Appendix L 

RESPONSES TO COMMENTS

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List of Comment Letters 

AP1 Applicant Comment Letter from Cameron LNG LLC / Cameron Interstate Pipeline LLC 

AP2 Applicant Comment Letter from Cameron LNG LLC / Cameron Interstate Pipeline LLC 

FG1 Federal Government Comment Letter from the U.S. Department of Fish and Wildlife 

FG2 Federal Government Comment Letter from the U.S. Department of the Interior 

FG3 Federal Government Comment Letter from the National Marine Fisheries Service 

FG4 Federal Government Comment Letter from the U.S. Environmental Protection Agency 

IN1 Individual Comment Letter from Charlie Atherton 

IN2 Individual Comment Letter from Charlie Atherton 

IN3 Individual Comment Letter from Kristin Brooks 

IN4 Individual Comment Letter from Joe Ellender 

IP1 Interested Parties Comment Letter from Ragley Historical Society 

IP2 Interested Parties Comment Letter from Sierra Club and Tulane Environmental Law Clinic 

LG1 Local Government Comment Letter from Cameron Parish Police Jury 

PM1 Public Meeting Transcript from the Sulphur Public Meeting 

SG1 State Government Comment Letter from State of Louisiana Department of Wildlife and 

Fisheries 

SG2 State Government Comment Letter from State of Louisiana Department of Wildlife and 

Fisheries 
AP1-1 AP1-1: Comment acknowledged. The EIS has been updated to reflect this 

information.

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1-5 AP1-5: The text of the first bullet in Section 2.2.1 has been revised in the 

final EIS to more accurately describe the existing types of loading, unloading, vapor return, and hybrid arms. 

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

AP1-2AP1-3AP1-4AP1-6

AP1-4: Section 1.2.4 of the final 

AP1-6: The EIS has been revised to clarify this issue. 

EIS has been revised to include this 

AP1-2: The final EIS has been revised to state that Cameron has option agreements for these properties.AP1-3: The schedule for the Project has been revised throughout the final EIS.statement. 

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AP1-6

(con’t)

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1-7 AP1-7: The relevant text and tables of the EIS have been revised to 

include information on the reduced widths of the construction right-of-way described in the comment by Cameron Interstate and to address the potential effects of the changes. In addition, Recommended Mitigation Measure No. 18 has been deleted from the EIS.

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1-9

AP1-8: In addition to revising the text to report the reductions in the acreages of wetlands affected, we have revised Table 4.4.5-1.

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

AP1-7(con’t)AP1-8

AP1-9: Comment acknowledged.

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AP1-10 AP1-10: The text and graphics of the EIS have been revised to identify the 

location of the vapor fence provided by Cameron LNG in the comment. In addition, Recommended Mitigation Measure No. 23 has been deleted from the EIS.

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1-10

(con’t)

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1-11 AP1-11: The text and graphics of the EIS have been revised to identify 

the location of the vapor fence provided by Cameron LNG in the comment, including descriptions of the changes made to avoid concerns with internal road crossings. In addition, Recommended Mitigation Measure No. 30 has been deleted from the EIS.

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1-11

(con’t)

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

AP1-11(con’t)

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AP1-12 AP1-12: The Exponent Letter Report is available in the full comment letter 

presented in Docket No. CP13-25-000, Accession No. 20140220-5191. 

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1-13 AP1-13: The Department of the Army permit issued to Cameron LNG is 

provided in Appendix K of this EIS. 

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1-14 AP1-14: Comment acknowledged. See responses to comments FG3-1 

and FG3-3 (Comment letter FG-3 from National Marine Fisheries Service dated January 30, 2014.) 

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP1-14

AP1 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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AP2-1 AP2-1: Comment acknowledged. 

AP2 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

AP2-2 AP2-2: The relevant portions of the EIS have been revised to provide the 

required information on the maximum capacity of the Project. 

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AP2 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

AP2-2(con’t)AP2-3

AP2-3: The relevant portions of the EIS have been revised to provide the currently anticipated schedule for the Project as provided by the commenter. 

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AP2 – Cameron LNG LLC / Cameron Interstate Pipeline LLC

Applicant Comments

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FG1 – U.S. Department of Fish and Wildlife

Federal Government Comments

FG1-1: Comment acknowledged. FG1-1

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FG1-3

FG1 – U.S. Department of Fish and Wildlife

Federal Government Comments

FG1-2

FG1-4

FG1-3: Comment acknowledged. The text of the EIS has been revised as requested in section 4.1.6.3 and in summary sections as appropriate.FG1-4: The COE issued a Department of the Army permit for the Terminal Expansion after the draft EIS was published. The text of the EIS has been revised to present the revised wetland mitigation acreages. FG1-2: Comment acknowledged. The text of the EIS has been revised to acknowledge this concurrence.

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FG1-7

FG1-5: See response to comment FG1-4. Section 4.6.3.4 of the EIS has been revised to reflect the elevations and a construction schedule of the mitigation areas. More detailed information in the mitigation plan included in the Department of the Army permit issued to Cameron LNG and provided in Appendix K of the EIS.

FG1 – U.S. Department of Fish and Wildlife

Federal Government Comments

FG1-6: Comment acknowledged. The recommendation regarding these surveys between MPs 2.8 and 4.7 is in the final EIS. If the Project is authorized this will be a condition of the FERC order authorizing the Project.FG1-7: Comment acknowledged.

FG1-5FG1-6

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FG2 – U.S. Department of the Interior

Federal Government Comments

FG2-1: See response to comment FG1-1 in comment letter FG1. FG2-1

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FG2-3

FG2 – U.S. Department of the Interior

Federal Government Comments

FG2-2

FG2-4

FG2-2: See response to comment FG1-2 in comment letter FG1.FG2-3: See response to comment FG1-3 in comment letter FG1.FG2-4: See response to comment FG1-4 in comment letter FG1. 

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FG2-6

FG2 – U.S. Department of the Interior

Federal Government Comments

FG2-5: See response to comment FG1-5 in comment letter FG1.

FG2-6 : See response to comment FG1-6 in comment letter FG1.

FG2-4(con’t)FG2-5FG2-7 FG2-7: Comment acknowledged.

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FG2 – U.S. Department of the Interior

Federal Government Comments

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FG3-1

FG3-1: The COE issued Cameron LNG a Department of the Army permit that includes a detailed mitigation plan approved by the COE. The permit is provided in Appendix K. We revised portions of section 4.6.3.4 to update Cameron LNG’s proposed impacts and mitigation, including a summary of key information in the mitigation plan.

FG3 – National Marine Fisheries Service

Federal Government Comments

FG3-2 FG3-2: See response to FG3-1.

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FG3-3

FG3-3: The acreage of COE jurisdictional wetlands was initially determined to be 99 acres; however, the draft EIS also reflected the full 213.7 acres of wetland that would be filled (section 4.4.4). The COE has since revised its wetlands determinations and issued the Department of the Army permit. The final EIS has been revised to provide updated jurisdictional wetland impact and mitigation acreages.

FG3 – National Marine Fisheries Service

Federal Government Comments

FG3-4: Comment acknowledged.

FG3-4

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FG4 – U.S. Environmental Protection Agency

Federal Government Comments

FG4-1

FG4-1: This is FERC staff's response to the commenter’s draft EIS comment letter. As a commenter, you are on our environmental mailing list and will receive a copy of this final EIS. When the Commission makes a decision on the project, it will be publicly available on FERC's eLibrary. We have provided responses below to the comments included in this comment letter.

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FG4 – U.S. Environmental Protection Agency

Federal Government Comments

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FG4-2

FG4-2: Section 4.9 of the EIS addresses Environmental Justice, and we 

are providing additional information on Environmental Justice below. As noted in the EIS, the route of the Pipeline Expansion would be within or adjacent to existing pipeline and utility rights-of-way. Therefore, routing was not selected to disproportionately impact low income or minority populations. In addition, there are no towns or communities near the proposed route: the closest community is the city of Sulphur, about 2.3 miles from the route. Similarly, the proposed Terminal Expansion site is adjacent to the existing Cameron LNG Terminal and was not selected to disproportionately impact low income or minority populations. The residence closest to the Terminal Expansion site is about 1.2 miles to the northwest, and the nearest community is the town center of Hackberry, about 2.6 miles to the south. We are not aware of any reported Environmental Justice concerns for the existing pipelines or the existing terminal.The ethnic makeup of Cameron, Calcasieu, and Beauregard Parishes is predominantly white (96.5, 71.5, and 82.2 percent, respectively, with “black or African American” the next highest at 1.9, 25.1, and 13.5 percent, respectively. Other ethnic groups (American Indian and Alaska native, native Hawaiian and other Pacific Islander, two or more races, and Hispanic or Latino origin) make up 4.7 percent of the population of 

Cameron Parish, 6.3 percent of the population of Calcasieu Parish, and 7.6 percent of the population of Beauregard Parish. The makeup of the state population is similar: 63.7 percent white, 32.4 black or African 

American, and the remaining ethnic groups 8.4 percent. Further the per capita income of the three parishes ranges from $21,543 to 24,634, and the per capita income of the state is about $23,094. 

To ensure that information on the Project was available to residents in the vicinity of the proposed Project, we sent a Notice of Intent to prepare an environmental impact statement to federal, state, and local officials; agency representatives; conservation organizations; Native American tribes; local libraries and newspapers in the Project area; and property owners in the vicinity of planned Project facilities and held a public 

FG4 – U.S. Environmental Protection Agency

Federal Government Comments

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FG4-2

(con’t)

FG4-3: We believe that Cameron LNG’s proposed mitigation measures identified in section 4.11.1.4, its adoption of the measures in our Upland, 

Erosion Control, Revegetation, and Maintenance Plan (Plan), and our traffic recommendation in section 4.9.6.1, provide sufficient mitigation for dust control to minimize the potential impacts of fugitive dust emissions during construction. In addition, in adopting our Plan (Plan), Cameron LNG would employ an Environmental Inspector for accountability and monitoring of environmental compliance during construction, including efficacy of the mitigation measures employed. Our analysis in section 4.2.5.1, also considered the wind erosion potential at the Cameron LNG 

Terminal site and the commensurate mitigation. We further note that speed limit signs are posted within the existing terminal, appropriately limiting vehicle speed, and would remain posted during construction. Lastly, we identify the nearest receptor to the Cameron LNG Terminal in section 4.11.2 and submit that construction would take place in areas where there are no residences or businesses near the construction site, and therefore it is unlikely that there would be sensitive receptors, such as those listed by the commenter, in the area near active construction areas. 

FG4 – U.S. Environmental Protection Agency

Federal Government Comments

FG4-3

FG4-2 (con’t): scoping meeting in Sulphur, Louisiana seeking input on the Project (see section 1.3.2). Notices were sent to about 300 interested parties. In addition, in March and August 2013 we mailed Project update brochures to ensure the public was up to date on the progress of the Project. We also notified the public that we were opening a comment period on the draft EIS and held a public comment meeting on the draft EIS in Sulphur. All public information is available on our e-library system. We did not receive any comments expressing concern about Environmental Justice impacts associated with the proposed Project and the Project would not significantly impact urban or residential areas. As a result of these considerations, we conclude that there would not be disproportionately high and adverse human health or environmental effects on minority, low-income communities, or Native American tribes because none are present in the vicinity of the Project.

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FG4 – U.S. Environmental Protection Agency

Federal Government Comments

FG4-3(con’t)

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FG4 – U.S. Environmental Protection Agency

Federal Government Comments

FG4-3(con’t)

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FG4 – U.S. Environmental Protection Agency

Federal Government Comments

FG4-4

FG4-4: The EIS did indeed disclose the appropriate lifecycle GHG emission for the proposed action by quantifying the construction GHG emissions (including pre-construction activities, such as mobilization at the sites) as well as operational GHG emissions of the facilities, which considered maintenance activities during operation. We believe it to be presumptuous to present the operational GHG emissions for the entire “life” of the facilities because operation of the facilities is based on the 

international markets and economic viability. For this reason, the operational GHG emissions were presented on a yearly basis. With regard to GHG emissions associated with decommissioning the Project facilities, we state in section 2.8 that Cameron LNG and Cameron Interstate would need to comply with FERC’s abandonment regulations, including environmental requirements in which we would evaluate the associated GHG emissions. 

FG4-5

FG4-5: The commenter contends that the proposed Project and other planned LNG export projects, if constructed and operated, will cause an increase in environmental impacts from induced gas production and pipeline transportation. While it is reasonable to assume that export of natural gas could result in increased natural gas production, where this gas would come from is speculative and would likely change throughout the operation of the project. Further, the development of natural gas is not the subject of this EIS nor is the issue directly related to the proposed Project. Production and gathering activities, and the pipelines and facilities used for these activities, are not regulated by FERC, but are overseen by the affected region’s state and local agencies with jurisdiction over the management and extraction of the resource. Determining the well and gathering line locations and the environmental impacts associated with their development and operation is not feasible as the market and gas availability at any given time would determine the source of the natural gas.As part of its NEPA analysis of proposed projects, the FERC often considers the potential environmental impacts of natural gas production 

and development occurring in the project area as part of the cumulative impacts analysis to the extent that there is meaningful information available to assist the FERC’s decision-making process in a particular proceeding (as indicated in our cumulative impacts discussion [section 4.13]). With respect to production and development activities that are not within a project area, the FERC determines whether such activities should be included in the EA or EIS based upon a fact-specific analysis. 

FG4-6

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FG4 – U.S. Environmental Protection Agency

Federal Government Comments

FG4-5 (con’t): CEQ regulations require agencies to consider environmental effects of proposed actions, including direct and indirect effects, if these effects are “reasonably foreseeable.” Where appropriate, the FERC evaluates the specific facts to determine whether natural gas production and development is a “reasonably foreseeable” direct or indirect result of construction and operation of the project under consideration, or whether such activities are too speculative or attenuated to warrant inclusion in the EA or EIS.In this case, the environmental impacts from induced production and pipeline transportation which may result from additional gas development are not “reasonably foreseeable” and such additional development, or any correlative potential impact, is not an “effect” of the Cameron Liquefaction Project for purposes of a cumulative impacts analysis. No specific gas play has been identified as a source of natural gas and the proposed Project does not depend on additional gas production, which may occur for reasons unrelated to the Project and over which the Commission has no control, such as state permitting for additional gas wells.Therefore, induced gas production and pipeline transportation and the impacts associated with gas production and transportation, other than the 

impacts associated with the proposed Pipeline Expansion, are outside of the scope of this EIS.

FG4-6: Section 4.4 of the draft EIS correctly depicted the acres of wetland that the Project would impact during construction. The only area that has significantly changed is the acreage of mitigation for those impacts, as the COE is now taking jurisdiction of many additional wetland acreages. The EIS has been revised to provide the current acreages of impact and mitigation. The COE issued a Department of the Army (DA) permit (Section 404 and Section 10 permits) for the Terminal Expansion after the draft EIS was prepared. The mitigation plan proposed by Cameron was reviewed and approved by the COE and is included in the DA permit. 

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FG4 – U.S. Environmental Protection Agency

Federal Government Comments

FG4-7

FG4-7: See response to comment FG4-6. In addition, the DA permit (Section 404 and Section 10 permits) issued to Cameron LNG by the COE on February 12, 2014 includes the mitigation plan, which provides the majority of the information requested by the commenter. The mitigation plan does not include financial assurances. We revised the EIS to include the DA permit as Appendix K. We also revised section 4.6.6.2 of the EIS to present key information regarding the mitigation plan.

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IN1-1

IN1-1: As discussed in the Environmental Assessment (EA) issued on March 29, 2005 for the Cameron LNG Berthing Amendment Project (CP02-378-002), Cameron LNG received a Coast Guard Letter of Recommendation (LOR) for the original project on March 30, 2004; however, the Coast Guard withdrew this LOR on March 21, 2005 after receiving Cameron LNG’s proposal to modify the berth. The letter referenced in this comment was issued on April 27, 2005 by the Coast Guard requesting Cameron LNG complete a Waterway Suitability Assessment (WSA) in accordance with the then forthcoming Navigation and Vessel Inspection Circular (NVIC) – Guidance on Assessing the Suitability of a Waterway for Liquefied Natural Gas Marine Traffic (NVIC 05-05), later published on June 14, 2005. Cameron provided a WSA to the Coast Guard, Marine Safety Unit Lake Charles on December 11, 2005 (as discussed in FERC’s EA for the Cameron LNG Terminal Expansion Project [Docket CP06-422]). On April 19, 2006, the Coast Guard issued a new LOR that stated, based on the review of Cameron LNG’s WSA, the Calcasieu River was considered suitable for the type and frequency of LNG marine traffic associated with the Cameron LNG project. Since 2006, Cameron LNG has filed several applications to modify its Terminal, and in each case, the Coast Guard has stated that the modifications did not require additional Coast Guard review. Similarly, for the proposed Cameron Liquefaction Project, the Coast Guard stated in a letter dated March 16, 2012, that it would not require revisions to the current WSA for the Cameron LNG Terminal nor would another LOR be required for the terminal because no additional LNG carrier traffic or revision to the routes were requested. We have also further consulted with the Coast Guard on this issue. The Coast Guard has indicated that it does not intend to have 

Cameron LNG prepare an additional WSA, and the decision regarding no need for another LOR for the proposed Terminal Expansion stands.

IN1 – Charlie Atherton

Individual Comments

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IN1-1

(con’t)

IN1-2: Comment acknowledged.

IN1 – Charlie Atherton

Individual Comments

IN1-2IN1-3IN1-4IN1-5IN1-6

IN1-3: We reviewed our files and don’t have an outstanding Freedom of Information Act request from Mr. Atherton at FERC.IN1-4: See response to Comment IN1-1.

IN1-5: Safety is addressed in section 4.12. Although the commenter has 

not specified which safety issues he is concerned about, his overall concerns are focused on issues under Coast Guard jurisdiction. As stated in section 4.12.7: “In a letter dated March 16, 2012, the Coast Guard stated that an 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 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.”IN1-6: See response to Comment IN1-1.

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IN1 – Charlie Atherton

Individual Comments

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IN1 – Charlie Atherton

Individual Comments

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IN1 – Charlie Atherton

Individual Comments

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IN1 – Charlie Atherton

Individual Comments

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IN1-7 NOTE: Mr. Atherton’s letter included four attachments that are not 

directly related to the proposed Project. Those attachments can be viewed at the FERC website, www.ferc.gov, Docket No. CP13-25-000, Accession No. 20120218-0034.

IN1 – Charlie Atherton

Individual Comments

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IN2 – Charlie Atherton

Individual Comments

IN2-1

IN2-1: See our response to comment IN1-1.There are currently five harbor tugs providing berth and escorting service for the Lake Charles area. The Lake Charles Pilots have stated that the current fleet of tugs would not be able to safely support the transit of any additional LNG vessels without causing significant delays in the movement of traffic throughout the remaining portions of the waterway. However, Cameron LNG has three additional tugs that are dedicated to serving the Terminal. As a result, the effects of the Project on harbor tug availability and response time on the traffic capacity of the Calcasieu Ship Channel can be considered negligible. 

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IN2-1

(con’t)

IN2 – Charlie Atherton

Individual Comments

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IN2-1

(con’t)

IN2 – Charlie Atherton

Individual Comments

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IN2 – Charlie Atherton

Individual Comments

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IN2 – Charlie Atherton

Individual Comments

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IN2-2 IN2-2: Comment acknowledged. See response to Comment IN1-1.

IN2 – Charlie Atherton

Individual Comments

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IN2-3: NOTE: Mr. Atherton’s letter included four attachments that are not 

directly related to the proposed Project. Those attachments can be viewed at the FERC website, www.ferc.gov, Docket No. CP13-25-000, Accession No. 20120218-0034.

IN2 – Charlie Atherton

Individual Comments

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IN3 – Kristin Brooks

Individual Comments

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IN3-1 IN3-1 Comment acknowledged. 

IN3 – Kristin Brooks

Individual Comments

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IN4-1 IN4-1 Comment acknowledged. 

IN4 – Joe Ellender

Individual Comments

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IP1-1 IP1-1: Comment acknowledged. 

IP1 – Ragley Historical Society

Interested Parties Comments

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-1

IP2-1: Our responses to the issues are provided below with the more specific comments.

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-1(con’t)

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-2: Comment acknowledged. FERC staff believes that itsenvironmental review and EIS evaluated the potential environmental impacts of the proposed Project. As noted below, portions of the EIS have been revised to present information made public after the draft EIS was issued.

IP2-2IP2-3

IP2-3: The alternatives analysis provided in the EIS is consistent with the Council on Environmental Quality (CEQ) regulations at 40 CFR 1500. Our alternatives analysis considers an alternative until it is proven to not be significantly environmentally preferable to the proposal by the applicant. Most of the eight alternatives suggested by the commenters in its scoping comments (pages 16 and 17, items one through 6 and item 8) were either not considered reasonable or beyond the scope of the EIS and are addressed in section 1.3 of the EIS, including table 1.3-2. The commenter’s suggested alternatives in item 7 regarding use of electrical power were addressed in section 3.3 of the draft EIS, and the final EIS was revised to include additional such alternatives. Issues related to alternatives that would minimize wetland and wildlife impacts are addressed in our responses to more specific comments below as well as in as well as in sections 3.3.1, 3.3.2, and 3.3.6 of the EIS. Other 

alternatives suggested in item 7, such as alternative pollution control technology, are addressed in sections 3.4, 3.6 and 3.7 of the EIS.

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-4

IP2-4: FERC staff does not assume “. . .that there is a need for Cameron to provide 1.7 bcf/d of capacity . . .”. The FERC is responsible, among other things, for conducting an environmental review of applications received irrespective of potential market demand. As noted in section 3.2.1 of the EIS, FERC staff believes that although we considered many projects as potential system alternatives, the market will ultimately decide which and how many of those facilities will be built. 

IP2-7

IP2-7: The EIS is not intended to be a determination of Project need. It is the duty and authority of the FERC's Commissioners to determine if the Project is in the public's convenience and necessity during its evaluation and review, prior to authorization. The FERC is not a proponent of the proposed Project, and therefore does not define the Project’s purpose and need. The purpose is defined by Cameron in its applications to the FERC, and we use that stated purpose in the EIS for the Project. The purpose and need statement in the EIS serves as a disclosure of Cameron’s stated purpose to which the FERC is responding and provides the basis for developing a reasonable range of alternatives. FERC staff neither endorses nor opposes Cameron’s assertions of need.

IP2-5

IP2-5: Our assessment of system alternatives considered the volume of 

LNG required to meet Cameron LNG’s existing contractual obligations with its customers. The projects assessed as system alternatives would also have contractual obligations that they would have to continue to meet in 

addition to Cameron’s proposed volume. 

IP2-6

IP2-6: Cameron LNG proposed an expansion of its existing facility and we conducted an environmental review of that proposal. However, our alternatives assessment included stand-alone export facilities as system alternatives (see section 3.2.1.2). 

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-8

IP2-8: See response to comment IP2-5.

IP2-7 (con’t)IP2-10

IP2-10: In order to address alternatives, we must make the assumption that the purpose and need of the Project (and competing projects) is valid.However, the market will ultimately decide which and how many LNG export facilities will be built and operated. Our assessment of the NoAction alternatives states, as noted by the commenter, that “other LNG export projects could also be developed . . .” [emphasis ours] and clearly states that with the No-Action Alternative, “. . . the potential adverse and beneficial environmental impacts identified in section 4.0 of this EIS would 

not occur.” See response to comment IP2-4. 

IP2-9

IP2-9: See responses to comments IP2-4, IP2-5, and IP2-7.

IP2-7 (con’t): Need is not an environmental issue to be addressed at length in the EIS to justify the Project. Applicants propose projects and present their objectives, and the FERC reviews those proposals, including producing an environmental document to satisfy NEPA. The CEQ 

regulations for implementing NEPA (at 40 CFR 1502.13) only require that the EIS “briefly specify the underlying purpose and need to which the agency is responding...”. The Commission will more fully consider the need for the Project when making its decision on whether or not to authorize the Project. Section 3 of the EIS contains a thorough analysis of alternatives to the Cameron Liquefaction Project, including the No-Action alternative. The EIS provides an accurate description of the applicant’s stated purpose and need for the proposed Project and evaluates potential alternatives to meeting that purpose and need. As stated previously, FERC believes that the market will determine the need for the Project

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-10 (con’t)IP2-12

IP2-12: Regarding the Project purpose and need, see response to comment IP2-7. The alternatives analysis is consistent with CEQ regulations, particularly 40 CFR 1502.14, which in addition to requiring detailed analysis of alternatives in comparative form, states that “and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.” For each alternative eliminated, the EIS states why the alternative was eliminated, and therefore we do not need a detailed analysis of those alternatives for comparison. The timeline for each alternative is not emphasized; however, it is still a component of the project and the evaluation of alternatives. The lack of providing a significant environmental advantage is the main reason for each alternative’s elimination. 

IP2-11

IP2-11: Because end users have not been and cannot be identified at this time, it is not possible to consider impacts of end use. Further, the impacts of end use in foreign, likely non-adjacent, countries is beyond the scope of a project proposed within the United States and evaluated under 

NEPA and CEQ regulations. 

IP2-13

IP2-13: The system alternatives addressed in section 3.1 of the EIS were not eliminated solely on the basis of the timing of in-service dates, although many of the projects were in such an early stage of development that if approved, they would not be completed within years of the anticipated in-service date of the proposed Project. As noted in section 3.1, the majority of the projects eliminated did not offer a significant environmental advantage over the proposed Project. Regarding Cameron’s contractual agreements, the relevant sections of the EIS have been revised to provide information regarding Cameron LNG’s contractual commitment to provide LNG by 2017. In addition, in response to this comment, we have added section 3.2.1.3 (Combined Projects Considered as a System Alternative) to the EIS.

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-13 (con’t)IP2-14

IP2-14: As noted above, the alternatives analysis is consistent with CEQ regulations, particularly 40 CFR 1502.14, which states that “and for alternatives which were eliminated from detailed study, briefly discuss the reasons for their having been eliminated.” For each alternative eliminated, the EIS states why the alternative was eliminated, primarily because it would not provide a significant environmental advantage. While each 

alternative may have areas that would impact fewer specific environmental resources, other resources may be impacted greater (e.g., offshore facilities would impact fewer wetlands; however these alternatives would have greater impacts on fish, Essential Fish Habitat (EFH), bottom habitats, and possible spills of hazardous materials). As noted in the EIS, the proposed Project would not have significant impacts, a statement that is substantiated by completed consultation with the State Historic Preservation Officer (SHPO) and the U.S. Fish and Wildlife Service (FWS), receipt of both an amended coastal use permit (CUP) and a Department of the Army (DA) permit for the Terminal Expansion (Section 404 of the Clean Water Act [CWA] and Section 10 of the Rivers and Harbors Act permits), air permits for the Terminal Expansion and the Holbrook Compressor Station, and the other environmental permits listed in table 1.5-1. An example is the most substantive impacts from this Project would likely come from the fill of wetlands. However, these are mostly low quality wetlands associated with the Terminal Expansion site and the U.S. Army Corps of Engineers (COE) and the National Oceanic and Atmospheric Administration, National Marine Fisheries Service (NMFS) agree that the creation of tidal wetlands would be more beneficial to wildlife and ecology. 

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IP2-15IP2-17 IP2-17: On the contrary, the draft EIS stated that even with only mitigating 

for 99.2 acres of jurisdictional wetland impact, we concluded that impacts on wetlands would not be significant. With the updated and increased acreages of mitigation, we continue to believe these impacts would not be 

IP2-15: We do not understand what 

significant. See response to comment IP2-16. 

the commenter is referring to 

regarding “alternatives that would limit the indirect impacts of Cameron’s proposed exports . . .”. However, we address indirect impacts in our response to comment IP-73. Regarding alternatives Commenters identified in their previous comment, see response to comment IP2-9.

IP2-16

IP2-16: Section 4.4 of the draft EIS correctly depicted the acres of wetland that the Project would impact during construction. The only area that has significantly changed is the acreage of mitigation for those impacts, as the COE is now taking jurisdiction of many additional wetland acreages. The EIS has been revised to provide the current acreages of impact and mitigation. The COE issued a DA permit (Section 404 and Section 10 permits) for the Terminal Expansion after the draft EIS was prepared. The mitigation plan proposed by Cameron was reviewed and approved by the COE and is included in the DA permit. We revised the EIS to include an assessment of upland sites as potential alternatives to the proposed Terminal Expansion site. (see new section 3.3.2). As stated in section 3.3, “We evaluated the area in the vicinity of the existing Cameron LNG Terminal [emphasis ours] for alternative sites to the proposed Terminal Expansion site. Proximity to the existing terminal was a criterion in the evaluation to allow Cameron LNG to use the existing infrastructure, such as the LNG storage tanks, the LNG carrier berths and cargo loading/unloading facilities, and associated facilities. Use of those 

existing facilities would avoid the impacts of constructing and operating new facilities.” However, we revised section 3.3 to provide an assessment of upland sites from about 5.2 to 13.3 straight-line miles from the proposed site (see new section 3.3.2).

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IP2-18IP2-19

IP2-19: We revised the EIS to include an assessment of upland sites as potential alternatives to the proposed Terminal Expansion site. (see new IP2-18: We used National Wetlands Insection 3.3.2).

ventory (NWI) maps to determine 

the acreages of the alternative sites TEA-1 and TEA-2. To provide a comparison of those wetland acreages to those of the proposed site, we also used NWI maps to obtain the acreages of wetlands on the proposed site. Therefore, the comparison of wetland acreages in section 3.3 does not need to be revised to include the updated wetland acreages in the DA permit for the Terminal Expansion. We continue to believe that these alternatives would not provide a significant environmental advantage to the proposed site. See response to comment IP2-16.

IP2-17(con’t)

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IP2-20 IP2-20: See response to comment IP2-16.IP2-19(con’t)

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IP2-23

IP2-23: We revised portions of section 4.6.6.2 to address the concerns of 

NMFS (including detailed information regarding the creation of marsh habitat). With this updated information, along with the updated acreages of marsh mitigation, we are requesting NMFS consider the EIS as our revised EFH assessment. 

IP2-21

IP2-21: See response to comment IP2-19. Additionally, Dominion Cove Point is proposing to use its existing facilities as part of its expansion to create an LNG export facility, similar to what Cameron LNG has proposed.

IP2-22

IP2-22: The purpose of an EIS is to disclose impacts, not necessarily eliminate all environmental impacts. As noted in sections 4.3.2 and 4.4.5, 

the methods proposed for construction of the pipeline through waterbodies and wetlands would not result in significant impacts and we determined that impacts on waterbodies and wetlands along the proposed route would be minimized to the extent practicable. FERC has concluded that the Cameron Interstate Plan and Procedures and use of a dry crossing method would minimize impacts. Where warranted, Cameron Interstate proposed to adopt the HDD method. 

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Interested Parties Comments

IP2-26 IP2-26: See response to IP2-16. In addition, the FERC does not 

determine compensation ratios for wetlands; that is the COE’s responsibility. We work in concert with the COE during the environmental review and are merely disclosing in the EIS the impacts and how on-site wetland impacts would be avoided, minimized, and mitigated to the extent 

practicable. In this case, tidal brackish marsh is more imperiled in the Project area than forested emergent wetland. Therefore, this mitigation seems reasonable.

IP2-23(con’t)IP2-24

IP2-24: As noted in section 4.3.2 of the EIS, “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.” We note that dredged materials from adjacent areas (e.g., the Calcasieu Ship Channel and the existing berthing area and turning basin) have successfully been used to create wetlands, indicating that the Project sediments could also reasonably be used to create wetlands. In addition, the Louisiana Department of Wildlife and Fisheries (LDWF) included the following statement in its comment letter on the draft EIS (comment letter SG2 in Appendix L): “LDWF has assisted the applicant in past years to create marsh from spoil material resulting from dredge activities of the LNG berthing slip. These spoil disposal areas have resulted in appropriate marsh elevations and successful re-vegetation. Therefore, LDWF continues to support such efforts.”

IP2-25 IP2-25: We understand that in sandy soil, the width of the top of the trench 

is difficult to minimize and therefore the width of the construction right-ofway to allow construction may be wider than normally desired. Cameron Interstate’s February 20, 2014 response to our recommendation in the draft EIS provides what we consider acceptable reductions to the right-ofway widths that are responsive to field conditions along those portions of the pipeline route. In addition, this reduction is in direct response to minimizing impacts on what would typically be considered higher quality wetlands (i.e., hardwood wetlands). 

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IP2-28

IP2-28: Comment acknowledged. See response to comment IP2-27.

IP2-26(con’t)IP2-27

IP2-27: In section 4.4 of the EIS, we acknowledge “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.” The pipeline would only remove 16.0 acres of wetland during its operation. While the terminal wetland impacts would be much greater, the creation of tidal marsh would also likely serve as flood control.

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IP2-32 IP2-32: We disagree with the commenter’s allegations and provide specific responses below. IP2-28(con’t)IP2-29

IP2-29: FERC did not conclude, nor did the EIS state, that there would be a “net zero loss” of wetlands. See responses to comments IP2-16 and IP2-24.

IP2-31 IP2-31: See response to comment IPI2-24.IP2-30

IP2-30: See response to comment IP2-23.

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IP2-32(con’t)IP2-33

IP2-33: The EIS does not rely on data from the 2003 EIS and the 2006 EA to evaluate impacts of the proposed Project. Cameron LNG is not proposing to increase the number or size of LNG carriers currently authorized to call on the terminal; those earlier documents are referred to because they were part of the decision-making process to authorize having 210 LNG carrier round trips from the territorial seas to the existing berthing facilities at the Cameron LNG Terminal. 

IP2-34

IP2-34: We agree that Cameron LNG has never had 210 ships per year call on its existing facility; however, they are permitted to do so, and environmental effects of those ships were reviewed in previous dockets. There would not be cumulative effects of shipping resulting from this Project as there are no changes proposed to the number or size of ships that are currently authorized to call on the Terminal. We do not believe this to be misleading, as we clearly state the number of vessels that are authorized for the Terminal. Further, the U.S. Coast Guard (Coast Guard) is the federal agency responsible for determining the suitability of waterways for LNG marine traffic. As noted in section 4.12.1 of the EIS: “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 [Waterway Suitability Assessment] is not required for the Terminal Expansion Project because the proposed modifications lie outside the Marine Transfer Area.”The FERC relies on the Coast Guard to carry out the necessary evaluations under its jurisdiction for LNG facilities, and we incorporate the findings of the Coast Guard into our environmental reviews of LNG export and import terminals. 

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IP2-34(con’t)

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IP2-34(con’t)

IP2-35: As noted in our response to IP2-34, Cameron LNG has not proposed an increase in the number of LNG carriers visiting the terminal or changes to the routes of carriers. The Coast Guard is responsible for assessing the suitability of the waterway, and the Coast Guard stated its assessment of the suitability of the waterway does not require revision. 

IP2-35

IP2-36: See response IP2-34. The potential Impacts of the proposed 

Project on water quality within the Calcasieu Ship Channel are addressed in section 4.3.2.2. Normal runoff from the Terminal Expansion is not anticipated to include either PCBs or PAHs. IP2-36

IP2-37: We are not aware of any agency or individual reporting impacts (including contaminated sediments) due to dredging of the existing terminal’s berthing area or the ensuing maintenance dredging. Further, we disclose the impacts of dredging in sections 4.3.2.2 and 4.6.2.1 of the 

EIS.

IP2-37

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IP2-37(con’t)

IP2-38: As stated in the EIS, Cameron LNG would follow the stormwater discharge requirements of its Environmental Plan, which includes the FERC Plan, as well as the requirements of the Louisiana Pollutant Discharge Elimination System permit. Those actions would be consistent with the current stormwater discharge at the existing terminal. Hazardous materials would be stored and handled in accordance with the requirements of the Cameron LNG Environmental Plan, which includes offsite disposal.

IP2-38

IP2-39: Discharges associated with construction of the Project would follow the requirements of the Cameron LNG and Cameron Interstate Environmental Plans and the appropriate state discharge permits.

IP2-39

IP2-40: As noted previously, Cameron LNG does not propose any modifications to the number or size of vessels currently authorized to call on the Terminal. However, we note that the revisions to ballast water discharge regulations represent improvements to the regulations and 

would result in greater avoidance of invasive species issues than previous regulations. LNG carriers visiting the terminal would be required to comply with the current regulations and would be monitored for compliance by the Coast Guard. Ballast water would initially be obtained at the port of departure of an LNG carrier, but the ballast water would be exchanged in the open ocean and treated on board the vessel. Ballast water would be discharged at the berthing facility as LNG is loaded on the LNG carrier, the same as the authorized loading of foreign-sourced LNG onto LNG carriers that is currently authorized at the existing terminal.

IP2-40

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Interested Parties Comments

IP2-40(con’t)

IP2-42: We disagree. The total water use over the 3-year construction period represents approximately 0.01 percent of the annual withdrawal volume reported for the Chicot Aquifer (see section 4.3.1.2). As stated in section 4.3.1.2 of the EIS, during operation water would be supplied through an existing on-site connection. The draft EIS inaccurately noted the supplier would be the City of Hackberry, whereas Cameron Parish Waterworks District 2 would provide the water. This correction was made in section 4.3.1.2 of the final EIS. As stated in the EIS, Cameron LNG and 

the provider would agree to water usage volumes and rates. As a result, we do not believe that it is appropriate to assess potential alternative water supplies. 

IP2-42

IP2-43: During the course of the research conducted in preparing the EIS, 

we did not encounter any information indicating construction of the existing terminal resulted in impacts on groundwater. 

IP2-43

IP2-44: See response to comment IP-24 regarding the potential for contaminated sediments. Cameron LNG would comply with the requirements of the Modified Maintenance Dredge Permit issued to Cameron LNG by the Louisiana Department of Natural Resources (LDNR) on November 20, 2013, which we believe would minimize sediment and turbidity impacts to the extent practicable and would not cause a significant impact on the environment. Therefore, we believe alternative methods of construction are not warranted. 

IP2-44

IP2-41: LNG carriers are currently authorized to export LNG from the Cameron LNG Terminal and would discharge ballast water under that authorization. See response to comment IP2-40.

IP2-41

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IP2-44(con’t)

IP2-44 (con’t): See responses to comments IP2-33 and IP2-34. Section 4.3.2.2 recognizes that dredging would result in temporary increases in the currently high turbidity levels of the area in the vicinity of dredging. As noted in our response to comment IP2-44, Cameron LNG has been issued a Modified Dredging Permit by LDNR and would comply with the requirements of that permit. In addition, as stated in section 4.6.2.1, 

“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.” As a result, no alternative dredging methods were assessed, and we believe the proposed and permitted dredging methods would not result in a significant impact. 

IP2-46: The potential impacts of operation of the proposed Project on water quality are addressed in the EIS. The potential impacts of operation of the existing facility were addressed in previous environmental documents. We do not believe that stopping the export process and starting the import process, or vice versa, would result in additional impacts on water quality.

IP2-46

IP2-47: The EIS addresses the potential impacts of normal operation of 

the Project. If a spill occurs, the facility has been designed to avoid impacts on the public, and Cameron provided contingency plans to address the release and a list of the agencies it would contact regarding the release. These plans are consistent with the approved plans for the existing terminal. Spills of hazardous substances would be contained, 

cleaned up, and materials would be disposed of at state-approved facilities. We believe that these measures would minimize the likelihood of any significant impacts on the environment.

IP2-47

IP2-45: As noted in section 4.3.1.2, the maximum piling depth would be approximately 110 feet below ground surface, and the shallowest aquifer is approximately 200 feet from the surface. We believe that impacts would be minimized and not significant, and alternatives to structural piles are therefore not required. IP2-45

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IP2-47(con’t)

IP2-48: Section 4.6.1.1 provides an assessment of the direct and indirect potential impacts on wildlife due to construction and operation of the Terminal Expansion. As noted in that section, “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, section 4.6.1.1 states that the mitigation areas that would be developed as a part of the Project (see Appendix K) “would provide higher quality habitat for wildlife currently using the Terminal Expansion area.” Cumulative impacts on wildlife are not addressed in the page referred to by the commenter, but are addressed in section 4.13.2.5.

IP2-48

IP2-50: The FERC and Cameron consulted with FWS and NMFS regarding the Project’s impacts on threatened and endangered species. Cameron conducted habitat surveys in the vicinity of Project components to determine what habitat was available for threatened and endangered species, then conducted species-specific surveys within those habitats. These surveys were conducted in consultation with FWS and NMFS. As noted in comment letter FG1, the FWS concurred with our determination that the Project is not likely to adversely affect threatened and endangered 

species. Consultation with NMFS is ongoing.

IP2-50

IP2-51: Section 4.6.3 of the EIS provides a detailed description of, and an evaluation of, potential impacts on EFH. See our response to comment FG3-1 (NMFS comment letter). 

IP2-51

IP2-49: The text of section 4.6.3.4 of the EIS has been revised to address 

the issue regarding indigenous fish raised by the commenter. 

IP2-49

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IP2-52: We revised section 4.11.1.5 to include a discussion of the ozone modeling analysis completed by Cameron LNG.

IP2-52

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IP2-52(con’t)

IP2-53: As stated in section 4.11.1.5, ”Modeling was also conducted for mobile sources of air emissions, which include LNG ships and support vehicles...” and “Mobile source emissions and modeling results are discussed in section 4.13.2.11, Cumulative Impacts.” As stated in section 4.13.2.11, modeling considered off-site sources available on LDEQ’s website, which would (1) include all existing projects as well as those under construction for which necessary data to consider them in the modeling conducted was available, and (2) would not include potential future projects not yet proposed. As stated in section 4.13.2.11, “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.”Lastly, in the absence of EPA-defined significance criteria for ozone, these cumulative modeling results for the ozone precursor, NO2, were presented 

in the EIS, demonstrating no new violations, and no increases in the severity or frequency of violations of the NAAQS, which EPA established to protect human health and public welfare for criteria pollutants, including ozone.

IP2-53

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IP2-53(con’t)

IP2-54: The estimated greenhouse gas (GHG) emissions for construction 

and operation of the Terminal Expansion and the Pipeline Expansion have been recalculated using the revised global warming potential (GWP) values in EPA’s November 2013 finalized amendments to its Greenhouse Gas Reporting Rule. The revised emissions are listed in tables 4.11.1-5, 4.11.1-6, 4.11.1-7, and 4.11.1-8. The GHG emission estimates reported in this EIS reflect the 100-year potential for methane for consistency with the EPA’s standard metric for defining the GWPs in its Greenhouse Gas Reporting Rule and the internationally accepted standard for reporting GHG emissions. . 

IP2-54

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IP2-54(con’t)

IP2-55: See responses to individual comments below.

IP2-55

IP2-56: We disagree. We concluded that the alternatives would not provide a significant environmental advantage after reviewing the probable impacts from emissions. (We note that the use of purchased power was recommended by the Sierra Club, which Cameron LNG agreed to use. Therefore, the argument that this alternative was not fully discussed seems to be arbitrary.) We also disagree with the last sentence of the paragraph and believe that the assessment of design alternatives for the Holbrook Compressor Station is consistent with NEPA and CEQ regulations. 

IP2-56

IP2-57: Section 3.4.2 of the EIS was revised to address the use of electric motors instead of the combustion turbines as a potential alternative. 

IP2-57

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IP2-57(con’t)

IP2-58: According to in the Interstate Natural Gas Association of America Foundation White Paper (INGAA Foundation) on waste heat (INGAA 2008), there is potential for the recovery of waste heat energy at facilities 

with natural gas turbines over 15,000 horsepower and a 60 percent load factor. However, in the absence of historical data for operational throughput of these LNG export facilities and the uncertainty of whether or not the liquefaction facilities would indeed operate at least at a 60 percent load factor, it is premature to suggest any further actions for waste heat recovery facilities to generate electricity.[Reference cited: INGAA Foundation. 2008. Waste Heat Recovery Opportunities for Interstate Natural Gas Pipelines. February. Available at: http://www.ingaa.org/Foundation/FoundationReports/Studies/7616/6208.aspx]

IP2-58

IP2-59: As described in section 4.11.1.5, during normal operation of the Project, emissions from the Project would be in compliance with the air permits issued by LDEQ (see table 1.5-1). Similarly, the emissions from power plants providing the electrical power that Cameron LNG would purchase to provide power to the Terminal Expansion would have to be in compliance with air permits. If Cameron LNG were to use electric liquefaction compressors using purchased power, emissions from the power plants providing the electrical power would have to be in compliance with air permits. As a result, no matter which form of power is used, the provider of the power must comply with the requirements of air permits (Title V and/or PSD permits). The text of section 3.4.2 has been revised to address the use of electrically powered liquefaction compressors as a potential design alternative for the Terminal Expansion.

IP2-59

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IP2-59(con’t)

IP2-60: See response to comment IP2-59. IP2-60IP2-61: After discussions with Beauregard Electric, Cameron Interstate reported in its April 23, 2013 filing that “Beauregard Electric indicated that 

they purchase their power from the Big Cajun II Power Plant, a local coalfired power plant.” FERC accepts that information as being accurate. See response to comment IP2-59.

IP2-61

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IP2-61(con’t)

IP2-62: See responses to comments IP2-57 through IP-59.

IP2-62

IP2-63: Our analysis of air quality impacts and emissions associated with the proposed Project includes a disclosure of the estimated emissions and mitigation measures both proposed by the Applicant and those recommended by FERC staff. However, in regard to specific mitigation technology, staff defers to the agencies with particular technical expertise over the resource. In this case, the LDEQ has federally delegated authority to enforce the Clean Air Act (CAA) and ensure that emission sources, such as the Cameron LNG Terminal, comply with the CAA and the SIP, including requiring technically, economically, and reasonable emissions control technologies.

IP2-63

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IP2-63(con’t)

IP2-64: The discussion of best available control technology (BACT) for GHG emissions is included in the cumulative impacts discussion as a means of presenting potential mitigation measures for reducing the 

Project’s GHG emissions and the Project’s contribution to cumulative impacts on climate change.Section 4.13.2.11 has been revised to indicate that Cameron LNG and Cameron Interstate would incorporate GHG BACT analyses as part of the air permits issued by LDEQ. Further, while the analysis in the EIS is very similar to that performed for the PSD permit to evaluate air quality impacts, the LDEQ, with delegated authority from the EPA under the CAA, is responsible for administering the PSD permit program in Louisiana. A BACT analysis is not required as part of a NEPA analysis. The emissions and modeling presented in the EIS are based on the operating equipment emission rates with the selected control technology committed to by Cameron LNG. The results of the modeling analysis identify that impacts 

would be within the allowable values.

IP2-64

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Interested Parties Comments

IP2-64(con’t)

IP2-65: We acknowledge that EPA Region 6 determined that CCS for the Freeport LNG Liquefaction Project was technically feasible for the GHG emissions from the natural gas pretreatment and combustion emissions for 

the Freeport LNG Liquefaction Project . However, Sierra Club fails to acknowledge in its comment letter that EPA Region 6 currently concludes in its Statement of Basis for the draft GHG PSD for the Freeport LNG Terminal that although technically feasible, CCS technology for the pretreatment process and combustion emissions was shown to be not only economically infeasible, but could result in increased emissions of criteria pollutants and GHGs, and therefore, eliminated CCS from further consideration, further noting that energy efficient technologies are preferred over add-on controls such as CCS. We do realize that EPA Region 6 might revise its opinion on the feasibility of CCS in its final GHG PSD permit based on certain factors, and potentially require implementation of CCS technology at the Freeport LNG Terminal, whereas, it may not be implemented at the Cameron LNG Terminal. However, we maintain that the LDEQ is the appropriate agency federally delegated by EPA with particular technical expertise over air quality to account for all the pertinent factors and use its permitting process to appropriately enforce all mitigation measures for compliance with the NAAQS and the CAA.

IP2-65

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IP2-65(con’t)

IP2-66: We believe that the carbon capture and sequestration options identified by the commenter were analyzed appropriately in the EIS in the context of an evaluation of potential mitigation measures for the GHG emissions associated with the Project. We reiterate here that the LDEQ is the appropriate agency federally delegated by EPA with particular technical expertise over air quality to account for all the pertinent factors and to use its permitting process to appropriately enforce all mitigation measures for compliance with the NAAQS and the CAA. IP2-66

IP2-67: See responses to comments IP2-63 and IP2-64.

IP2-67

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IP2-68

IP2-69: We disagree. As stated previously, we believe that the analysis in the EIS, in combination with the survey reports provided directly to the FWS and NMFS, more than adequately consider project impacts on listed species. In fact, in its comment letter on the draft EIS (comment letter FG1 in Appendix L), the FWS concurred with our determination that the Project is not likely to adversely affect threatened and endangered species.

IP2-69

IP2-70: We conclude that we have complied with the ESA.

IP2-70

IP2-68: As noted in section 3.7.2, we evaluated the use of selective catalytic reduction (SCR) at the Holbrook Compressor Station, in response to the commenter’s scoping comment and stated that the LDEQ concluded that SCR and use of an oxidation catalyst were not feasible pollution control options due to economic, environmental, and energy impacts. Cameron LNG also evaluated the use of SCR on the GE 7EA turbines at the Terminal Expansion as part of its air permit application. The LDEQ eliminated this control technology for reasons stated in its PSD permit PSD-LA-766 issued to Cameron LNG and in its response to comments from the Sierra Club dated October 2, 2013 (included as Exhibit 13 in the Sierra Club comment letter, available at www.ferc.gov, Docket No. CP13-25, Accession No. 20140303-5142.). We reiterate that a BACT analysis is not required as part of a NEPA analysis. Lastly, we defer to the LDEQ’s decision-making process regarding feasible pollution control options. 

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IP2-70(con’t)

IP2-71: FERC requested that the FWS consider in addition to the draft 

EIS the various survey reports prepared by Cameron (submitted separately), as our Biological Assessment (BA) for the proposed Project. The FERC and Cameron consulted with FWS and NMFS regarding the Project’s impacts on threatened and endangered species. Cameron conducted habitat surveys in the vicinity of Project components to determine what habitat was available for threatened and endangered species, then conducted species-specific surveys within those habitats. These surveys were conducted in consultation with FWS and NMFS. Survey reports included data identifying habitat and species-specific surveys (including the red-cockaded woodpecker) to help confirm presence or absence of listed species. Through use of these surveys, consultation with resource agencies, and our own expertise, we were able to draw reasonable conclusions regarding impacts on listed species. Our assessment noted that 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 (section 4.7.1.1). We also noted that manatees are not likely present, appropriate habitat for foraging is minimal, and in fact, the manatee has not been observed in the vicinity of the Terminal Expansion site in over 80 years (see section 4.7.1.3). Although foraging and transit habitat for the Kemp’s ridley sea turtle exist near the site of the proposed construction dock, given the level of industrial activity in the Calcasieu Ship Channel, it is highly unlikely that this species would use any habitat near the proposed Terminal Expansion. Finally, we revised the text of section 4.7.1.4 to include information on additional sea turtle species in our analysis. In addition, no bald eagle nesting sites were found within 0.5 mile of any Project facilities (see section 4.7.2.1). We believe these conditions provide reasonable justification for our conclusions. 

IP2-71

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IP2-71(con’t)

IP2-71 (con’t): As noted in its comment letters on the draft EIS (see comment letter FG1 in Appendix L), the FWS concurred with our determinations of effect regarding threatened and endangered species. The agency also stated that “No further consultation, regarding threatened and endangered species, with the FWS Lafayette Field Office will be necessary unless there are significant changes in the scope or location of the project.” Based on those statements, we believe that FWS has implicitly accepted the EIS as the BA, and therefore a separate BA is not necessary. The purpose of a BA is to analyze the direct and indirect impacts of an action on listed species. We believe that we have done this and further believe that our impact assessments of threatened and endangered species as described in the EIS are scientifically defensible, appropriate, are consistent with NEPA, and meet the requirements of both the ESA and CEQ. Consultation with NMFS is ongoing. 

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Interested Parties Comments

IP2-71(con’t)

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Interested Parties Comments

IP2-71(con’t)

IP2-72 We agree that end users would cause environmental impacts; however, it is not possible to know where those end users would be, or for us to realistically be able to characterize those impacts (especially in foreign countries, where environmental constraints would be different from the U.S. permitting process). Thus, determining the end users and associated impacts is not reasonably foreseeable. Our response to the last two sentences of this paragraph is included below in our response to comment IP2-73.

IP2-72

L-95
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-72(con’t)

IP2-73: The commenter contends that the proposed Project and other planned LNG export projects, if constructed and operated, will cause an 

increase in environmental impacts from induced gas production and 

pipeline transportation. The development of natural gas in shale plays by hydraulic fracturing is not the subject of this EIS nor is the issue directly related to the proposed Project. Production and gathering activities, and the pipelines and facilities used for these activities, are not regulated by FERC, but are overseen by the affected region’s state and local agencies with jurisdiction over the management and extraction of the shale gas resource. Determining the well and gathering line locations and the environmental impacts associated with their development and operation is not feasible as the market and gas availability at any given time would determine the source of the natural gas.As part of its NEPA analysis of proposed projects, the FERC often considers the potential environmental impacts of natural gas production and development occurring in the project area as part of the cumulative impacts analysis to the extent that there is meaningful information available to assist the FERC’s decision-making process in a particular proceeding. With respect to production and development activities that are not within the project area, the FERC determines whether such activities should be included in the EA or EIS based upon a fact-specific analysis. CEQ regulations require agencies to consider environmental effects of proposed actions, including direct and indirect effects, if these effects are “reasonably foreseeable.” Where appropriate, the FERC evaluates the specific facts to determine whether natural gas production and development is a “reasonably foreseeable” direct or indirect result of construction and operation of the project under consideration, or whether 

such activities are too speculative or attenuated to warrant inclusion in the EA or EIS.

IP2-73

L-96
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

IP2-73 (con’t): In this case, the environmental impacts from induced production and pipeline transportation which may result from additional shale gas development are not “reasonably foreseeable” and such additional development, or any correlative potential impact, is not an “effect” of the Cameron Liquefaction Project for purposes of a cumulative impacts analysis. No specific shale-gas play has been identified as a source of natural gas and the proposed Project does not depend on additional shale gas production, which may occur for reasons unrelated to the Project and over which the Commission has no control, such as state permitting for additional gas wells.Therefore, induced gas production and pipeline transportation and the impacts associated with gas production and transportation, other than the 

impacts associated with the proposed Pipeline Expansion, are outside of the scope of this EIS.

L-97
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-98
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-99
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-100
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-101
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-102
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-103
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-104
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-105
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-106
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-107
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-108
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-109
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-110
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-111
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-112
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-113
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-114
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-115
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-116
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-117
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-118
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-119
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-120
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-121
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-122
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

L-123
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-73(con’t)

IP2-74: The commenter contends that increased exports of LNG will have economic harms such as raising domestic gas prices, eliminating jobs in manufacturing and other domestic industries, and transferring wealth from working class families to large corporations. The U.S. Department of Energy (DOE) has exclusive jurisdiction over the export of natural gas as a 

commodity. DOE has delegated to the FERC the authority to approve or disapprove the construction and operation of particular facilities, the site at 

which such facilities would be located, and with respect to natural gas that involves the construction of new domestic facilities, the place of entry for imports or exit for exports. However, the Secretary of the DOE has not 

delegated to the FERC any authority to approve or disapprove the import or export of the commodity itself or to consider the type of issues raised by the commenter as part of the FERC’s public interest determination. Thus, the issue of whether the export of LNG will cause economic harm is beyond FERC’s purview. Our authorization alone will not enable the export of any additional volumes of LNG. 

IP2-74

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-74(con’t)

L-125
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-74(con’t)

L-126
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-74(con’t)

IP2-75: See response to comment IP2-11.

IP2-75

L-127
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-75(con’t)

L-128
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-75(con’t)

L-129
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-75(con’t)

L-130
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-75(con’t)

L-131
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-75(con’t)

L-132
IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-75(con’t)

IP2-76: See response to IP2-73. IP2-76

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IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

IP2-76(con’t)

IP2-77: We disagree and believe that the EIS is consistent with NEPA and meets CEQ requirements. As a result of our thorough analysis in the draft EIS, the FWS concurred with our determinations regarding threatened and endangered species and has implicitly accepted the EIS as the BA. As described above, we have taken a hard look at alternatives, and once it becomes clear that the alternative does not provide a significant 

environmental advantage, it is eliminated from further consideration. This reduces the length of our environmental documents, while coming to a 

reasoned conclusion. The final EIS incorporates revisions to the wetlands determinations of the COE that were not available when the draft EIS was being finalized and provides complete, consistent, and up-to-date data. We note that we had disclosed the impacts on wetlands in our draft, and that the major change to the wetlands section is the acreage of mitigation that is now being proposed, which would further offset environmental impacts than what was discussed in the draft EIS. Therefore, we conclude that those revisions do not substantively alter our assessments of impacts. 

IP2-77

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IP2-78: NOTE: The comment letter from the Sierra Club and the Tulane 

Environmental Law Clinic had 62 attachments that are available for review on the FERC website, www.ferc.gov, Docket No. CP13-25-000, Accession No. 2014030-5142.

IP2 – Sierra Club and Tulane Environmental Law Clinic

Interested Parties Comments

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LG1-1 LG1-1: Comment acknowledged.

LG1 – Cameron Parish Police Jury

Local Government Comments

L-136
PM1 – Sulphur Public Meeting

Public Meeting Comments

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PM1 – Sulphur Public Meeting

Public Meeting Comments

L-138
PM1 – Sulphur Public Meeting

Public Meeting Comments

L-139
PM1 – Sulphur Public Meeting

Public Meeting Comments

L-140
PM1-1 PM1-1: Comment acknowledged. 

PM1 – Sulphur Public Meeting

Public Meeting Comments

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PM1-1

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-142
PM1-2 PM1-2: Comment acknowledged. 

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-143
PM1-2

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

PM1-3 PM1-3: Comment acknowledged. 

L-144
PM1-3

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-145
PM1-3

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-146
PM1-3

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-147
PM1-4 PM1-4: Comment acknowledged.

PM1 – Sulphur Public Meeting

Public Meeting Comments

PM1-5 PM1-5: Comment acknowledged.

L-148
PM1-5

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-149
PM1-5

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-150
PM1-6 PM1-6: Comment acknowledged. 

PM1 – Sulphur Public Meeting

Public Meeting Comments

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PM1-6

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

PM1-7: Comment acknowledged. PM1-7

PM1-8: See our response to comment IN1-1. PM1-8

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PM1-8

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-153
PM1-8

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-154
PM1-8

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-155
PM1-8

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

PM1-9

L-156
PM1-9

(con’t) PM1-9: Comment acknowledged. 

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-157
PM1-10 PM1-10: Comment acknowledged. 

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-158
PM1-10

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

PM1-11 PM1-11: Comment acknowledged. 

L-159
PM1-11

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-160
PM1-11

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-161
PM1-11

(con’t)

PM1 – Sulphur Public Meeting

Public Meeting Comments

L-162
SG1-1

SG1-1: Sections 4.3, 4.4, 4.5, 4.6, and 4.7 of the EIS describe the impacts 

and mitigation methods Cameron would implement to minimize and avoid impacts on fish and wildlife. In addition, Cameron Interstate’s implementation of its Wetland and Waterbody Construction and Mitigation Procedures would avoid, minimize, and mitigate impacts on wetlands. Further, the Department of the Army (DA) permit issued to Cameron LNG by the COE (see Appendix K), includes Cameron LNG’s mitigation plan for wetlands that would reduce potential impacts on includes fish and wildlife. We anticipate that if the COE issues a DA permit to Cameron Interstate, it will also include required mitigation measures to protect wetlands and biological resources. Cameron Interstate’s Migratory Bird Conservation Plan was approved by FWS and Cameron Interstate executed a written agreement to purchase 17.43 acres of mitigation from The Conservation Fund. 

SG1 – State of Louisiana Department of Wildlife and Fisheries

State Government Comments

SG1-2

SG1-3

SG1-2: We agree and added a recommendation that Cameron Interstate should comply with the conditions set forth in the permits issued for these stream crossings (see sections 4.6.2.2 and 5.3).

SG1-3: We agree and added a recommendation that Cameron Interstate should inspect water extracted from water bodies, as well as equipment, for the presence of invasive aquatic weeds, including but not limited to giant salvinia or aquatic animals, such as apple snails, before being brought to the site and before being moved from the site to prevent their transport, and to destroy or remove those species from the equipment or water (see sections 4.6.2.2 and 5.3). 

L-163
SG1-4 SG1-4: Comment acknowledged.

SG1 – State of Louisiana Department of Wildlife and Fisheries

State Government Comments

L-164
SG1 – State of Louisiana Department of Wildlife and Fisheries

State Government Comments

L-165
SG1 – State of Louisiana Department of Wildlife and Fisheries

State Government Comments

L-166
SG1 – State of Louisiana Department of Wildlife and Fisheries

State Government Comments

L-167
SG1 – State of Louisiana Department of Wildlife and Fisheries

State Government Comments

L-168
SG1 – State of Louisiana Department of Wildlife and Fisheries

State Government Comments

L-169
SG1 – State of Louisiana Department of Wildlife and Fisheries

State Government Comments

L-170
SG2-1 SG2-1: See response to comment SG1-1 in comment letter SG1. 

SG2 – State of Louisiana Department of Wildlife and Fisheries

State Government Comments

SG2-2SG2-3

SG2-2: See response to comment SG1-1 in comment letter SG1.SG2-3: See response to comment SG1-3 in comment letter SG1.

L-171
SG2-4 SG2-4: Comment acknowledged.

SG2 – State of Louisiana Department of Wildlife and Fisheries

State Government Comments

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