CONCLUSIONS AND RECOMMENDATIONS

SECTION 5

5-1 Conclusions And Recommendations

5.0 CONCLUSIONS AND RECOMMENDATIONS

5.1 SUMMARY OF THE ENVIRONMENTAL ANALYSIS 

The conclusions and recommendations presented in this section are those of the FERC 

environmental staff. Our conclusions and recommendations are based on input from the COE, 

Coast Guard, DOE, and DOT as cooperating agencies in the preparation of this EIS. However, 

the cooperating agencies will present their own conclusions and recommendations in their 

respective Records of Decision or determinations. The cooperating agencies can adopt this EIS 

consistent with 40 CFR 1501.3 if, after an independent review of the document, they conclude 

that their requirements have been satisfied. Otherwise, they may elect to conduct their own 

supplemental environmental analyses.

We conclude that construction and operation of the Cameron Liquefaction Project would 

result in mostly temporary and short-term environmental impacts. However, the Project would 

result in permanent impacts on wetlands, forests, pine plantations, agricultural lands, migratory 

birds, and EFH. Long-term environmental impacts would occur on some species. In addition, 

there would be short-term impacts on traffic on LA-27 in the vicinity of the Terminal Expansion 

site during construction. As part of our analysis, we developed specific mitigation measures that 

are practical, appropriate, and reasonable for the construction and operation of the Project. We 

are, therefore, recommending that these mitigation measures be attached as conditions to any 

authorization issued by the Commission. We conclude that implementation of the mitigation 

proposed by Cameron and our recommended mitigation would ensure that impacts in the Project 

area would be avoided or minimized and would not be significant. A summary of the Project 

impacts and our conclusions are presented below by resource. 

5.1.1 Geologic Resources

Construction and operation of the Project would not materially alter the geologic 

conditions of the Project area, and the Project would not affect mining of resources during 

construction or operation. The Pipeline Expansion would not cross any significant geologic 

hazards, including areas of seismic activity or subsidence. Cameron Interstate committed to 

conducting geotechnical studies to determine general subsurface conditions, evaluating the 

potential for settlement at the Holbrook Compressor Station site, and developing engineering 

designs to avoid or minimize any geotechnical hazards, such as settlement, at the site. The 

design of the liquefaction facility is currently at the Front End Engineering Design level of 

completion. Information regarding the development of the final design would need to be 

reviewed by FERC staff in order to ensure that the final design addresses the requirements 

identified in the FEED. Therefore, we are recommending that Cameron LNG file Terminal 

Expansion design and construction details stamped and sealed by the professional engineer of 

record. Blasting is not anticipated during construction of either the Pipeline Expansion or the 

Terminal Expansion. Based on Cameron’s proposal, including implementation of the FERC and 

Cameron Interstate Plans and Procedures and our recommended mitigation measures, we 

conclude that impacts on geological resources would be adequately minimized and would not be 

significant, and that the potential for impacts on the Project from geologic hazards would also be 

minimal. 
Conclusions And Recommendations 5-2

5.1.2 Soils

Construction of the Project facilities would disturb soils, resulting in increased potential 

for erosion, compaction, mixing of topsoil, and the introduction of rock into the topsoil. Soils 

within the general Project area are moderately susceptible to water and wind erosion. Most soils 

have low to moderate revegetation potential, although some prime farmland soil with high 

revegetation potential would be affected by the Pipeline Expansion. The erosion potential of the 

soils is reduced by the generally level topography of the area. 

There are no prime farmland soils on the site of the Terminal Expansion. Most impacts 

on prime farmland soils from construction of the Pipeline Expansion would be short-term and 

would not affect the potential use of prime farmland for future agricultural purposes. The 

Holbrook Compressor Station would impact 14.8 acres of prime farmland, but would not result 

in a significant reduction of usable prime farmland soils in the area. 

Cameron LNG did not encounter contaminated soil during construction of the existing 

LNG Terminal and the associated pipeline facilities. Cameron would implement its 

Unanticipated Hazardous Waste Discovery Plans if unanticipated contaminated soil is discovered 

during construction. The potential impacts from soil erosion would be minimized through the 

use of erosion control and revegetation measures described in the FERC and Cameron Interstate 

Plans. 

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 on land located west of the Terminal Expansion site that is owned and operated by 

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

Section 404 and Section 10 permits issued to Cameron LNG by the 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. 

5.1.3 Water Resources

The Project is underlain by the upper portion of the Coastal Lowlands Aquifer System 

(known as the Chicot Aquifer), an EPA-designated sole-source aquifer; however, we do not 

anticipate any long-term or significant impacts on the aquifer due to construction or operation of 

the Project. Standard construction procedures could affect groundwater resources by altering 

overland water flow and infiltration rates. Because the recharge areas are much larger than the 

footprint of the Project, changes in groundwater recharge as a result of Project construction are 

not expected to be significant. There are no active public water supply wells, wellhead 

protection areas, or springs within 150 feet of any of the proposed Project facilities. 

Cameron LNG would withdraw water for hydrostatic testing and dust control at the 

Terminal Expansion facilities from an onsite well. The estimated overall volume for the 3-year 

construction period would be about 0.01 percent of the annual volume removed from the aquifer 

for domestic and industrial uses and the aquifer would recharge quickly. Implementation of the 

FERC Procedures would minimize adverse impacts on surface water quality. On December 23, 

2013, LDEQ issued a discharge permit to Cameron LNG.
5-3 Conclusions And Recommendations

During dredging of the work dock area, Cameron LNG would use a hydraulic cutterhead 

dredge and, if appropriate, would install turbidity curtains to reduce impacts on water quality in 

the Calcasieu Ship Channel. Construction of the Terminal Expansion facilities would eliminate 

one of two man-made freshwater pond basins. Cameron LNG would use the remaining pond as 

a stormwater retention basin during construction and may fill it during operation. LDNR issued 

a Modified Maintenance Dredge Permit on November 20, 2013 that includes dredging for the 

proposed work dock. The COE permits and those permits included required procedures and 

mitigation measures for dredging of the berthing area for the proposed work dock that would 

minimize impacts on water quality. We conclude that the potential impacts on groundwater and 

surface water quality during construction and operation of the Terminal Expansion would be 

minimized through implementation of the FERC Plan and Procedures, and no significant impacts 

on water resources would occur due to construction and operation of the proposed Terminal 

Expansion. In addition, Cameron LNG must comply with its CUP and Section 404 and Section 

10 permits.

The Pipeline Expansion would cross 27 streams (with one stream crossed twice) and one

pond. Cameron Interstate would cross all perennial waterbodies using the HDD method, and use 

the open-cut and dry-ditch crossing methods on other waterbodies. Cameron Interstate would 

cross all waterbodies in accordance with federal and state regulations and permit requirements 

and minimize impacts by following the measures identified in its Procedures. Installation of the 

pipeline would have only temporary impacts on waterbodies when open-cut or dry-ditch crossing 

methods are employed and avoid impacts when using the HDD method. We believe that the 

potential impacts on groundwater and surface water quality during construction and operation of 

the Pipeline Expansion would be minimized through implementation of the Cameron Interstate 

Plan and Procedures.

Construction of the Pipeline Expansion would require the use of surface water sources for 

hydrostatic testing of the pipeline segments. We conclude adherence to the Cameron Interstate 

Procedures would minimize impacts on water resources related to water withdrawal and 

discharge. In addition, Cameron Interstate would follow the requirements of the LDEQ

discharge permit for hydrostatic test water withdrawal and discharge that it must obtain prior to 

construction. 

5.1.4 Wetlands

Construction and operation of the Terminal Expansion would affect a total of about 213.5

acres of wetland. All wetlands affected during construction of the Terminal Expansion would be 

permanently filled, but impacts on the 213.5 acres of jurisdictional wetlands would be offset by

Cameron LNG’s mitigation measures, including creation of about 256 acres of offsite tidal 

brackish marsh wetland habitat. To further minimize impacts on wetlands, Cameron LNG would 

comply with all conditions of the Section 404 and Section 10 permits issued to Cameron LNG by 

the COE on February 12, 2014 and the amended CUP issued to Cameron LNG by the LDNR. 

Construction and operation of the Pipeline Expansion would affect a total of about 56.7

acres of land classified as wetlands. Of the total affected acres, Cameron Interstate would 

permanently impact 16.0 acres, including conversion of 1.3 acres from forested to emergent 

wetlands. Cameron Interstate would mitigate the permanent loss of forested wetlands by 

purchasing mitigation credits from a COE-approved mitigation bank servicing the area, and 
Conclusions And Recommendations 5-4

would further minimize impacts on wetlands through collocation of its pipeline, reduction of 

right-of-way width, and implementation of measures presented in its Procedures. Cameron 

Interstate would continue working with the COE to determine the appropriate mitigation bank.

In addition, Cameron Interstate agreed to reduce the width of the right-of-way and ATWS in 

seven areas with bottomland hardwood wetland species, which would avoid impacts to a total of 

1.3 acres of bottom hardwood wetlands. We are recommending that Cameron Interstate file 

revised photo-alignment sheets depicting the reduced right-of-way widths. We are also 

recommending that Cameron Interstate complete wetlands surveys in areas not previously 

completed.

Based on Cameron’s proposal and proposed mitigation measures, implementation of the 

wetland mitigation plan included in the COE’s permit and the amended CUP, implementation of 

the FERC and Cameron Interstate Plans and Procedures, and our recommended mitigation 

measures, we determined impacts on wetland resources would be adequately minimized and 

mitigated and would not be significant. We also conclude Cameron Interstate’s impacts on 

herbaceous and scrub-shrub wetlands would generally be temporary or short-term, while impacts 

on forested wetlands would result in long-term to permanent impacts. However, we conclude 

that implementation of Cameron’s compensatory mitigation would ensure that impacts on filled 

and forested wetlands would be offset by sufficient mitigation.

5.1.5 Vegetation

No vegetative communities of special concern have been identified within the area 

affected by the Project. 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, and portions of these areas were also disturbed during construction of 

the existing Cameron LNG Terminal. Much of the property is comprised of vegetation 

indicative of disturbed sites. As a result, we conclude that the loss of vegetation from the 

Terminal Expansion would be minor but permanent. Cameron LNG would implement 

compensatory mitigation for wetland vegetation impacts as mentioned above. 

Impacts of the Pipeline Expansion on vegetation would range from short-term to 

permanent, including impacts on upland forest, pine plantation, open land, agricultural land, and 

wetlands. To minimize vegetation impacts (including wetlands), Cameron Interstate would 

collocate and overlap existing rights-of-way to the extent practicable, comply with the 

requirements in the Section 404 permit issued by the COE, employ the spill prevention measures

in its Environmental Plan, adhere to the mitigation measures provided in its Plan and Procedures, 

and consult the local USDA NRCS regarding re-seeding specifications and appropriate 

guidelines. Cameron Interstate would allow most of the construction right-of-way to revert to 

vegetation types present prior to construction, although upland woody vegetation would not be 

allowed within the permanent right-of-way. About 19.4 acres of upland forest and pine 

plantation would be permanently affected along the route. 

Access road improvements would have a minor impact on existing vegetation. The one

contractor yard required for the Pipeline Expansion would primarily affect open vegetation types 

which we expect to quickly return to pre-construction conditions after completion of the Project.
5-5 Conclusions And Recommendations

The Chinese tallow tree is the only noxious species of concern along the pipeline route, 

and Cameron Interstate would control growth of this species using the methods described in its 

Environmental Plan. In addition, Cameron Interstate’s Plan and Procedures include measures to 

minimize the introduction of noxious weeds from areas outside of the right-of-way during

construction. As stated in these documents, Cameron Interstate would develop Project-specific 

procedures in coordination with the NRCS to prevent the introduction or spread of noxious 

weeds and soil pests resulting from construction and restoration activities. 

We anticipate that impacts on herbaceous vegetation generally would be temporary or 

short-term and would not be significant, and that impacts on forested tracts would result in longterm and limited permanent impacts. Further, Cameron Interstate would parallel and overlap 

existing rights-of-way to the extent practicable and be parallel and adjacent to existing rights-ofway for the remainder of the route, thereby substantially reducing impacts on forested areas.

5.1.6 Wildlife and Aquatic Resources

Construction and operation of the Terminal Expansion would result in the removal of all 

habitats at the site and conversion of the site to industrial land. This would have a permanent 

effect on wildlife and wildlife habitats of the site; however, much of the Terminal Expansion site 

was previously disturbed, as described above, resulting in degraded wildlife habitat and a 

reduction in habitat diversity and the number of species on the site. Cameron LNG would 

mitigate wetland habitat impacts through the creation of tidal brackish marsh, which would 

provide additional habitat. 

During construction and operation of the Terminal Expansion, temporary and minor 

impacts on aquatic resources would also occur due to the initial and periodic dredging of the 

work dock area. NMFS and the GMFMC identified the Calcasieu Ship Channel and adjacent 

coastal marsh as EFH. The EFH within the proposed Terminal Expansion site boundary includes 

estuarine water bottoms and estuarine water column. To minimize impacts from dredging on 

EFH and EFH species, Cameron LNG would use a hydraulic cutterhead dredge. Cameron LNG 

would beneficially use dredged materials at existing disposal sites and in Cameron LNG’s marsh 

mitigation area to create tidal brackish marsh, providing additional habitat for EFH species. As 

noted above, the mitigation area was approved by the COE and the LDNR and is included in its

COE permit and CUP issued to Cameron LNG. As requested by NMFS in its comment letter on 

the draft EIS, we included information on the mitigation plan in the EIS and appended the COE 

permit, which includes the mitigation plan. Through implementation of the FERC Procedures 

and Cameron LNG’s proposed mitigation measures, effects on EFH and EFH species in and near 

the terminal construction area would be localized, minor, and temporary.

Vegetation types providing wildlife habitat in land affected by the Pipeline Expansion

include upland forest, agriculture, wetlands, pine plantation, and open land. The impacts of 

construction and operation would range from temporary to permanent, with the impact 

dependent on the resource requirements of each species and the existing habitat present. 

Clearing of the temporary construction right-of-way would reduce cover, nesting, and foraging 

habitat for some species. However, species that use early successional shrub or forest 

communities may benefit from the clearing and revegetation process. 
Conclusions And Recommendations 5-6

Cameron Interstate filed a Migratory Bird Conservation Plan with the 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 it 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 conclude 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. 

Because Cameron Interstate would collocate the pipeline as much as possible with other 

rights-of-way and would adhere to its Plan and Procedures, including revegetation requirements, 

we conclude construction and operation of the Pipeline Expansion would not significantly affect 

local wildlife populations and do not expect additional habitat fragmentation. 

All waterbodies that would be affected by the Project could support warm, freshwater 

fisheries. No sensitive fish species, fisheries of concern, or EFH have been identified within the 

waterbodies the Pipeline Expansion would cross. While construction could result in several 

impacts on fisheries resources, these impacts would be minor due to the relatively small area of 

the waterbody affected, the use of HDDs at perennial stream crossings, and implementation of

the Cameron Interstate Procedures. In response to a comment by the LDWF, we added a 

recommendation that Cameron file revised Environmental Plans that include measures to prevent 

the transport and spread of invasive aquatic weeds and animals during construction of both the 

Terminal Expansion and the Pipeline Expansion. 

Based on Cameron Interstate’s proposal, including implementation of its Plan and 

Procedures, we conclude impacts on wildlife and aquatic resources would be adequately 

minimized and not significant.

5.1.7 Threatened, Endangered, and Other Special Status Species

Based on consultations with the FWS and Cameron’s species-specific surveys, four

federally listed species potentially occur in the general Project area. We anticipate that 

construction and operation of the proposed Project would not likely adversely affect the Kemp’s 

ridley sea turtle, West Indian manatee, and piping plover at the Terminal Expansion, and the redcockaded woodpecker at the Pipeline Expansion. We requested that the FWS and NMFS 

consider the draft EIS as the BA for the proposed Project as part of our ESA Section 7 

consultation process. In its comments on the draft EIS, the FWS concurred with the 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, NMFS concluded that re-initiation of Section 7 consultation would 

not be necessary as the impacts were previously considered in Docket No. CP06-422-000. 

Therefore, Section 7 consultation under the ESA is complete. 
5-7 Conclusions And Recommendations

The area between MPs 13.9 and 14.9 includes designated habitat where there is a 

potential for the presence of the red-cockaded woodpecker and we are aware that construction 

would not begin for more than 1 year after the last survey of that area. We are recommending

that Cameron Interstate resurvey that area within 1 year of the construction start date. 

Two state-listed species and five other species of concern were identified by agencies and

stakeholders as potentially occurring within the vicinity of the Project. Cameron Interstate 

agreed to minimize impacts on areas with western saline longleaf pine savannahs by lengthening 

its HDD in that area, which would also minimize impacts on the state listed dotted gay-feather 

and silveus dropseed. We are recommending that Cameron Interstate file revised photoalignment sheets of its lengthened HDD. Based on the presence of potential habitat and our 

recommendation, we conclude that Cameron Interstate’s collocation with existing pipeline

corridors and overlapping the construction workspace with these existing disturbed areas would

avoid or minimize potential impacts on state-listed species by reducing the overall extent of new 

clearing and land disturbance.

In summary, we conclude that implementation of Cameron’s mitigation measures, our 

recommendations, and use of the FERC and Cameron Interstate Plans and Procedures during 

construction and operation of the Project would adequately minimize impacts on federally and 

state-listed species along with other species of concern.

5.1.8 Land Use, Recreation, and Visual Resources

Construction of the Terminal Expansion would be within and adjacent to the existing 

Cameron LNG Terminal and would result in permanent impacts on about 502.2 acres of open 

land, industrial/commercial land, forested and non-forested wetlands, and open water. All of the 

affected area would be permanently converted to industrial land. A portion of the Terminal 

Expansion site is within the designated coastal zone, which is managed by the LDNR, Office of 

Coastal Management. The LDNR reviewed coastal zone consistency concurrently with Cameron 

LNG’s CUP application and issued an amended CUP with an approved mitigation plan on 

January 21, 2014. 

Cameron LNG has not requested any changes in the number or route of LNG carriers 

currently authorized to call on the terminal. Although barge traffic in the Gulf Intracoastal 

Waterway and in the Calcasieu Ship Channel would increase during construction, we anticipate 

that the overall impact on recreational boating and fishing would be minor. 

Views of the Terminal Expansion would generally be similar to those of the adjacent 

existing Cameron LNG Terminal. Cameron LNG filed a revised design for vapor fences in its 

comment letter on the draft EIS (see comment letter AP1 in Appendix L), that would reduce the 

design to 1,500 feet of fencing in an area adjacent to the existing Cameron LNG Terminal where 

views are dominated by the existing LNG storage tanks and other facilities of the terminal. 

Cameron LNG agreed to construct the fencing with an aesthetic design, similar to concrete sound 

barriers used along highways near residential areas. Based on those considerations, we conclude 

that the visual impact of the Terminal Expansion would be minor although permanent.

Construction and operation of the Pipeline Expansion would include both temporary and 

permanent impacts on a variety of land uses: forested wetlands, scrub-shrub and emergent 
Conclusions And Recommendations 5-8

wetlands, upland forest and planted pine forest, open space, open water, residential land, 

industrial land, and agricultural land. The entire pipeline right-of-way would overlap with or be 

adjacent to existing rights-of-way, with about 15.5 miles of the right-of-way collocated with the 

existing Cameron Interstate Pipeline right-of-way. Except for a permanent access road 

constructed for the Holbrook Compressor Station, Cameron Interstate would use public 

roadways and existing access roads. Most of the affected area would return to pre-construction 

use after the pipeline is installed. Overall, Cameron Interstate would permanently impact about 

88.1 acres of land. 

Cameron Interstate would impact visual resources along the pipeline route by clearing of 

the right-of-way and construction of the Holbrook Compressor Station. Visual impacts

associated with the pipeline would be greatest where the pipeline route parallels or crosses roads, 

trails, or prominent off-site observation points, and other places where the right-of-way may be 

seen by passing motorists or recreationists. The presence of construction personnel and 

equipment would result in short-term impacts on the viewshed of those areas. Although clearing 

of forested land would result in minor long-term and permanent impacts on the viewshed, we 

conclude that the visual character would not change substantially from existing conditions at 

these observation points because the pipeline would be constructed within or directly adjacent to 

existing pipeline or utility corridors. The area surrounding the Holbrook Compressor Station is 

mainly forested and would provide a visual screen resulting in temporary and minor impacts on

the viewshed of that area.

Cameron Interstate would implement mitigation measures proposed in its site-specific 

construction plans to minimize potential impacts on the four houses within 135 feet of the 

construction right-of-way. 

Cameron Interstate would construct the pipeline near or across several recreation areas 

including a scenic highway, two Louisiana Natural and Scenic Rivers (Hickory Branch and 

Beckwith Creek), Sam Houston Jones State Park, Holbrook Park, and a private hunting area. 

Given the current hunting management practices, we do not conclude construction or operation 

of the Pipeline Expansion would adversely affect hunting activities. Cameron Interstate would 

bore under the scenic highway and use the HDD method to cross the scenic rivers to avoid or 

minimize impacts on these areas. On 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. The two parks in the vicinity of the Project are more than 1.5 

miles from the right-of-way and we do not anticipate direct construction-related impacts. 

5.1.9 Socioeconomics

Construction of the Project would increase the population within Cameron, Calcasieu, 

and Beauregard Parishes for the 4.5-year construction period of the Terminal Expansion. 

Although the peak construction workforce for the Terminal Expansion would be about 3,500 

workers, with some of the workers from the local area, the workforce would be housed 

throughout the three-parish area where there is a large amount of transient housing, and the 

impact on housing would be minor to moderate. We anticipate that the impact of the combined 

workforce of the Terminal Expansion and the Pipeline Expansion on public services would be 

minor. 
5-9 Conclusions And Recommendations

Construction and operation of the Project would increase local and state tax revenues 

from sales taxes, payroll taxes, and property taxes, and would likely increase local employment. 

The Pipeline Expansion would result in minor, long-term, and permanent impacts on local 

forestry economics, as construction would result in the loss of about 20.6 acres of pine plantation 

for the life of the Project. 

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 

adjacent to other existing linear facilities. The Project would not significantly impact urban or 

residential areas, and no disproportionately high and adverse human health or environmental 

effects on minority, low-income communities, or Native American tribes have been identified.

Cameron LNG has proposed mitigation to reduce the impact on LA-27 traffic in the 

vicinity of the Terminal Expansion site during commuting periods for the workforce. We are 

recommending that Cameron LNG develop a Traffic Management Plan with additional 

mitigation to further reduce the impact. With incorporation of the additional mitigation, we 

conclude that the impact of traffic on LA-27 due to construction of the Terminal Expansion 

would not be significant. 

Barges would deliver equipment and materials to the work dock and to an existing dock 

on the Gulf Intracoastal Waterway. The impact of barge traffic on the waterway and the 

Calcasieu Ship Channel would be moderate during the initial stages of construction and would 

decline to a minor impact after about the first year of construction when barge traffic decreases. 

Cameron LNG has not requested to increase the number of LNG carriers calling on the 

terminal above the number currently authorized.

5.1.10 Cultural Resources

Cultural resource surveys were conducted for the Project, including surveys of the 

Terminal Expansion site, the pipeline right-of-way, the Holbrook Compressor Station, contractor 

yard, access roads, and the new and modified pipeline interconnections. No archaeological or 

historic architectural resources were identified within the survey areas, and the SHPO and FERC 

staff agree that no historic properties would be affected. The review process under Section 106 

of the NHPA is complete for the Project. 

5.1.11 Air Quality and Noise

Construction of the Project would result in temporary impacts on air quality due to 

emissions from fossil-fueled construction equipment and fugitive dust. Cameron would 

incorporate dust control measures during construction to minimize fugitive dust, and we 

conclude the impact of construction on air quality would be minor. We would not expect 

construction equipment emissions to cause or significantly contribute to a violation of an 

applicable air quality standard. There would be long-term impacts on air quality during 

operation of the proposed Terminal Expansion facilities and the Holbrook Compressor Station. 

However, Cameron LNG would minimize operational emissions from the expanded terminal in 

the vicinity of the Terminal Expansion by using purchased electrical power from a new nonjurisdictional Entergy transmission line. Operation of the Terminal Expansion and Holbrook 
Conclusions And Recommendations 5-10

Compressor Station would comply with the requirements of applicable federal and state 

regulations, and BACT would be installed as described in Cameron LNG’s Title V and PSD 

Permits issued for the Terminal Expansion on October 1, 2013, and in Cameron Interstate’s Title 

V and PSD Permits for the Holbrook Compressor Station issued on December 20, 2013.

Construction activities and the associated noise would vary depending on the phase of 

construction in progress at any one time. While individuals in the immediate vicinity of 

construction activities could experience an increase in noise, this effect would be temporary and 

localized. HDD crossings associated with the pipeline construction represent the greatest 

potential for prolonged noise impacts during construction. Based on noise assessments 

completed for the HDD sites, Cameron Interstate committed to implementing mitigation 

measures to reduce noise levels as needed. This would include methods such as installation of 

partial noise barriers around the hydraulic power units, the use of silencers or mufflers on 

engines, and gear box noise blankets. During initial drilling of the four HDD entry points nearest 

to the NSAs, Cameron Interstate would collect noise measurements to confirm that noise levels 

at the nearest NSAs are acceptable. If HDD operation with implementation of Cameron 

Interstate’s mitigation measures results in noise levels unacceptable to residents, Cameron 

Interstate would reimburse landowners who may elect to use temporary housing at a local hotel 

or motel during HDD-related construction activities. We are recommending that Cameron 

Interstate file noise measurements at the start of drilling operations and state any mitigation 

measures that it has implemented if HDD noise is above an Ldn of 55 dBA. We conclude that 

Cameron Interstate’s commitments would lessen impacts on residents to the extent practicable. 

Based on the distance to the NSA nearest the Terminal Expansion site, sound levels from 

construction would not be expected to result in adverse impacts on the NSA. Operation of the 

expanded terminal would generate sound levels that would occur throughout the life of the 

proposed Project, but the increase in noise levels would be just above the “barely detectable” 

noise level increase of 3 dBA and would result in minor impacts on the nearest NSA. In

addition, the noise level would be below the FERC limit of an Ldn of 55 dBA. We are 

recommending, however, that Cameron LNG file a full-load noise survey no later than 60 days 

after each liquefaction train is put in service for the first and second liquefaction trains. If noise 

levels attributable to operation of the Terminal Expansion exceed the FERC limit of an Ldn of 55 

dBA, Cameron LNG would reduce the terminal’s noise contribution to result in a noise level that 

is no higher than the FERC guideline. We are also recommending that Cameron LNG file a fullload noise survey no later than 60 days after placing all the Terminal Expansion facilities in 

service. Therefore, we conclude that operational noise from the expanded terminal would result 

in minor impacts on the nearest NSA. 

The modeling analyses for the proposed Holbrook Compressor Station resulted in 

calculated noise levels below an Ldn of 55 dBA at the nearest NSAs. To ensure that noise levels 

would be below an Ldn of 55 dBA, we are recommending that Cameron Interstate file noise 

surveys during full load and if the noise levels exceed the FERC guideline, that Cameron 

Interstate install additional noise controls to meet the guideline within 1 year of the in-service 

date. As a result, we conclude that the impact on noise levels during operation would be minor.
5-11 Conclusions And Recommendations

5.1.12 Safety

We evaluated the safety of the proposed LNG facilities associated with the Terminal 

Expansion, including a review of the cryogenic design of the facilities proposed for liquefaction, 

related facilities, and safety systems. Our assessments addressed hazards, preliminary 

engineering design, siting requirements, siting analysis, emergency response, and facility 

security. As part of our evaluation, we performed a technical review of the preliminary 

engineering designs and conclude that sufficient layers of safeguards would be included in the 

facility designs to mitigate the potential for an incident that could damage the facility or impact 

the safety of the off-site public. 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 hazardous liquids. In a letter to FERC dated November 

18, 2013, DOT stated it has no objection to Cameron's methodology for determining the 

candidate design spills to establish the required siting for its proposed Terminal Expansion

facilities. In accordance with 33 CFR 127, the Coast Guard reviewed the proposed liquefaction 

facilities and stated that a Letter of Intent or a revision to the Water Suitability Assessment 

would not be required for the Terminal Expansion because the proposed modifications clearly lie 

outside the Marine Transfer Area. We identify specific recommendations to be addressed by 

Cameron LNG prior to initial site preparation, prior to construction of final design, prior to 

commissioning, prior to introduction of hazardous fluids, and prior to commencement of service.

As a result, we conclude that potential hazards from the siting, construction, and operation of the 

facility at this location would not have a significant impact on public safety.

Cameron Interstate would design, construct, operate and maintain its pipeline and 

aboveground facilities to meet or exceed the DOT Minimum Federal Safety Standards in 49 CFR 

192 and other applicable federal and state regulations. By designing and operating the proposed 

Project in accordance with the applicable standards, the Project would represent only a slight

increase in risk to the nearby public.

5.1.13 Cumulative Impacts

We considered the contributions of the proposed Project in specific cumulative impact 

areas for the resources affected by the Project. As a part of that assessment, we identified

existing projects, projects under construction, projects that are proposed or planned, and 

reasonably foreseeable projects, including agriculture and silviculture, existing LNG terminals 

and future LNG liquefaction projects, currently operating and future oil and gas projects, land 

transportation projects, and commercial developments and dredging projects. Our assessment 

considered the impacts of the proposed Project combined with the impacts of the other projects 

on resources within all or part of the same area and time. 

We conclude that for most resources the Project’s contribution to cumulative impacts on 

resources affected by the Project would not result in significant impacts. Construction traffic 

associated with the Terminal Expansion could contribute significantly to traffic congestion on 

LA-27 in the vicinity of the Terminal Expansion site, particularly when construction worker 

shifts begin and end during the period when the workforce peaks. That construction traffic 

during commuting time may coincide with construction traffic of other projects in general area, 

if those projects are approved and constructed. We conclude that with incorporation of the 

mitigation measure proposed by Cameron LNG and mitigation measures we are recommending, 
Conclusions And Recommendations 5-12

the cumulative impact on traffic along LA-27 would be reduced. However, if all of the projects 

are under construction at the same time, the impact on traffic along LA-27 south of Sulphur due 

to construction worker traffic may result in periods of congestion and delay on portions of the 

highway.

Similarly, because several projects in the Lake Charles area could be under construction 

at the same time as Cameron’s Project, there may be increased congestion 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. Impacts would be greatest in the vicinity 

of the major projects, and mitigation measures may be implemented by the proponents of those 

projects to reduce the impacts.

Simultaneous construction of the Cameron Liquefaction Project and the projects in the 

Lake Charles area would require a large number of workers from the local labor pool and import 

of construction workers. To find adequate housing, it is likely that workers may have to reside in 

adjacent parishes. The cumulative effect would benefit the transient housing market but would 

adversely affect those seeking transient housing. 

The combined construction workforces of projects under simultaneous construction 

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. Because the construction periods of the proposed Project and many of the 

projects identified in the cumulative impact analysis could overlap, in some cases over a period 

of several years, there is a potential for a significant cumulative impact on such services in 

Calcasieu Parish. However, Cameron LNG and the other LNG projects in the Project area would 

develop emergency response plans to lessen the impacts on emergency services.

5.2 ALTERNATIVES

As alternatives to the proposed action, we evaluated the No-Action Alternative, system 

alternatives for the Terminal Expansion and the Pipeline Expansion, alternative Terminal 

Expansion sites, alternative terminal configurations and designs, alternative Pipeline Expansion 

aboveground facility sites, and alternative compressor station designs. While the No Action 

Alternative would avoid the environmental impacts identified in this EIS, the objectives of the 

Project would not be met. However, the purpose of and need for the Project would likely be met 

by other LNG export projects developed elsewhere, would result in similar or greater impacts at 

other locations, and potential end users would make other arrangements to obtain natural gas 

service or use alternative fossil fuel energy sources, other traditional long-term fuel source 

alternatives, and/or renewable energy sources to compensate for the reduced availability of 

natural gas that would otherwise be supplied by the proposed Project. 

We evaluated 13 Terminal Expansion system alternatives including five existing LNG 

import terminals with planned, proposed, or authorized liquefaction projects, seven stand-alone 

LNG export terminals, and combinations of two or more of those terminals providing a portion 

of the LNG volume required by Cameron LNG’s existing customers. To meet all or part of 

Cameron LNG’s contractual agreements, each of these projects would require substantial 
5-13 Conclusions And Recommendations

construction beyond what is currently planned and would not offer significant environmental 

advantages over the proposed Terminal Expansion. Similarly, the use of more than one project 

to meet Cameron LNG’s objectives would require substantial construction beyond what is 

currently planned and would not offer significant environmental advantages over the Terminal 

Expansion. As a result, we eliminated all potential system alternatives from further 

consideration. 

We evaluated alternative Terminal Expansion sites near the western and southern borders 

of the existing Cameron LNG Terminal. We conclude that use of those areas would result in 

substantially greater impacts on open water, marsh, fish, wildlife, and active oil and gas activities 

than those associated with development of the proposed site. We also evaluated potential upland 

sites that could accommodate the area needed for the Terminal Expansion. All of the potential 

upland sites are a substantial distance from the existing LNG storage tanks and were eliminated 

primarily due to safety issues associated with a lengthy LNG pipeline. In addition, the selected 

location of each of the components within the Terminal Expansion site was based on the relevant 

regulations, codes, and guidelines, and we did not find any alternative configurations that would 

meet the regulations, codes, and guidelines, while avoiding or reducing impacts in comparison to 

those of the proposed terminal configuration. As a result, we conclude that development of the 

expanded terminal on the alternative sites or with alternate configurations would not be 

environmentally preferable.

We evaluated three existing pipeline systems as system alternatives to the proposed 

Pipeline Expansion and determined that those system alternatives would not have sufficient 

capacity to meet the natural gas requirements of the Terminal Expansion without substantial 

expansion. We conclude that the construction impacts of expanding those pipeline systems 

would be similar to or greater than those of the proposed pipeline. Consequently, we conclude 

that none of the pipeline system alternatives would be environmentally preferable to the 

proposed Pipeline Expansion.

Cameron LNG originally proposed to install and operate gas turbine-driven generators, 

while purchased power alternatives could be more fully explored and analyzed. Cameron LNG 

completed its evaluation and eliminated on-site power turbine generators in favor of purchased 

power for the proposed Terminal Expansion, to be supplied by the new non-jurisdictional 

Entergy electric transmission line. The use of on-site power generation is now considered a 

design alternative. During operation, most emissions and the noise levels of the turbine 

generators would be greater than those of purchased power in the vicinity of the Terminal 

Expansion site. For both options, dispersion modeling results showed no exceedances of SILs 

with the exception of NO2, which showed no contribution of exceedance of NAAQS in refined 

analyses. Although it is not possible to determine the difference of the emissions of NOx and 

CO2 between the two design options, if any, the total increase in emissions from the power 

generation plants that would provide electricity to the transmission line would generally be 

comparable to those of the gas-driven on-site generators. We also evaluated the alternative of 

providing purchased power for the liquefaction equipment instead of using the proposed gasfired compressors. Based on the information gathered from the site-power generation 

alternative, we concluded that the total increase in emissions from the power generation plants 

that would provide electricity to the compressors would generally be comparable to those of the 

gas-driven on-site compressors.
Conclusions And Recommendations 5-14

The noise levels during operation of the expanded terminal using the on-site power 

generation alternative would be slightly greater than those using purchased power, with both 

options being below the FERC noise level criterion of an Ldn of 55 dBA at the nearest NSA. 

Therefore, we conclude noise at the nearest NSA from the expanded terminal would not be 

significant for either alternative. Because on-site power generation would not provide a 

significant environmental advantage, it was not considered further.

We evaluated four site alternatives to the proposed Holbrook Compressor Station site.

Cameron Interstate could not acquire the land for two of the alternative sites. Although the 

potential impacts associated with emissions, access road construction, and construction of an 

electrical distribution line would be greater at the proposed Holbrook Compressor Station than 

the two remaining alternative sites, we conclude those differences would be minor. In addition, 

the proposed site would have less impact on forest land, wetlands, and NSAs than the remaining 

two alternative sites. We also evaluated the alternative of providing purchased power for each of 

the alternative sites. Based on the information gathered from the purchased power generation 

alternative, we concluded that the total increase in emissions from the power generation plants 

that would provide electricity to the compressors would generally be comparable to those of the 

gas-driven on-site compressors. Therefore, we conclude that the alternative sites would not 

provide a significant environmental advantage to the proposed site. No alternative sites were 

identified that would be environmentally preferable to the other proposed aboveground facilities 

associated with the Pipeline Expansion.

We also evaluated the use of electric-powered compressors and purchased power as an

alternative to the proposed natural gas-fired compressors at the Holbrook Compressor Station. 

Use of purchased power would require construction of a 3.5-mile-long non-jurisdictional, 230-

kV electric distribution line from LA-27 to the proposed Holbrook Compressor Station site and a 

switch yard in or near the site. That distribution line, which would be in addition to the 

distribution line required for electric power for other equipment at the site, would require 

clearing a new right-of-way adjacent to the proposed Cameron Interstate pipeline right-of-way 

from LA-27 to the Holbrook Compressor Station site. Based on the additional environmental 

impacts that would result from construction of the distribution line, operational considerations of 

the compressor station, and emissions data for the two power options, we conclude that the use 

of purchased power for operating the Holbrook Compressor Station does not offer a significant

environmental advantage over the proposed on-site power generation. 

We reviewed Cameron Interstate’s alternatives to the proposed design of the Holbrook 

Compressor Station, including fewer, larger, more efficient turbines, use of selective catalytic 

reduction to reduce nitrogen oxide emissions, and use of an oxidation catalyst to reduce carbon 

monoxide emissions. These alternatives would require substantially more fuel than the proposed 

design or are not feasible due to economic and/or environmental impacts, as described in the 

BACT analysis included in the Title V and PSD Permits issued by LDEQ. We conclude that 

these alternatives would not provide a significant environmental advantage to the proposed 

Project.

5.3 FERC STAFF’S RECOMMENDED MITIGATION

If the Commission authorizes the Project, we are recommending that the following 

measures be included as specific conditions in the Commission’s Order. We believe that these 
5-15 Conclusions And Recommendations

measures would further mitigate the environmental impacts associated with the construction and 

operation of the proposed Project. 

1. Cameron LNG and Cameron Interstate shall follow the construction procedures and 

mitigation measures described in their applications, supplemental filings (including 

responses to staff data requests), and as identified in the EIS, unless modified by the 

Order. Cameron LNG and Cameron Interstate must:

a. request any modification to these procedures, measures, or conditions in a filing 

with the Secretary;

b. justify each modification relative to site-specific conditions;

c. explain how that modification provides an equal or greater level of environmental 

protection than the original measure; and

d. receive approval in writing from the Director of OEP before using that 

modification.

2. For LNG facilities, the Director of OEP has delegated authority to take all steps 

necessary to ensure the protection of life, health, property, and the environment during 

construction and operation of the Terminal Expansion Project. This authority shall 

include:

a. stop-work authority and authority to cease operation; and

b. the design and implementation of any additional measures deemed necessary to 

assure continued compliance with the intent of the conditions of the Order.

3. For pipeline facilities, the Director of OEP has delegated authority to take whatever steps 

are necessary to ensure the protection of all environmental resources during construction 

and operation of the Pipeline Expansion Project. This authority shall allow:

a. the modification of conditions of the Order; and

b. the design and implementation of any additional measures deemed necessary 

(including stop-work authority) to assure continued compliance with the intent of 

the environmental conditions as well as the avoidance or mitigation of adverse 

environmental impact resulting from Pipeline Expansion Project construction and 

operation.

4. Prior to any construction, Cameron LNG and Cameron Interstate shall file affirmative 

statements with the Secretary, certified by senior company officials, that all company 

personnel, EI’s, and contractor personnel will be informed of the EI’s authority and have 

been or will be trained on the implementation of the environmental mitigation measures 

appropriate to their jobs before becoming involved with construction and restoration 

activities.

5. The authorized facility locations shall be as depicted in the EIS, as supplemented by filed 

alignment sheets. As soon as they are available and before the start of construction, 
Conclusions And Recommendations 5-16

Cameron LNG and Cameron Interstate shall file with the Secretary any revised detailed 

survey alignment maps/sheets at a scale not smaller than 1:6,000 with station positions 

for all facilities approved by the Order. All requests for modifications of environmental 

conditions of the Order or site-specific clearances must be written and must reference 

locations designated on these alignment maps/sheets. 

Cameron Interstate’s exercise of eminent domain authority granted under NGA Section 

7(h) in any condemnation proceedings related to the Order must be consistent with these

authorized facilities and locations. Cameron Interstate’s right of eminent domain granted 

under NGA Section 7(h) does not authorize it to increase the size of its natural gas 

pipeline to accommodate future needs or to acquire a right-of-way for a pipeline to 

transport a commodity other than natural gas.

6. Cameron LNG and Cameron Interstate shall file detailed alignment maps/sheets and 

aerial photographs at a scale not smaller than 1:6,000 identifying all route realignments or 

facility relocations, and staging areas, pipe storage yards, new access roads, and other 

areas that would be used or disturbed and have not been previously identified in filings 

with the Secretary. Approval for each of these areas must be explicitly requested in 

writing. For each area, the request must include a description of the existing land 

use/cover type, documentation of landowner approval, whether any cultural resources or 

federally listed threatened or endangered species would be affected, and whether any 

other environmentally sensitive areas are within or abutting the area. All areas shall be 

clearly identified on the maps/sheets/aerial photographs. Each area must be approved in 

writing by the Director of OEP before construction in or near that area.

This requirement does not apply to extra workspaces allowed by FERC’s and Cameron 

Interstate’s Plan or minor field realignments per landowner needs and requirements that 

do not affect other landowners or sensitive environmental areas such as wetlands.

Examples of alterations requiring approval include all route realignments and facility 

location changes resulting from:

a. implementation of cultural resources mitigation measures;

b. implementation of endangered, threatened, or special concern species mitigation 

measures;

c. recommendations by state regulatory authorities; and

d. agreements with individual landowners that affect other landowners or could 

affect sensitive environmental areas.

7. Within 60 days of the acceptance of the Authorization and the Certificate and

before construction begins, Cameron LNG and Cameron Interstate shall file 

Implementation Plans for the review and written approval by the Director of OEP. 

Cameron LNG and Cameron Interstate must file revisions to their plans as schedules 

change. The plans shall identify:
5-17 Conclusions And Recommendations

a. how Cameron LNG and Cameron Interstate will implement the construction 

procedures and mitigation measures described in its respective application and 

supplements (including responses to staff data requests), identified in the EIS, and 

required by the Order;

b. how Cameron LNG and Cameron Interstate will incorporate these requirements 

into the contract bid documents, construction contracts (especially penalty clauses 

and specifications), and construction drawings so that the mitigation required at 

each site is clear to onsite construction and inspection personnel;

c. the number of EIs assigned per spread and aboveground facility sites, and how the 

company will ensure that sufficient personnel are available to implement the 

environmental mitigation;

d. company personnel, including EIs and contractors, who will receive copies of the 

appropriate materials;

e. the location and dates of the environmental compliance training and instructions 

Cameron LNG and Cameron Interstate will give to all personnel involved with 

construction and restoration (initial and refresher training as the Project 

progresses and personnel change), with the opportunity for OEP staff to 

participate in the training session(s);

f. the company personnel (if known) and specific portion of Cameron LNG’s and 

Cameron Interstate’s organization having responsibility for compliance;

g. the procedures (including use of contract penalties) Cameron LNG and Cameron 

Interstate will follow if noncompliance occurs; and

h. for each discrete facility, a Gantt or PERT chart (or similar Project scheduling 

diagram), and dates for:

1) the completion of all required surveys and reports;

2) the environmental compliance training of onsite personnel;

3) the start of construction; and

4) the start and completion of restoration.

8. Cameron LNG shall employ at least one EI for the Terminal Expansion and Cameron 

Interstate shall employ at least one EI per construction spread. Each EI shall be:

a. responsible for monitoring and ensuring compliance with all mitigation measures 

required by the Order and other grants, permits, certificates, or authorizing 

documents;

b. responsible for evaluating the construction contractor’s implementation of the 

environmental mitigation measures required in the contract (see condition 7

above) and any other authorizing document;
Conclusions And Recommendations 5-18

c. empowered to order correction of acts that violate the environmental conditions of 

the Order, and any other authorizing document;

d. a full-time position separate from all other activity inspectors;

e. responsible for documenting compliance with the environmental conditions of the 

Order, as well as any environmental conditions/permit requirements imposed by 

other federal, state, or local agencies; and

f. responsible for maintaining status reports.

9. Beginning with the filing of its Implementation Plan, Cameron LNG and Cameron 

Interstate shall each file updated status reports on a monthly basis for the Terminal 

Expansion and a weekly basis for the Pipeline Expansion until all construction and 

restoration activities are complete. On request, these status reports will also be provided 

to other federal and state agencies with permitting responsibilities. Status reports shall 

include:

a. an update on Cameron LNG’s and Cameron Interstate’s efforts to obtain the 

necessary federal authorizations;

b. the construction status at the Terminal Expansion site and of each spread of the 

Pipeline Expansion, work planned for the following reporting period, and any 

schedule changes for stream crossings or work in other environmentally sensitive 

areas;

c. a listing of all problems encountered and each instance of noncompliance 

observed by each EI during the reporting period (both for the conditions imposed 

by the Commission and any environmental conditions/permit requirements 

imposed by other federal, state, or local agencies);

d. a description of the corrective actions implemented in response to all instances of 

noncompliance, and their cost;

e. the effectiveness of all corrective actions implemented;

f. a description of any landowner/resident complaints which may relate to 

compliance with the requirements of the Order, and the measures taken to satisfy 

their concerns; and

g. copies of any correspondence received by Cameron LNG or Cameron Interstate

from other federal, state or local permitting agencies concerning instances of 

noncompliance, and Cameron LNG’s or Cameron Interstate’s response.

10. Prior to receiving written authorization from the Director of OEP to commence 

construction of any Project facilities, Cameron LNG and Cameron Interstate shall file 

with the Secretary documentation that each has received all applicable authorizations 

required under federal law (or evidence of waiver thereof).
5-19 Conclusions And Recommendations

11. Cameron LNG must receive written authorization from the Director of OEP prior to 

introducing hazardous fluids into the Terminal Expansion facilities. Instrumentation 

and controls, hazard detection, hazard control, and security components/systems 

necessary for the safe introduction of such fluids shall be installed and functional.

12. Cameron LNG must receive written authorization from the Director of OEP before 

placing the Terminal Expansion facilities into service. Such authorization will only be 

granted following a determination that the facilities have been constructed in accordance 

with FERC approval and applicable standards, can be expected to operate safely as 

designed, and the rehabilitation and restoration of the areas affected by the Terminal 

Expansion are proceeding satisfactorily.

13. Cameron Interstate must receive written authorization from the Director of OEP before 

placing the Pipeline Expansion into service. Such authorization will only be granted 

following a determination that rehabilitation and restoration of the right-of-way and other 

areas affected by the Pipeline Expansion Project are proceeding satisfactorily. 

14. Within 30 days of placing the Authorized and Certificated facilities in service, 

Cameron LNG and Cameron Interstate shall each file an affirmative statement with the 

Secretary, certified by a senior company official:

a. that the facilities have been constructed in compliance with all applicable 

conditions, and that continuing activities will be consistent with all applicable 

conditions; or

b. identifying which of the authorization or Certificate conditions Cameron LNG 

and Cameron Interstate has complied with or will comply with. This statement 

shall also identify any areas affected by the Project where compliance measures 

were not properly implemented, if not previously identified in filed status reports, 

and the reason for noncompliance.

15. Cameron LNG shall 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 foundation designs;

c. seismic specifications used in conjunction with procuring equipment; and

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

In addition, Cameron LNG shall file, in its Implementation Plan, the schedule for 

producing this information. (section 4.1.3.2) 

16. Prior to construction, Cameron Interstate shall complete wetland surveys of the rightof-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. (section 4.4.5)
Conclusions And Recommendations 5-20

17. Prior to construction, Cameron Interstate shall file with the Secretary for review and 

written approval by the Director of OEP, revised photo-alignment 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 (section 4.4.5.2); and the proposed extension of the HDD crossing 

of Beckwith Creek to avoid the saline pine savannah that is east of Beckwith Creek, as 

required by Condition 5 above (section 4.7.2.1).

18. Prior to construction, Cameron shall file revised Environmental Plans with the 

Secretary for review and written approval by the Director of OEP that include measures 

to prevent the transport and spread of invasive aquatic weeds and animals. Cameron 

should then submit the FERC-approved plan to the LDFW. (section 4.6.2.1)

19. Prior to construction, Cameron Interstate shall 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 shall ensure that the FERC 

staff receives the updated survey report for the red-cockaded woodpecker within 1 year

of the construction start date, as well as any comments received from the FWS regarding 

impacts on this species. (section 4.7.1.2) 

20. Prior to construction, Cameron LNG shall 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 USDOT’s LOS. If the traffic 

study indicates a USDOT LOS of D or worse, Cameron LNG shall implement 

additional mitigation measures to reduce traffic impacts. (section 4.9.6.1)

21. Cameron Interstate shall file, in the weekly construction status reports, the following

information 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. (section 4.11.2.2)

22. Cameron LNG shall 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 
5-21 Conclusions And Recommendations

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 shall 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 shall 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. (section 4.11.2.3)

23. Cameron LNG shall 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 shall 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 shall file a report on what changes are 

needed and shall install the additional noise controls to meet the level within 1 year of 

the in-service date. Cameron LNG shall 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. (section 4.11.2.3)

24. Cameron Interstate shall 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 shall 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 shall:

a. file a report with the Secretary, for review and written approval by the Director of 

OEP, on what changes are needed;

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. (section 

4.11.2.3)

25. Prior to construction of the final design, Cameron LNG shall 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. (section 4.12.3)

Recommendations 26 through 73 shall apply to the Cameron LNG Terminal Expansion. 

Information pertaining to these specific recommendations shall 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 
Conclusions And Recommendations 5-22

condition. Specific engineering, vulnerability, or detailed design information meeting the criteria 

specified in Order No. 683 (Docket No. RM06-24-000), including security information, shall be 

submitted as critical energy infrastructure information (CEII) 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, will be subject to public disclosure. All information shall be 

filed a minimum of 30 days before approval to proceed is requested. (section 4.12.3)

26. Prior to initial site preparation, Cameron LNG shall 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. (section 4.12.5.3)

27. Prior to initial site preparation, Cameron LNG shall provide procedures for controlling 

access during construction. (section 4.12.3)

28. Prior to initial site preparation, Cameron LNG shall file the quality assurance and 

quality control procedures for construction activities. (section 4.12.3)

29. Prior to initial site preparation, Cameron LNG shall file a plot plan of the final design 

showing all major equipment, structures, buildings, and impoundment systems. (section 

4.12.3)

30. Cameron LNG shall update its ERP to include the Terminal Expansion facilities as well 

as instructions to handle on-site refrigerant and NGL-related emergencies. Cameron shall 

file the ERP with the Secretary for review and written approval by the Director of the 

OEP prior to initial site preparation. ( section 4.12.6)

31. The ERP shall 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 shall include funding mechanisms for the 

capital costs associated with any necessary security/emergency management equipment 

and personnel base. Cameron LNG shall file the Cost Sharing Plan for review and 

written approval by the Director of OEP prior to initial site preparation. (section 

4.12.6)

32. The final design shall 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 shall be provided and all 

changes shall be clearly indicated on all diagrams and drawings. (section 4.12.3)

33. The final design shall provide up-to-date Process Flow Diagrams with heat and material 

balances and P&IDs, which include the following information: 

a. equipment tag number, name, size, duty, capacity, and design conditions; 

b. equipment insulation type and thickness; 
5-23 Conclusions And Recommendations

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. (section 4.12.3)

34. The final design shall 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. (section 4.12.3)

35. The final design shall provide an up-to-date complete equipment list, process and 

mechanical data sheets, and specifications. (section 4.12.3)

36. The final design shall provide complete plan drawings and a list of the hazard detection 

equipment. The drawings shall clearly show the location and elevation of all detection 

equipment. The list shall include the instrument tag number, type and location, alarm 

locations, and shutdown functions of the proposed hazard detection equipment. (section 

4.12.3) 

37. The final design shall provide complete plan drawings and a list of the fixed and 

wheeled dry-chemical, hand-held fire extinguishers, and other hazard control equipment. 

Drawings shall clearly show the location by tag number of all fixed, wheeled, and handheld extinguishers. The list shall include the equipment tag number, type, capacity, 

equipment covered, and automatic and manual remote signals initiating discharge of the 

units. (section 4.12.3)

38. The final design shall provide facility plans and drawings that show the location of the 

firewater and foam systems. Drawings shall clearly show: firewater and foam piping; 

post indicator valves; and the location of and area covered by each monitor, hydrant, 

deluge system, foam system, water-mist system, and sprinkler. The drawings shall also 

include piping and instrumentation diagrams of the firewater and foam system. (section 

4.12.3)

39. The final design shall include an updated fire protection evaluation of the proposed 

facilities carried out in accordance with the requirements of NFPA 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 shall be filed. (section 4.12.3)

40. The final design shall ensure that the LNG storage tank piping supports are adequately 

designed for the higher rated in-tank pump flow rates. (section 4.12.3)
Conclusions And Recommendations 5-24

41. The final design shall 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. (section 4.12.3)

42. The final design shall specify that for hazardous fluids, the piping, and piping nipples 2 

inches or less are to be no less than Schedule 160. (section 4.12.3) 

43. The final design of the electrical purge seal arrangement shall 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. (section 4.12.3)

44. The final design shall 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. (section 4.12.3)

45. The final design shall provide electrical area classification drawings. (section 4.12.3)

46. The final design shall provide spill containment system drawings with dimensions and 

slopes of curbing, trenches, and impoundments. (section 4.12.3)

47. The final design of the hazard detectors shall account for the calibration gas when 

determining the LFL set points for methane, propane, and ethylene, and condensate. 

(section 4.12.3)

48. The final design shall provide pressure relieving protection for flammable liquid piping 

segments (i.e., refrigerants, liquid hydrocarbons, condensate products) that can be 

isolated by valves. (section 4.12.3)

49. The final design shall specify that the pressure of the shell side of Inlet Gas Preheater, 

H1-1001, shall not exceed the allowable operating pressure during pressure relief 

conditions, and the relieving device shall discharge to a safe location. (section 4.12.3)

50. The final design shall 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-DTSH0035. (section 4.12.3)

51. The final design shall specify that the C5+ Condensate Storage Tank fill connection is 

located above the maximum liquid level. (section 4.12.3)

52. The final design shall address the potential for reverse flow through the Molecular Sieve 

Driers in the event that emergency vent valve XV1-10128 opens. (section 4.12.3)

53. The final design shall 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, shall be filed. (section 

4.12.3)

54. The final design shall include the cause-and-effect matrices for the process 

instrumentation, fire and gas detection system, and emergency shutdown system. The 
5-25 Conclusions And Recommendations

cause-and-effect matrices shall include alarms and shutdown functions, details of the 

voting and shutdown logic, and setpoints. (section 4.12.3)

55. The final design shall include a drawing showing the location of the emergency 

shutdown (ESD) buttons. ESD buttons shall be easily accessible, conspicuously labeled,

and located in an area which would be accessible during an emergency. (section 4.12.3)

56. The final design shall include a pressure survey of the anticipated operating and design 

conditions for the wet and dry flares. The survey shall include a report showing the 

stream analysis, flow rates, temperatures, and operating pressures from the relief 

discharge to the flare inlet. (section 4.12.3)

57. The final design shall include a plan for clean-out, dry-out, purging, and tightness 

testing. This plan shall address the requirements of the American Gas Association’s 

Purging Principles and Practice required by 49 CFR 193, and shall provide justification if 

not using an inert or non-flammable gas for cleanout, dry-out, purging, and tightness 

testing. (section 4.12.3) 

58. The final design shall include the sizing basis and capacity for the final design of 

pressure and vacuum relief valves for major process equipment, vessels, and storage 

tanks. (section 4.12.3)

59. The final design shall provide the procedures for pressure/leak tests which address the 

requirements of ASME VIII and ASME B31.3, as required by 49 CFR 193. (section 

4.12.3)

60. The final design shall include certification that any modifications are 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 shall consult with DOT on any actions 

necessary to comply with Part 193. (section 4.12.5.2)

61. The final design shall include details 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 shall be filed a minimum of 30 days before approval to 

proceed is requested. (section 4.12.5.3)

62. The final design shall include details of the impingement shrouds as well as procedures 

to maintain and inspect the impingement shrouds. This information shall be filed a 

minimum of 30 days before approval to proceed is requested. (section 4.12.5.3)

63. Prior to commissioning, Cameron LNG shall 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. (section 

4.12.3)

64. Prior to commissioning, Cameron LNG shall provide a detailed schedule for 

commissioning through equipment startup. The schedule shall include milestones for all 
Conclusions And Recommendations 5-26

procedures and tests to be completed: prior to introduction of hazardous fluids; and 

during commissioning and startup. Cameron LNG shall file documentation certifying 

that each of these milestones has been completed before authorization to commence the 

next phase of commissioning and startup will be issued. (section 4.12.3)

65. Prior to commissioning, Cameron LNG shall provide results of the LNG storage tank 

hydrostatic test and foundation settlement results. (section 4.12.3)

66. Prior to commissioning, Cameron LNG shall tag all equipment, instrumentation, and 

valves in the field, including drain valves, vent valves, main valves, and car-sealed or 

locked valves. (section 4.12.3)

67. Prior to commissioning, Cameron LNG shall file a tabulated list and drawings of the 

proposed hand-held fire extinguishers. The list shall include the equipment tag number, 

extinguishing agent type, capacity, number, and location. The drawings shall show the 

extinguishing agent type, capacity, and tag number of all hand-held fire extinguishers.

(section 4.12.3)

68. Prior to commissioning, Cameron LNG shall file updates addressing the Terminal 

Expansion facilities in the operation and maintenance procedures and manuals, as well as 

safety procedures. (section 4.12.3)

69. Prior to commissioning, Cameron LNG shall maintain a detailed training log to 

demonstrate that operating staff has completed the required training. (section 4.12.3)

70. Prior to introduction of hazardous fluids, Cameron LNG shall complete a firewater 

pump acceptance test and firewater monitor and hydrant coverage test. The actual 

coverage area from each monitor and hydrant shall be shown on facility plot plan(s).

(section 4.12.3)

71. Prior to introduction of hazardous fluids, Cameron LNG shall 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. (section 4.12.3)

72. Prior to commencement of service, Cameron LNG shall label piping with fluid service 

and direction of flow in the field in addition to the pipe labeling requirements of NFPA 

59A. (section 4.12.3)

73. Prior to commencement of service, progress on the construction of the proposed 

systems shall be reported in monthly reports filed with the Secretary. Details shall

include a summary of activities, problems encountered, contractor 

nonconformance/deficiency logs, remedial actions taken, and current Project schedule. 

Problems of significant magnitude shall be reported to the FERC within 24 hours.

(section 4.12.3)

In addition, recommendations 74 through 76 shall apply throughout the life of the Terminal 

Expansion facility:
5-27 Conclusions And Recommendations

74. The facility shall 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 shall 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, 

shall be submitted. (section 4.12.3)

75. Semi-annual operational reports shall 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 shall 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, non-scheduled maintenance or repair (and 

reasons therefore), relative movement of storage tank inner vessels, hazardous fluids 

releases, fires involving, negative pressure (vacuum) within a storage tank and higher 

than predicted boil-off rates. Adverse weather conditions and the effect on the facility 

also shall be reported. Reports shall 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 shall 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. (section 4.12.3)

76. Significant non-scheduled events, including safety-related incidents (e.g., hazardous 

fluids releases, fires, explosions, mechanical failures, unusual over pressurization, and 

major injuries) and security-related incidents (e.g., attempts to enter site, suspicious 

activities) shall 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 shall be made immediately, without unduly 

interfering with any necessary or appropriate emergency repair, alarm, or other 

emergency procedure. In all instances, notification shall be made to the FERC staff 

within 24 hours. This notification practice shall be incorporated into the LNG facility's 

emergency plan. Examples of reportable LNG, NGL, condensate, or refrigerant related 

incidents include:

a. fire; 

b. explosion;

c. estimated property damage of $50,000 or more;
Conclusions And Recommendations 5-28

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 follow-up report or follow-up in the upcoming semi-annual 

operational report. All company follow-up reports shall include investigation results and 

recommendations to minimize a reoccurrence of the incident. (section 4.12.3)