities) should be reported to the FERC

staff. In the event an abnormality is of significant magnitude to threaten 

public or employee safety, cause significant property damage, or interrupt 

service, notification should be made immediately, without unduly interfering 

with any necessary or appropriate emergency repair, alarm, or other 

emergency procedure. In all instances, notification should be made to the 

FERC staff within 24 hours. This notification practice should be 

incorporated into the LNG facility's emergency plan. Examples of 

reportable hazardous fluids-related incidents include:
Safety 4-168

a. fire; 

b. explosion;

c. estimated property damage of $50,000 or more;

d. death or personal injury necessitating in-patient hospitalization;

e. release of hazardous fluids for 5 minutes or more;

f. unintended movement or abnormal loading by environmental causes, 

such as an earthquake, landslide, or flood, that impairs the 

serviceability, structural integrity, or reliability of an LNG facility 

that contains, controls, or processes hazardous fluids;

g. any crack or other material defect that impairs the structural 

integrity or reliability of an LNG facility that contains, controls, or 

processes hazardous fluids; 

h. any malfunction or operating error that causes the pressure of a 

pipeline or LNG facility that contains or processes hazardous fluids to 

rise above its maximum allowable operating pressure (or working 

pressure for LNG facilities) plus the build-up allowed for operation of 

pressure limiting or control devices; 

i. a leak in an LNG facility that contains or processes hazardous fluids

that constitutes an emergency; 

j. inner tank leakage, ineffective insulation, or frost heave that impairs 

the structural integrity of an LNG storage tank;

k. any safety-related condition that could lead to an imminent hazard 

and cause (either directly or indirectly by remedial action of the 

operator), for purposes other than abandonment, a 20 percent 

reduction in operating pressure or shutdown of operation of a

pipeline or an LNG facility that contains or processes hazardous 

fluids; 

l. safety-related incidents occurring at or en route to and from the LNG 

facility involving hazardous fluids; or

m. an event that is significant in the judgment of the operator and/or 

management even though it did not meet the above criteria or the 

guidelines set forth in an LNG facility’s incident management plan.

• In the event of an incident, the Director of OEP has delegated authority to 

take whatever steps are necessary to ensure operational reliability and to 

protect human life, health, property or the environment, including authority 

to direct the LNG facility to cease operations. Following the initial company 

notification, the FERC staff would determine the need for a separate followup report or follow-up in the upcoming semi-annual operational report. All 

company follow-up reports should include investigation results and 

recommendations to minimize a reoccurrence of the incident.
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4.12.4 Siting Requirements

The principal hazards associated with the substances involved in the liquefaction, storage 

and vaporization of LNG result from cryogenic and flashing liquid releases, flammable and toxic 

vapor dispersion, vapor cloud ignition, pool fires, BLEVEs, and overpressures. As discussed in 

section 4.12.3, our FEED review indicates that sufficient layers of protection would be 

incorporated into the facility design to mitigate the potential for an initiating event to develop 

into an incident that could impact the safety of the off-site public. Siting of the facility with 

regard to potential off-site consequences is also required by DOT’s regulations in 49 CFR 193, 

Subpart B as an additional safeguard to help ensure that impact to the public would be 

minimized. The Commission’s regulations under 18 CFR 380.12(o)(14) require Cameron LNG 

to identify how the proposed design complies with the DOT’s siting requirements. As part of 

our review, we used Cameron LNG’s information, developed to comply with DOT’s regulations, 

to assess whether or not the facility would have a public safety impact. The Part 193 

requirements state that an operator or government agency must exercise control over the 

activities that can occur within an “exclusion zone,” defined as the area around an LNG facility 

that could be exposed to specified levels of thermal radiation or flammable vapor in the event of 

a release. Approved mathematical models must be used to calculate the dimensions of these 

exclusion zones. The 2001 edition of NFPA 59A, an industry consensus safety standard for the 

siting, design, construction, operation, maintenance, and security of LNG facilities, is 

incorporated into Part 193 by reference, with regulatory preemption in the event of conflict. The 

following sections of Part 193 specifically address the siting requirements applicable to each 

LNG container and LNG transfer system:

• Part 193.2001, Scope of part, excludes any matter other than siting provisions 

pertaining to marine cargo transfer systems between the marine vessel and the last 

manifold or valve immediately before a storage tank; 

• Part 193.2051, Scope, states that each LNG facility designed, replaced, relocated 

or significantly altered after March 31, 2000, must be provided with siting 

requirements in accordance with Subpart B and NFPA 59A (2001). In the event 

of a conflict with NFPA 59A (2001), the regulatory requirements in Part 193 

prevail;

• Part 193.2057, Thermal radiation protection, requires that each LNG container 

and LNG transfer system have thermal exclusion zones in accordance with 

Section 2.2.3.2 of NFPA 59A (2001); and

• Part 193.2059, Flammable vapor-gas dispersion protection, requires that each 

LNG container and LNG transfer system have a dispersion exclusion zone in 

accordance with Sections 2.2.3.3 and 2.2.3.4 of NFPA 59A (2001).

For the LNG facilities proposed for the Terminal Expansion Project, these Part 193 siting

requirements would be applicable to the following equipment:

• one 42,267,526 gallon (net) full containment LNG storage tank and associated 

piping and appurtenances - Parts 193.2057 and 2059 require the establishment of 

thermal and flammable vapor exclusion zones for LNG tanks. NFPA 59A (2001), 

Section 2.2.3.2 specifies four thermal exclusion zones based on the design spill 
Safety 4-170

and the impounding area. NFPA 59A (2001), Sections 2.2.3.3 and 2.2.3.4 specify 

a flammable vapor exclusion zone for the design spill which is determined with 

Section 2.2.3.5;

• a 30-inch-diameter LNG header used for ship loading - Parts 193.2001, 2057, and 

2059 require thermal and flammable vapor exclusion zones for the marine cargo 

transfer system. NFPA 59A (2001) does not address LNG transfer systems;

• four 10,127-gpm in-tank pumps and associated piping and appurtenances for the 

proposed LNG storage tank; twelve 10,127-gpm in-tank pumps (four per tank) to 

replace the existing 3,706-gpm in-tank pumps and associated piping and 

appurtenances; and six 6,058-gpm LNG product pumps (two per liquefaction 

train; one operating and one spare) and associated piping and appurtenances -

Parts 193.2057 and 2059 require thermal and flammable vapor exclusion zones. 

NFPA 59A (2001) Section 2.2.3.2 specifies the thermal exclusion zone and 

Sections 2.2.3.3 and 2.2.3.4 specify the flammable vapor exclusion zone based on 

the design spills for containers and process areas; and

• three liquefaction heat exchangers (one per liquefaction train) and associated 

piping and appurtenances, including a 24-inch-diameter LNG rundown line -

Parts 193.2057 and 2059 require thermal and flammable vapor exclusion zones. 

NFPA 59A (2001) Section 2.2.3.2 specifies the thermal exclusion zone and 

Sections 2.2.3.3 and 2.2.3.4 specify the flammable vapor exclusion zone based on 

the design spills for containers and process areas.

Previous FERC environmental assessments/impact statements for past projects have 

identified inconsistencies and areas of potential conflict between the requirements in Part 193 

and NFPA 59A (2001). Sections 193.2057 and 193.2059 require exclusion zones for each LNG 

container and LNG transfer system, and an LNG transfer system is defined in Section 193.2007 

to include cargo transfer system and transfer piping (whether permanent or temporary). 

However, NFPA 59A (2001) requires exclusion zones only for “transfer areas,” which is defined 

as the part of the plant where the facility introduces or removes the liquids, such as truck loading 

or ship-unloading areas. The NFPA 59A (2001) definition does not include permanent plant 

piping, such as cargo transfer lines. Section 2.2.3.1 of NFPA 59A (2001) also states that transfer 

areas at the water edge of marine terminals are not subject to the siting requirements in that 

standard.

The DOT has addressed some of these issues in a March 2010 letter of interpretation. In 

that letter, DOT stated that: (1) the requirements in the NFPA 59A (2001) for transfer areas for 

LNG apply to the marine cargo transfer system at a proposed waterfront LNG facility, except 

where preempted by the regulations in Part 193; (2) the regulations in Part 193 for LNG transfer 

systems conflict with NFPA 59A (2001) on whether an exclusion zone analysis is required for 

transfer piping or permanent plant piping; and (3) the regulations in Part 193 prevailed as a result 

of that conflict. The DOT has determined that an exclusion zone analysis of the marine cargo 

transfer system is required.

In the FERC environmental assessments/impact statements for past projects, we have also 

noted that when the DOT incorporated NFPA 59A into its regulations, it removed the regulation 

that required impounding systems around transfer piping. As a result of that change, it is unclear 
4-171 Safety

whether Part 193 or the adopted sections of NFPA 59A (2001) require impoundments for LNG 

transfer systems. We note that Part 193 requires exclusion zones for LNG transfer systems, and 

that those zones were historically calculated based on impoundment systems. We also note that 

the omission of containment for transfer piping is not a sound engineering practice. For these 

reasons, we generally recommend containment for all LNG transfer piping within a plant’s 

property lines.

Federal regulations issued by the Occupational Safety and Health Administration 

(OSHA) under 29 CFR 1910.119 (Process Safety Management of Highly Hazardous Chemicals; 

Explosives and Blasting Agents [PSM]), and the EPA under 40 CFR 68 (Risk Management 

Plans) cover hazardous substances, such as methane, propane, and ethylene at many facilities in 

the U.S. However, OSHA and EPA regulations are not applicable to facilities regulated under 49 

CFR 193. On October 30, 1992, shortly after the promulgation of the OSHA Process Safety 

Management regulations, OSHA issued a letter of interpretation that precluded the enforcement 

of PSM regulations over gas transmission and distribution facilities. In a subsequent letter on 

December 9, 1998, OSHA further clarified that this letter of interpretation applies to LNG 

distribution and transmission facilities.

In addition, EPA’s preamble to its final rule in Federal Register, Volume 63, Number 3, 

639 645, clarified that exemption from the requirements in 40 CFR 68 for regulated substances 

in transportation, including storage incident to transportation, is not limited to pipelines. The 

preamble further clarified that the transportation exemption applies to LNG facilities subject to 

oversight or regulation under 49 CFR 193, including facilities used to liquefy natural gas or used 

to transfer, store, or vaporize LNG in conjunction with pipeline transportation. Therefore, the 

above OSHA and EPA regulations are not applicable to facilities regulated under 49 CFR 193. 

As stated in Section 193.2051, LNG facilities must be provided with the siting requirements of 

NFPA 59A (2001 edition). The siting requirements for flammable liquids within an LNG 

facility are contained in NFPA 59A, Chapter 2:

• NFPA 59A, Section 2.1.1 requires consideration of clearances between flammable 

refrigerant storage tanks, flammable liquid storage tanks, structures and plant 

equipment, both with respect to plant property lines and each other. This section 

also requires that other factors applicable to the specific site that have a bearing 

on the safety of plant personnel and surrounding public be considered, including 

an evaluation of potential incidents and safety measures incorporated in the 

design or operation of the facility.

• NFPA 59A Section 2.2.2.2 requires impoundments serving flammable 

refrigerants or flammable liquids to contain a 10-minute spill of a single 

accidental leakage source or during a shorter time period based upon 

demonstrable surveillance and shutdown provisions acceptable to the DOT. In 

addition, NFPA Section 2.2.2.5 requires impoundments and drainage channels for 

flammable liquid containment to conform to NFPA 30, Flammable and 

Combustible Liquids Code.

• NFPA 59A Section 2.2.3.2 requires provisions to minimize the damaging effects 

of fire from reaching beyond a property line, and requires provisions to prevent a 

radiant heat flux level of 1,600 BTU/ft2-hr from reaching beyond a property line 
Safety 4-172

that can be built upon. The distance to this flux level is to be calculated with 

LNGFIRE or using models that have been validated by experimental test data 

appropriate for the hazard to be evaluated and that are acceptable to DOT.

• NFPA 59A Section 2.2.3.4 requires provisions to minimize the possibility of any 

flammable mixture of vapors from a design spill from reaching a property line 

that can be built upon and that would result in a distinct hazard. Determination of 

the distance that the flammable vapors extend is to be determined with DEGADIS 

or alternative models that take into account physical factors influencing LNG 

vapor dispersion. Alternative models must have been validated by experimental 

test data appropriate for the hazard to be evaluated and must be acceptable to 

DOT. Section 2.2.3.5 requires the design spill for impounding areas serving 

vaporization and process areas to be based on the flow from any single accidental 

leakage source.

For the following liquefaction facilities that are proposed for the Terminal Expansion, the 

FERC staff identified that the refrigerant siting requirements from Part 193 and NFPA 59A 

would be applicable to the following equipment:

• three liquefaction heat exchangers (one per liquefaction train) and associated 

piping and appurtenances;

• one 46,250-gallon ethylene storage bullet and associated piping;

• two 120,500-gallon propane storage bullets and associated piping; 

• two 993,600-gallon stabilized condensate product storage tanks;

• one 260-gpm ethylene pump and associated piping; 

• one 540-gpm propane pump and associated piping and appurtenances; 

• two 485-gpm condensate product pumps and associated piping; two 94-gpm 

condensate shipping pumps and associated piping; and

• two 124-gpm NGL product pumps and associated piping and appurtenances.

4.12.5 Siting Analysis

Suitable sizing of impoundment systems and selection of design spills on which to base 

hazard analyses are critical for establishing an appropriate siting analysis. Although 

impoundment capacity and design spill scenarios for storage tank impoundments are well 

described by Part 193, a clear definition for other impoundments is not provided either directly 

by the regulations or by the adopted sections of NFPA 59A (2001). Under NFPA 59A (2001) 

Section 2.2.2.2, the capacity of impounding areas for vaporization, process, or LNG transfer 

areas must equal the greatest volume that can be discharged from any single accidental leakage 

source during a 10-minute period or during a shorter time period based upon demonstrable 

surveillance and shutdown provisions acceptable to the DOT. However, no definition of single 

accidental leakage source is provided in the regulations.
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We recommend impoundments be sized based on the greatest flow capacity from any

single pipe for 10 minutes, while recognizing that different spill scenarios may be used for the 

single accidental leakage sources for the hazard calculations required by Part 193. A similar 

approach is used with impoundments for process vessels. We also recommend these 

impoundments be able to contain the contents of the largest process vessel served, while 

recognizing that smaller design spills may be appropriate for Part 193 calculations.

4.12.5.1 Impoundment Sizing

Part 193.2181 references NFPA 59A (2001) for siting, which specifies each impounding 

system serving an LNG storage tank must have a minimum volumetric liquid capacity of 110 

percent of the LNG tank’s maximum design liquid capacity for an impoundment serving a single 

tank. We also consider it prudent design practice to provide a barrier to prevent liquid from 

flowing to an unintended area (i.e., outside the plant property) in the event that the full 

containment storage tank primary and secondary containers have a common cause failure. The 

purpose of the barrier is to prevent liquid from flowing off the plant property, and does not 

define containment or an impounding area for thermal radiation or flammable vapor exclusion 

zone calculations or other code requirements already met by sumps and impoundments 

throughout the site.

Table 4.12.5-1 lists the spill volumes and their corresponding impoundment systems. For 

the Terminal Expansion, Cameron LNG proposes one full containment LNG storage tank where 

the outer tank wall would serve as the impoundment system. The proposed LNG storage tank 

would have a design maximum volume of 44,769,588 gallons. As shown in table 4.12.5-1, the 

outer tank would have a volumetric capacity of 52,199,423 gallons, which exceeds the 110 

percent requirement by 2,952,876 gallons. The outer tank would contain 116 percent the design 

capacity of the inner tank, meeting the Part 193 requirements. The Cameron LNG Terminal has 

an existing earthen storm surge barrier around the perimeter of the facility, which also serves to 

limit liquid from flowing off the plant property in the case of a common cause failure of the 

existing full containment storage tank primary and secondary containers. Cameron LNG would 

extend this storm surge barrier around the proposed LNG storage tank. The existing storm surge 

barrier structure was constructed with a volume equivalent to one full storage tank. The new 

portion of the barrier surrounding the proposed LNG storage tank would increase this holding 

capacity and would meet our recommendation that a barrier be provided to prevent liquid from 

flowing off plant property.
Safety 4-174

TABLE 4.12.5-1

Impoundment Area Sizing

Source Spill Size

(gallons) Impoundment System Impoundment Size(gallons)

LNG Storage Tank 44,769,588 Outer Tank Concrete Wall 52,199,423

30-inch Ship Loading Header 706,500 LNG Spill Impoundment 781,510

In-tank Pump Withdrawal 

Header 471,000 LNG Spill Impoundment 781,510

LNG Rundown Line (south) 233,250 LNG Spill Impoundment 781,510

LNG Rundown Line (north) 233,350 Liquefaction Area Sump 235,530

24-inch MRL Process Piping 107,750 Liquefaction Area Sump 235,530

Ethylene Storage Tank 46,250 Refrigerant Storage Sump 181,777

Propane Storage Tank 120,500 Refrigerant Storage Sump 181,777

Condensate Storage Tank 993,600 Condensate Containment 1,451,638

Fresh Amine Tank 142,130 Amine Diked Area 311,062

Lean Amine Tank 142,130 Amine Diked Area 311,062

Potential spills occurring from the 30-inch-diameter LNG ship loading header, the 24-

inch-diameter in-tank pump withdrawal header, and the 24-inch-diameter LNG rundown line 

south of the liquefaction process area would drain toward the concrete troughs and would be 

directed to the existing LNG Spill Impoundment Basin. The existing LNG Spill Impoundment 

Basin is 85 feet long, 60.7 feet wide, and 21.25 feet deep with a usable capacity of 781,510 

gallons. The existing LNG Spill Impoundment Basin is within the storm surge barrier at the 

center of the Cameron LNG Terminal vaporization area, the existing LNG storage tank area, and 

the south jetty area. For the Terminal Expansion Project, the largest spill to the existing LNG 

Spill Impoundment Basin would be a 10-minute spill volume of 528,340 gallons from a 

guillotine rupture of the existing 30-inch-diameter LNG ship loading header. This 10-minute 

spill volume only considers the rated flow rate of the LNG in-tank pumps while the maximum 

possible flow rate for a pump would occur at pump runout. On March 12, 2014, Cameron LNG 

submitted pump curves and specified the maximum flow rates for the LNG in-tank pumps and 

LNG product pumps. The maximum flow rate for each LNG in-tank pump would be 11,775 

gpm. A guillotine rupture of the existing 30-inch-diameter LNG ship loading pipeline during 

export operation, with six LNG in-tank pumps running in parallel, would result in the 10-minute 

spill volume of 706,500 gallons. The LNG Spill Impoundment Basin would also contain spills 

from the LNG in-tank pump withdrawal header and the LNG rundown line. The proposed LNG 

storage tank would be equipped with four LNG in-tank pumps, each rated at 10,127 gpm with a 

maximum flow rate of 11,775 gpm. With all four LNG in-tank pumps operating, the volume for 

a 10-minute spill from the LNG in-tank pump withdrawal header would be 471,000 gallons. 

Any spills from the 24-inch-diameter LNG rundown line occurring south of the liquefaction 

trains would be sloped toward the existing LNG Spill Impoundment Basin. According to 

Cameron LNG’s March 12, 2014 filing, the maximum flow rate of each LNG product pump 

from the liquefaction area would be 7,775 gpm. A 10-minute spill volume from the 24-inch-
4-175 Safety

diameter LNG rundown line would be 233,250 gallons. These spills would be contained in the 

existing LNG Spill Impoundment Basin.

Cameron LNG proposes to construct two new concrete impoundment sumps, the 

Refrigerant Storage Sump and the Liquefaction Area Sump, to contain possible LNG and other 

hydrocarbon liquid spills from the refrigerant storage area and the liquefaction process area. The 

refrigerant storage tanks and associate piping within the curbed and concrete padded area would 

be sloped to direct any spills into the Refrigerant Storage Sump, which would be approximately 

200 feet directly south of the refrigerant storage area. The Refrigerant Storage Sump would be

30 feet long, 30 feet wide, and 27 feet deep with a usable volume of 181,777 gallons. The 

proposed Refrigerant Storage Sump would contain spills from the 57,800-gallon ethylene storage 

tank and the 120,500-gallon propane storage tank. 

Potential LNG, MRL, and NGL spills within the curbed and concrete-padded area from 

the liquefaction process trains would be sloped to the Liquefaction Area Sump, which would be 

east of the liquefaction process area. Cameron LNG originally proposed dimensions of the 

Liquefaction Area Sump to be 32-feet-long, 32-feet-wide with a usable depth under the trough 

penetration of 25 feet. However, on March 12, 2014, Cameron LNG filed a revision altering the 

total depth of the sump to 36.5 feet in order to account for the LNG product pump runout spill 

volume. This revision would increase the usable depth to 30.75 feet and usable volume to 

235,530 gallons. The largest spill into the Liquefaction Area Sump would be a guillotine rupture 

of the 24-inch-diameter LNG rundown line adjacent to the liquefaction process area. With three 

LNG product pumps operating in parallel during liquefaction, a 10-minute spill volume from the 

24-inch-diameter LNG rundown line would be 233,250 gallons. The largest refrigerant spill 

would be a 10-minute spill volume of 107,750 gallons from the 24-inch-diameter heavy MRL 

process piping located at the liquefaction heat exchanger. A 10-minute spill from the NGL line 

at the Medium Pressure Separator would be a volume of 3,410 gallons. These spills would be 

contained in the proposed Liquefaction Area Sump.

Cameron LNG proposes to install two stabilized condensate product storage tanks, each 

with a maximum volumetric capacity of 993,600 gallons. Each stabilized condensate storage 

tank would have its own secondary containment. Containment for a stabilized condensate 

product storage tank would be provided by a concrete pad and wall that would be 166.5 feet

long, 166.5 feet wide, and 7 feet high, with a usable volume of 1,451,638 gallons.

Cameron LNG proposes to install a 142,130-gallon fresh amine tank and a 142,130-

gallon lean amine tank within a 140-foot-long by 80-foot-wide by 4-foot-high common diked 

area. The diked area would have a usable volumetric capacity of 311,062 gallons and would 

hold the entire contents of both amine tanks.

4.12.5.2 Design Spills

Design spills are used in the determination of the hazard calculations required by Part 

193. Prior to the incorporation of NFPA 59A in 2000, the design spill in Part 193 assumed the 

full rupture of “a single transfer pipe which has the greatest overall flow capacity” for not less 

than 10 minutes (old Part 193.2059(d)). With the adoption of NFPA 59A, the basis for the 

design spill for impounding areas serving only vaporization, process, or LNG transfer areas 
Safety 4-176

became the flow from any single accidental leakage source. Neither Part 193 nor NFPA 59A 

(2001) defines “single accidental leakage source.” 

In a letter to the FERC staff, dated August 6, 2013, DOT requested that LNG facility 

applicants contact the Office of Pipeline Safety's Engineering and Research Division regarding 

the Part 193 siting requirements.44 Specifically, the letter stated that DOT required a technical 

review of the applicant’s design spill criteria for single accidental leakage sources on a case-bycase basis to determine compliance with Part 193.

In response, Cameron LNG provided DOT with its design spill criteria and identified 

leakage scenarios for the proposed equipment. DOT reviewed the data and methodology 

Cameron LNG used to determine the design spills based on the flow from various leakage 

sources including piping, containers, and equipment containing LNG, refrigerants, and 

flammable fluids. On November 18, 2013, DOT provided a letter to the FERC staff stating that 

DOT had no objection to Cameron LNG's methodology for determining the candidate design 

spills to be used in establishing the Part 193 siting requirements for the proposed LNG 

liquefaction facilities.45 46 The design spills produced by this method were identified in the 

documents reviewed by DOT and have been filed in the docket for this Project. These are the 

same design spills described in the following sections.

DOT’s conclusions on the candidate design spills used in the siting calculations required 

by Part 193 was based on preliminary design information which may be revised as the 

engineering design progresses. If Cameron LNG’s design or operation of the proposed facility 

differs from the details provided in the documents on which DOT based its review, then the 

facility may not comply with the siting requirements of Part 193. As a result, we are 

recommending that:

• Prior to the construction of the final design, Cameron LNG should file with 

the Secretary for review and written approval by the Director of OEP, 

certification that the final design is consistent with the information provided 

to DOT as described in the design spill determination letter dated November

18, 2013 (Accession Number 20131121-4000). In the event that any

modifications to the design alters the candidate design spills on which the 

Title 49 CFR Part 193 siting analysis was based, Cameron LNG should 

consult with DOT on any actions necessary to comply with Part 193.

 44 August 6, 2013 Letter from Kenneth Lee, Director of Engineering and Research Division, Office of Pipeline 

Safety to Terry Turpin, LNG Engineering and Compliance Branch, Office of Energy Projects. Filed in Docket 

Number CP13-25 on August 13, 2013. Accession Number 20130813-4019 45 November 18, 2013 Letter “Re: Cameron LNG, LLC, Cameron LNG Liquefaction Project, FERC Docket No. 

CP13-25-000, Design Spill Determination” from Kenneth Lee to Lauren H. O'Donnell. Filed in Docket 

Number CP13-25 on November 21, 2013. Accession Number 20131121-4000 46 PHMSA based this decision on the following documents: (1) Resource Report 11 Reliability and Public Safety, 

FERC Docket Accession Number 20121207-5141; (2) Cameron response to FERC/PHMSA Data Request, 

FERC Docket Accession Number 20130829-5203; and (3) Cameron response to FERC/PHMSA Data Request, 

FERC Docket Accession Number 20130920-5157.
4-177 Safety

As design spills vary depending on the hazard (vapor dispersion, overpressure or radiant 

heat), the specific design spills used for the Cameron LNG siting analysis are discussed under 

“Vapor Dispersion Analysis” and “Thermal Radiation Analysis” in this section.

4.12.5.3 Vapor Dispersion Analysis

As discussed in section 4.12.2, a large quantity of LNG spilled without ignition would 

form a flammable vapor cloud that would travel with the prevailing wind until it either dispersed 

below the flammable limit or encountered an ignition source. In order to address this hazard, 49 

CFR § 193.2059 requires each LNG container and LNG transfer system to have a dispersion 

exclusion zone in accordance with sections 2.2.3.3 and 2.2.3.4 of NFPA 59A (2001). Taken 

together, Part 193 and NFPA 59A (2001) require that flammable vapors either from an LNG tank 

impoundment or a single accidental leakage source do not extend beyond a facility property line 

that can be built upon. This is the Part 193 standard that we used in analyzing the siting of the

proposed Project.

Title 49 CFR §193.2059 requires that dispersion distances be calculated for a 2.5 percent 

average gas concentration (one-half the LFL of LNG vapor) under meteorological conditions 

which result in the longest downwind distances at least 90 percent of the time. Alternatively, 

maximum downwind distances may be estimated for stability Class F, a wind speed of 4.5 mph, 

50 percent relative humidity, and the average regional temperature.

The regulations in Part 193 specifically approve the use of two models for performing 

these dispersion calculations, DEGADIS and FEM3A. The use of alternative models is also 

allowed, but must be specifically approved by the DOT. Although Part 193 does not require the 

use of a particular source term model, modeling of the spill and resulting vapor production is 

necessary prior to the use of vapor dispersion models. In the past, applicants have typically used 

the SOURCE5 program to model the vapor production from an LNG spill.

Based on requests for clarification on the source term requirements of Part 193, the DOT 

issued two formal interpretations in July of 2010 regarding the regulations under 49 CFR 193.47 

In these interpretations, the DOT stated that:

• SOURCE5 could no longer be used to determine the vapor gas exclusion zone for 

compliance with § 193.2059 unless the deficiencies identified in the Fire 

Protection Research Foundation’s reports “Evaluating Vapor Dispersion Models 

for Safety Analysis of LNG Facilities Research Project (Apr. 2007)” and “LNG 

Source Term Models for Hazard Analysis: A Review of the State-of-the-Art and 

an Approach to Model Assessment (Mar. 2009)” had been addressed; and

• source term models must have a credible scientific basis and must not ignore 

phenomena which can influence the discharge, vaporization, and conveyance of 

LNG. 

 47 PHMSA Interpretation “Re: Request for Written Interpretation on the Applicability of 49 CFR 193 to Proposed 

Waterfront Liquefied Natural Gas Plant in the City of Fall River, Massachusetts” (July 7, 2010) and PHMSA 

Interpretation “Re: Request for Written Interpretation on the Applicability of 49 CFR 193 to Proposed LNG 

Import Terminal in Robbinston, Maine” (July 16, 2010).
Safety 4-178

As a result of these interpretations, alternative dispersion models became necessary in 

order to examine the effects of jetting, flashing and conveyance of LNG for exclusion zone 

calculations. In August 2010, the DOT issued Advisory Bulletin ADB-10-07 to provide 

guidance on obtaining approval of alternative vapor-gas dispersion models under Subpart B of 

49 CFR 193. In October 2011, two dispersion models were approved by DOT for use in vapor 

dispersion exclusion zone calculations: PHAST-UDM Version 6.6 and Version 6.7 (submitted 

by Det Norske Veritas) and FLACS Version 9.1 Release 2 (submitted by GexCon). PHAST 6.7 

and FLACS 9.1, with their built-in source term models, were used to calculate dispersion 

distances. 

As discussed under “Design Spills” in section 4.12.5.2, failure scenarios must be selected 

as the basis for the Part 193 dispersion analyses. Process conditions at the failure location would 

affect the resulting vapor dispersion distances. In determining the spill conditions for these 

leakage sources, process flow diagrams for the proposed design, used in conjunction with the 

heat and material balance information (i.e., flow, temperature, and pressure), can be used to 

estimate the flow rates and process conditions at the location of the spill. In general, higher flow 

rates would result in larger spills and longer dispersion distances; higher temperatures would 

result in higher rates of flashing; and higher pressures would result in higher rates of jetting and 

aerosol formation. Therefore, two scenarios may be considered for each design spill:

• the pressure in the line is assumed to be maintained by pumps and/or hydrostatic 

head to produce the highest rate of flashing and jetting (i.e. flashing and jetting 

scenario); and

• the pressure in the line is assumed to be depressurized by the breach and/or 

emergency shutdowns to produce the highest rate of liquid flow within a curbed, 

trenched, or impounded area (i.e. liquid scenario).

Alternatively, a single scenario for each design spill could be selected if adequately 

supported with an assessment of the depressurization calculations and/or an analysis of process 

instrumentation and shutdown logic acceptable to DOT.

In addition, the location and orientation of the leakage source must be considered. The 

closer a leakage source is to the property line, the higher the likelihood that the vapor cloud 

would extend off-site. As most flashing and jetting scenarios would not have appreciable liquid 

rainout and accumulation, the siting of impoundment systems would be driven by liquid 

scenarios, while siting of piping and other remaining portions of the plant would be driven by 

flashing and jetting scenarios.

Cameron LNG reviewed multiple releases for the liquid scenarios and for the flashing 

and jetting scenarios. Cameron LNG used the following conditions, corresponding to 49 CFR 

§193.2059, for the vapor dispersion calculations: ambient temperature of 68°F, relative humidity 

of 50 percent, wind speed of 4.5 mph, atmospheric stability class of F and a ground surface 

roughness of 0.03 m. In addition, a sensitivity analysis to the wind speed and direction was 

provided to demonstrate the longest predicted downwind dispersion distance in accordance with 

the PHAST and FLACS Final Decisions.
4-179 Safety

Cameron LNG accounted for the facility geometry, including the impoundment and 

trench geometry details as established by available plant layout drawings. The plant geometry 

accounts for any on-site wind channeling that could occur. The releases were initiated after 

sufficient time had passed in the model simulations to allow the wind profile to stabilize from 

effects due to the presence of buildings and other on-site obstructions.

Vapor Dispersion Analyses for LNG

According to table 2.2.3.5 of NFPA 59A, the design spill is the largest flow from the 

container (i.e., storage tank) withdrawal pumps for a 10-minute duration at full-rated capacity. 

In order to address the highest rate of LNG flow (i.e., liquid scenario) into the existing LNG 

Impoundment Basin, Cameron LNG specified the design spill as the guillotine rupture of the 30-

inch-diameter LNG ship loading line with six in-tank pumps from multiple LNG storage tanks 

operating in parallel. This liquid spill would result in a maximum flow rate of 52,834 gpm for a

10-minute duration. FLACS was used to predict the extent of the 1⁄2-LFL vapor cloud. In the 

FLACS simulation, Cameron LNG selected a spill location on the 30-inch-diameter ship loading 

line within the existing Terminal at the shortest distance to the Cameron LNG Terminal’s west 

property line along LA-27. Cameron LNG initially proposed to install two layers of 20-foothigh vapor fences along the north and west property lines to confine the vapor clouds and limit 

the extent of the vapor dispersion zones. In addition, a third layer of vapor fencing, 

approximately 100 feet long, would be provided at the 30-inch-diameter ship loading line located 

near the west property line. In the FLACS simulation, Cameron LNG modeled the vapor fences 

as 0 percent porosity.

Cameron LNG stated the design of the vapor fences would be completed during detailed 

engineering and would take into account wind load and overpressure. Cameron LNG also stated 

that the vapor fences would be periodically inspected and repaired as needed through the life of 

the facility. In order to ensure that the vapor fences are designed to withstand the wind load and 

overpressure and are maintained throughout the life of the facility, we are recommending that:

• Prior to construction of the final design, Cameron LNG should file with the 

Secretary for review and written approval by the Director of OEP, the 

details of the vapor fences as well as procedures to maintain and inspect the 

vapor barriers provided to meet the siting provisions of 49 CFR § 193.2059. 

This information should be filed a minimum of 30 days before approval to 

proceed is requested. 

In addition, the vapor fence layout provided in Resource Report 11 of the application, 

showed a vapor fence segment directly north of the liquefaction facility, encompassing the 

refrigerant storage and truck loading area. However, the vapor fence layout did not include the 

truck turnaround route, as this vapor fence segment would intersect with the truck turnaround 

route for trucks exiting the truck loading area. In order to address the discrepancy in the vapor 

fence layout, we requested that Cameron LNG address the vapor fence sections that may obstruct 

the truck turnaround route. On February 20, 2014, Cameron LNG filed a response stating that 

the amount of vapor fencing proposed in the application was overly extensive to assure the 

resulting vapor dispersion would stay onsite; however, Cameron LNG reviewed the FLACS 

vapor dispersion results and determined that the vapor fence sections adjacent to the proposed 

liquefaction facilities would not be needed. The updated vapor fence arrangement includes only 
Safety 4-180

three vapor fence layers adjacent to the 30-inch-diameter ship loading line, as shown in figure 

4.12-1. This revised vapor fence arrangement would not obstruct the truck turnaround route.

The FLACS results indicated that the 1⁄2-LFL vapor cloud would extend beyond the vapor 

fences as well as Cameron LNG property but would remain within an area designated as the 

Barbe Limit of Exclusion Zone, located west of the Cameron LNG property line and across 

highway LA-27. The Barbe Limit of Exclusion Zone is defined by a September 17, 2003 

Servitude and Easement Agreement between Cameron LNG and the Lake Charles Harbor and 

Terminal District, established to grant Cameron LNG legal control over the thermal radiation 

exclusion zones from the LNG storage tanks which were placed into service in July 2009. As 

part of its role as a cooperating agency on this document, DOT provided comments stating that 

its legal staff would need to review this agreement. In order to ensure that the Cameron LNG’s 

arrangement addresses the exclusion zone requirements of Part 193, we recommend that:

• Prior to initial site preparation, Cameron LNG should file with the Secretary 

concurrence from DOT that the Barbe Limit of Exclusion Zone complies 

with the exclusion zone requirements of 49 CFR 193. 2059.

In order to address the highest rate of LNG flow (i.e. liquid scenario) into the 

Liquefaction Area Sump, Cameron LNG specified the design spill as a hole equivalent to 

1⁄3 diameter of the 24-inch-diameter LNG rundown header located east of the liquefaction process 

area, resulting in a 12,020 gpm spill rate. The FLACS results indicate that the 1⁄2-LFL vapor 

cloud would remain within Cameron LNG’s property boundary at all times. 

Cameron LNG used PHAST Version 6.7 to perform diameter sensitivity, wind 

sensitivity, and elevation sensitivity studies in order to achieve worst case jetting and flashing 

scenarios. For the jetting and flashing scenario of an LNG spill from the 30-inch-diameter ship 

loading line, Cameron LNG considered a release source at the shortest distance to the west 

property line along LA-27. The diameter sensitivity study indicated that a release from a 

10-inch-diameter hole from the ship loading line would generate the highest vapor production 

rate, which would consequently result in longer 1⁄2-LFL vapor cloud distances. Cameron LNG 

proposed to install impingement shrouds around the entire 30-inch-diameter ship loading line in 

order to mitigate high momentum jetting and flashing releases and induce liquid rainout. The 

impingement shrouds would be designed and constructed to withstand the mechanical stress and 

thermal environment of a release. The Terminal’s maintenance and inspection program would 

be updated to ensure the integrity and replacement of these impingement shrouds in the event of 

damage. As Cameron LNG’s impingement shroud design is only at a preliminary stage, we are 

recommending that:

• Prior to construction of the final design, Cameron LNG should file with the 

Secretary, for review and written approval by the Director of OEP, the 

details of the impingement shrouds final design as well as procedures to 

maintain and inspect the impingement shrouds. This information should be 

filed a minimum of 30 days before approval to proceed is requested.
4-181 Safety

Figure 4.12-1 Vapor Fences Proposed at the Cameron LNG 

Terminal
Safety 4-182

The installation of the impingement shrouds allowed Cameron LNG to model the 

downward release in PHAST, which resulted in a significant liquid rainout into the trench. 

Cameron LNG also used Starr-CCM+, a commercially available computational fluid dynamics 

code developed by CD-Adapco, to support the assumption that the impingement shrouds would 

direct the flow of LNG downward. The resulting liquid and vapor mass flow rates were used as 

input to FLACS. The FLACS results indicated the 1⁄2-LFL for the liquid rainout into the trench 

would remain within Cameron LNG property, and the 1⁄2-LFL for LNG flashing and jetting 

would extend beyond the first two layers of vapor fences but would be confined by the third 

layer of vapor fence. The 1⁄2-LFL vapor cloud for the flashing and jetting scenario from the 

30-inch-diameter ship loading line would remain within the property line considering installation 

of the vapor fences and impingement shrouds. Cameron LNG also analyzed a design spill from 

each in-tank pump discharge header at the LNG storage tank area. This 24-inch-diameter in-tank 

pump discharge header runs from the top of the LNG storage tank down the side of the tank and 

connects to the 30-inch-diameter ship loading line. Cameron LNG selected a 1-inch-diameter 

hole on the 24-inch-diameter in-tank pump discharge header from the existing LNG storage tank 

located at the shortest distance to the west property line. 

Cameron LNG performed a sensitivity study using PHAST for design spills along the 24-

inch-diameter in-tank pump discharge header at the top, middle, and bottom of the LNG storage 

tank at various wind speeds. The PHAST results indicated no liquid rainout. The PHAST 

results indicate that the 1⁄2-LFL vapor cloud for the LNG flashing and jetting scenarios at the top 

and middle of the LNG storage tank would extend 225 feet at an elevation of 162 feet and 180 

feet at an elevation of 77 feet, respectively. In performing the dispersion calculations, Cameron 

LNG used wind speeds of 16 and 20 – meters per second (m/s) that reflect the higher elevations 

of this piping. Selection of these speeds was based a sensitivity analysis ranging from 1 m/s to 

20 m/s which found that 16 m/s and 20 m/s resulted in the longest dispersion distances. The 1⁄2-

LFL vapor clouds from these two releases would not reach the ground level and would remain 

within Cameron LNG property. Regarding the release from the 24-inch-diameter in-tank pump 

discharge header at the LNG storage tank ground elevation, Cameron LNG previously used 

FLACS to model a spill from a 2-inch-diameter hole with the same process conditions and 

demonstrated that the 1⁄2-LFL vapor cloud would be contained within Cameron LNG property by 

the vapor fences; therefore, a smaller release from the 1-inch-diameter hole would not extend 

beyond the vapor fences.

Cameron LNG considered the highest rate of LNG flashing and jetting from the 

liquefaction process area would be a release from an 8-inch-diameter hole from the 

24-inch-diameter LNG rundown line. Impingement shrouds would also be installed along the

24-inch-diameter LNG rundown line to mitigate the vapor production rate and induce rainout. 

The liquid portion from this release into the trench was modeled using FLACS, and the vapor 

portion was modeled using PHAST. Other design spill considerations for LNG flashing and 

jetting from the liquefaction process area include a 1-inch-diameter hole from the LNG pump 

single discharge line and a 1-inch-diameter hole from the 24-inch-diameter LNG product line 

downstream of the liquefaction heat exchanger. Table 4.12.5-2 provides the results for LNG 

jetting and flashing scenarios from the liquefaction process area. The distances to the 1⁄2-LFL 

vapor cloud for all LNG flashing and jetting scenarios from the liquefaction process area would 

also remain within Cameron LNG property.
4-183 Safety

TABLE 4.12.5-2

Vapor Dispersion Scenarios from LNG Flashing and Jetting Releases

Scenario Release location Wind Speed

(meters/second)

Approximate downwind 

distance to 1⁄2-LFLa (feet)

1 In-tank Pump Discharge Header at 

Top of the LNG Storage Tank 20 225

2 In-tank Pump Discharge Header at 

Middle of LNG Storage Tank 16 180

3 In-tank Pump Discharge Header at 

Ground Level - 320b

4 LNG Rundown Header 1 1,253

5 LNG Pump Discharge 1 655

6 Liquefaction Heat Exchanger 2 390

a LFL = lower flammability limit b Approximate distance from the spill source to the vapor fence.

As Cameron LNG’s calculations show the dispersion from flammable vapors would stay 

within Cameron LNG property, we conclude that the siting of the proposed Project would not 

have a significant impact on public safety. If the facility is constructed and operated, compliance 

with the requirements of 49 CFR 193 would be addressed as part of DOT’s inspection and 

enforcement program.

Vapor Dispersion Analyses for Other Hazardous Fluids

Even though Cameron LNG considered all possible releases from the MRL process 

system, the propane pre-cool system, and the heavy hydrocarbon removal system at the 

liquefaction process area, only the spills that produced the highest release rates and consequently 

the longest 1⁄2-LFL vapor cloud distances are discussed in this section. As stated, the lines are 

assumed to be maintained at a constant pressure in order to produce the highest rate of flashing 

and jetting. The highest rate of MRL release would be from a 1-inch-diameter hole at the MRL 

process line downstream of the mixed refrigerant chiller. Cameron LNG considered methane 

and ethylene as a single component for the MRL flammable vapor dispersion analyses, and 

ethylene was chosen as input for the overpressure analysis due to its higher reactivity. While we 

agree that ethylene as a single component may result in the longest distance to the 1-psi 

overpressure, using either methane or ethylene as a single component input to PHAST may not 

result in the longest flammable vapor dispersion distance. In order to address this, we used the 

composition of MRL for the richest case given in the heat and material balance sheets as input to 

PHAST for a horizontal release. PHAST result indicated no liquid rainout, and the 1⁄2-LFL 

distance is shown in table 4.12.5-3. 
Safety 4-184

TABLE 4.12.5-3

Vapor Dispersion Scenarios from Refrigerant, NGL, and Condensate Releases

Scenario Material Release Location Wind Speed

(meters/second)

Approximate downwind 

distance to 1⁄2-LFL (feet)

1 Mixed Refrigerant Liquefaction Process 1 297

2 Propane Liquefaction Process 1 985

3 NGL Liquefaction Process 3 958

4 Ethylene Refrigerant Storage 5 826

5 Propane Refrigerant Storage 6 485

5 Ethylene Truck Unloading 6 1,200

6 Propane Truck Unloading 7 870

7 Condensate Condensate Storage 2 1,873

Propane would be used in the liquefaction cycle to pre-cool the feed gas and mixed 

refrigerant vapor. The worst case scenario for a propane liquid release at the liquefaction process 

area would be a horizontal release of the 4-inch connection at the propane condenser header. 

The highest rate of NGL release would be a 1-inch-diameter hole from the 4-inch-diameter NGL 

process line downstream of the High Pressure Separator. The results for these design spills 

considered in the liquefaction area are provided in table 4.12.5-3 and show that the 1⁄2-LFL vapor 

clouds would remain within Cameron LNG’s property.

At the refrigerant storage area where the ethylene and propane storage tanks would be 

located, Cameron LNG considered design spills from a 1-inch-diameter hole for both of the 

ethylene and propane make-up lines. PHAST results indicated that ethylene and propane spills 

from the 1-inch-diameter holes would result in no liquid rainout.

In the refrigerant truck unloading area, Cameron LNG considered design spills from the 

2-inch-diameter transfer lines from the propane and ethylene trucks to the propane and ethylene 

make-up tanks. The maximum spill duration were assumed to be the de-inventory time of the 

ethylene and propane trucks for 5 minutes and 6 minutes, respectively. The results for the design 

spills in the horizontal direction considered in the truck loading area resulted in no liquid rainout.

In order to determine the longest 1⁄2-LFL vapor cloud distance for a release from the 

stabilized condensate storage area, Cameron LNG assumed the entire content of one stabilized 

condensate tank would be instantaneously spilled into the containment area. The 1⁄2 -LFL vapor 

cloud would remain within Cameron LNG’s property. 

Table 4.12.5-3 provides the PHAST Version 6.7 results for the refrigerants and NGL 

jetting and flashing scenarios as well as stabilized condensate liquid spill scenario. The PHAST 

simulations indicated that horizontal direction releases from the liquefaction process area, 

refrigerant storage area, and truck unloading area would result in jetting and flashing without any 

liquid accumulation due to the process conditions and hole sizes. 

The distances to the 1⁄2-LFL vapor cloud for all refrigerant and NGL release scenarios 

discussed above would remain within the Cameron LNG property. As Cameron LNG’s 
4-185 Safety

calculations show the vapor dispersion would stay within Cameron LNG property, we conclude 

that the siting of the proposed Project would not have a significant impact on public safety. If 

the facility is constructed and operated, compliance with the requirements of 49 CFR 193 would 

be addressed as part of DOT’s inspection and enforcement program.

Since the stabilized condensate would contain benzene, a toxic product, Cameron LNG 

used PHAST Version 6.7 to calculate the dispersion distances to toxic threshold exposure limits 

based on the Acute Exposure Guideline Level (AEGLs). AEGLs are recommended for use by 

federal, state, and local agencies, as well as the private sector for emergency planning, 

prevention, and response activities related to the accidental release of hazardous substances. 

Other federal agencies, such as the Department of Energy, use AEGLs as the primary measure of 

toxicity.

There are three AEGLs which are distinguished by varying degrees of severity of toxic 

effects with AEGL-1 (level 1) being the least severe to AEGL-3 being the most severe. AEGL-1 

is the airborne concentration of a substance that the general population, including susceptible 

individuals, could experience notable discomfort, irritation, or certain asymptomatic nonsensory 

effects. However, these effects are not disabling and are transient and reversible upon cessation 

of the exposure. AEGL-2 is the airborne concentration of a substance above which it is 

predicted that the general population, including susceptible individuals, could experience 

irreversible or other serious, long-lasting adverse health effects or an impaired ability to escape. 

AEGL-3 is the airborne concentration of a substance above which it is predicted that the general 

population, including susceptible individuals, could experience life-threatening health effects or 

death. The EPA provides AEGLs for a list of chemicals at varying exposure times (10 minutes, 

30 minutes, 1 hour, 4 hours, and 8 hours). Table 4.12.5-4 shows the toxic concentrations of 

benzene at each AEGL and corresponding exposure time based on EPA’s published information 

(EPA 2012).

TABLE 4.12.5-4

Acute Exposure Guideline Levels (in ppm) for Benzene

Guideline 

Level 10-minute 30-minute 60-minute 4-hour 8-hour

AEGL 1 130 73 52 18 9

AEGL 2 2,000 1,100 800 400 200

AEGL 3 9,700 5,600 4,000 2,000 990

Cameron LNG’s toxicity analysis conservatively assumed that the entire content of the 

stabilized condensate tank for the richest case was instantaneously spilled into the containment 

area. Similar to flammability concentrations, a safety factor of 2 (i.e. 1⁄2 AEGL) was also applied 

to reflect uncertainties associated with the model. The maximum dispersion distance to the 9 

ppm benzene concentration (i.e., 1⁄2 AEGL-1 at 4 hours) was found to extend 1.1 miles. This 

vapor cloud would travel offsite and extend over Gulf Port Oil and Gas’s field office, Cardinal 

Hunting Club’s building, a private boat storage shed, and three abandoned drilling rig locations. 

Cameron LNG would update its Emergency Response Plan to notify the Gulf Port Oil and Gas, 

the Cardinal Club, and the boat storage shed owner in the event of an emergency that involves a 
Safety 4-186

stabilized condensate tank failure. There would be no residences, parks, hospitals, churches or 

other sensitive areas within this distance. Additionally, the toxicity effects associated with 

AEGL-1 are non-disabling and reversible. As a result, we conclude the stabilized condensate 

would not present a significant impact to the public. If the facility is constructed and operated, 

compliance with the requirements of 49 CFR 193 would be addressed as part of DOT’s 

inspection and enforcement program.

Overpressure Considerations

As discussed in section 4.12.2, the propensity of a vapor cloud to detonate or produce 

damaging overpressures is influenced by the reactivity of the material, the level of confinement 

and congestion surrounding and within the vapor cloud, and the flame travel distance. It is 

possible that the prevailing wind direction may cause the vapor cloud to travel into a partially 

confined or congested area. 

LNG Vapor Clouds

As adopted by Part 193, section 2.1.1 of NFPA 59A (2001) requires an evaluation of 

potential incidents and safety measures incorporated in the design or operation of the facility be 

considered. As discussed under “Overpressures” in section 4.12.2, unconfined LNG vapor 

clouds would not be expected to produce damaging overpressures. The presence of heavier 

hydrocarbons influences the propensity for a detonation or deflagration with damaging 

overpressures. Product with greater amounts of heavier hydrocarbons is more sensitive to 

detonation. The Terminal Expansion would be designed to receive feed gas with methane 

concentrations as low as 91 percent. These compositions are not in the range shown to exhibit 

overpressures and flame speeds associated with high-order explosions and detonations. 

The Coast Guard studies referenced under “Overpressures” in section 4.12.2 indicated 

overpressures of 4 bar and flame speeds of 35 m/s (meters per second) were produced from 

vapor clouds of 86 percent to 96 percent methane in near stoichiometric proportions using 

exploding charges as the ignition source. The 4 bar overpressure was the same overpressure 

produced during the calibration test involving exploding the charge ignition source alone, so it 

remains unclear that the overpressure was attributable to the vapor deflagration. However, 

unconfined methane vapor clouds ignited with low energy ignition sources have been shown to 

produce flame speeds ranging from 5.2 to 7.3 m/s, which is much less than the flame speeds 

associated with explosions or detonations. 

Additional tests were conducted to study the influence of confinement and congestion on 

the propensity of a vapor cloud to detonate or produce damaging overpressures. The tests used 

obstacles to create a partially confined and turbulent scenario, but found that flame speeds 

developed for methane were not significantly higher than the unconfined case and were not in 

the range associated with detonations. 

Given the LNG compositions which would be handled onsite, potential ignition sources, 

and the expected vapor dispersion characteristics, damaging overpressures would not be 

expected to occur from ignition of an unconfined vapor cloud. However, ignition of a confined 

natural gas vapor cloud could result in higher overpressures. In order to prevent such an 

occurrence, the liquefaction process area and the refrigerant storage area would be located away 
4-187 Safety

from proposed and existing buildings in the Cameron LNG Terminal. In addition, Cameron 

LNG proposes to install flammable gas detectors in occupied building heating, ventilation, and 

air conditioning (HVAC) inlets to reduce the likelihood of flammable vapors dispersing into 

these buildings. 

As discussed in section “Vapor Dispersion Analysis,” methane vapor from potential LNG 

releases at the ship loading header would be limited and confined within three layers of 20-foothigh vapor fences. Of the three vapor fence layers, Cameron LNG identified the shortest 

distance between any parallel vapor fences would be 20 feet apart, which would approximately 

be the same as the fence height. PHAST Version 6.7 was used to predict the 1-psi overpressure 

distance from the methane vapor trapped between the vapor fences. The PHAST results 

indicated that the maximum overpressure due to ignition of the methane vapor cloud between the 

vapor fences would be 0.46 psi and would extend 72 feet from the ignition location. This 

distance would remain within Cameron LNG’s property.

Vapor Clouds from Other Hazardous Fluids 

The refrigerants which would be used in the liquefaction process streams have a higher 

reactivity than LNG, and in some circumstances may produce damaging overpressures when 

ignited. In order to evaluate this hazard, Cameron LNG used PHAST Version 6.7 to perform an 

explosion overpressure analysis. Three explosion models including the 

trinitrotoluene-equivalent model, the Netherland Organization for Applied Scientific Research 

TNO multi-energy model, and the Baker-Strehlow-Tang model were used as inputs in the 

PHAST overpressure analysis. Cameron LNG used the vapor dispersion results, previously 

discussed in section “Vapor Dispersion Analysis,” from the releases of refrigerants from the 

liquefaction process area, the refrigerant storage area, and the truck unloading area as input to the 

explosion models. 

Table 4.12.5-5 provides the worst-case results of the three explosion models for each 

scenario. PHAST results showed that the maximum overpressure from the ignition of the 

propane and NGL vapor clouds at the proposed LNG storage tank would be 2.3 psi. Cameron 

LNG indicated that the LNG storage tank would be designed for an external blast loading of 2.4 

psi. For the mixed refrigerant overpressure scenario, Cameron LNG selected ethylene as the 

input to the PHAST model because it is a higher reactivity fuel compared to other mixed 

refrigerant components. In all overpressure scenarios, the 1-psi overpressure distance would 

remain within the Cameron LNG property. As a result, we conclude that the siting of the 

proposed Project would not have a significant impact on public safety. If the facility is 

constructed and operated, compliance with the requirements of 49 CFR 193 would be addressed 

as part of DOT’s inspection and enforcement program.
Safety 4-188

TABLE 4.12.5-5

Overpressure Scenarios from Refrigerant Releases

Scenario Material Release Locations Approximate 1-psi overpressure 

distance (feet)

1 MRL Liquefaction Process Area 479

2 Propane Liquefaction Process Area 778

3 NGL Liquefaction Process Area 617

4 Ethylene Refrigerant Storage Area 975

5 Propane Refrigerant Storage Area 470

6 Ethylene Truck Unloading Area 1,460

7 Propane Truck Unloading Area 843

4.12.5.4 Thermal Radiation Analysis

As discussed in section 4.12.2, if flammable vapors are ignited, the deflagration could 

propagate back to the spill source and result in a pool fire causing high levels of thermal 

radiation (i.e., heat from a fire). In order to address this, 49 CFR Section 193.2057 specifies 

hazard endpoints in terms of flux levels for spills into LNG storage tank containment and spills 

into impoundments for process or transfer areas. For any distance from a pool fire, a flux level,

which expresses how much thermal radiation would be received at that point, can be calculated. 

Each LNG container and LNG transfer system is required to have a thermal exclusion zone in 

accordance with Section 2.2.3.2 of NFPA 59A (2001). Together, Part 193 and NFPA 59A 

(2001) specify different hazard endpoints for spills into LNG storage tank containment and spills 

into impoundments for process or transfer areas. For LNG storage tank spills, there are three 

radiant heat flux levels which must be considered:

• 1,600 Btu/ft2-hr - This level can extend beyond the facility’s property line that can 

be built upon but cannot include areas that, at the time of facility siting, are used 

for outdoor assembly by groups of 50 or more persons;

• 3,000 Btu/ft2

-hr - This level can extend beyond the facility’s property line that can 

be built upon but cannot include areas that, at the time of facility siting, contain 

assembly, educational, health care, detention or residential buildings or structures; 

and

• 10,000 Btu/ft2-hr - This level cannot extend beyond the facility’s property line 

that can be built upon.

The requirements for spills from process or transfer areas are more stringent. For these 

impoundments, the 1,600 Btu/ft2-hr flux level cannot extend beyond the facility’s property line 

that can be built upon. These are the Part 193 standards that we used in analyzing the siting of 

the proposed Project.

Part 193 requires the use of the LNGFIRE3 computer program model developed by the 

Gas Research Institute to determine the extent of the thermal radiation distances. Part 193 

stipulates that the wind speed, ambient temperature, and relative humidity that produce the 
4-189 Safety

maximum exclusion distances must be used, except for conditions that occur less than 5 percent 

of the time based on recorded data for the area. Cameron LNG submitted a thermal radiation 

analysis that showed the following ambient conditions resulted in maximum exclusion distances: 

wind speeds of 9 to 23 mph, ambient temperature of 32°F, and 20 percent relative humidity. We 

agree with Cameron LNG’s selection of atmospheric conditions.

For its analysis, Cameron LNG calculated thermal radiation distances for the 1,600-, 

3,000-, and 10,000-Btu/ft2

-hr incident radiant heat levels for the LNG storage tank using the 

outer tank’s concrete wall diameter (260 feet) as the pool diameter. The flame base was set 

equal to the top of the concrete wall (142 feet). Target heights were set at the ground level. In 

addition, Cameron LNG calculated thermal radiation distances using LNGFIRE3 for the 

1,600-Btu/ft2

-hr incident radiant heat level centered on the existing LNG Spill Impoundment 

Basin. 

Cameron LNG also used LNGFIRE3 to predict the thermal radiation distance at the level 

of 1,600-BTU/ft2-hr for fires from the Liquefaction Area Sump, the Refrigerant Storage Sump, 

and the Condensate Storage Tank Dikes. Although LNGFIRE3 is specifically designed to 

calculate thermal radiation flux levels for LNG pool fires, LNGFIRE3 could also be used to 

conservatively calculate the thermal radiation flux levels for flammable hydrocarbons such as 

ethylene, propane, NGL, and condensate. Two of the parameters used by LNGFIRE3 to 

calculate the thermal radiation flux is the mass burning rate of the fuel and the surface emissive 

power (SEP) of the flame, which is an average value of the thermal radiation flux emitted by the 

fire. The mass burning rate and SEP of an ethylene, propane, NGL, or condensate fire would be 

less than an equally sized LNG fire. Since the thermal radiation from a pool fire is dependent on 

the mass burning rate and SEP, the thermal radiation distances required for ethylene, propane, 

NGL, and condensate fires would not extend as far as the exclusion zone distance previously 

calculated for an LNG fire in the same sump. 

The resulting maximum thermal radiation distances are shown in table 4.12.5-6 and 

figure 4.12-2. The 10,000-, 3,000-, and 1,600-Btu/ft2

-hr heat fluxes from the LNG storage tank 

and the 1,600-Btu/ft2

-hr heat flux from the existing LNG Impoundment Basin, the Liquefaction 

Area Sump, the Refrigerant Storage Sump, and the stabilized condensate storage tank dike would 

remain within the facility property lines. As Cameron LNG’s calculations show the radiant heat 

limits for Part 193 would stay within Cameron LNG property, we conclude that the siting of the 

proposed Project would not have a significant impact on public safety. If the facility is 

constructed and operated, compliance with the requirements of 49 CFR 193 would be addressed 

as part of DOT’s inspection and enforcement program.
Safety 4-190

TABLE 4.12.5-6

Thermal Radiation Exclusion Zones for Impoundment Basins

Flux Level 

(Btu/ft2

-hr )

FullContainment 

Tank Outer 

Containment 

(feet)a

Existing LNG 

Impoundment 

Basin (feet)a

Liquefaction 

Area Sump

(feet)a

Refrigerant 

Storage Sump 

(feet)a

Condensate 

Storage Tank 

Dike

(feet)a

10,000 369 194 130 125 453

3,000 752 296 168 160 622

1,600 977 372 196 186 745

a from center of impoundment

4.12.5.5 BLEVE

Cameron LNG proposes to locate the ethylene and propane storage systems away from 

potential fire sources and outside all thermal radiation zones. These remote locations would 

result in negligible risk of a BLEVE occurring at the refrigerant storage area. There would be 

two stabilized condensate storage tanks at the site. Since the two stabilized condensate storage 

tanks would be located adjacent to each other, the radiant heat from a tank fire would impinge 

over the adjacent tank. In order to address the potential fireball and overpressure from a 

BLEVE, Cameron LNG used PHAST Version 6.7 to estimate the distance to the 5 kW per 

square meter (kW/m2) radiant heat level 1-psi overpressure. PHAST results show that the

distance to the 5 kW/m2 radiant heat level from a fireball scenario would be 4,565 feet away 

from the center of the stabilized condensate storage tank and extend beyond Cameron LNG’s 

property. Cameron LNG identified a private boat storage shed and three abandoned drilling rig 

locations within this distance; however, there would be no parks, hospitals, churches, or other 

occupied locations or dwellings. Cameron LNG would update its Emergency Response Plan to 

notify the boat storage shed owner in the event of an emergency that involves a stabilized 

condensate tank failure. As a result, we conclude that the siting of the proposed Project would 

not have a significant impact on public safety. If the facility is constructed and operated, 

compliance with the requirements of 49 CFR 193 would be addressed as part of DOT’s 

inspection and enforcement program.
4-191 Safety

Figure 4.12-2 Thermal Radiation Exclusion Zones 1,600-BTU/ft2

for LNG Storage Tank, Condensate Storage Tank, and 

Impoundment Sumps
Safety 4-192

4.12.6 Emergency Response 

Section 3A(e) of the NGA, added by Section 311 of the EPAct, stipulated that in any 

order authorizing an LNG terminal, the Commission shall require the LNG terminal operator to 

develop an emergency response plan (ERP) in consultation with the Coast Guard and state and 

local agencies. The ERP has been in place since the Cameron LNG Terminal began operation in 

July of 2009. The existing ERP would need to be updated to include the proposed liquefaction 

facilities and emergencies related to refrigerant handling. Therefore, we are recommending

that:

• Cameron LNG should update its ERP to include the Terminal Expansion 

facilities as well as instructions to handle on-site refrigerant and NGL-related 

emergencies. Cameron LNG should file the ERP with the Secretary for 

review and written approval by the Director of OEP prior to initial site 

preparation.

• The ERP should include a Cost-Sharing Plan identifying the mechanisms for 

funding all Project-specific security/emergency management costs that would 

be imposed on state and local agencies. In addition to the funding of direct 

transit-related security/emergency management costs, this comprehensive 

plan should include funding mechanisms for the capital costs associated with 

any necessary security/emergency management equipment and personnel 

base. Cameron LNG should file the Cost-Sharing Plan for review and 

written approval by the Director of OEP prior to initial site preparation.

4.12.7 Facility Security and LNG Vessel Safety

The security requirements for the Project are governed by 49 CFR 193, Subpart J -

Security. This subpart includes requirements for conducting security inspections and patrols, 

liaison with local law enforcement officials, design and construction of protective enclosures, 

lighting, monitoring, alternative power sources, and warning signs. Requirements for 

maintaining safety of the liquefaction facility are in the Coast Guard regulations in 33 CFR 127. 

Requirements for maintaining security of the terminal are in 33 CFR 105. 

The Cameron LNG Terminal commenced service in July 2009 and has been receiving 

LNG shipments for import and re-export purposes. The existing facility has a Facility Security 

Plan, as required by 33 CFR 105, which has been approved by the Coast Guard. In addition, the 

LNG ship transits to the existing facility are performed under the “LNG Vessel Management and 

Emergency Plan” established by the Coast Guard for the Calcasieu Ship Channel. There are no 

proposed changes in the marine systems or the expected number of vessels as a result of the 

proposed Project. 

In a letter to the Coast Guard dated February 27, 2012, Cameron LNG detailed the 

Terminal Expansion modifications and stated it believed there would be no additional waterway 

impacts beyond those examined for the 346 ship transits assumed in the December 2005 WSA 

submitted to the Coast Guard for import operations. In a letter dated March 16, 2012, the Coast 

Guard stated that a LOI or a revision to the WSA was not required. However, the Coast Guard 

specified that applicable amendments to the Operations Manual, Emergency Manual, and 
4-193 Safety

Facility Security Plan must be made that capture changes to the operations associated with the 

Terminal Expansion Project. As required by 33 CFR 105 and 127, Cameron LNG would amend 

these documents and submit them to the Coast Guard prior to operation of the facility as an 

export terminal.

4.12.8 Pipeline Safety Standards

Regarding Cameron Interstate’s proposed facilities for the Pipeline Expansion, the 

transportation of natural gas by pipeline involves some risk to the public in the event of an 

accident and subsequent release of gas. The greatest hazard is a fire or explosion following a 

major pipeline rupture.

Methane, the primary component of natural gas, is colorless, odorless, and tasteless. It is 

not toxic, but is classified as a simple asphyxiate, possessing a slight inhalation hazard. If 

breathed in high concentration, oxygen deficiency can result in serious injury or death. 

Methane has an ignition temperature of 1,000o

F and is flammable at concentrations 

between 5 and 15 percent in air. Unconfined mixtures of methane in air are not explosive. 

However, a flammable concentration within an enclosed space in the presence of an ignition 

source can explode. It is buoyant at atmospheric temperatures and disperses rapidly in air.

DOT is mandated to provide pipeline safety under 49 USC 601. The PHMSA Office of 

Pipeline Safety (OPS) administers the national regulatory program to ensure the safe 

transportation of natural gas and other hazardous materials by pipeline. It develops safety 

regulations and other approaches to risk management that ensure safety in the design, 

construction, testing, operation, maintenance, and emergency response of pipeline facilities. 

Many of the regulations are written as performance standards which set the level of safety to be 

attained and allow the pipeline operator to use various technologies to achieve safety. PHMSA 

ensures that people and the environment are protected from the risk of pipeline incidents. This 

work is shared with state agency partners and others at the federal, state, and local level. Section 

5(a) of the Natural Gas Pipeline Safety Act provides for a state agency to assume all aspects of 

the safety program for intrastate facilities by adopting and enforcing the federal standards, while 

Section 5(b) permits a state agency that does not qualify under Section 5(a) to perform certain 

inspection and monitoring functions. The state of Louisiana has a Section 5(a) certification.

DOT pipeline standards are published in 49 CFR 190 to 199. Part 192 addresses natural 

gas pipeline safety issues. Under a Memorandum of Understanding on Natural Gas 

Transportation Facilities (Memorandum) dated January 15, 1993 between the DOT and the 

FERC, DOT has the exclusive authority to promulgate federal safety standards used in the 

transportation of natural gas. Section 157.14(a)(9)(vi) of the FERC’s regulations require that an 

applicant certify that it will design, install, inspect, test, construct, operate, replace, and maintain 

the facility for which a certificate is requested in accordance with federal safety standards and 

plans for maintenance and inspection, or shall certify that it has been granted a waiver of the 

requirements of the safety standards by DOT in accordance with Section 3(e) of the Natural Gas 

Pipeline Safety Act. Cameron Interstate has stated that it would design, construct, operate, and 

maintain its pipeline and aboveground facilities associated with the Pipeline Expansion in 

accordance with or exceeding the DOT’s Minimum Federal Safety Standards in 49 CFR 192. 
Safety 4-194

The FERC accepts this certification and does not impose additional safety standards other 

than DOT standards. If the Commission becomes aware of an existing or potential safety 

problem, there is a provision in the Memorandum to promptly alert DOT. The Memorandum 

also provides for referring complaints and inquiries made by state and local governments and the 

general public involving safety matters related to pipelines under the Commission’s jurisdiction. 

The FERC also participates as a member of DOT’s Technical Pipeline Safety Standards 

Committee which determines if proposed safety regulations are reasonable, feasible, and 

practicable.

The regulations at 49 CFR 192 are intended to ensure adequate protection for the public 

and to prevent natural gas facility accidents and failures. Part 192 specifies material selection 

and qualification, minimum design requirements, and protection from internal, external, and 

atmospheric corrosion. Part 192 also defines area classifications, based on population density in 

the vicinity of the pipeline, and specifies more rigorous safety requirements for populated areas. 

The class location unit is an area that extends 220.0 yards on either side of the centerline of any 

continuous 1-mile length of pipeline. The four area classifications are defined as follows:

• Class 1 - location with 10 or fewer buildings intended for human occupancy;

• Class 2 - location with more than 10 but less than 46 buildings intended for 

human occupancy;

• Class 3 - location with 46 or more buildings intended for human occupancy, or 

where the pipeline lies within 100 yards of any building or small well-defined 

outside area occupied by 20 or more people during normal use; and 

• Class 4 - location where buildings with four or more stories aboveground are 

prevalent.

Class locations representing more populated areas require higher safety factors in 

pipeline design, testing, and operation. Buried pipelines constructed on land in Class 1 locations 

must be provided with a minimum coverage of 30.0 inches in normal soil and 18 inches in 

consolidated rock. Class 2, 3, and 4 locations, as well as drainage ditches of public roads and 

railroad crossings, require a minimum cover of 36.0 inches in normal soil and 24 inches in 

consolidated rock. All pipelines installed in navigable rivers, streams, and harbors must have a 

minimum cover of 48.0 inches in normal soil or 24.0 inches in consolidated rock. 

In some cases, Cameron Interstate’s safety standards for the Pipeline Expansion would 

exceed the DOT minimum requirements. For example, Cameron Interstate would test 100 

percent of mainline welds, whereas the minimum requirement for nondestructive testing is at 

least 10 percent in Class 1 locations (88.3 percent of the pipeline), at least 15 percent in Class 2 

locations (11.2 percent of the pipeline), and at least 90 percent in Class 3 locations (0.5 percent 

of the pipeline). In addition, Cameron Interstate would provide 36 inches of cover for the entire 

length of pipeline, unless alternative measures are required on a site-specific basis. Currently, 

DOT would require only 11.7 percent of the pipeline length to meet 36 inches of cover while the 

remaining 88.3 percent would only require 30.0 inches of cover. 

Part 192.179 specifies the maximum distance from a point on a pipeline to a 

sectionalizing block valve: each point on a pipeline in a Class 1 location must be within 10.0 
4-195 Safety

miles of a block valve, in Class 2 locations the distance is 7.5 miles, and in Class 3 and 4 

locations, the distance is 4.0 and 2.5 miles respectively. Pipe wall thickness and pipeline design 

pressures, hydrostatic test pressures, MAOP, inspection and testing of welds, and frequency of 

pipeline patrols and leak surveys must also conform to higher standards in more populated areas. 

If a subsequent increase in population density adjacent to the right-of-way indicates a 

change in class location above existing design for the pipeline, Cameron Interstate would reduce 

the MAOP or replace the segment with pipe of sufficient grade and wall thickness, if required, to 

comply with DOT code of regulations for the new class location.

In 2002, Congress passed an act to strengthen the nation’s pipeline safety laws. The 

Pipeline Safety Improvement Act of 2002 (HR 3609) was passed by Congress on November 15, 

2002, and signed into law by the President in December 2002. Since December 17, 2004, gas 

transmission operators are required to develop and follow a written integrity management 

program that contains all the elements described in 49 CFR 192.911 and addresses the risks on 

each covered transmission pipeline segment. Specifically, the law establishes an integrity 

management program which applies to all high consequence areas (HCA). DOT (68 FR 69778, 

69 FR 18228, and 69 FR 29903) defines HCAs as they relate to the different class zones,

potential impact circles, or areas containing an identified site as defined in 49 CFR 192.903.

OPS published a series of rules from August 6, 2002 to May 26, 2004 (69 FR 29903) that 

defines HCAs where a gas pipeline accident could do considerable harm to people and their 

property and require an integrity management program to minimize the potential for an accident.

This definition satisfies, in part, the Congressional mandate in 49 USC 60109 for OPS to 

prescribe standards that establish criteria for identifying each gas pipeline facility in a high 

density population area.

The HCA may be defined in one of two ways. In the first method an HCA includes: 

• current Class 3 and 4 locations;

• any area in Class 1 or 2 locations where the potential impact radius is greater than 

660 feet and there are 20 or more buildings intended for human occupancy within 

the potential impact circle; or

• any area in Class 1 or 2 locations where the potential impact circle includes an 

identified site.

In the second method, an HCA includes any area within a potential impact circle which 

contains:

• 20 or more buildings intended for human occupancy; or

• an identified site.

Once a pipeline operator has determined the HCAs on its pipeline, it must apply the 

elements of its integrity management program to those segments of the pipeline within the 

HCAs. DOT regulations specify the requirements for the integrity management plan in 49 CFR 

192.911. 
Safety 4-196

Table 4.12.8-1 identifies preliminary class locations for the Pipeline Expansion, by 

milepost, based on the definitions in 49 CFR 192. The majority of the proposed route crosses

open land that is sparsely populated, with about 18.5 miles in a Class 1 area, 2.3 miles in a Class 

2 area, and 0.1 mile in a Class 3 area. None of the proposed route is in a Class 4 area. Prior to 

construction of the pipeline, Cameron Interstate would reassess the class locations along the 

pipeline route and ensure the pipeline is designed and constructed for the current class locations 

as well as for any anticipated future changes in class locations. Cameron Interstate also would 

assess the pipeline route for HCAs in accordance with 49 CFR 192.761 prior to construction. 

The pipeline integrity management rule for HCAs requires inspection of the entire pipeline in 

HCAs every 7 years. 

TABLE 4.12.8-1

Preliminary Area Class Locations for the Pipeline Expansion a

Milepost From Milepost To Length (miles) Location Class

0.0 0.7 0.7 2

0.7 1.1 0.4 1

1.1 1.8 0.7 2

1.8 14.7 13.0 1

14.7 15.8 1.0 2

15.8 17.1 1.4 1

17.1 17.2 0.1 3

17.2 21.0 3.7 1

Miles Class 1 18.5

Miles Class 2 2.3

Miles Class 3 0.1

Total Miles 21.0

a The numbers in this table have been rounded for presentation purposes. As a result, the totals may not reflect 

the sum of the addends.

The minimum standards for operating and maintaining pipeline facilities are prescribed in 

49 CFR 192, including the requirement to establish a written plan governing these activities. 

Cameron Interstate would continuously monitor and control its pipeline via computer at the 

manned gas control center maintained in Houston, Texas. Cameron Interstate also operates a 

local area office along the proposed pipeline route where qualified, full-time staff are available to 

provide appropriate emergency response as necessary. The staff is fully trained in safe pipeline 

operations, hazardous material handling, public liaison programs, maintenance, and normal, 

abnormal, and emergency procedures.
4-197 Safety

Cameron Interstate would patrol and inspect its pipeline via aerial or ground vehicles on a 

periodic basis in accordance with DOT requirements or better. The frequency of these 

inspections would be affected by activity along the pipeline route, such as construction or 

possible encroachment. These inspections would identify conditions indicative of pipeline leaks, 

evidence of pipeline damage or deterioration, damage to erosion controls, loss of cover, thirdparty activities or conditions which may presently or in the future affect pipeline integrity, safety, 

or operation of the pipeline. The pipeline system would participate in the state “One Call” 

program.

Under 49 CFR 192.615, each pipeline operator must also establish an emergency plan 

that includes procedures to minimize the hazards in a natural gas pipeline emergency. Key

elements of the plan include procedures for the following:

• receiving, identifying, and classifying emergency events, gas leakage, fires, 

explosions, and natural disasters;

• establishing and maintaining communications with local fire, police, and public 

officials, and coordinating emergency response;

• emergency shutdown of system and safe restoration of service; 

• making personnel, equipment, tools, and materials available at the scene of an 

emergency; and

• protecting people first and then property, and making them safe from actual or 

potential hazards.

Part 192 requires that each operator establish and maintain liaison with appropriate fire, 

police, and public officials to learn the resources and responsibilities of each organization that 

may respond to a natural gas pipeline emergency, and to coordinate mutual assistance. The 

operator must also establish a continuing education program to enable customers, the public, 

government officials, and those engaged in excavation activities to recognize a gas pipeline 

emergency and report it to appropriate public officials. Cameron Interstate would provide the 

appropriate training to local emergency service personnel before the pipeline is placed in service. 

No additional specialized local fire protection equipment would be required to handle pipeline 

emergencies.

Cameron Interstate would expand its current emergency plan to include the Pipeline 

Expansion.

4.12.8.1 Pipeline Accident Data

The DOT requires all operators of natural gas transmission pipelines to notify the DOT of 

any significant incidents and to submit a report within 20 days. Significant incidents are defined 

as any leaks that:

• cause a death or personal injury requiring hospitalization; or
Safety 4-198

• involve property damage of more than $50,000 in 1984 dollars.48

During the 20-year period from 1992 through 2011, a total of 1,197 significant incidents 

(PHMSA 2012c) were reported on the more than 300,000 total miles of natural gas transmission 

pipelines nationwide (PHMSA 2012a).

Additional insight into the nature of service incidents may be found by examining the 

primary factors that caused the failures. Table 4.12.8-2 provides a distribution of the causal 

factors, as well as the number of each incident by cause. The dominant incident cause is 

corrosion and pipeline material, weld, or equipment failure constituting 45.3 percent of all 

significant incidents. The pipelines included in the data set in table 4.12.8-2 vary widely in 

terms of age, pipe diameter, and level of corrosion control. Each variable influences the incident 

frequency that may be expected for a specific segment of pipeline. The frequency of significant 

incidents is strongly dependent on pipeline age. Older pipelines have a higher frequency of 

corrosion incidents, since corrosion is a time-dependent process.

TABLE 4.12.8-2

Significant Incidents by Cause Natural Gas Transmission Pipelines (1992 through 2011) a

Cause Number of Incidents Percent of Total Incidents b

Corrosion 272 22.7

Pipeline Material, Weld, or Equipment Failure 271 22.6

Excavation c 207 17.3

Natural Force Damage 147 12.3

Other Outside Forces d 63 5.3

Incorrect operation 30 2.5

All Other Causes e 207 17.3

Total 1,197 –

a From PHMSA (2012c).

b Due to rounding, column may not equal 100 percent.

c Includes third-party damage.

d Fire, explosion, vehicle damage, previous damage, intentional damage.

e Miscellaneous causes or unknown causes.

The use of both an external protective coating and a cathodic protection system (a 

technique to reduce corrosion [rust] of the natural gas pipeline), required on all pipelines 

installed after July 1971, significantly reduces the corrosion rate compared to unprotected or 

partially protected pipe.

 48 $50,000 in 1984 dollars is approximately $110,487 as of January 2012 (Bureau of Labor Statistics 2013).
4-199 Safety

Outside forces, including excavations and natural events, are the cause in 34.9 percent of 

significant pipeline incidents. Table 4.12.8-3 presents information on the outside forces 

incidents by cause. These mostly result from the encroachment of mechanical equipment such as 

bulldozers and backhoes; earth movements due to soil settlement, washouts, or geologic hazards; 

weather effects such as winds, storms, and thermal strains; and willful damage.

TABLE 4.12.8-3

Outside Forces Incidents by Cause (1992-2011) a

Cause Number of Incidents Percent of Total Incidents b

Third-party excavation damage 173 14.5

Operator excavation damage 26 2.2

Unspecified equipment damage/Previous damage 8 0.7

Heavy Rain/Floods 70 5.8

Earth Movement 39 3.3

Lightning/Temperature/High Winds 21 1.8

Other/Unspecified Natural Force 17 1.4

Vehicle (not engaged with excavation) 41 3.4

Fire/Explosion 8 0.7

Previous Mechanical Damage 5 0.4

Fishing or Maritime Activity 5 0.4

Intentional Damage 1 0.1

Other/Unspecified Outside Force 3 0.3

Total 417 –

a Data for excavation, other outside forces, and natural force damage are from table 4.12.9-1.

b The numbers in this table have been rounded for presentation purposes. As a result, the totals may not reflect the sum of 

the addends.

Older pipelines have a higher frequency of outside forces incidents partly because their 

location may be less well known and less well marked than newer lines. In addition, the older 

pipeline systems contain a disproportionate number of smaller diameter pipelines, which have a 

greater rate of outside forces incidents. Small diameter pipelines are more easily crushed or 

broken by mechanical equipment or earth movements.

Since 1982, operators have been required to participate in "One Call" public utility 

programs in populated areas to minimize unauthorized excavation activities in the vicinity of 

pipelines. The "One Call" program is a service used by public utilities and some private sector 

companies (for example, oil pipelines and cable television) to provide pre-construction 

information to contractors or other maintenance workers on the underground location of pipes, 

cables, and culverts.
Safety 4-200

4.12.8.2 Impacts on Public Safety

The service incident data summarized in table 4.12.8-2 include pipeline failures of all 

magnitudes with widely varying consequences.

Table 4.12.8-4 presents the average annual injuries and fatalities that occurred on natural 

gas transmission lines between 2007 and 2011. The data have been separated into employees 

and nonemployees, to better identify a fatality rate experienced by the general public. Fatalities 

for natural gas transmission lines averaged two per year over the 20-year period from 1992 to 

2011 (PHMSA 2012c).

The majority of fatalities from pipelines involve local distribution pipelines. These are 

natural gas pipelines that are not regulated by the FERC and that distribute natural gas to homes 

and businesses after transportation through interstate natural gas transmission pipelines. In 

general, these distribution lines are smaller diameter pipes, often made of plastic or cast iron 

rather than welded steel, and tend to be older pipelines that are more susceptible to damage. In 

addition, distribution systems do not have large rights-of-way and pipeline markers common to 

the FERC-regulated natural gas transmission pipelines.

TABLE 4.12.8-4

Annual Average Fatalities Associated With Natural Gas Transmission Pipelines a

Year

Injuries Fatalities

Employees Public Employees Public

2007 6 1 1 1

2008 3 2 0 0

2009 4 7 0 0

2010 10 51 2 8

2011 1 0 0 0

Total 24 61 3 9

a From PHMSA (2012b)

The nationwide totals of accidental fatalities from various manmade and natural hazards 

are listed in table 4.12.8-5 in order to provide a relative measure of the industry-wide safety of 

natural gas transmission pipelines. Direct comparisons between accident categories should be 

made cautiously, however, because individual exposures to hazards are not uniform among all 

categories. Furthermore, the fatality rate is more than 25 times lower than the fatalities from 

natural hazards such as lightning, tornados, floods, and earthquakes.

The available data show that natural gas transmission pipelines continue to be a safe, 

reliable means of energy transportation. From 1992 to 2011, there were an average of 60 

significant incidents and 2 fatalities per year. The number of significant incidents over the more 

than 300,000 miles of natural gas transmission lines indicates the risk is low for an incident at 

any given location. As described above, the Pipeline Expansion would be constructed and 
4-201 Cumulative Impacts

operated in accordance with DOT; therefore we believe that operation of the Pipeline Expansion 

would be safe and would represent only a slight increase in risk to the nearby public.

TABLE 4.12.8-5

Nationwide Accidental Deaths a

Type of Accident Annual Number of Deaths

All Accidents 123,706

Motor Vehicle 43,945

Falls 22,631

Drowning 3,443

Fire, Smoke Inhalation, Burns 3,286

Poisoning 29,846

Floods b 93

Tornados b 74

Lighting b 54

Natural Gas Transmission Pipelines c 2

a All data, unless otherwise noted, reflect 2007 statistics from U.S. Census Bureau (U.S. Census Bureau 2011).

b 30-year average from NOAA (2012).

c Data from PHMSA (2012b) 

4.13 CUMULATIVE IMPACTS

NEPA requires the lead federal agency to consider the potential cumulative impacts of 

proposals under their review. Cumulative impacts may result when the environmental effects 

associated with the proposed action are superimposed on or added to impacts associated with 

past, present, and reasonably foreseeable future projects. Cumulative impacts can result from 

individually minor, but collectively significant, actions taking place over a period of time. 

Generally, we believe that cumulative impacts could result only from the construction of other

projects in the same vicinity and impacting the same resource areas as the proposed facilities. In 

such a situation, although the impact associated with each project might be minor, the cumulative 

impact resulting from all projects being constructed in the same general area could be greater.

Our analysis includes other projects in the vicinity of the proposed Project that affect the 

same resources as the proposed Project in the same approximate time frame. Specifically, 

actions included in the cumulative impact analysis must:

• impact a resource area potentially affected by the proposed Project;

• cause the impact within all or part of the same area affected by the proposed 

Project for that resource; and 

• cause the impact within all or part of the time span as that of the potential impact 

from the proposed Project.
Cumulative Impacts 4-202

Using this approach, the potential for cumulative impacts was assessed by combining the 

potential environmental impacts of the proposed Project with the impacts of identified projects.

The cumulative impact area for each resource is defined in section 4.13.2. 

4.13.1 Projects and Activities Considered

There are many existing, under construction, planned, and reasonably foreseeable 

projects in the vicinity of Cameron’s Project. Table 4.13.1-1 lists the substantial projects and 

activities we considered in this cumulative impact analysis. In addition, agriculture and 

silviculture activities occur in the Project area.

TABLE 4.13.1-1

Activities and Projects Considered in the Cumulative Impact Analysis a

Activity/Project Location Description Timeframe

Existing Facilities and Ongoing and Completed Activities 

Cameron LNG Terminal Cameron Parish, LA LNG Terminal In operation

Sabine Pass LNG 

Terminal Cameron Parish, LA LNG Terminal In operation

Golden Pass LNG 

Terminal Jefferson County, TX LNG Terminal In operation

Trunkline Lake Charles 

LNG Terminal Calcasieu Parish, LA LNG Terminal In operation

Cameron Interstate 

Pipeline

Cameron, Calcasieu, and 

Beauregard Parishes, LA

36-mile-long natural gas pipeline 

and Ragley Compressor Station In operation

LA Storage Pipeline Calcasieu and Beauregard 

Parishes, LA

23.3-mile-long natural gas 

pipeline collocated largely with 

existing Cameron Interstate 

Pipeline

In operation

Targa Pipeline Cameron Parish, LA

175-mile-long natural gas 

pipeline extending into Cameron 

Parish from off-shore locations

In operation

Cheniere Creole Trail 

Pipeline

Cameron, Calcasieu, 

Beauregard, Jefferson 

Davis, Allen, and Acadia 

Parishes, LA

Portion of 94-mile-long natural 

gas pipeline extending from 

Sabine Pass LNG Terminal

In operation

Texas Eastern 

Transmission Company 

Calcasieu and Beauregard 

Parishes, LA

Portion of 9,200-mile-long natural 

gas pipeline system extending 

from the Gulf Coast to the 

northeastern United States

In operation
4-203 Cumulative Impacts

TABLE 4.13.1-1

Activities and Projects Considered in the Cumulative Impact Analysis a – Continued

Activity/Project County or Parish and 

State Description Timeframe

Florida Gas Transmission Calcasieu Parish, LA

5,300-mile-long natural gas 

pipeline system extending from 

the Gulf Coast to Florida

In operation

Tennessee Gas Pipeline Cameron and Calcasieu 

Parishes, LA

13,900-mile-long natural gas 

pipeline system extending from 

the Gulf Coast to the 

northeastern United States

In operation

Transcontinental Gas 

Pipe Line

Cameron and Calcasieu 

Parishes, LA

10,200-mile-long natural gas 

pipeline system extending from 

the Gulf Coast to the 

northeastern United States

In operation

Trunkline Pipeline Calcasieu and Beauregard 

Parishes, LA

3,059-mile-long pipeline system 

extending from the Gulf Coast to 

the mid-western United States

In operation

ConocoPhillips Pipeline Calcasieu and Beauregard 

Parishes, LA

Liquids pipeline extending 

through Beauregard Parish In operation

Spectra Energy Pipeline Calcasieu and Beauregard 

Parishes, LA

Natural gas pipeline extending 

through Beauregard Parish In operation

Entergy Electrical 

Transmission Line Calcasieu Parish, LA Electrical transmission line In operation

Louisiana State Highway 

27, including bridge over 

Intracoastal Waterway

Cameron Parish, LA

Two-lane state highway; Main 

access route to the Cameron 

LNG Terminal

In operation

Interstate 10 Calcasieu 

River Bridge Maintenance 

Project

Cameron Parish, LA Roadway and bridge 

maintenance

Maintenance 

completed 2012

Dredging of West 

Calcasieu Port Calcasieu Parish, LA

Removal of 180,000 cubic yards 

of dredge material for expansion 

of barge basin

Dredging completed 

2012

Dredging Calcasieu Pass 

Loop and East Fork of 

Calcasieu Ship Channel

Calcasieu Parish, LA

Removal of about 2.2 million 

cubic yards of dredge material 

due to infiltration after Hurricane 

Rita

Dredging completed 

in 2011

Sasol North America 

Chemical Complex

Westlake, LA (Calcasieu 

Parish)

Seven chemical manufacturing 

units and related facilities In operation

Currently Proposed, Under Construction, and Planned, or Reasonably Foreseeable Projects

Sabine Pass Liquefaction 

Project Cameron Parish, LA

Addition of liquefaction and 

associated facilities to the Sabine 

Pass LNG Terminal 

Under construction: 

anticipated Inservice 2015

Lake Charles Liquefaction 

Project

Calcasieu and Beauregard 

Parishes, LA

Addition of liquefaction and 

associated facilities to the 

Trunkline LNG Terminal; 3 new 

pipelines ranging from 0.47 mile 

to 16.4 miles in length; new 

59,840-horsepower compressor 

station; and upgraded 

compressor stations

In pre-filing:

anticipated inservice in 2018
Cumulative Impacts 4-204

TABLE 4.13.1-1

Activities and Projects Considered in the Cumulative Impact Analysis a – Continued

Activity/Project County or Parish and 

State Description Timeframe

Golden Pass Liquefaction 

Project Jefferson County, TX

Addition of liquefaction and 

associated facilities to the Golden 

Pass LNG Terminal 

In pre-filing:

anticipated inservice in 2019

Magnolia LNG Export 

Terminal Calcasieu Parish, LA Planned LNG export terminal

In pre-filing: 

scheduled 

completion October 

2017

Gasfin LNG Export 

Terminal Cameron Parish, LA Planned LNG export terminal

In preliminary 

planning stage, no 

schedule 

announced

Waller Point LNG Export 

Terminal Cameron Parish, LA Planned LNG export terminal

In preliminary 

planning stage, no 

schedule 

announced

Natural Gas Liquids 

Pipeline Cameron Parish, LA

Portion of 4.5-mile-long, 6-inchdiameter non-jurisdictional 

pipeline outside of the Terminal 

Expansion site, extending 

southwest from the site boundary 

to a storage/transfer facility (as 

an option to NGL transport by 

truck; see section 1.4)

Application filed: no 

schedule 

announced; if 

constructed, likely 

during 2014 or later

NGL Transport by Truck 

from Expanded Terminal 

Cameron and Calcasieu 

Parishes, LA 

Non-jurisdictional truck traffic 

outside of the expanded terminal, 

transporting NGL from the site 

(as an option to the NGL 

Pipeline; see section 1.4)

If used, startup at 

beginning of 

operation of the 

Project in 2017.

Creole Trail Pipeline Gillis 

Compressor Station Calcasieu Parish, LA

53,125 horsepower compressor 

station about 12.5 miles from 

proposed Holbrook Compressor 

Station

Construction began 

in fourth quarter 

2013

Lake Charles Clean 

Energy (LCCE) 

Gasification Project

Lake Charles, LA

Cogeneration facility that would 

convert petroleum coke to 

methanol

Application filed:

scheduled 

completion 2017

Lake Charles Carbon 

Capture and 

Sequestration Project 

Lake Charles, LA 

Facility to capture, purify carbon 

dioxide (CO2) from the LCCE 

Gasification Project, and 

transport it in a 12-mile-long, 16-

inch-diameter pipeline from the 

facility to the existing Green 

Pipeline for enhanced oil 

recovery in Texas 

Application filed: 

scheduled 

completion 2017

Beauregard Electric 

Transmission Line Calcasieu Parish, LA

3.5-mile-long electrical 

distribution line to provide power 

to the proposed Holbrook 

Compressor Station

Planned completion 

2015 or 2016
4-205 Cumulative Impacts

TABLE 4.13.1-1

Activities and Projects Considered in the Cumulative Impact Analysis a – Continued

Activity/Project County or Parish and 

State Description Timeframe

Entergy 230-kV Electrical 

Transmission Line

Cameron and Calcasieu 

Parishes, LA

12-mile-long electrical 

transmission line to provide 

power to the proposed Terminal 

Expansion 

In preliminary 

planning stage, no 

schedule 

announced; would

be concurrent with 

construction of 

Terminal Expansion 

if approved.

Liberty Gas Storage 

Project Cameron Parish, LA

Natural Gas Storage facility, 

including 5.5-mile-long pipeline to 

the existing Cameron Interstate 

Pipeline and compressor station.

Construction 

planned to begin in 

early 2015

COE Maintenance 

Dredging of Calcasieu 

River

Cameron and Calcasieu 

Parishes, LA

Dredging along 68-mile-long 

Calcasieu River navigation 

channel 

Ongoing (biannual)

Golden Nugget Lake Charles, LA Riverboat/Dockside casino 

Under construction, 

opening planned for 

the third quarter of 

2014

IFG Port Holdings Export 

Grain Terminal Calcasieu Parish, LA Replacement/upgrade of existing grain export terminal

Under construction, 

opening planned for 

2014

Sasol North America 

Ethane Cracker

Westlake, LA (Calcasieu 

Parish)

The facility will convert ethane 

contained in natural gas to 

ethylene

Construction from 

2014 through 2017

Sasol North America 

Gas-to-Liquids Plant

Westlake, LA (Calcasieu 

Parish)

The plant will convert natural gas 

into liquid fuels and chemicals

Construction from 

2016 through 2020

G2X Energy Lake Charles, LA Natural gas-to-gasoline facility

Construction to 

begin 2014 pending 

permit approval, 

opening planned for 

2017

AAR Lake Charles, LA

Aircraft Maintenance, Repair and 

Overhaul facility at Chennault 

International Airport

Under construction, 

opening planned for 

2017

a This table is not intended to provide an all-inclusive listing of projects; however, it does list those projects that are 

most likely to contribute to the cumulative impacts within the vicinity of the proposed Project.

Descriptions of potential cumulative impacts by resource category are presented in 

section 4.13.2. In addition to the projects listed in table 4.13.1-1, we considered impacts from 

past projects in the area, including oil and gas exploration and development projects, and 

agricultural activities in the vicinity of the proposed Project. Impacts associated with 

maintenance of existing facilities and permanent rights-of-way near the proposed Pipeline 

Expansion right-of-way would also contribute to cumulative impacts.
Cumulative Impacts 4-206

4.13.1.1 Existing LNG Terminals and Future LNG Liquefaction Projects

We identified four existing LNG import terminals and three planned49 liquefaction and 

export projects in the general vicinity of the proposed Project that could contribute to cumulative 

impacts with those of the proposed Terminal Expansion. The four existing terminals are the 

Cameron, Lake Charles, Sabine Pass, and Golden Pass LNG Terminals (see figure 3.3-1). Each 

of these facilities also has planned/proposed liquefaction projects as well. The planned 

liquefaction and export projects are the Magnolia LNG, Waller Point, and Gasfin Projects (see 

figure 3.3-1). Brief descriptions of each of the LNG projects are provided below. This 

cumulative impacts analysis considered the impacts of operation of the existing terminals as well 

as the potential construction and operational impacts of the planned or proposed liquefaction 

projects. 

Cameron LNG Terminal

As described in further detail throughout this EIS, the existing Cameron LNG Terminal is 

adjacent to the proposed Terminal Expansion site. The impacts of operation of the LNG terminal 

– which include the impacts associated with berthing, loading or unloading of up to two LNG 

tankers simultaneously, vaporization and associated activities, and the use of three LNG storage 

tanks (see section 2.1.1 for additional information on facilities at the existing Cameron LNG 

Terminal) − are considered in this cumulative impacts analysis, along with the impacts of the 

other proposed and planned projects. 

Lake Charles LNG Terminal

The existing Lake Charles LNG Terminal is in Cameron Parish, approximately 6 miles 

straight-line distance north-northeast of the proposed Terminal Expansion (see figure 3.3-1). 

The planned Lake Charles Liquefaction Project would be adjacent to that site and would include 

the addition of three liquefaction trains and associated facilities. The Lake Charles Liquefaction 

Project is in the pre-filing review process.

50 Section 3.1.1.1 provides additional information on 

the Lake Charles LNG Terminal.

Magnolia LNG Project

Magnolia LNG announced its planned stand-alone LNG export terminal at the Port of 

Lake Charles. Magnolia LNG would construct its facility in Calcasieu Parish, approximately 

5.5 miles straight-line distance northeast of the Terminal Expansion, at the port’s Industrial 

Canal, off the Calcasieu Ship Channel and across from the Lake Charles LNG Terminal (see 

figure 3.3-1). At the time this final EIS was prepared, Magnolia LNG was in the FERC prefiling process,

51 and was expected to file its application with FERC in late April 2014. Magnolia 

plans to begin construction in the first quarter of 2015 and start commercial operations in 

October 2017. Section 3.1.1.2 provides additional information on the Magnolia LNG Terminal.

 49 Proposed LNG projects are projects for which the proponent has submitted a formal application with the FERC; 

planned LNG projects are projects that are either in pre-filing at the FERC or have been announced, but have 

not initiated the pre-filing process. 50 Docket No. PF12-8. 51 Docket No. PF13-9.
4-207 Cumulative Impacts

Gasfin LNG Project

Gasfin Development USA, LLC (Gasfin) announced its plan for a stand-alone 

liquefaction project in Cameron Parish. The Gasfin LNG Project would be constructed

approximately 16 miles south of the Terminal Expansion, on the east side of the Calcasieu Ship 

Channel (see figure 3.3-1). The project is in the initial development phase and an anticipated 

schedule has not been released. Due to the distance of this facility from the proposed Project, we 

do not believe the impacts would have a cumulative effect on any resources in the Project area, 

including air quality impacts as discussed in section 4.13.2.11.

Waller Point LNG Project

Waller Point LNG also announced a planned stand-alone LNG export terminal in 

Cameron Parish. The Waller Point LNG Project would be constructed about 17 miles south of 

the Terminal Expansion on the western shore of the entrance to the Calcasieu Ship Channel. The 

project is in the initial development phase and Waller Point LNG has not announced a planned 

schedule. Due to the distance of this facility from the proposed Project, we do not believe the 

impacts would have a cumulative effect on any resources in the Project area, including air quality 

impacts as discussed in section 4.13.2.11.

Sabine Pass LNG Terminal

The Sabine Pass LNG Terminal is in Cameron Parish, approximately 38 miles southwest 

of the proposed Terminal Expansion, near the Texas/Louisiana border. The Sabine Pass 

Liquefaction Project was authorized by the Commission in April 2012 and is currently under 

construction, with an anticipated in-service date in 2015.52 The initial phase of the project will 

include two liquefaction trains with further expansion of up to two additional trains based on 

customer interest. Due to the distance of this facility from the proposed Project, we do not 

believe the impacts would have a cumulative effect on any resources in the Project area, 

including air quality impacts as discussed in section 4.13.2.11.

Golden Pass LNG Terminal

The Golden Pass LNG Terminal is in Jefferson County, Texas, approximately 40 miles 

southwest of the proposed terminal. The planned liquefaction project at the existing terminal 

was in the pre-filing stage at the time this EIS was prepared.53 Due to the distance of this 

facility from the proposed Project, we do not believe the impacts would have a cumulative effect 

on any resources in the Project area, including air quality impacts as discussed in section 

4.13.2.11.

4.13.1.2 Currently Operating Oil and Gas Facilities

There are oil and gas wells in the vicinity of the proposed Terminal Expansion site, 

particularly in the West Hackberry Oilfield, which is generally west of the Terminal Expansion 

site. In addition, there are many oil and gas gathering and transmission pipelines and related 

facilities. Those facilities are in place and generally would not contribute to the cumulative 

 52 Docket No. CP11-72. 53 Docket No. PF13-14.
Cumulative Impacts 4-208

impacts associated with construction of the expanded terminal; however, the operation of the 

wells permanently removed both wetlands and vegetation. There are no major storage or 

processing facilities in the vicinity. 

The Pipeline Expansion route would be parallel and adjacent to or overlap portions of 

other rights-of-way, including those of the existing Cameron Interstate, LA Storage, Cheniere 

Creole Trail, Spectra Energy, ConocoPhillips, and Targa pipelines; and the planned Entergy 

Electrical Transmission Line. The Pipeline Expansion would connect to the existing FGT, 

Tennessee Gas, TETCO, Transco, and Trunkline Pipelines. These pipelines have been in service 

for a number of years and the only impacts relating to the cumulative impact analysis include

maintenance of the permanent rights-of-way in the vicinity of the interconnections and emissions 

from compressor stations associated with the pipelines. 

4.13.1.3 Future Oil and Gas Facilities 

Leucadia Energy Projects

Leucadia Energy, LLC (Leucadia) has proposed to construct the Lake Charles Carbon 

Capture and Sequestration (CCSq) Project in Lake Charles (Calcasieu Parish), approximately 11

miles straight-line distance north-northeast of the proposed terminal site. The Lake Charles 

CCSq Project would involve the capture and sequestration of CO2 from Leucadia’s Lake Charles 

Clean Energy (LCCE) Gasification Project, a proposed petroleum coke gasification plant at the 

Port of Lake Charles. The LCCE Gasification Project would convert petroleum coke into syngas 

to produce methanol, hydrogen gas, and sulfuric acid, as well as CO2. The LCCE Gasification 

Project is sited on approximately 70 acres of previously undeveloped land on the west bank of 

the Calcasieu River.

As part of the Lake Charles CCSq Project, Leucadia would construct about 12 miles of 

16-inch-diameter CO2 pipeline and associated ancillary equipment to connect to the existing 

Green Pipeline in the vicinity of Buhler, Louisiana. The interconnection with the Green Pipeline 

would be about 1.4 miles southeast of MP 4.9 of Cameron Interstate’s Pipeline Expansion route. 

In its draft EIS for the Lake Charles CCSq Project, DOE (2013) stated that the CO2 pipeline 

route would parallel existing linear rights-of-way to the extent possible and cross under the 

Houston River and I-10. The pipeline’s Houston River crossing would be about 10 river miles 

downstream of Cameron Interstate’s proposed Houston River crossing and would be 

accomplished using the HDD method.

DOE (2013) stated that the Lake Charles CCSq Project and the LCCE Gasification 

Project would be constructed concurrently, with construction planned to begin in the fourth 

quarter of 2013, and operation to begin approximately 40 months later (early 2017). 

Non-Jurisdictional Condensate Transport Projects

As discussed in section 1.4, Cameron LNG identified a potential 4-mile-long, 6-inchdiameter pipeline that would transport stabilized condensate, produced as a by-product of the 

liquefaction process, to a storage and transport facility. The pipeline would extend from the 

expanded terminal to Targa NGL storage facility near Hackberry. The planned route extends 

generally west-southwest from the Terminal Expansion site, through an area consisting of about 

75 percent shallow open water and 25 percent broken marsh wetland. If the condensate pipeline 
4-209 Cumulative Impacts

is approved and constructed, construction would occur prior to the in-service date of 2017 to

allow operation when the first liquefaction train of the expanded terminal is planned to be in 

operation. 

Even if the NGL pipeline is constructed, trucks may also be used to transport condensate 

from the truck loading/unloading facility at the expanded terminal. Tanker truck shipping of the 

condensate is considered a non-jurisdictional activity and is included in this cumulative impact 

analysis (see section 1.4). If used to transport condensate, tanker trucks would load condensate 

for delivery to the market place using public roads, primarily LA-27 and I-10. This traffic would 

not begin earlier than when the expanded terminal is operational in 2017. Tanker truck transport 

of LNG must comply with DOT requirements for the transportation of hazardous materials. The 

distance from the Terminal Expansion site to I-10 is about 15 miles. 

Liberty Gas Storage Expansion Project

The Liberty Gas Storage Expansion Project received its FERC Certificate in June 2009. 

The Order granting the Certificate was issued to Liberty Gas Storage, LLC and was transferred 

to LA Storage, LLC. The project site is on an approximately 159.5-acre parcel on the southern 

shore of Black Lake in Cameron Parish, about 5.3 miles southwest of the proposed Terminal 

Expansion site. LA Storage will convert three existing salt dome (brine-storage) caverns for 

natural gas storage, develop one new salt dome cavern for natural gas storage, and construct and 

operate one 18,940-horsepower compressor station and associated facilities. 

LA Storage will also construct and operate a 5.1-mile-long, 36-inch-diameter, bidirectional natural gas pipeline connecting the storage facility to the Cameron Interstate Pipeline 

west of the Terminal Expansion site. The pipeline will extend across Black Lake and its 

associated wetlands to the interconnection with the Cameron Interstate Pipeline near the 

shoreline of Black Lake and the Gulf Intracoastal Waterway. The shortest distance between the 

pipeline and the Terminal Expansion site is about 1.8 miles. The project will also include an 

approximately 4-mile-long, 16-inch-diameter, brine disposal pipeline that will connect to the 

brine facilities on the Liberty Project site to saltwater disposal wells sited southeast of the storage 

site. LA Storage will begin construction in 2015, and plans to complete construction prior to 

startup of the liquefaction facilities at the expanded terminal.

G2X Energy Natural Gas-to-Gasoline Plant

G2X Energy plans to construct a Natural Gas-to-Gasoline Plant along the industrial canal 

of the Port of Lake Charles on a 200-acre site owned by the Lake Charles Harbor & Terminal 

District. The facility would produce a total of 12,500 barrels per day of product (90 percent 

gasoline). The project would include a berthing facility, and product from the project will be 

shipped to customers by marine vessels or by pipeline. The site is about 5 miles north-northeast 

of the Terminal Expansion. Pending approval of its permits, G2X Energy expects to begin 

construction of the facility in 2014, with completion planned for 2017. 

Sasol North America Projects 

Sasol North America (Sasol) operates a chemical complex in Westlake, Louisiana, just 

northwest of Lake Charles and the City of Lake Charles. The complex includes seven 

manufacturing units situated on approximately 400 acres. In late 2013, Sasol completed 
Cumulative Impacts 4-210

construction of the world's first commercial ethylene tetramerization unit at the complex. The 

plant is in operation and can produce more than 100,000 metric tons per year of combined 1-

octene and 1-hexene. 

Sasol announced plans to construct and operate an Ethane Cracker at the complex. The 

cracker will convert ethane contained in natural gas to ethylene, with a planned production rate 

of 1.5 million tons of ethylene per year. Construction would take place from late 2014through 

2017, when project startup is anticipated. Sasol also announced plans to construct and operate a 

Natural Gas-to-Liquids Plant at the complex. The plant will produce more than 96,000 barrels 

per day of liquid fuels and chemicals. Construction is expected to begin in 2016 and continue for 

4 years. The plant is expected to be in full operation in 2020. 

Sasol stated that the two projects would have a peak construction workforce of 7,000 and 

a permanent workforce of 1,200. 

4.13.1.4 Land Transportation Projects

The primary roadways in the vicinity of the proposed Project are LA-27 and I-10. 

According to representatives of Cameron, Calcasieu, and Beauregard Parishes, there are no new 

roadways planned in the foreseeable future, and the only roadway projects likely to occur are 

maintenance projects, including resurfacing. As a result, land transportation projects are not 

further considered. 

4.13.1.5 Other Projects and Activities Considered 

IFG Port Holdings, LLC Export Grain Terminal Expansion

IFG Port Holdings, LLC’s export grain terminal at the Port of Lake Charles is about 13 

miles upriver from the Terminal Expansion site. The grain terminal is currently undergoing an 

extensive expansion and renovation while continuing to operate. The facility will handle 

agricultural products such as rice, wheat, corn, soybeans, and dried distillers’ grain for shipment 

to other countries. Construction began in 2012 and is expected to be completed in 2014. 

Ameristar Casinos/Golden Nugget Casino and Hotel

Ameristar Casinos, Inc. began construction of a dockside casino and hotel on Lake 

Charles with an 18-hole golf course and other sport facilities in 2012. In July 2013, Ameristar 

Casinos, Inc. announced the project would be sold to Golden Nugget. Construction of the 

facilities is expected to be completed by the end of 2014. The resort would be about 12 miles 

straight-line distance north-northeast of the Terminal Expansion site on a 242-acre site adjacent 

to the L’Auberge Lake Charles Casino Resort. 

Chennault International Airport Expansion

AAR is opening an aircraft maintenance, repair, and overhaul facility at an existing 

hangar at the Chennault International Airport in Lake Charles, Louisiana and is currently 

constructing an additional 118,000 square feet of new hangar space. The airport is about 16 

miles northeast of the Terminal Expansion. Construction is expected to be completed in 2017. 
4-211 Cumulative Impacts

Dredging Projects

Several dredging projects near the Cameron LNG Terminal have been completed and 

several others are planned or associated with the construction of planned projects such as the 

Lake Charles CCSq Project and the expanded IFG Port Holdings export grain terminal. In 

addition, every 2 years the COE conducts maintenance dredging in the portion of the Calcasieu 

Ship Channel adjacent to the terminal site, and Cameron LNG attempts to conduct concurrent 

periodic dredging of its LNG carrier berths at the existing Cameron LNG Terminal. 

Non-Jurisdictional Electrical Lines

As discussed in section 1.4, a non-jurisdictional electrical distribution line is necessary to 

provide electrical power to the proposed Holbrook Compressor Station. Beauregard Electric 

would build the approximately 3.5-mile-long distribution line that would extend from a tie-in 

with an existing Beauregard Electric 230-kV electrical transmission line for the sole use of the 

proposed Holbrook Compressor Station. See section 1.4.4 for a description of the planned route. 

If Cameron Interstate receives a Certificate for the Pipeline Expansion, the distribution line 

would likely be constructed during 2015 and 2016, concurrent with construction of the pipeline 

and Holbrook Compressor Station.

To provide electrical power to the Terminal Expansion, Entergy would build an 

approximately 12-mile-long, double-circuit, 230-kV electrical transmission line in Calcasieu and 

Cameron Parishes (Entergy transmission line) and a new switch yard to replace the existing 

switch yard at the terminal. As described in section 1.4, this is a non-jurisdictional project which 

Entergy would construct and operate for the sole use of the proposed Terminal Expansion. See 

section 1.4.4 for a description of the planned facilities

It is likely that Entergy would construct the transmission facilities while the first 

liquefaction train is under construction to provide power for the planned startup of the expanded 

terminal in 2017. 

4.13.2 Potential Cumulative Impacts by Resource

The following sections address the potential cumulative impacts from Cameron’s Project 

and those of projects identified within the cumulative impact area defined for each resource. In 

the analysis below, the reference to “the Lake Charles projects” refers to the Lake Charles LNG 

Project, the Magnolia LNG Project, the Leucadia Projects, the IFG Port Holdings Export 

Terminal Expansion, the Ameristar Casinos/Golden Nugget Casino and Hotel, the Chennault 

International Airport Expansion, the Sasol Projects, and the G2X Energy Natural Gas-toGasoline Plant.

4.13.2.1 Geologic Conditions

The cumulative impact area for geologic resources and hazards was considered to be the 

area adjacent to proposed construction areas for the Terminal Expansion and the Pipeline 

Expansion. 

At the proposed Terminal Expansion site, Cameron LNG would modify the existing 

topographic contours to accommodate its equipment and facilities and maintain adequate 
Cumulative Impacts 4-212

drainage from the site. This would result in contours similar to those of the adjacent existing 

Cameron LNG Terminal and would not differ substantially from the existing topography. The 

only projects in the cumulative impacts area for geologic conditions of the Terminal Expansion, 

other than the existing LNG Terminal, would be portions of the non-jurisdictional NGL pipeline 

and the Entergy transmission line near the site. Neither project is expected to result in noticeable 

changes in topography. The small change in topography at the proposed terminal site combined 

with the changes that resulted from these other projects would not result in significant 

cumulative impacts on geologic conditions. 

Construction and operation of the Pipeline Expansion would occur largely within 

previously disturbed areas, and Cameron Interstate does not anticipate any blasting along the 

right-of-way. The Pipeline Expansion would have minimal impacts on geological resources 

because Cameron Interstate would restore topographic contours along the right-of-way to 

preconstruction conditions to the extent practicable. These contours would tie-in to the existing 

easements that Cameron Interstate would parallel. The non-jurisdictional electric distribution 

line is the only other project in the geologic cumulative impact area of the Pipeline Expansion. 

That project would not result in changes of topography. Therefore, the cumulative impact of the 

Pipeline Expansion on geologic resources would be minor. 

In addition, the proposed Project would not have an impact on marketable mineral 

resources and therefore would not contribute to cumulative impacts on those resources. 

4.13.2.2 Soils 

The cumulative impact area for soils was considered to be the area adjacent to the 

proposed construction areas for the Terminal Expansion and the Pipeline Expansion. Past 

impacts on soils resources in the vicinity of the proposed Project have resulted from agricultural 

and commercial forestry processes and construction and maintenance of existing roads, railroads, 

natural gas and oil pipelines, utility lines, and electrical transmission line rights-of-way. 

Clearing and grading associated with construction of the Terminal Expansion and the Pipeline 

Expansion could result in soil loss due to erosion, which could reduce soil fertility and impair 

revegetation. However, Cameron would implement Project-specific mitigation plans and 

procedures to minimize erosion as a result of water and wind and aid in the reestablishment of 

vegetation after construction. In addition, Cameron Interstate would construct about 74 percent 

of its Pipeline Expansion adjacent to and overlapping existing rights-of-way, minimizing impacts 

on previously undisturbed areas to the extent practicable. 

A portion of the planned non-jurisdictional NGL pipeline would be constructed adjacent 

to the proposed terminal site, primarily through wetlands and coastal marsh, as would a portion 

of the Entergy transmission line. The Beauregard Electric transmission line would be parallel 

and adjacent to the pipeline construction right-of-way. The construction procedures of these 

projects would include measures to minimize soil erosion and restore the construction right-ofway soon after construction is complete. As a result, those projects in combination with the 

proposed Project would not contribute significantly to a cumulative impact on soils.
4-213 Cumulative Impacts

4.13.2.3 Water Resources

The cumulative impact area established for groundwater resources was limited to the 

aquifers from which the proposed Project would withdraw water. The cumulative impact area 

associated with surface water resources extends about two miles upstream and downstream of (1) 

the Terminal Expansion site boundaries, and (2) the pipeline stream crossings. This distance was 

selected as the distance within which suspended sediments would be expected to settle out from 

the water column and be re-deposited, and is considered a conservative estimate based on the 

relatively low flow rates of the affected waterbodies. Very few, if any, of the barges used for 

construction of the proposed Project would have ballast systems, and Cameron LNG did not 

request an increase in the number of LNG carriers currently authorized to use the existing 

terminal. Therefore, we believe that the proposed Project would not contribute to cumulative 

impacts associated with ballast water discharge in the Calcasieu Channel or Gulf Intracoastal 

Waterway. 

Cameron LNG would obtain water for construction of the Terminal Expansion from an 

existing onsite well, including water required for hydrostatic testing of the new LNG storage 

tank and facility piping. This would require about 30 million gallons, obtained at a rate of about 

1,280 gpm over a period of about 5 weeks. The existing well draws from the Chicot Aquifer, 

which is also a source of water for public water supply, industry, irrigation, and other users. The 

nearest offsite well drawing from that aquifer is more than 150 feet from the site. Use of the well 

during construction of the Terminal Expansion would have a temporary and minor impact on the 

aquifer and would end after water withdrawal for hydrostatic testing is complete. As a result, the 

cumulative impact of use of this water during construction along with other withdrawals would 

not be significant. 

During operation, the proposed Project would use substantially less water than during 

construction, with water obtained from the City of Hackberry municipal supply. In addition, 

there are no other projects listed in table 4.13.1-1 that would require the use of large amounts of 

water from the Hackberry municipal water supply system. As a result, there would not be 

significant cumulative impacts on the municipal water system. 

Construction of the proposed work dock would include dredging about 205,000 cubic 

yards of material from 9.4 acres adjacent to the shoreline. Cameron LNG would place the 

dredged material in its approved beneficial use area at an elevation sufficient to create tidal 

marsh. Cameron LNG would also conduct maintenance dredging at the work dock during 

operation of the Project. Impacts associated with dredging would be minor and temporary due to 

the methods used to minimize sediment suspension in the water column, the high ambient levels 

of turbidity in the channel, and the relatively rapid deposit of the suspended sediments. 

Dredging projects and projects listed in table 4.13.1-1 that potentially require dredging 

include the previously completed Cameron Loop and East Fork dredging, the water-related 

projects in the Lake Charles area, the Gasfin and Waller Point Projects, maintenance in the 

channel by the COE, and maintenance of the berthing area of the existing Cameron LNG 

Terminal. However, all but the latter two projects are outside of the cumulative impact area for 

the proposed Project because dredge sediments would likely drop out before reaching a point 

about 2 miles from the terminal due primarily to the relatively low flow of the channel. 
Cumulative Impacts 4-214

Therefore, these facilities were not included in the cumulative impact analysis for water 

resources. 

The COE conducts maintenance dredging of the channel every 2 years, including 

dredging in the vicinity of the proposed work dock. Impacts associated with that dredging are 

minor and temporary for the same reasons as described above for dredging of the work dock. 

Similarly, Cameron LNG conducts periodic maintenance dredging at the LNG carrier berths that 

are adjacent to the channel and the proposed work dock. The impacts of that dredging are also 

minor and temporary, as described in our previous EIS and 2006 EA for the existing terminal.54 

Cameron LNG intends to conduct maintenance dredging of the berthing area and the work dock 

at the same time as the COE maintenance dredging of the channel. If those dredging activities 

occur at the same time, there would be a cumulative impact that would cause temporary and 

minor impacts on water quality of the channel. Because water quality would return to predredging conditions shortly after dredging is completed, we do not believe this cumulative 

impact would be significant.

We are not aware of any other substantial construction projects within the cumulative 

impact area for surface water runoff. As a result, there would not be a significant cumulative 

impact on surface water due to construction and operation of the Terminal Expansion. 

Shoreline erosion is a concern along the Gulf Intracoastal Waterway and the Calcasieu 

Ship Cannel. Erosion may be caused by ship traffic or by engineered structures, such as levees 

along beaches or rivers. Natural processes, such as tide-induced currents, sea level changes, 

wind waves, and hurricanes or other extreme storms, also contribute to shoreline erosion. 

There would likely be several years of concurrent construction and associated barge 

traffic for the proposed Terminal Expansion and the Lake Charles and Magnolia LNG 

Liquefaction Projects, assuming all receive the necessary authorizations and permits. In 

addition, construction of the Lake Charles projects would likely require barges to deliver 

equipment and materials to the construction sites and may overlap with construction of the 

proposed Project for several years. All of the above projects would also likely increase barge 

traffic in the Gulf Intracoastal Waterway between Port Arthur and the confluence of the 

waterway and the Calcasieu Ship Channel, and in the channel between its confluence with the 

waterway up to the Port of Port Charles. The Gasfin and Waller Point Projects at the south end 

of the channel would also likely use barges during construction, and it is likely that many of the 

barges for those projects would transport equipment and materials from Port Arthur to the 

construction sites via the Gulf of Mexico and the southern end of the Calcasieu Ship Channel. If 

there is barge traffic along the Gulf Intracoastal Waterway and the channel to the Gasfin and 

Waller Point construction sites, they would also contribute to cumulative impacts on shoreline 

erosion.

Construction of the Terminal Expansion would increase barge traffic on the waterway 

and the channel between Port Arthur and the work dock. The primary increase in barge traffic 

during construction of the Terminal Expansion would occur during the first 14 months of 

construction and would decrease from a high of about 9 barges per day up through month 7 of 

construction, to about 4 barges per day in months 11 through 14, then 1 barge every 3 days 

 54 Hackberry EIS (Docket No. CP02-374) and Cameron LNG Terminal Expansion EA (Docket No. CP06-422).
4-215 Cumulative Impacts

through the end of construction. If the Terminal Expansion and other projects discussed above 

were constructed during the same time period, there could be a substantial increase in barge 

traffic. The additional barge traffic could create shoreline erosion, but it is not expected to be 

significant. 

Cameron LNG has not proposed to increase LNG carrier traffic beyond that previously 

authorized and would therefore not contribute to cumulative impacts beyond those previously 

assessed. Impacts associated with LNG carrier traffic were addressed in the previous FERC 

environmental reviews.55 

The Pipeline Expansion would require 29 waterbody crossings. Impacts on water quality 

due to open-cut waterbody crossings can include sedimentation and turbidity, alteration or 

removal of in-stream and stream bank cover, and introduction of water pollutants from 

inadvertent equipment spills or leaks, or entrainment of small organisms during hydrostatic 

testing. However, the short duration of pipeline construction through waterbodies would 

generally result in temporary impacts on the water quality and flow. Cameron Interstate’s Plan

would limit vegetation maintenance within a 25-foot-wide riparian strip and includes erosion 

control measures to avoid or reduce runoff from construction activities. The use of the HDD

crossing method would avoid direct impacts on nine waterbodies, including all major 

waterbodies. Although impacts on surface waters could occur during the HDD installation 

process (e.g., through an inadvertent release of drilling fluid), Cameron Interstate would reduce 

the likelihood and potential damage associated with such events by the implementation of its

HDD Contingency Plan. 

Although runoff from construction activities near waterbodies upstream or downstream 

of the proposed construction right-of-way could also result in impacts, we are not aware of any 

substantial construction projects that would affect surface water quality within two miles of 

Cameron Interstate’s proposed waterbody crossings. Previously constructed pipeline crossings 

may have created changes in stream flow and channel configuration, although there is no 

evidence indicating any such changes have resulted in substantial alterations to the channels. As 

a result, the cumulative impact on surface water resources due to runoff and open-cut waterbody 

crossings would be minor. 

We did not identify any other projects that would contribute to the cumulative impacts 

from hydrostatic test water withdrawal and discharge on water resources in the cumulative 

impact area for the Pipeline Expansion. Therefore, we believe the cumulative impacts due to the 

Pipeline Expansion’s withdrawal and discharge of hydrostatic test water would be temporary and 

minor.

4.13.2.4 Wetlands

The cumulative impact area for wetlands was considered to be the area adjacent to the 

proposed Project construction areas. 

Construction of the Terminal Expansion would result in the loss of wetlands on the 

proposed terminal site. However, compensatory mitigation for wetland loss would be required 

 55 Hackberry EIS (Docket No. CP02-374), Cameron LNG Terminal Expansion EA (Docket No. CP06-422) and 

Environmental Assessment, Cameron LNG Export Project (Docket No. CP10-496).
Cumulative Impacts 4-216

by the COE, the LDNR Office of Coastal Management, and LDEQ that would result in no net 

loss of wetland function and could improve regional coastal marsh resources. Cameron LNG 

proposed to create tidal brackish marsh wetland west of the Project at a ratio of 1.2 acres for each 

acre of COE-jurisdictional wetland impacted by the proposed Terminal Expansion. This would 

create about 255 acres of marsh habitat using dredged materials from construction of the work 

dock. Although the non-jurisdictional NGL pipeline would be near the Terminal Expansion site 

and extend through wetlands and coastal marsh, LA-27 is between the proposed terminal site and 

those wetlands. The planned NGL pipeline route would extend through areas consisting of about 

75 percent shallow open water and 25 percent broken marsh wetland. Construction of the NGL 

pipeline would temporarily impact about 23 acres of marsh wetlands, which we would expect to 

reestablish within one growing season. The marsh areas would not be maintained by mowing,

and the impacts due to establishment of a permanent right-of-way would be minor. As a result, 

construction and operation of the NGL pipeline would have a minor, temporary impact on 

wetlands. The proponent would have to obtain a Section 404 Permit from the COE and a CUP 

from the LDNR which may require compensatory mitigation if there is a loss of wetlands.

A portion of the non-jurisdictional Entergy transmission line would extend along the west 

side of LA-27 in the vicinity of the Terminal Expansion site. Construction of the transmission 

line, including pole placement and stringing along portions of the 150-foot-wide right-of-way 

would result in a minor and short-term impact on approximately 91 acres of existing emergent 

wetland vegetation communities and habitat structure. Permanent impacts would occur along the 

right-of-way on approximately 20 acres of forested wetlands that Entergy would permanently 

convert to an emergent or scrub/shrub state. Entergy must obtain a Section 404 Permit from the 

COE and a CUP from the LDNR which may require compensatory mitigation for the conversion 

of wetlands. 

Due to the isolated nature of impacts on wetlands, which would be on the opposite side of 

LA-27 from the Terminal Expansion for the NGL pipeline and the Entergy transmission line, and 

proposed mitigation, we do not anticipate that construction and operation of the Terminal 

Expansion in combination with the NGL pipeline and Entergy transmission line would result in a 

significant cumulative impact on wetlands.

Past impacts on wetland resources in the vicinity of the proposed Pipeline Expansion 

route have resulted from agricultural and commercial forestry processes and construction and 

maintenance of existing roads, railroads, natural gas and oil pipelines, utility lines, and electrical 

transmission line rights-of-way. Construction of the proposed pipeline would result in the loss of 

some wetlands, including forested wetlands. To mitigate the permanent loss of those wetlands 

along the proposed pipeline right-of-way, Cameron Interstate would purchase mitigation credits 

from a COE-approved mitigation bank; details regarding the number and type(s) of credits would 

be decided by the COE upon review of the Cameron Interstate Section 404 Permit application. 

Because Cameron Interstate would compensate for wetland impacts, construction of the Pipeline 

Expansion would not contribute to a cumulative loss of wetlands. The only other project in the 

cumulative impact area for the Pipeline Expansion that has not yet been constructed is the 

electrical distribution line for the Holbrook Compressor Station. This project may temporarily 

impact wetlands during construction. In addition, if wetlands cannot be avoided during 

placement of the power poles, there could be minimal permanent impact on wetlands that may 

also require mitigation. 
4-217 Cumulative Impacts

Cumulative impacts on wetlands during project operation would occur where the Pipeline 

Expansion is collocated with the permanent rights-of-way of other pipelines crossing the same 

wetland, and the wetlands are maintained by periodic mowing and tree removal. However, these 

wetlands were previously disturbed during construction of the other pipelines, and the impacts 

were likely mitigated in accordance with COE and LDNR requirements during or shortly after 

construction. Most wetlands would be maintained in an herbaceous state; therefore, the primary 

cumulative impact would be conversion rather than a loss of wetland acreage, and when added to 

compensatory mitigation, we believe the cumulative impact on wetlands would not be 

significant. 

4.13.2.5 Vegetation and Wildlife 

The cumulative impact area for vegetation and wildlife was considered to be the area 

adjacent to and near the proposed Project construction areas. 

The existing Cameron LNG Terminal is adjacent to the proposed Terminal Expansion 

site. Construction and operation of the existing terminal resulted in the loss of all vegetation 

(about 116 acres) and wildlife habitat on that site, as did construction and operation of adjacent 

LA-27. Construction of the Terminal Expansion would remove 371.9 acres of vegetation from 

the Terminal Expansion site north of the existing terminal, and 52.9 acres of vegetation from the 

existing terminal, a total of 424.7 acres. The affected vegetative communities have low species 

diversity and are not productive as agricultural land, grazing land, or high-quality wildlife 

habitat. Therefore, we believe the cumulative impact on wildlife would not be significant. 

Cameron LNG proposes to create tidal brackish marsh wetland habitat adjacent to the 

Project (west of LA-27) as compensatory mitigation at a ratio of 1.2 acres for each acre of COEjurisdictional wetland impacted by the proposed terminal expansion. A total of about 255 acres 

of marsh habitat would be created using dredge spoil from construction of the work dock. The 

mitigation area would be adjacent to 220 acres of marsh habitat created during construction of 

the existing Cameron LNG Terminal, thus contributing to a larger area of contiguous marsh 

habitat and would be beneficial to wildlife. Created marsh habitat would vegetate naturally and 

be monitored for quality and functionality for a period of 20 years. In addition to the proposed 

marsh creation area, Cameron LNG proposes to create another marsh area for beneficial use of 

maintenance dredge material as part of its current CUP. 

Although the northern portion of the non-jurisdictional NGL pipeline would be installed 

near the proposed terminal site, construction of the pipeline would likely affect only wetlands 

that would reestablish relatively quickly (see section 1.4). The non-jurisdictional Entergy 

transmission line would affect vegetation along the west side of LA-27 in the vicinity of the 

Terminal Expansion site. Vegetation clearing for construction along the 150-foot-wide right-ofway would result in a minor and short-term impact on wetlands as discussed above. Pole 

placement could result in a minor, permanent impact on wetlands.

It is anticipated that Entergy would implement best management practices during 

construction to minimize impacts on wetlands. Due to these best management practices and 

Cameron LNG’s proposed wetland mitigation, we do not believe there would be a significant 

cumulative impact on vegetation and wildlife. 
Cumulative Impacts 4-218

Past impacts on vegetation in the vicinity of the proposed Pipeline Expansion route have 

resulted from agricultural and commercial forestry processes and construction and maintenance 

of existing roads, railroads, natural gas and oil pipelines, utility lines, and electrical transmission 

line rights-of-way. Clearing and grading of the Cameron Interstate Pipeline Expansion would 

result in the removal of vegetation, alteration of wildlife habitat, and displacement of wildlife. 

The proposed route is adjacent and parallel to existing rights-of-way, and construction would 

increase the width along a portion of that corridor. The proposed Pipeline Expansion would not 

create an additional corridor or cause additional fragmentation. Most of the temporary 

construction rights-of-way and ATWS areas adjacent to the proposed route were allowed to 

revegetate to a vegetative state similar to pre-construction conditions, including forested areas. 

During construction, mobile wildlife species would relocate to adjacent habitats and we expect 

most displaced individuals would return to the habitats of the Pipeline Expansion right-of-way 

after restoration. 

The Lake Charles CCSq Project includes a CO2 pipeline that would extend northwest of 

that facility. However, the terminus of the pipeline would be its interconnection with the 

existing Denbury Green Pipeline, about 1.4 miles southeast of the proposed Pipeline Expansion 

route and would not be within the cumulative impact area for vegetation and wildlife. The only 

new project in table 4.13.1-1 that has the potential for contributing to cumulative impacts on 

vegetation and wildlife along the pipeline corridor is the portion of the non-jurisdictional 

electrical distribution line that would extend from Holbrook Park Road to the Holbrook 

Compressor Station. Construction of the electric line would affect a small area of vegetation, 

and it would likely incorporate best management practices to reduce potential impacts on 

vegetation and wildlife. We believe that the incorporation of standard best management 

practices during construction, restoration, and maintenance would minimize the degree and 

duration of the cumulative impacts on vegetation and terrestrial wildlife from these projects. As 

a result, we conclude that construction and operation of the Terminal Expansion would not 

contribute to a significant impact on vegetation and wildlife in the cumulative impact area. 

4.13.2.6 Aquatic Resources

We considered the cumulative impact area for aquatic resources to be the same as for 

water resources (2 miles upstream and downstream of the Terminal Expansion site boundaries 

and pipeline stream crossings). Dredging would impact bottom dwelling marine organisms and 

the bottom habitat, including EFH, within the dredged area and would result in conversion of 

subtidal habitat to deep water habitat for the duration of the Project. This would be an 

incremental addition to similar existing, converted habitat at the adjacent berthing area of the 

existing Cameron LNG Terminal, which is maintained as deep water habitat by dredging. The

adjacent Calcasieu Ship Channel is also maintained by dredging every 2 years by the COE. Due 

to the substantial amount of subtidal habitat in the cumulative impact area, we believe the Project 

would have a minor cumulative impact on aquatic species.

The water-related Lake Charles projects are about 5.5 to 11 miles (straight-line distance) 

from the proposed work dock. Sediments would likely drop out of the waters of the Calcasieu 

Ship Channel before those waters reach the vicinity of the Terminal Expansion site. Therefore, 

we believe those projects would not contribute to cumulative impacts on aquatic resources in the 

cumulative impact area for the Terminal Expansion. 
4-219 Cumulative Impacts

The impact of increases in turbidity due to dredging at the work dock would be 

temporary and localized to the dredged area and directly adjacent areas and relatively short 

downstream distances due to the slow-moving nature of the channel (see section 4.13.2.3). As a 

result, marine species would experience localized effects. If dredging at the work dock takes 

place at the same time as maintenance dredging of the existing Cameron LNG Terminal berthing 

areas and the maintenance dredging of the channel, the geographic extent of temporary impacts 

would increase beyond the area affected by dredging for the work dock. The impact area would 

be smaller if the dredging projects were not concurrent, but the total duration of impacts within 

the cumulative impact area would increase. In either case, we believe the impact in the 

cumulative impact area would not be significant because these impacts would be temporary and 

localized and we believe turbidity would return to pre-dredging levels soon after dredging is 

completed. 

Potential impacts on fisheries resources resulting from construction of the proposed 

Pipeline Expansion include sedimentation and turbidity, alteration or removal of in-stream and 

stream bank cover, water withdrawal during hydrostatic testing, and introduction of pollutants

from inadvertent equipment spills or leaks. The construction impacts of the adjacent pipelines 

occurred during and shortly after construction. These areas have been restored and would not 

contribute to cumulative impacts during construction of the pipeline extension. Water 

withdrawal for hydrostatic testing of the proposed Pipeline Expansion would be in compliance 

with the screening requirements and withdrawal rates of the permit from LDNR, which includes 

input from LDFW, to reduce impacts on aquatic species. As a result, cumulative impacts on 

aquatic resources from construction or operation of the proposed Pipeline Expansion would not 

be significant. 

4.13.2.7 Threatened and Endangered Species

Ten species listed by FWS as threatened or endangered potentially occur near the 

proposed Project facilities. The Terminal Expansion would have no effect on six species and 

would not contribute to cumulative impacts on those species. We have not addressed species in 

the “no effect” category in this cumulative impact analysis. We conclude the Terminal 

Expansion is not likely to affect three species: the federally endangered Kemp’s ridley sea turtle, 

the federally endangered West Indian manatee, and the federally threatened piping plover. The 

cumulative impact area for the turtle and the manatee is the Calcasieu Ship Channel. The 

cumulative impact area for the piping plover is the shoreline along the channel within about 2 

miles of the proposed terminal site. We conclude that the Pipeline Expansion is not likely to 

adversely affect one federally endangered species, the red-cockaded woodpecker. The 

cumulative impact area for the red cockaded woodpecker is the pipeline construction right-ofway and the area within about 0.5 mile of the right-of-way and within 0.5 mile of the Holbrook 

Compressor Station site. In its comments on the draft EIS, FWS concurred with our not likely to 

adversely affect determination and stated that no further consultation regarding threatened and 

endangered species will be necessary unless there are significant changes in the scope or location 

of the Project. Additionally, we and NMFS concluded that the potential impacts from the 

Terminal Expansion have not substantially changed from the impacts discussed in Docket No. 

CP06-422-000. Because NMFS has already concurred with our determination that these impacts 

are not likely to adversely affect listed species, NMFS stated that re-initiation of consultation is 

not necessary and consultation is complete. As noted in section 4.7, no Kemp’s ridley sea turtles 
Cumulative Impacts 4-220

have been known to nest in Louisiana. Potential foraging and transit habitat for the species 

exists near the site of the proposed work dock; however, the high level of industrial activity 

adjacent to the Calcasieu Ship Channel and the usage of the channel by ship traffic make it 

unlikely that this species would use the habitat at the work dock. All of the projects within the 

Calcasieu Ship Channel must also complete Section 7 of the ESA consultation. As a result, it is 

not likely that the Terminal Expansion, the other liquefaction projects along the channel, or the 

water-related Lake Charles projects would have significant cumulative impacts on the Kemp’s 

ridley sea turtle.

The West Indian manatee is present in marine, estuarine, and freshwater environments. 

Manatees have been spotted in the Calcasieu River Basin; however, given the level of industrial 

activity in the area, their presence near the Terminal Expansion project area is unlikely, as noted 

in section 4.7. The LNHP database includes a historical sighting near the Terminal Expansion

area in 1929, but none since then. In addition, there is a minimal amount of appropriate habitat 

in the channel for this species. As a result, it is not likely that the Terminal Expansion, the other 

liquefaction projects along the channel, or the water-related Lake Charles projects would

contribute to cumulative impacts on the West Indian manatee.

The piping plover is a migratory species that winters in Atlantic and Gulf coastal regions 

of the United States and several Caribbean islands, and breeds in the northern United States and 

Canada (see section 4.7). However, preferred shoreline types are not currently present along the 

Terminal Expansion site and it is not likely that the species would use that area or areas adjacent 

to the terminal site due to the level of industrial activity in the vicinity. As a result, it is not 

likely that the Terminal Expansion would contribute to cumulative impacts on the piping plover.

The red-cockaded woodpecker is known to occur in both Beauregard and Calcasieu 

Parishes. It is generally a non-migratory species that requires mature pine forests. On January 

24, 2013, Cameron Interstate and FWS personnel conducted surveys of the species. No redcockaded woodpeckers or nest clusters were identified within the survey area. Therefore, due to 

the small amount of available habitat and the lack of observations of individuals or nest cavities, 

we believe the proposed Pipeline Expansion would not likely have significant cumulative 

impacts on the red-cockaded woodpecker. 

The only projects identified near the Terminal Expansion site are the non-jurisdictional 

NGL pipeline and the non-jurisdictional Entergy transmission line. The NGL pipeline would 

only impact marsh wetlands. Based on FWS correspondence, this project would have no effect 

on federally-listed threatened or endangered species.

56 Additionally, the Entergy transmission 

line would traverse the same habitats and would likely not impact threatened or endangered 

species. As a result, there would not be cumulative impacts on threatened or endangered species 

due to construction and operation of the proposed Terminal Expansion. 

The only project in the threatened or endangered species cumulative impact area for the 

Pipeline Expansion is the electric distribution line. Construction of the project would have a 

minimal impact on habitat. Operation of the project is not expected to increase impacts on 

wildlife, and there would not be an increase in the width of the existing corridors that the 

 56 Provided in Docket Number CP13-25 in Appendix D.1 of Cameron LNG’s April 26, 2013 Response to FERC’s 

Environmental and Engineering Data Request dated April 3, 2013 (Accession Number 20130429-5029).
4-221 Cumulative Impacts

distribution line would parallel. Therefore, we believe that cumulative impacts on threatened or 

endangered species due to construction and operation of the Pipeline Expansion would not be 

significant. 

4.13.2.8 Land Use, Visual Resources, and Recreation

Land Use

The cumulative impact area for land use was considered to be the area adjacent to and in 

the vicinity of the proposed Project. 

The existing Cameron LNG Terminal site is dedicated to industrial use. Construction of 

the Terminal Expansion would impact existing industrial, wetland, forest, and open water land 

uses and convert them to industrial use. The proposed Terminal Expansion along with the 

existing LNG Terminal, the NGL pipeline, the Entergy transmission line, LA-27, and the many 

small oil and gas projects in the vicinity of the Terminal Expansion would result in a cumulative 

increase in the conversion of a variety of land uses to industrial and transportation use in the 

cumulative impact area. However, the COE and LDNR would require compensatory mitigation 

for wetland loss for the Terminal Expansion and the NGL pipeline and may require 

compensatory mitigation for the Entergy transmission line. Because there are many areas of 

wetlands, forest, and open water adjacent to the site, we believe that the Terminal Expansion 

would not result in a significant cumulative impact on land use. 

Construction of the Pipeline Expansion would impact wetlands, agriculture, forested, 

industrial, and open water land uses. Only a short segment of the planned electrical distribution 

line to the Holbrook Compressor Station would be in the cumulative impact area for the Pipeline 

Expansion. The distribution line would parallel Holbrook Park Road east of the proposed 

pipeline corridor, and between Holbrook Park Road and the compressor station it would parallel 

the pipeline right-of way. Construction of the distribution line within the cumulative impact area 

is not expected to require additional tree removal, and ground disturbance would be minimal for 

pole placement. 

As a result, we believe the cumulative impact on land use would not be significant. 

Visual Resources

The cumulative impact area for visual resources was considered to be the area within the 

viewsheds of the proposed Project facilities. Because of the height of the structures at the 

expanded terminal, the viewshed of the terminal would extend for several miles in all directions. 

The viewshed for the proposed Pipeline Expansion is about 0.5 mile from the pipeline corridor 

and the aboveground facilities. 

The Terminal Expansion would be consistent with the visual character of the adjacent 

Cameron LNG terminal, the ongoing industrial facilities and activities along the Calcasieu Ship 

Channel, and the many small oil and gas facilities near the Terminal Expansion site. The visual 

character of the Terminal Expansion would be similar to that of the adjacent Cameron LNG 

Terminal. We do not believe there would be a significant cumulative visual impact. 
Cumulative Impacts 4-222

The non-jurisdictional NGL pipeline would be buried from the Terminal Expansion site 

to its southern terminus and would not affect the visual character of the area after construction is 

complete. The southern terminus of the NGL pipeline is expected to be at storage facilities about 

4 miles west-southwest of the Terminal Expansion site and would not affect visual quality. 

Entergy would install self-supporting single-circuit steel poles for each circuit and single-circuit 

H-frame structures for long span and high clearance crossings. The transmission lines and the 

structures supporting the lines would alter the visual quality of that viewshed and expand the 

industrial character of the area to the west side of LA-27. However, the visual quality would be 

consistent with the industrial character of the area in the vicinity of the existing Cameron LNG 

Terminal and consistent with electrical transmission lines that parallel many roadways in the 

area. 

We did not identify any other proposed major projects within the same viewshed as the 

expanded terminal. As a result, we believe that the cumulative impact on visual resources would 

not be significant. 

The proposed Pipeline Expansion route is adjacent and parallel to existing pipeline and 

utility corridors, which would minimize changes to the viewshed. This would result in a minor 

widening of the rights-of-way, a change of visual character that would likely not be noticeable 

outside of forested areas. Only a short segment of the planned electrical distribution line to the 

Holbrook Compressor Station would be within the cumulative impact area of the Pipeline 

Expansion for visual resources. That would consist of about 0.5 mile along Holbrook Park Road 

leading up to the Pipeline Expansion right-of-way, and a distance of about 0.25 mile adjacent to 

the Pipeline Expansion right-of-way between Holbrook Road and the compressor station. 

Although the poles and wires of the distribution line would alter the visual character of that area, 

the width of the existing corridors that the distribution line would parallel would not change, and 

we conclude that the cumulative impact on visual resources would not be significant. 

Aboveground facilities, such as the Holbrook Compressor Station and interconnections, 

would have additional visual impacts; however, these interconnections would be installed 

adjacent to existing aboveground natural gas facilities, and the Holbrook Compressor Station 

would not be in the viewshed of many observers. Therefore, there would not be a significant 

cumulative impact on visual resources associated with the proposed Pipeline Expansion and 

other past, present, and reasonably foreseeable projects in the visual resources cumulative impact 

area for the Pipeline Expansion. 

Recreation

For the proposed Terminal Expansion, the cumulative impact area for recreational-use 

vessels was considered to be the Calcasieu Ship Channel to its confluence with the Gulf 

Intracoastal Waterway, and the Gulf Intracoastal Waterway from its confluence with the channel 

to the Port Arthur area. The cumulative impact area for recreational facilities for both the 

Terminal Expansion and the Pipeline Expansion was considered to be Cameron, Calcasieu, and 

Beauregard Parishes. 

In the initial phases of construction of the Terminal Expansion, the increase in barge 

traffic may affect some recreational and commercial users of the channel and the waterway, 

resulting in a moderate, short-term impact that would last about 14 months. 
4-223 Cumulative Impacts

During construction of the Lake Charles projects, supply ship and barge traffic would 

likely increase in the Calcasieu Ship Channel and the Gulf Intracoastal Waterway, from Port 

Arthur to the Port of Port Charles. That would represent a cumulative impact with the proposed 

Project on the Gulf Intracoastal Waterway. However, recreational vessels currently encounter

supply ship and barge traffic on the waterway. Further, the cumulative impact of Project vessel 

traffic in the waterway during construction would be short-term. Therefore, we believe 

cumulative impacts on boat traffic would not be significant. 

Barge traffic during operation of the Project would be minimal and would not contribute 

to impacts on the waterway. Cameron LNG has not proposed to change its authorized LNG 

carrier traffic. Therefore, we believe operation of the Project would not contribute to cumulative 

impacts on recreational vessel traffic in the Calcasieu Ship Channel or nearby waterways. 

The portion of LA-27 from Sulphur to its intersection with the Gulf Beach Highway is a 

part of the Creole Trail, including LA-27 in the vicinity of the proposed Terminal Expansion site. 

During the construction period for the Terminal Expansion, Cameron LNG would increase 

traffic on LA-27 between Sulphur and the Terminal Expansion site. Construction of the nonjurisdictional NGL Pipeline would add traffic to LA-27 in the vicinity of the Terminal Expansion 

for about 1 year during the construction period of the Terminal Expansion. Workers commuting 

to construction sites for the Entergy transmission line and Liberty Gas Storage Expansion Project 

would also add to traffic on LA-27 between Sulphur and the Terminal Expansion site, and 

activities associated with construction of the transmission line adjacent to LA-27 may result in 

temporary disruptions of traffic flow. In addition, during the latter stages of Terminal Expansion 

construction, the Gasfin and Waller Point LNG Projects may add to the construction worker 

traffic on LA-27, if those projects are authorized and constructed. As with the Terminal 

Expansion, most of the traffic associated with construction of those projects would likely be 

associated with commuting construction workers during the early morning and evening hours. 

Concurrent construction of the projects discussed above could substantially increase 

traffic on LA-27 from Sulphur to the turnoffs to the construction sites. The increase would not 

be during the time of day most recreational users of the Creole Trail would be affected. We have 

recommended mitigation measures to reduce the impact of construction-related traffic near the 

Terminal Expansion site, including uniformed traffic control at the access driveways of the 

Terminal Expansion site during construction commuting times, development of a plan to provide 

mass transportation to and from the Terminal Expansion site for construction workers, and 

conducting a traffic study during construction to assess the LOS at that time and developing 

additional mitigation measures if the roadway experiences an LOS of D or worse. We believe 

that our recommended mitigation would reduce the potential cumulative impact on LA-27 to less 

than significant levels during construction commuting times. Operation of the expanded 

terminal would contribute a minor amount of traffic to the roadway and there would not be a 

significant cumulative impact. 

Because the Creole Trail does not extend north of Sulphur, it is not likely that 

construction-related traffic for the pipeline would contribute to cumulative impacts on the trail. 

Although pipeline construction workers and their families may use the Creole Trail at times, we 

do not expect the impact to be significant. 
Cumulative Impacts 4-224

As described in section 4.9, most of the Terminal Expansion workers from out of the area 

are expected to reside in Cameron and Calcasieu Parishes, as would workers on the projects in 

southwestern Cameron Parish listed in table 4.13.1-1. Some of the workers may bring their 

families. As described in section 4.13.2.9, construction workers for the Lake Charles projects 

would reside primarily in Cameron, Calcasieu, Beauregard, and Jefferson Davis Parishes, with 

some workers possibly housed in Allen Parish. When not working, construction workers and 

the families of some workers may use LA-27 and other portions of the Creole Trail. This would 

increase traffic on LA-27 and other roadways that are part of the Creole Trail. However, outside 

of commuting times, we do not believe the increase in traffic along LA-27 and other portions of 

the Creole Trail would substantially increase, and we do not believe the cumulative impact on 

recreational use of the Creole Trail would be significant. 

The construction period for Cameron’s Project would likely be concurrent with those of 

several of the major Lake Charles projects and the three non-jurisdictional projects (the NGL 

pipeline, the Entergy transmission line, and the electrical distribution line for the Pipeline 

Expansion). Construction of the Gasfin and Waller Point LNG Projects may also be concurrent 

with construction of the proposed Project. Under those conditions, based on the sizes of some of 

the projects and the large number of construction workers required, the local labor force of 

qualified construction workers would likely be fully absorbed. This would result in a greater 

number of non-local workers than typically anticipated for construction projects in the area and a 

substantial increase in workers from out of the area. It is likely that many of those workers, and 

in some cases their families, would use the recreational facilities and other recreational 

opportunities available in Cameron, Calcasieu, Beauregard, and Jefferson Davis Parishes. 

Although this may stress some individual recreational facilities, we do not expect the overall

impact to be significant due to the large geographic area in which the workers would be housed 

and the number of recreational opportunities within that area. 

During operation, Cameron would employ an additional 135 workers. Although many of 

these workers and their families would likely use the recreational facilities of the cumulative 

impact area, the impact on the facilities and other users of those facilities would be minor and the 

cumulative impact on recreation would not be significant. The total number of permanent 

employees for the new projects listed in table 4.13.1-1 would be substantially lower than the 

number of construction workers required. As with the construction workers, the permanent 

employees would be housed throughout Cameron, Calcasieu, and Beauregard Parishes, and there 

are many recreational opportunities within that area. Therefore, the combined permanent 

workforce of the projects in table 4.13.1-1 that are under construction, planned, or reasonably 

foreseeable is not expected to have a significant impact on recreational facilities in the area.

After the Pipeline Expansion is constructed, the recreational activities currently taking 

place along the pipeline route and adjacent utility corridors could continue. There are no known 

recreational activities taking place on the proposed site of the Holbrook Compressor Station, 

although some hunting may occasionally occur there. As a result, there would be, at most, a 

minor cumulative impact on recreation due to the Pipeline Expansion. 
4-225 Cumulative Impacts

4.13.2.9 Socioeconomics

Socioeconomic Conditions

We considered the cumulative impact area for socioeconomics to include Cameron, 

Calcasieu, and Beauregard Parishes, where Cameron would construct its facilities and workers 

would reside during construction and operation of its Project.

Construction of Cameron’s Project would generate a substantial number of jobs for a 

period of about 4 years starting in 2014. Construction of many other projects listed in table 

4.13.1-1 would also occur during portions of that time period, including the major projects in the 

Lake Charles area and possibly the Golden Pass Liquefaction Project and the Waller Point and 

Gasfin LNG Projects. Simultaneous construction of those projects would require a large number 

of workers from the local labor pool. The cumulative effect would be a substantial reduction in 

unemployment in the area. However, that reduction in unemployment would also require the 

import of more construction workers than typically required for any single project. 

The influx of non-local workers would impact transient housing in Cameron, Calcasieu, 

and Beauregard Parishes. As described in section 4.9.4, there is an adequate amount of vacant 

transient housing in Cameron, Calcasieu, and Beauregard Parishes to house workers on the 

Cameron Project. However, with concurrent construction of many other major projects noted 

above, it is likely that there would not be any transient housing available in Cameron, Calcasieu, 

and Beauregard Parishes, and non-local workers unable to find acceptable housing in any of 

those three parishes could likely reside in adjacent Jefferson Davis and Allen Parishes. If peak 

construction workforce periods of many of the projects coincide, it is possible there may not be 

sufficient transient housing in the five parishes to accommodate all of the non-local workers. For 

example, if the peak workforce of the proposed Project occurs during the same time period as the 

peak workforce of the two Sasol projects, there would be about 10,500 workers in the area for 

just those three projects. That would benefit the transient housing, market but would adversely 

affect those seeking transient housing. Some members of the workforce and others seeking 

transient housing may be forced to commute long distances to obtain housing in parishes more 

distant than the five parishes nearest the projects. 

The Sabine Pass Liquefaction Project is currently under construction, and most of the 

non-local workers are likely housed in the Port Arthur, Texas area. It is likely that most of the 

non-local workers that would be involved in construction of the Golden Pass Liquefaction 

Project would reside in the Port Arthur area. As a result, neither Sabine Pass nor Golden Pass 

Liquefaction Project is expected to cumulatively affect housing in the socioeconomic cumulative 

impact area of the proposed Project.

The combined construction workforces of projects would increase the need for some 

public services, such as police, medical services, and schools. The need for those services would 

generally be spread throughout the parishes that house the workforce, but because the majority of 

construction would take place in Cameron and Calcasieu Parishes, there may be an increased 

need for medical and emergency services at or near the sites of the projects. Cameron LNG 

would construct and staff a medical facility on the Terminal Expansion site to address most 

injuries and illnesses. As a result, the Project’s contribution to the cumulative impact on medical 

and emergency services in Cameron and Calcasieu Parishes during construction would likely be 
Cumulative Impacts 4-226

occasional and minor. However, because the construction periods of the proposed Project and 

many other projects could overlap, there is a potential for a significant cumulative impact on 

such services in Calcasieu Parish, and likely some impact in the surrounding parishes. If the 

medical and emergency services, or other public services, are adversely affected during 

construction, the project sponsors may mitigate the impact by providing funding for temporarily 

increasing the staff and equipment of the public services affected. 

With construction of some of the major projects listed in table 4.13.1-1 lasting several 

years, it is likely that some construction workers would bring their families, including school-age 

children. That would increase the population in some schools in the parishes housing the 

workers with families. However, it is likely that those families would be housed throughout 

many school districts in the five parishes and the increases in school populations would be 

distributed through many schools. As a result, it is not likely that the cumulative impact on 

schools during the concurrent construction periods would be significant. 

A large workforce for the simultaneously constructed projects would have a beneficial 

impact on revenues for the state and for Cameron, Calcasieu, and Beauregard Parishes due to 

expenditures for services and materials for the projects, increased expenditures by local workers, 

and expenditures by the non-local workforce and any family members accompanying the nonlocal workers. The parishes would also receive a substantial increase in property taxes from 

these projects. 

Marine Transportation

The cumulative impact area for marine transportation associated with the proposed 

Terminal Expansion was considered to be the Calcasieu Ship Channel up to its confluence with 

the Gulf Intracoastal Waterway, and the Gulf Intracoastal Waterway from that point to the Port 

Arthur area. 

As previously described, construction of the major Lake Charles projects would increase 

barge and support vessel traffic in the Gulf Intracoastal Waterway from Port Arthur to the 

channel, and in the channel to the Port of Port Charles. Construction of those projects is not 

expected to affect marine transportation on the channel south of its confluence with the 

waterway. Concurrent construction of those projects and the Terminal Expansion would likely 

result in a cumulative impact on vessel traffic in the waterway, primarily by increasing vessel 

travel times from congestion. However, the major vessel traffic increase from the Project would 

be during the first 7 months and is not expected to result in a significant cumulative impact on 

vessel traffic in the waterway.

The Gasfin and Waller Point export terminal projects are proposed near the mouth of the 

Calcasieu Ship Channel, which would have minor effect on vessel travel in the Terminal 

Expansion’s cumulative impact area. However, if barges are brought from Port Arthur through 

the Gulf Intracoastal Waterway and down the channel to the proposed sites, there would be 

additional barge traffic. The Port of Lake Charles would dictate the movement of these barges to 

minimize disruption. Therefore, we believe this cumulative impact would not be significant. 
4-227 Cumulative Impacts

Land Transportation

We considered the cumulative impact area for land transportation to include the three

parishes that would house the Project facilities and the construction workers for the proposed 

Project: Cameron, Calcasieu, and Beauregard Parishes.

During construction of the Project and the Lake Charles projects, roadways in the area 

from west of Sulphur to the eastern portion of Calcasieu Parish would experience a substantial 

increase in daily vehicle trips. If workers require housing in Jefferson Davis or Allen Parishes, 

roadways from the Lake Charles area to some portions of those parishes would also experience 

increases in traffic during commuting periods for construction workers. Increases would result 

from workers commuting to and from the construction sites; deliveries of equipment, materials, 

and supplies to the sites; and removal of materials from the sites. There may be a substantial 

decrease in the level of service on surface streets between Sulfur and Lake Charles, and perhaps 

along I-10, particularly during commuting periods, and possibly in the area east of Lake Charles. 

During commuting times, impacts would be greatest in the vicinity of the major projects, and 

mitigation measures may have to be implemented by the proponents of those projects to reduce 

the impacts. 

Construction workers for the projects in the Lake Charles area would not travel along 

LA-27 south of the I-10 bridge; therefore, these projects would not contribute to cumulative 

impacts due to construction-related traffic along LA-27 in that area. It is not likely that other 

construction-related traffic for the Lake Charles projects would use that route. However, 

construction of the non-jurisdictional NGL pipeline, the non-jurisdictional Entergy transmission 

line, and the Liberty Storage Expansion Project would contribute to cumulative impacts on 

traffic along that portion of LA-27, primarily at the beginning and end of each construction shift. 

Construction of both the NGL pipeline and the Entergy transmission line may also result in 

temporary disruptions to traffic flow along LA-27 in the vicinity of the Terminal Expansion site. 

In addition, if the Gasfin LNG Project and the Waller Point LNG Project are authorized and 

under construction at the same time, construction traffic from those projects would contribute to 

the cumulative impact on traffic along LA-27 in that area. As noted above, we recommended 

mitigation measures to reduce the impact of construction-related traffic near the Terminal 

Expansion site. We believe that implementation of these mitigation measures would reduce the 

potential cumulative impact of the Terminal Expansion on traffic along LA-27 between the 

Terminal Expansion site and Sulphur. However, if the times of shifts for each of the projects 

discussed above are similar, the overall impact on traffic along LA-27 due to construction 

worker traffic may result in long delays on portions of the highway and it may be appropriate for 

the proponents of the projects to implement additional mitigation measures to reduce the 

impacts.

4.13.2.10 Cultural Resources

The cumulative impact area for cultural resources was considered to be the area adjacent 

to and near the proposed Project. No cultural resources were identified as a result of surveys 

completed for the Project. Therefore, the Project and other projects in the area would not add to 

cumulative impacts on cultural resources. 
Cumulative Impacts 4-228

4.13.2.11 Air Quality and Noise

Air Quality

The cumulative impact area for air quality during construction of the expanded terminal 

is the area adjacent to and near the border of the terminal site. The cumulative impact area for 

air quality during operation of the proposed Project was established based on the expanded 

terminal’s PSD Area of Impact of 6.2 miles (10 km). This area encompasses the Lake Charles 

projects. The existing Golden Pass LNG Terminal, the planned Golden Pass Export Project, the 

Sabine Pass LNG Terminal, the Sabine Pass Liquefaction Project (currently under construction),

the planned Gasfin and Waller Point LNG Projects, and the compressor stations for other natural 

gas pipelines systems are outside of this area and are not expected to contribute to cumulative 

impacts on air quality in combination with the proposed Project. However, Cameron LNG 

conducted an ozone modeling analysis to demonstrate the Terminal Expansion’s impacts on 

ozone concentrations; this analysis included the Sabine Pass Liquefaction Project. The ozone 

modeling analysis is discussed in section 4.11.1.5. Because the Terminal Expansion and the 

Pipeline Expansion are located over a large geographic area, the cumulative air quality impacts 

of each project would be minimal; therefore, the discussion below focuses on the cumulative air 

quality impacts of each project separately.

Construction of the Terminal Expansion would temporarily impact air quality due to 

emissions from the combustion engines used to power construction equipment and from fugitive 

dust resulting from equipment movement on dirt roads and earth-disturbing activities. The future 

projects in the vicinity of the Terminal Expansion that would be constructed in a similar 

timeframe as the proposed Terminal Expansion are the non-jurisdictional NGL pipeline, the nonjurisdictional Entergy transmission line, and the Liberty Gas Storage Project. The constructionrelated impacts of those projects would be temporary and the project proponents for those 

projects would minimize fugitive dust to the extent practicable. Because construction of the 

NGL pipeline and the Entergy transmission line would be linear and move quickly, air emissions 

associated with these projects would be intermittent. The construction of the Liberty Gas 

Storage Project would be localized to the storage field about 5.3 miles from the Terminal 

Expansion. Based on the intermittent and short-term nature of construction of those projects, we 

believe that construction of the Terminal Expansion would not contribute to a significant 

cumulative impact on air quality.

Although the region in the vicinity of the proposed Project is currently in attainment with 

air quality standards, increases in industrial point sources could affect local and regional air 

quality. Under LDEQ regulations, the expanded terminal would be considered a major 

emissions source and would contribute to cumulative impacts on air quality within the 

cumulative impact area. 

The cumulative modeling analysis in section 4.11.1 was performed to quantitatively 

demonstrate that the Terminal Expansion operational impacts, in addition to existing major 

sources of air emissions in the area of impact (6.2 miles [10 km]), would not have a significant 

impact on air quality. While the Terminal Expansion would contribute to a cumulative impact 

on air quality in the PSD area of impact, as shown in the modeling analysis, this impact would 

not exceed the NAAQS, which were established to protect public health (including sensitive 

populations) and public welfare. Projects that would potentially be constructed in the future, and 
4-229 Cumulative Impacts

are considered to be major sources of air emissions, would be required to conduct a similar PSD 

analysis. Should operation of a new project result in a significant impact on air quality, the 

LDEQ would enforce operational limitations or require emissions controls that ensure the 

facility’s compliance with the SIP and attainment with the NAAQS. In addition, Cameron LNG 

would be required to comply with permit conditions during operation of the facility and 

incorporate the required controls to limit the emission of certain criteria pollutants, HAPs, and/or 

GHGs. Based on the cumulative modeling analysis and the required emission controls, we 

conclude that there would be no significant cumulative impact on air quality as a result of the 

Terminal Expansion. 

In addition to operation of the expanded terminal and the projects listed above, air 

emissions from LNG marine traffic and other project-related vessels, considered mobile sources 

of air emissions, would occur along the entire waterway from the boundary of territorial waters 

to the vessel berths. Due to the transitory nature of these mobile sources and the large area 

covered, we believe the associated emissions would not have a significant cumulative impact on 

air quality along the waterway. Cameron LNG has not requested an increase in the currently 

authorized number of LNG carriers; therefore, operation of the carriers and any associated 

mobile sources would not contribute to a cumulative impact on the air quality of the area beyond 

that previously assessed. While there would not be an increase in the currently authorized 

number of LNG carriers or the previously assessed vessel emissions, we evaluated emissions for 

total vessel operations as part of the cumulative impact analysis for the proposed Terminal 

Expansion. Mobile source emissions were calculated for the LNG carriers while loading and 

while berthed at dockside without loading (a condition termed “hoteling”), for the LNG carriers

while in transit, and for the tug assist vessels, both within and outside of the moored safety zone 

(see table 4.13.2-1). These mobile source emissions are not considered for permitting purposes 

by either EPA or LDEQ.

TABLE 4.13.2-1

Summary Of Existing Mobile Source Emissions From Marine Vessel Activities

Activity Emissions (tons per year)

CO SO2 NOx PM VOC

Operation While Berthing or at Berth

Maneuvering in/out Berth 1.6 0.2 7.0 0.1 0.4

LNG Carrier Loading 40.4 5.9 148.6 2.7 3.9

LNG Carrier Hoteling 17.4 2.6 67.1 1.1 1.7

Tug Assist and Stand-by 

during Berthing/ 

Loading/Hoteling

12.0 3.1 46.3 4.5 4.3

Total 71.4 11.8 269.0 8.4 10.3

Outside Moored Safety Zone

LNG Carrier Transit 42.3 3.4 165.6 2.1 14.1

Assist Tug Maneuvering/ 

Transit 2.2 0.7 53.9 0.9 0.8

Total 44.5 4.1 219.5 3.0 14.9
Cumulative Impacts 4-230

In addition, air quality dispersion modeling was conducted for CO, SO2, NO2, and 

stationary sources proposed for the Terminal Expansion, combined with mobile sources within 

the moored safety zone. Table 4.13.2-2 lists the highest levels for each pollutant per averaging 

period. The modeling was performed using the AERMOD version 12060, AERMAP (version 

11103), the terrain preprocessor, AERMET (version 11059), the meteorological preprocessor, 

and AERSURFACE (version 08009), which estimate surface characteristics required for input to 

AERMET. Meteorological data from 2007 to 2011 was used as input to the models.

TABLE 4.13.2-2

Summary of Screening Results for Stationary and Mobile Source Emissions

Pollutant and Averaging 

Period

Year of Highest 

Level

Modeled Concentration 

(μg/m3

)

Significant Impact Level 

(μg/m3)

CO 1-hour 2007 166 2,000

CO 8-hour 2010 51.58 500

SO2 3-hour 2008 9.24 25

SO2 24-hour 2010 2.53 5

SO2 Annual 2011 0.16 1

NO2 Annual 2011 4.13 1

The CO and SO2 screening levels were below the SILs, therefore, further refined 

modeling was not required. 

The NO2 screening resulted in levels greater than the SILs; therefore, refined modeling 

was conducted for NO2 (see table 4.13.2-3). Cameron LNG obtained the off-site sources for the 

refined NO2 analysis from the LDEQ website. Major sources within the area of impact were 

modeled for the NO2 annual average NAAQS run. For the NO2 background concentration, the 

Westlake monitoring station was used. An NO2 concentration of 15 μg/m3 was used as 

background for the annual average NAAQS model based on the highest annual average of the 5 

years of Westlake monitoring data. The results of refined modeling indicated that NO2 would 

not exceed any of the applicable NAAQS. 

TABLE 4.13.2-3

Summary of Refined Modeling Results and Incremental Consumption for Stationaryand Mobile-Source NO2 Emissions

Refined Modeling Increment Consumption

Year of 

Highest 

Level

Total Concentration 

(μg /m3

) [Modeled+ 

Background] NAAQS

Year of 

Highest 

Level

Project Contribution to 

Modeled Maximum 

Concentration (μg /m3

)

Significant 

Impact Level 

(μg /m3

)

2007 87 100 2007 0.14 1

A PSD increment consumption analysis was also conducted. The increment-consuming 

sources within the area of impact obtained from the LDEQ were included for this analysis. That 

analysis indicated that NO2 levels would be greater than Class II allowable levels, requiring 
4-231 Cumulative Impacts

further analysis to determine if the Project impact on PSD increment consumption, including 

mobile sources, would be significant. The analysis indicated that the Project, including mobile 

sources, did not exceed the SILs at any of the receptors above the increment consumption 

standard, and therefore would not contribute significantly to consumption of the PSD Class II 

increment, and has also demonstrated compliance with the standard.

Based on the modeling analysis, we conclude that the cumulative impact of the Terminal 

Expansion with the existing mobile sources at the Cameron LNG Terminal would not have a 

significant impact on air quality in the cumulative impact area.

The cumulative impact area for air quality during construction of the Pipeline Expansion 

is the area adjacent to and near the edge of the construction right-of-way. The cumulative impact 

area for operation of the Pipeline Expansion is also 32 miles (52 km) from the site. During 

construction of the Pipeline Expansion, combustion engines and fugitive dust would create 

temporary and minor impacts on air quality. The electrical distribution line is the only other 

project in table 4.13.1-1 that would be in the vicinity of the proposed Pipeline Expansion. We 

expect construction emissions of the electrical distribution line would be similar, but less than 

those of the Pipeline Expansion. Further, Cameron would use certain measures such as watering 

the right-of-way to minimize construction-related emissions. Therefore, we believe that the 

cumulative impact of construction on the local air quality would not be significant. 

The cumulative modeling analysis in section 4.11.1 was performed to quantitatively 

demonstrate that the Holbrook Compressor Station operational impacts, in addition to existing 

major sources of air emissions in the area of impact (32 miles), would not have a significant 

impact on air quality. While the new compressor station would contribute to a cumulative 

impact on air quality in the PSD area of impact, as shown in the modeling analysis, this impact 

would not exceed the NAAQS, which were established to protect public health (including 

sensitive populations) and public welfare. Projects that would potentially be constructed in the 

future, and are considered to be major sources of air emissions, would be required to conduct a 

similar PSD analysis. Should operation of a new project result in a significant impact on air 

quality, the LDEQ would enforce operational limitations or require emissions controls that 

ensure the facility’s compliance with the SIP and attainment with the NAAQS. In addition, 

Cameron would be required to comply with permit conditions during operation of the facility and 

incorporate the required controls to limit the emission of certain criteria pollutants, HAPs, and/or 

GHGs. Normal operation of the Cameron pipeline would not result in measurable air quality 

impacts that would contribute cumulatively to the local air quality. Based on the cumulative 

modeling analysis and the required emission controls, we conclude that there would be no 

significant cumulative impact on air quality as a result of the Pipeline Expansion.

Climate Change

The cumulative impact analysis described below does not focus on a specific cumulative 

impact area because climate change is a global phenomenon. Climate change is the change in 

climate over time, whether due to natural variability or as a result of human activity, and cannot 

be represented by single annual events or individual anomalies. As an example, a single large 

flood event or particularly hot summer may not be an indication of climate change, but a series 

of floods or high temperatures that statistically change the average precipitation or temperature 

over years or decades may indicate climate change.
Cumulative Impacts 4-232

The Intergovernmental Panel on Climate Change (IPCC) is the leading international, 

multi-governmental scientific body for the assessment of climate change. The United States is a 

member of the IPCC and participates in the IPCC working groups to develop reports. The 

leading United States scientific body on climate change is the U.S. Global Change Research 

Program (USGCRP).

Thirteen federal departments and agencies participate in the USGCRP, which began as a 

presidential initiative in 1989 and was mandated by Congress in the Global Change Research Act 

of 1990. The IPCC and USGCRP have recognized the following:

• globally, GHGs have been accumulating in the atmosphere since the beginning of 

the industrial era (circa 1750);

• combustion of fossil fuels (coal, petroleum, and natural gas), combined with 

agriculture and clearing of forests is primarily responsible for the accumulation of 

GHG;

• anthropogenic GHG emissions are the primary contributing factor to climate 

change; and 

• impacts extend beyond atmospheric climate change alone, and include changes to 

water resources, transportation, agriculture, ecosystems, and human health.

The USGCRP issued a report (Global Climate Change Impacts in the United States) in

June 2009 summarizing the impacts of climate change on the United States and the projected 

impacts of climate change in the future. The report includes a description of overall impacts by 

resource and impacts for various regions of the United States. 

Although climate change is a global concern, this cumulative impact analysis focuses on 

the cumulative impacts of climate change in the general area of the proposed Project. The 

USGCRP (2009) report notes the following impacts in the continental Southeast and Coastal 

regions:

• average temperatures have risen about 2° F since 1970 and are projected to 

increase another 4.5 to 9°F during this century;

• increases in illness and death due to greater summer heat stress;

• the destructive potential of Atlantic hurricanes increased since 1970 and the 

intensity (with higher peak wind speeds, rainfall intensity, and storm surge height 

and strength) is likely to increase during this century;

• within the past century in the United States, relative sea level changes ranged 

from falling several inches to rising about 2 feet and are projected to increase 

another 3 to 4 feet this century;

• sea level rise and human alterations have caused 1,900 square miles of coastal 

wetland loss in Louisiana during the past century, reducing the capacity of those 

wetlands to protect against storm surge, and projected sea level rise is anticipated 

to result in the loss of a large portion of the nation’s remaining coastal wetlands;
4-233 Cumulative Impacts

• declines in dissolved oxygen in streams and lakes have caused fish kills and loss 

of aquatic species diversity;

• moderate to severe spring and summer drought areas have increased 12 to 14 

percent (with frequency, duration and intensity also increasing and projected to 

increase);

• longer periods of time between rainfall events may lead to declines in recharge of 

groundwater and decreased water availability;

• responses to decreased water availability, such as increased groundwater 

pumping, may lead to stress or depletion of aquifers and a strain on surface water 

sources;

• increases in evaporation and plant water loss rates may alter the balance of runoff 

and groundwater recharge, which would likely to lead to saltwater intrusion into 

shallow aquifers; 

• coastal waters temperature rose about 2°F in several regions and are likely to 

continue to warm as much as 4 to 8°F this century; and 

• coastal water warming may lead to the transport of invasive species through 

ballast water exchange during ship transit.

The GHG emissions associated with construction and operation of the Project are 

identified in section 4.11. Those emissions would not have any direct impacts on the

environment in the general area of the Project, but may contribute incrementally to impacts in 

other areas. Cameron LNG and Cameron Interstate would incorporate GHG BACT analyses as 

part of the air permits issued by LDEQ. Potential controls for these emissions include preventing 

the GHG formation, or the emissions, such as, monitoring piping components to prevent GHG 

emissions, as well as (1) carbon capture and storage (CCS), (2) use of the most thermally 

efficient equipment, (3) use of low carbon fuels, (4) use of renewable energy sources [solar and

wind], (5) Solid Oxide Fuel Cell Technology, and (6) good combustion/operating practices.

BACT for GHG Emissions

CCS has three main components: CO2 capture and/or compression, transport, and storage. 

Approximately 90 percent of the CO2 emissions from the proposed equipment would originate 

from the natural gas-fired compressor turbines, and CO2 could theoretically be captured by

scrubbing the exhaust stream with solvents such as amines and ammonia. However, separating 

CO2 from this flue gas is challenging. For example, a high volume of gas must be treated 

because the CO2 is dilute (3 to 4 percent by volume in natural gas-fired systems), trace impurities 

(such as particulate matter, sulfur oxides, and nitrogen oxides) can degrade the CO2 capture 

materials, and compressing captured CO2 from near atmospheric pressure to pipeline pressure

requires a large auxiliary power load. EPA has also identified “a low purity CO2 stream” as a 

“significant and overwhelming technical” issue.

There are no known installations of successful post-combustion capture of CO2 on gasfired turbines or compressors. EPA stated, “an applicant is generally not required to undergo 

extensive delays and expense to research and test unproven technologies as part of the BACT 
Cumulative Impacts 4-234

process.” Further, the agency stated that “technologies in the pilot scale testing stages of 

development would not be considered available for BACT review.” Therefore, LDEQ finds CO2

capture to be technically infeasible. In addition, Cameron LNG indicated that CCS technology is 

not at the licensing and commercial stages, and as an emerging technology it has limited success 

for gas-fired internal combustion engines. We agree that controls have not been demonstrated on 

sources similar to those proposed, nor has technology been demonstrated applicable to the 

Project. 

The proposed Project is in a region that does not have any geological formations that

support sequestration; therefore, local storage of CO2 is not an option, and transport from the 

expanded terminal to a distant storage facility would be required. In its GHG BACT analysis, 

Cameron LNG indicated that it could not commit to CCS because no CO2 pipeline currently 

exists near the proposed LNG Terminal. The Denbury Resources CO2 pipeline extends through 

Calcasieu Parish, Orange County, Texas, and Jefferson County, Texas, areas which border 

Cameron Parish. However, for the Terminal Expansion to connect to this CO2 pipeline,

Cameron LNG would have to secure the necessary rights-of-way (or perhaps purchase additional 

property) and construct a pipeline in excess of 20 miles. Alternatively, Cameron LNG could 

have subscribed to the proposed CO2 pipeline that would extend from the Lake Charles CCSq

Project to the Denbury pipeline, which would require a shorter pipeline. However, the Lake 

Charles CCSq Project appears to be fully subscribed with CO2 from the Lake Charles CCSq

Project. 

As a result, of these considerations, we eliminated CCS from further consideration as 

BACT for GHG emissions. 

To prevent freezing of CO2 in natural gas during the liquefaction process, the CO2 is 

removed and vented to the atmosphere through thermal oxidizers. There are no controls 

available to eliminate these emissions. The flares are designed to convert any flare gas to CO2. 

There is no additional control for the GHG emissions from the flares. Proper plant operations to 

minimize flare gas are determined as BACT for GHG emissions.

With CCS considered infeasible, there is no known applicability of solar thermal 

technology or solid oxide fuel cell technology to any facilities that are similar to those of the 

expanded terminal. The remaining control options consist of using the most efficient turbines, 

low carbon fuels, and good combustion/operating practices. Prevention of GHG emissions is the 

best control option for fugitive sources. Implementing a leak detection and repair program to 

minimize methane emissions is determined as BACT for GHG fugitive emissions. 

Cameron LNG proposes to install six refrigeration turbines. These are high thermal 

efficiency turbine models, fired with natural gas, a low-carbon fuel. Good combustion/operating 

practices would increase thermal efficiency. Good combustion/operating practices may not 

reduce CO2 emissions, but would reduce emissions of methane, which is a GHG component.

Nitrous oxide emissions would be minimal, and controlling those emissions would potentially 

increase other criteria pollutants, such as NOX; therefore, additional N2O control is not practical. 

Use of natural gas-fired high thermal efficiency turbines in combination with good combustion

and operating practices is determined as BACT for GHG emissions from the turbines. Cameron 

LNG would incorporate this BACT into operation of the expanded terminal.
4-235 Cumulative Impacts

Cameron LNG proposes to install several diesel-fired emergency generator engines and 

water pump engines to support plant operations if the main power source is not operating. Each 

engine would operate less than 100 hours per year. Selection of an engine with the highest fuel 

efficiency and good combustion and operating practices are the only feasible control options for 

diesel fuel GHG emissions and have been determined as BACT.

Cameron Interstate would use good operation and maintenance practices to reduce GHGs 

from natural gas-fired compressor engines, which has been determined as BACT. 

There is no standard methodology to determine how the Project’s incremental 

contribution to GHGs would translate into physical effects on the global environment. However, 

the emissions would increase the atmospheric concentration of GHGs, in combination with past 

and future emissions from all other sources, and contribute incrementally to climate change that 

produces the impacts previously described. Because we cannot determine the Project’s 

incremental physical impacts due to climate change on the environment, we cannot determine 

whether or not the Project’s contribution to cumulative impacts on climate change would be 

significant.

Noise

The cumulative impact area for noise is within about 1.5 miles of the Terminal 

Expansion, 1 mile of the pipeline route, and a 1-mile radius of the Holbrook Compressor Station.

The only NSA in the vicinity of the terminal expansion site is a rural residence about 1.2 

miles northwest of the site boundary. Based on the distance to the NSA, sound levels from 

construction equipment could reach 48 dBA, which is less than our noise criteria of an Ldn of 55 

dBA, and would not be expected to result in adverse impacts on the NSA. Sheet and pile driving 

could contribute sound levels of 53 dBA, which is also less than our noise criteria, and would 

also not be expected to result in significant impacts on the NSA. The only projects in the 

cumulative impact area that may be constructed at the same time as the Terminal Expansion are 

the non-jurisdictional NGL pipeline and the non-jurisdictional Entergy transmission line. The 

majority of the construction of the NGL pipeline would be south of the Terminal Expansion site, 

more distant from the terminal’s nearest NSA, and would not be expected to increase noise levels 

at the NSA. Construction of the Entergy transmission line is not expected to result in significant 

impacts on the NSA closest to the terminal. As a result, we believe that construction of the 

Terminal Expansion along with the non-jurisdictional projects would not result in a significant 

noise impact on the nearest NSA. 

The estimated operational noise level of the expanded terminal at the nearest NSA (about 

1.2 miles to the northwest) is 43.8 dBA Ldn, which is 2.9 dBA greater than the estimated ambient 

noise levels. The threshold of perception of change in sound levels for human hearing is about 

3dB; therefore, the increase would be unnoticeable or barely noticeable at the nearest NSA. 

Therefore, operational noise from the Terminal Expansion would result in minor impacts on the 

NSA. We did not identify any other projects that would contribute to operational noise impacts 

in the terminal’s cumulative impact area for noise. 

Construction of the Pipeline Expansion, including aboveground facilities, would affect 

ambient noise levels at some nearby residences. Those noise impacts would attenuate quickly as 
Cumulative Impacts 4-236

the distance from the noise source increases, and construction proceeds along the pipeline rightof-way. The duration of construction activities, and therefore noise impacts, at any one location 

would be temporary. The only project within the Pipeline Expansion’s cumulative impact area 

for noise is the electrical distribution line for the Holbrook Compressor Station. The noise 

generated during construction of that project would be temporary and also attenuate quickly as 

the distance from the noise source increases. Therefore, we believe cumulative noise impacts

from construction of the Pipeline Expansion would not be significant. 

Two NSAs are within the cumulative impact area for the Holbrook Compressor Station. 

We did not identify any other projects that would contribute to operational noise impacts in the 

cumulative impact area for the Holbrook Compressor Station. 

4.13.2.12 Safety

For the proposed Terminal Expansion, we considered the cumulative impact area for 

marine vessel traffic to include the Calcasieu Ship Channel from the coast of the Gulf of Mexico 

to its confluence with the Gulf Intracoastal Waterway, and from the latter’s confluence with the 

channel to the Port Arthur area. The cumulative impact area for the expanded terminal itself is 

the area adjacent to and in the vicinity of the terminal site, and the cumulative impact area for the 

pipeline was considered to be within about 660 yards of the pipeline centerline. The cumulative 

impact area for emergency services includes the area in the general vicinity of the proposed 

Terminal Expansion (which includes the two non-jurisdictional projects, the NGL pipeline and 

the Entergy transmission line), the Lake Charles projects, the Gasfin and Waller Point LNG 

Projects, and the Pipeline Expansion.

Cameron would mitigate impacts on public safety through the implementation of 

applicable federal, state, and local rules and regulations for the proposed Project as described in 

section 4.12. Those rules and regulations would ensure that the applicable design and 

engineering standards are implemented to protect the public and avoid or minimize the potential 

for accidents and failures. 

Because Cameron LNG has not requested an increase in the number of LNG carriers 

calling on the terminal, the Terminal Expansion would not add to the current risk assessment of 

public safety on the Calcasieu Ship Channel or of an intentional attack on an LNG carrier at 

berth or in transit in the channel. 

As noted in section 4.12.8, the risk associated with the Pipeline Expansion would be 

small. In addition, the proposed Pipeline Expansion route is parallel and adjacent to several 

pipelines and crosses several other pipelines. Although operation of the proposed Pipeline 

Expansion would increase the risk of a pipeline accident, we believe the increase in risk would 

be small. As a result, we believe that the cumulative impact on risk for the Pipeline Expansion 

would not be significant.

Emergency response time is a key aspect of public health and safety. Key emergency 

services are provided by the existing Cameron and Lake Charles LNG terminals in Cameron and 

Calcasieu Parishes, and those services would expand to include the associated proposed 

liquefaction projects. In accordance with our regulations, Cameron LNG would prepare a 

comprehensive plan that identifies the cost sharing mechanisms for funding these emergency 
4-237 Cumulative Impacts

response costs. Therefore, we believe that the cumulative impact of each project’s 

comprehensive plans would not result in a significant impact on public safety. 

If any or all of the stand-alone liquefaction projects (the Magnolia, Gasfin, and Waller 

Point LNG Projects) are authorized, constructed, and operated, each would also have to prepare 

and implement a similar comprehensive plan to provide emergency services. In addition, we

anticipate that the other major projects in the Lake Charles area (the LCCE Gasification Project, 

the Lake Charles CCSq Project, the IFG Port Holdings export terminal expansion, the Sasol 

Projects, and the G2X Energy Natural Gas-to-Gasoline Plant) would include emergency services 

within their facilities, as well as emergency response plans developed with the appropriate 

agencies. Emergency responses at any of those facilities may temporarily stress emergency 

services in the area, but we would not expect them to result in a long-term significant impact on 

those services. In the unlikely event of major emergencies at several of the facilities at the same 

time, there could be a short-term but significant cumulative impact on emergency services within 

Cameron and Calcasieu Parishes. That impact could be mitigated by assistance from emergency 

service providers from surrounding parishes.