1.0 – Introduction 1-1

1.0 INTRODUCTION 

1.1 PROJECT SUMMARY 

On September 4, 2007, Jordan Cove Energy Project, L.P. (Jordan Cove) and Pacific Connector 

Gas Pipeline, L.P. (Pacific Connector)1 filed applications with the Federal Energy Regulatory 

Commission (FERC or Commission) under sections 3 and 7 of the Natural Gas Act (NGA). The 

applications were noticed in the Federal Register on September 13, 2007. In Docket No. CP07-

444-000 Jordan Cove seeks authorization to construct and operate a new liquefied natural gas 

(LNG) import terminal on the east side of the North Spit of Coos Bay, in Coos County, Oregon. 

In Docket No. CP07-441-000 Pacific Connector seeks a Certificate of Public Convenience and 

Necessity (Certificate) to construct and operate a new 36-inch-diameter natural gas sendout 

pipeline extending from Jordan Cove’s proposed LNG terminal southeast for about 234 miles 

through Coos, Douglas, Jackson, and Klamath Counties, Oregon. Hereafter in this 

environmental impact statement (EIS), Jordan Cove and Pacific Connector are also referred to as 

the applicants, and their inter-related proposals are collectively referred to as the Jordan Cove 

Energy and Pacific Connector Gas Pipeline (JCE & PCGP) Project, or the Project. 

In Docket Nos. CP07-442-000, and CP07-443-000, Pacific Connector also applied for a blanket 

certificate under Part 157, subpart F of the Commission’s regulations and requested issuance of a 

blanket certificate under Subpart G of Part 284, respectively. According to the FERC’s 

regulations at Title 18 Code of Federal Regulations (CFR) Part 380.4, these requests for blanket 

authorities are categorically excluded from environmental review. The currently unknown and 

unspecified future actions that may take place under the blanket certificate issued under Part 157 

that may result in ground disturbance or changes in operational air or noise emissions, reported 

to the Commission by the applicants as prior notices or annual reports, would be subject to 

individual environmental reviews in accordance with Part 157.206 of the FERC regulations. 

The FERC is the federal agency responsible for authorizing onshore LNG terminals and 

interstate natural gas transmission facilities, as specified in section 311(e)(1) of the Energy 

Policy Act of 2005 (EPAct) and the NGA. For the JCE & PCGP Project, in accordance with 

section 313(b)(1) of the EPAct, the FERC is the lead federal agency for the coordination of all 

applicable federal authorizations, and is also the lead federal agency for preparation of this EIS 

in compliance with the requirements of the National Environmental Policy Act of 1969 (NEPA), 

as outlined in the Council on Environmental Quality (CEQ) regulations for implementing the 

NEPA (40 CFR Parts 1500-1508), and the FERC’s regulations (18 CFR Part 380). 

The United States (U.S.) Department of Agriculture Forest Service (USFS), U.S. Army Corps of 

Engineers (COE), U.S. Environmental Protection Agency (EPA), U.S. Department of Homeland 

Security Coast Guard (Coast Guard), U.S. Department of the Interior Bureau of Land 

Management (BLM), Bureau of Reclamation (BOR) and Fish and Wildlife Service (FWS), the 

Pipeline and Hazardous Materials Safety Administration (PHMSA) within the U.S. Department 

of Transportation (DOT), and Douglas County, Oregon, are cooperating agencies for the 

 

1

 Jordan Cove is a limited partnership, formed under the laws of Delaware, whose main stockholders are Fort Chicago LNG II, 

L.P. and Energy Projects Development L.L.C. Pacific Connector is also a limited partnership, formed in Delaware. Its main 

stockholders are Williams Pacific Connector Gas Pipeline, LLC, a subsidiary or Williams Gas Pipeline Company, LLC; PG&E 

Strategic Capital, Inc., a subsidiary of PG&E Corporation; and Fort Chicago LNG II, L.P., a subsidiary Fort Chicago Energy 

Partners L.P. 
1-2 1.0 – Introduction

development of this EIS. A cooperating agency has jurisdiction by law or special expertise with 

respect to environmental impacts involved with the proposal, and is involved in the NEPA 

analysis. The U.S. Department of Agriculture, Department of the Army, Department of the 

Interior, EPA, and DOT are cooperating in a manner consistent with an interagency agreement 

with the FERC regarding early coordination of required environmental and historic preservation 

reviews signed in May 2002. The DOT is participating in the NEPA analysis under the terms of 

an interagency agreement between the PHMSA, the FERC, and the Coast Guard, issued 

February 11, 2004. 

The Coast Guard is a cooperating agency to the FERC, serving as a subject matter expert for, and 

providing recommendations on the maritime safety and security aspects of the Project. The 

Coast Guard does not issue a permit, license or order in this context, and is responsible for 

assessing the suitability of the waterway and issuing a Letter of Recommendation (LOR) (see 

section 1.5.2.1). That LOR may be considered by the FERC (as the siting authority), the COE, 

or state and local authorities that have jurisdiction, to assist with their decisions concerning 

approval of the Project. The COE has authority to issue dredging and wetland permits for the 

Project under the Rivers and Harbors Act (RHA) and Clean Water Act (CWA) (see section 

1.5.2.2). The EPA has responsibilities under the Clean Air Act (CAA) and CWA (see sections 

1.5.1.7 and 1.5.2.3). The DOT has authority to enforce safety regulations and standards for the 

LNG terminal beginning at the last valve immediately before the storage tanks, and the design 

and operation of the Pacific Connector pipeline (see section 4.12.10). 

On April 17, 2006, the BLM Oregon State Office received a right-of-way application from 

Pacific Connector under section 28 of the Mineral Leasing Act of 1920 (MLA), as amended (30 

United States Code [USC] 185) for authorization to construct, operate, maintain, and terminate 

the Pacific Connector pipeline where it crosses federal lands. Federal lands are defined as “all 

lands owned by the United States except lands in the National Park System, lands held in trust 

for an Indian or Indian Tribe, and lands on the Outer Continental Shelf.” The BLM, BOR, and 

USFS are federal agencies that administer lands that would be crossed by portions of the Pacific 

Connector pipeline (see section 1.5.2.4). Section 28(c)(2) of the MLA states that “[w]here the 

surface of the Federal lands involved is administered by the Secretary [of the Interior] or by two 

or more Federal agencies, the Secretary is authorized, after consultation with the agencies 

involved, to grant or renew rights-of-way or permits through the Federal lands involved.” The 

Secretary of the Interior has delegated this authority to the Director of the BLM who has further 

delegated authority to the BLM Oregon State Director. On May 5, 2006, the BLM Oregon State 

Director accepted Pacific Connector’s application and established a cost-reimbursement 

agreement under the regulations in 43 CFR Part 2880. 

All actions on the federal lands proposed in Pacific Connector’s application must comply with 

the respective Land and Resource Management Plans (LRMP) of the affected federal land 

management agencies. In implementing the NEPA process to assess the proposed action on 

federal lands, this EIS is tiered by reference to these management plans, as amended by the 

Northwest Forest Plan (NWFP) and the December 2008 Western Oregon Plan Revisions 

A “Rev Bar” or vertical line in the margin identifies text that has been modified in this 

final EIS and differs substantially from the corresponding text in the draft EIS. 
1.0 – Introduction 1-3 

(WOPR).2 Because the BLM, BOR, and USFS must comply with the requirements of the 

NEPA, their respective local LRMPs, authorizing legislation, regulations, policies, and 

procedures before granting or consenting to a right-of-way across lands under their 

administration, these agencies have elected to act as cooperating agencies in the preparation of 

the EIS. The USFS has indicated that it may need to amend the existing Umpqua, Rouge River, 

and Winema National Forest LRMPs prior to issuance of a Right-of-Way Grant by the BLM. 

The BLM has indicated that the Project may be consistent with the December 2008 Resource 

Management Plans (RMPs) for the Coos Bay, Roseburg, and Medford Districts and the Klamath 

Falls Resource Area, and that amendments to these plans may not be necessary. The EIS 

examines the impacts of construction and operation of the proposed action and alternatives. The 

USFS will analyze the significance of any proposed Forest Plan amendments as related to the 

respective National Forest LRMPs in a separate (or supplementary) NEPA process. The USFS 

will not independently analyze environmental impacts resulting from construction and operation 

of the Pacific Connector pipeline, as those impacts are already addressed in this final EIS. 

Douglas County would be crossed by the Pacific Connector pipeline, between mileposts (MP) 

45.5 and 109.6, and its Land Department has chosen to be a cooperating agency in the 

preparation of the EIS. However, the Douglas County Board of Commissioners have passed a 

resolution recommending that the pipeline should not be constructed unless and until Pacific 

Connector negotiates with all affected landowners and all landowner concerns are addressed to 

their satisfaction. 

The proposed action analyzed in this EIS includes the activities outlined in Jordan Cove’s and 

Pacific Connector’s applications to the FERC. The FERC and all of the cooperating agencies 

must consider the potential environmental impacts of the applicants’ proposals as disclosed in 

this EIS prior to making their decisions. 

The facilities associated with Jordan Cove’s proposed LNG import terminal include: 

• access channel dredged between the existing Coos Bay navigation channel and the LNG 

unloading slip; 

• LNG carrier unloading slip excavated from an upland adjacent to Coos Bay; 

• LNG unloading system at the berth, consisting of three 16-inch-diameter unloading arms 

and one 16-inch-diameter vapor return arm, with a maximum unloading capacity rate of 

12,000 cubic meters per hour (m3

/hr); 

• LNG transfer system from the berth to the storage tanks, consisting of one 2,600-footlong, 36-inch-diameter cryogenic unloading line; 

• LNG storage system, consisting of two full-containment LNG storage tanks, each with a 

capacity 160,000 m3

 (1,006,000 barrels). Each tank would be equipped with two fully 

submerged LNG in-tank pumps with an individual capacity rate of 5,300 gallons per 

minute (gpm); 

• boil-off gas (BOG) recovery system, consisting of three cryogenic centrifugal BOG 

compressors, each with a rated capacity of 2,300 cubic feet per minute (ft3

/min), and two 

non-cryogenic reciprocating BOG pipeline compressors with an individual capacity rated 

at 2,500 ft3

/min; 

 

2

 The BLM used the WOPR process to issue six individual Records of Decision (ROD) and revise six Resource 

Management Plans (RMP) concurrently for the Districts addressed in southern Oregon. 
1-4 1.0 – Introduction

• LNG transfer system from the storage tanks to the vaporizers, consisting of six LNG 

booster pumps each sized for 2,200 gpm; 

• LNG vaporizer system, consisting of six submerged combustion vaporizers each sized for 

200 million standard cubic feet per day (Mscfd); 

• natural gas liquids (NGL) extraction facility, with the NGL to be sold to another entity; 

• 37-megawatt, natural gas fired, simple-cycle combustion turbine powerplant to provide 

electric power for the LNG terminal; 

• waste heat recovery system; 

• emergency vent system, LNG spill containment system, firewater system, utility system, 

hazard detection system, and control system; 

• associated buildings and support facilities; and 

• metering facilities. 

The proposed onshore facilities at the LNG terminal would be built on currently vacant land, of 

which 149 acres is owned or controlled by the Oregon International Port of Coos Bay (Port), and 

10 acres is owned by Roseburg Forest Products (Roseburg). Jordan Cove has agreements with 

both the Port and Roseburg for the future lease and purchase of this property.3

The Port would obtain the necessary permits and construct the access channel to the LNG 

terminal slip within Coos Bay, and would obtain permits for, and construct and own the slip at 

the terminal. Construction of the slip would convert about 41 acres of current uplands above the 

mean higher high water line (MHHW) on the North Spit to waterway in the bay, through the 

removal of about 4.25 million cubic yards (mcy) of material. The material dredged or excavated 

to create the access channel and slip would be transported to three proposed storage areas: at the 

Jordan Cove Storage Site, Weyerhaeuser Linerboard Sites, and Port Sand Storage Site. 

Jordan Cove would lease the eastern berth at the slip from the Port, and would construct its LNG 

carrier unloading facilities there. The western berth was originally intended for general cargo 

use; however, the Port has no committed plans now to develop the western cargo berth. 

Therefore, no facilities are proposed at this time for the western side of the slip. Jordan Cove 

would be the anchor tenant for the slip and its agreement with the Port is structured around 

accommodating the requirements of the LNG terminal. Any development of the cargo berth by 

the Port would have to conform to the priorities of Jordan Cove’s terminal and the unloading of 

LNG carriers. The LNG terminal and slip were designed on the basis that the thermal and vapor 

exclusion zones would not constrain the use of the western berth by other commercial ships, in 

the event that the Port secures a tenant and further develops plans for the cargo berth (see further 

discussion in section 4.12.4 of this EIS). A tug boat berth would be constructed on the north side 

of the slip. 

As part of our4 environmental analysis of Jordan Cove’s proposed LNG import terminal, this EIS 

considers the potential impacts resulting from the Port’s dredging of the access channel within 

Coos Bay, the excavation of the slip from current uplands, the disposal of dredged and excavated 

materials, and construction and operation of the slip. These impacts are considered part of the 

proposed action and are included in the environmental impact analysis where appropriate in 

 

3

 In June 2006, the Port finalized a property purchase agreement to acquire 1,300 acres on the North Spit of Coos Bay from the 

Weyerhaeuser Company. That same month the Port and Jordan Cove signed an Option to Purchase and Lease. The public may 

view these agreements through the Port’s Internet Web Page at www.portofcoosbay.com. 4

 The pronouns “we,” “us,” and “our” refer to the environmental staff of the FERC’s Office of Energy Projects (OEP). 
1.0 – Introduction 1-5 

Section 4. In addition, the EIS addresses the potential environmental impacts associated with 

temporary storage and staging areas that would be used during construction of the proposed LNG 

terminal, and temporary and permanent access roads associated with the facility, including haul 

roads to the dredged disposal areas, and slurry pipelines to dredge material storage areas. This 

EIS also addresses potential environmental impacts associated with LNG marine traffic along the 

waterway to the LNG import terminal. 

The natural gas sendout pipeline facilities proposed by Pacific Connector would include: 

• 234-mile-long, 36-inch-diameter welded steel underground natural gas pipeline (Pacific 

Connector pipeline), with a maximum allowable operating pressure (MAOP) of 1,440 

pounds per square inch (psig); 

• natural gas compressor station (Butte Falls Compressor Station), at about MP 132.1 along 

the route of the Pacific Connector pipeline, in Jackson County, Oregon, consisting of 

two new 10,310-horsepower (hp) compressor units; 

• four natural gas meter stations, including the Jordan Cove Receipt Meter Station at MP 

0.0 in Coos County; the Clarks Branch Delivery Meter Station at about MP 69.7 in 

Douglas County; the Shady Cove Delivery Meter Station at about MP 122.1 in Jackson 

County; and the Tule Lake, Russell Canyon, and Buck Butte Meter Stations at MP 230.95

in Klamath County; 

• gas control communication system, consisting of new radio towers at each meter station 

and the compressor station, use of an existing communication site owned by Northwest 

Pipeline GP (Williams Northwest)6, and leased space on seven other existing 

communication towers; 

• mainline block valves (MLV) at approximately 16 locations along the Pacific Connector 

pipeline; and 

• five pig7 launchers and receivers, four co-located with meter stations and the compressor 

station, and the fifth co-located with a MLV. 

The general location of facilities proposed by Jordan Cove and Pacific Connector are shown on 

figure 1-1. The proposed facilities are more fully described in section 2.1 of this EIS. 

The Pacific Connector pipeline would begin at an interconnection with Jordan Cove’s facilities 

at the Jordan Cove Receipt Meter Station within the LNG terminal tract. The pipeline would 

terminate near the California border, east of Malin, Oregon, with interconnections with the 

existing natural gas systems of Gas Transmission Northwest Corporation (GTN) at the Buck 

Butte Delivery Meter Station, with Tuscarora Gas Transmission Company (Tuscarora) at the 

Russell Canyon Delivery Meter Station, and with Pacific Gas and Electric Company (PG&E) at 

the Tule Lake Delivery Meter Station. In between, the Pacific Connector pipeline would deliver 

natural gas to the existing Williams Northwest Grants Pass Lateral interstate pipeline at the 

Clarks Branch Delivery Meter Station and deliver gas to Avista Corporation (Avista) at the 

Shady Cove Delivery Meter Station. Avista is a local distribution company (LDC) that is not 

 

5

 Although the total pipeline length is about 234.2 miles, the pipeline ends at MP 230.9 due to numerous pipeline reroutes made 

after mileposts were assigned. Pacific Connector attempted to maintain continuity of original mileposts and accounted for 

reroutes using milepost equations rather than changing mileposts along the entire route. 6

 In 2008 Northwest Pipeline Corporation was converted into a Master Limited Partnership known as Northwest Pipeline GP, 

with a subsidiary of the Williams Companies, Inc., being majority owner and serving as General Partner. 7

 A “pig” is a tool for cleaning and inspecting the inside of a pipeline. 
1-6 1.0 – Introduction

Figure 1-1. General Location Map of Proposed Facilities 
1.0 – Introduction 1-7 

regulated by the FERC.8 Facilities that might be constructed by Avista would be nonjurisdictional; however, this EIS also addresses non-jurisdictional facilities identified as 

associated with the JCE & PCGP Project (see section 2.2). 

This EIS also addresses the potential environmental impacts associated with the use of temporary 

storage and staging areas, temporary extra work space areas (TEWAs), and temporary uncleared 

storage areas (UCSAs) during construction of the pipeline, and temporary and permanent roads 

to serve as access to the right-of-way. 

The proposed Pacific Connector pipeline would cross private and public lands (see section 4.7). 

Pacific Connector would negotiate to acquire easements from private, local, county, and state 

landowners. If agreements cannot be reached, Pacific Connector could use the power of eminent 

domain under section 7h of the NGA, if the FERC issues a Certificate for the pipeline. However, 

a Certificate would not allow the use of eminent domain for federal or tribal lands. Pacific 

Connector must obtain a Right-of-Way Grant from the BLM to cross federal lands and reach an 

agreement with Indian tribes to cross tribal lands. 

1.2 ENVIRONMENTAL SETTING 

Jordan Cove’s proposed LNG terminal would be located in Coos County, Oregon, on the bay 

side of the North Spit of Coos Bay. LNG carriers would access the terminal through a waterway 

for LNG marine traffic, which is defined by the Coast Guard for this Project as extending from 

the outer limits of the U.S. territorial waters 12 nautical miles off the coast of Oregon, and up the 

Coos Bay navigation channel about 7.5 miles to the proposed terminal. 

The Pacific Connector pipeline would begin at the proposed LNG terminal, and proceed 

generally southeast for about 234 miles across portions of Coos, Douglas, Jackson, and Klamath 

Counties, to its end point near Malin, at the Oregon-California border. The pipeline would cross 

the Coast Range and the Camas Valley, the Klamath Mountains and Cascade Range, and then 

the Klamath Basin. Detailed descriptions of environmental resources potentially affected by the 

proposed Project are included in the respective sections of chapter 4 of this EIS. 

1.3 PURPOSE AND NEED 

The purpose for the Project, as summarized below, is defined by Jordan Cove and Pacific 

Connector. Need is not an environmental issue to be addressed at length in this document. The 

Commission will more fully consider the need for the JCE & PCGP Project when making its 

decision on whether the Project is consistent with the public interest in meeting the projected 

energy demands of the region. The FERC will use the EIS as an element in its review of Jordan 

Cove’s and Pacific Connector’s applications. After this final EIS is released, the Commission 

will determine whether the Project should be authorized. A final approval will only be granted 

if, after a consideration of both environmental and non-environmental issues related to markets 

and rates, the Commission finds that the proposed Project is in the public interest. The EIS and 

mitigation development discussed herein will be important factors in this final determination. 

This EIS includes a short discussion of the Project purpose and need to satisfy the requirements 

of the CEQ regulations for implementing the NEPA, which state that an EIS should only “briefly 

 

8

 The Avista facilities would not be regulated by the FERC, but, as interstate natural gas LDC, it would be regulated by the State 

of Oregon, through the Oregon Public Utilities Commission. 
1-8 1.0 – Introduction

specify the underlying purpose and need” for a proposed project (40 CFR 1502.13). Most of the 

data cited below were derived from reports provided by the applicants, and sources in the public 

domain, including reports published by the U.S. Department of Energy, Energy Information 

Administration (EIA), reports by state energy agencies, industry information, and independent 

scholarly documents. We present new information about recent domestic gas exploration and 

supplies in response to comments on the draft EIS. 

Jordan Cove and Pacific Connector state in their applications that they developed their Project 

because of the perceived need for additional supplies of natural gas in the Pacific Northwest, 

northern California, and northern Nevada. As argued by the applicants, several studies have 

indicated that there will be increased demand for natural gas in these markets in the future, but 

supplies through existing interstate pipeline systems serving those regions are constrained by 

several factions and may not be able to meet those demands. When Pacific Connector conducted 

its open season to test the market for transportation of natural gas from the proposed Jordan Cove 

LNG import terminal, it was able to negotiate agreements with a number of shippers, 

underscoring the strong support for the product this Project could provide. 

Some of the main objectives of the JCE & PCGP Project are to: 

• provide a new access point for overseas LNG supplies through a new LNG import 

terminal located on the southern Oregon coast that can accommodate industry-standard 

LNG carriers; 

• provide a new source of natural gas to Pacific Northwest, northern California, and 

northern Nevada markets to diversify the supply sources for these markets to meet future 

demands; and 

• serve multiple markets through an interstate pipeline with interconnections with new and 

existing pipeline infrastructure. 

LNG is natural gas that has been cooled to about -260 degrees Fahrenheit (°F) for shipment and 

storage as a liquid. As a liquid, LNG is about 600 times more compact than its equivalent 

amount of natural gas vapors. LNG is typically produced in foreign countries with abundant 

natural gas reserves, and transported long distances across oceans using specially designed 

carriers. There are currently 15 LNG exporting nations that combined hold about 33 percent of 

the world’s natural gas reserves (EIA 2008a). 

Jordan Cove has not revealed its expected sources for the LNG, but most likely it would come 

from around the Pacific Basin, including current LNG exporting nations such as Australia, 

Malaysia, Indonesia, and Brunei, and future LNG exporting nations including Russia, Papua 

New Guinea, and Peru. In 2006, Trinidad and Tobago was the largest supplier of LNG for the 

existing import terminals operating on the East and Gulf coasts, accounting for about 67 percent 

of all LNG imported into the United States (EIA 2008a). At the Jordan Cove import terminal, 

the LNG would be stored and then vaporized back into natural gas for transportation by pipeline 

into the existing national grid. 

Pacific Connector held an open season that commenced on February 1, 2007 and closed on 

March 5, 2007. Seven shippers executed 10 Precedent Agreements totaling 1,490,000 

decatherms per day (Dth/d) of contract demand (equivalent to about 1.4 billion standard cubic 

feet per day [Bscfd]). The Precedent Agreements are binding subject to certain precedent 

conditions. 
1.0 – Introduction 1-9 

The JCE & PCGP Project is specifically designed to provide up to about 1.0 Bscfd of natural gas 

to the Pacific Northwest, northern California, and northern Nevada markets by: 

• delivering natural gas to the Williams Northwest pipeline system through an interconnect 

between the Pacific Connector pipeline and the existing Grants Pass Lateral near Myrtle 

Creek, Oregon; 

• delivering natural gas to the existing Avista system through an interconnect with the 

Pacific Connector pipeline near Shady Cove, Oregon; and 

• delivering natural gas to the existing GTN, Tuscarora, and PG&E pipeline systems 

through interconnects at the terminus of the Pacific Connector pipeline near Malin, 

Oregon. 

Williams Northwest, GTN, and Tuscarora are interstate natural gas transportation systems 

regulated by the FERC. Williams Companies, Inc. (Williams) is a majority owner of Williams 

Northwest. Both GTN and Tuscarora are subsidiaries of the TransCanada Corporation. 

Williams Northwest and GTN transport natural gas produced in western Canada and the Rocky 

Mountains to the Pacific Northwest. GTN provides Canadian and Rocky Mountain gas to 

northern Nevada and northern California through its interconnections with Tuscarora and PG&E 

at the Oregon/California border east of Malin, Oregon. Tuscarora mainly serves the Reno, 

Nevada area. PG&E serves markets mainly in northern and central California, and operates both 

interstate facilities regulated by the FERC, and LDC facilities regulated by the California Public 

Utilities Commission. Avista is an LDC that provides natural gas to residential and 

commercial/industrial customers in or near the communities of Roseburg, Grants Pass, Medford, 

and Ashland, Oregon. 

In 2007, total natural gas consumption in Washington and Oregon was estimated to average 

about 1.2 Bscfd (ICF International [ICF] 2007). The states of Washington and Oregon do not 

produce much natural gas,9

 and import nearly all their natural gas through the Williams 

Northwest and GTN systems. In total, these existing pipelines have a current transportation 

capacity of about 4.1 Bscfd as they enter the region (from Canada and Idaho), with about 2.2 

Bscfd in capacity targeted for the California market. The Williams Northwest system can 

receive up to about 1.3 Bscfd from its interconnection with Westcoast Energy at Sumas, 

Washington. Its mainline pipeline coming from the north to Vancouver, Washington has a 

capacity of 630 mcfd. Coming west into Oregon from Caldwell, Idaho the system has a capacity 

of about 480 mcfd. Between its interconnection with GTN near Stanfield, Oregon and 

Vancouver, Washington the system has a capacity of 550 mcfd. The GTN system interconnects 

with TransCanada’s British Columbia system at Kingsgate, British Columbia; and with the 

Williams Northwest system at Spokane and Palouse, Washington and Stanfield, Oregon. The 

GTN system can transport more than 2.9 Bscfd, with about 1.0 Bscfd targeted for markets in the 

Pacific Northwest. In 2006 the states of Washington and Oregon combined imported about 

1,000 Bscf of natural gas, with 88 percent coming from Canada and 12 percent from the Rockies 

(ICF 2008b).10

In 2006, the entire state of Nevada consumed about 249,683 mcf of natural gas. However, that 

year only 5 mcf was produced from instate gas wells (EIA 2007b). There are two main interstate 

 

9

 Oregon has only 15 natural gas wells that produced 621 mcf in 2006, or about 0.2 percent of its consumption. 10 This report was filed with the FERC on November 17, 2008 by Jordan Cove in Docket No. CP07-444-000, and is available for 

viewing by the public through the FERC Internet website (www.ferc.gov) using the eLibrary feature. 
1-10 1.0 – Introduction

natural gas pipeline systems that serve northern Nevada: Paiute Pipeline Company (Paiute) and 

Tuscarora. Paiute, a subsidiary of Southwest Gas Corporation, receives natural gas from the 

Williams Northwest system at the Nevada/Idaho border near Owyhee, and from an 

interconnection with Tuscarora at Wadsworth Junction. The Paiute system serves the 

communities of Elko, Lovelock, Yearington, Fallon, Reno, Dayton, Carson City, Garnerville, 

and Lake Tahoe. Paiute provides natural gas to three LDCs: Sierra Pacific Power Company, 

Southwest-Northern Nevada, and Southwest-Northern California. Northern Nevada’s natural 

gas consumption is anticipated to grow an average of 4 percent per year over the next 10 years. 

It was estimated that in 2007, California produced about 143 mcfd of natural gas instate, or 

slightly more than 13 percent of its natural gas supplies. Its total consumption of natural gas in 

2006 was estimated to be about 2,292,056 mcf, or about 6,589 mcfd (EIA 2007b; California 

Energy Commission [CEC] 2006). There was about 9,130 mcfd of interstate pipeline capacity 

coming into California in 2006. PG&E held receipt capacity of 3,161 mcfd in 2006, with 2,021 

mcfd of that total coming into its existing Lines 400/401 from the interconnection with GTN 

(CEC 2007a). 

Energy demand in the United States will continue to rise steadily in the future, due to population 

growth and industrial needs. The EIA Annual Energy Outlook 2007 estimates that total energy 

consumption in the United States will increase from 100 quadrillion British thermal units (Btu) 

per year in 2005 to 125 quadrillion Btu per year in 2030, representing an annualized increase of 

1.1 percent. In 2006, natural gas represented 22 percent of the total energy used in the United 

States. More than half of all American homes are heated with natural gas, and it is the fuel of 

choice for about 41 percent of the nation’s industrial sector (James A. Baker III Institute for 

Public Policy [Baker Institute] 2008). According to the EIA, United States natural gas 

consumption is estimated to grow by 0.3 percent a year, and should increase from about 21.8 

trillion cubic feet (Tcf) per year in 2006 to 24.3 Tcf in 2016 (EIA 2007d). Modeling conducted 

by the Baker Institute of Rice University projected that natural gas demand in the United States 

should grow by about 1.3 percent a year for the next two decades. 

Part of the future demand for natural gas is driven by its increased use for electric power 

generation. Natural gas is the cleanest burning fossil fuel, and the electric generation industry is 

either retrofitting old plants from coal or oil, or building new gas fired power plants in response 

to air pollution requirements, or in anticipation of future government regulations to reduce 

greenhouse gases (GHG), including carbon emissions, to address climate change issues. 

Nationally, about 52 percent of all new power plants built since 1995 have been gas fired, and 

natural gas accounts for 90 percent of all new megawatts (MW) of electric power capacity 

installed over the last 12 years in the United States (Baker Institute 2008). In 2006, consumption 

of natural gas in the electric power sector totaled 6,222 Bscf, a 6 percent increase from the 

previous year; in spite of a slight decline in national industrial use at the same time. The overall 

picture for total natural gas consumption in 2006 in the United States showed that 33 percent was 

used for industrial purposes, 31 percent for electric generation, 22 percent for residential use, and 

14 percent by the commercial sector (EIA 2007b). The EIA (2008c) predicted that nationally the 

natural gas share of electricity generation would be about 22 percent in 2030. 

The CEC (2008) estimates that energy use in California should grow at a rate of about 1.25 

percent per year, with peak demand rising even faster, at 1.35 percent per year. California’s 

natural gas demand for all sectors combined is forecast to increase by about 1 percent annually, 
1.0 – Introduction 1-11 

while natural gas use by the electric power sector is expected to increase 2.4 percent over the 

next decade (CEC 2007a). In 2003, natural gas fueled 37 percent of the electricity used in 

California (California Electricity Oversite Board 2004). About 2,250 MW of new gas fired 

generation is expected to come on-line in northern California by 2010, with an associated peakday natural gas feedstock requirement of approximately 350,000 Dth/d. It is projected that by 

2016 natural gas consumption in California would total 7,058 mcfd, a 7 percent increase from 

2006. Nearly 41 percent of the gas consumed in California by that date would be used for 

electric power generation (CEC 2006).

Use of natural gas in the Pacific Northwest should continue to grow in the future due to 

additional gas fired electric generation, and population increases that will provide more 

residential customers. Natural gas accounts for about 50 percent of the energy currently 

consumed in the Pacific Northwest. The number of natural gas customers increased nearly 13 

percent between 2000 and 2005, despite a regional economic slump and higher commodity 

prices. Currently, more than 20 percent of the region’s electric generation is fueled by natural 

gas. This sector has shown the greatest growth since the early 1990s, as newly built gas fired 

electric generation plants increased total power outputs by 5.5 gigawatts (GW) or a factor of five. 

About 60 percent of the total power generation capacity in the Pacific Northwest came online 

after 2001 (Northwest Gas Association [NWGA] 2007); ICF 2007). Between 2001 and 2003, 

about 3,350 MW of new power generation was added to the Northwest; most of it fueled by 

natural gas, including 1,675 MW in Oregon (Oregon Department of Energy [ODE] 2005a). 

Natural gas fired electric generation capacity in Oregon increased from about 500 MW in 1990 

to 2,800 MW in 2006, while in Washington gas fired capacity increased from about 700 MW in 

1990 to an estimated 3,900 MW in 2008 (ICF 2008a). Over the last 3 years (2006 to 2008) about 

1,438 MW in additional gas fired electric generation capacity was put into service or is under 

construction and scheduled to come online in the Pacific Northwest (Northwest Power and 

Conservation Council [NWPCC] 2008). 

The Northwest Gas Association (NWGA 2007) estimated that natural gas consumption in the 

Pacific Northwest should increase at an average of 1.9 percent per year, for a total rise of 7.2 

percent through 2012, under normal weather conditions and expected economic and population 

growth. Under its base case, residential natural gas consumption is expected to increase about 9 

percent in total by 2012, while natural gas use for power generation would increase about 12 

percent over that period. According to a 2007 study produced by ICF for the Washington 

Energy Facility Siting Council, future natural gas use in the Pacific Northwest should grow at an 

annual rate in excess of 3 percent per year, with total consumption in Washington and Oregon 

combined reaching 741 Bscf per year by 2025. ICF expects residential demand for natural gas in 

Washington and Oregon to increase by a total of about 58 percent between 2007 and 2025, while 

gas used for electric generation would increase by about 180 percent in that same period. 

Since the early 1980s, natural gas production in the United States has fallen short of national 

demand. Domestic production of natural gas in the United States has risen from about 17.5 Tcf 

in 1991 to about 19.3 Tcf in 2006 (EIA 2007b). Meanwhile, natural gas consumption in the 

United States grew to about 21.8 Tcf by 2006. The shortfall between domestic production and 

consumption has been bridged by importing natural gas, mainly from Canada. About 16 percent 

of all natural gas consumed in the United States is imported from foreign countries, with Canada 

being the source of almost 86 percent of that total. In 2006, the Pacific Northwest received about 

7 percent of all of the natural gas imported into the United States from Canada (about 255 Bscf), 
1-12 1.0 – Introduction

the Midwest received about 46 percent (1,632 Bscf) and the Northeast got 28 percent (1,012 

Bscf) (EIA 2008a). In the future, the West Coast will have to increasingly compete with the rest 

of North America for its share of natural gas supplies from Western Canadian producers. 

The Western Canada Sedimentary Basin (WCSB), extending from British Columbia to 

Saskatchewan, produces nearly 98 percent of the natural gas used in Canada, and represents 

about 23 percent of the total production in North America. Presently, approximately 60 percent 

of the natural gas used in northern California, 80 percent of the natural gas used in Washington, 

70 percent of the natural gas used in Oregon, and 63 percent of the natural gas used in northern 

Nevada originates in the WCSB. Most of the remainder of the natural gas used in Washington, 

Oregon, Nevada, and California originates in the Rocky Mountains and San Juan Basins. 

Natural gas used in California also originates in the Permian Basin and within the state. 

Since 2001, production from the WCSB has been relatively constant, at about 6 Tcf per year. 

However, the WCSB has been characterized as a “mature” production area, and it is forecast to 

decline in the future from current production levels of about 17 Bscfd to less than 15 Bscfd by 

2013 (ICF 2007; NWGA 2007). The Alberta Energy and Utilities Board projected that natural 

gas from wells in the province of Alberta would decline at a rate of 2.5 percent per annum from 

2003 through at least 2013. The EIA (2008a) believes that WCSB producers are having 

difficulties maintaining output because of rising production costs and declining well 

productivity. At the same time that WCSB production would be declining, natural gas 

consumption in Canada should be increasing. Canadian domestic demand for natural gas is 

forecast to grow at a rate of 0.2 Bscfd. Natural gas is used for heavy oil and tar sand 

development in Alberta and for gas fired power plants in Ontario. In the last decade, annual 

imports of Canadian gas into Oregon through interstate pipelines from Washington have dropped 

from over 950 Bscf in 1997 to under 635 Bscf in 2006 (ICF 2008a). Total imports of natural gas 

from Canada to the United States are forecast to decline from 3.6 Tcf in 2006 to 1.2 Tcf in 2030 

(ODE 2008b). An independent analyst projected that Canadian natural gas exports to the United 

States would fall to 1.5 Tcf by 2014 (Beswick 2009). The EIA believes that Canadian exports of 

natural gas into the United States will drop in the future in part because of an increase in 

domestic production (Park 2009). 

The EIA (2008c) now predicts that domestic production of natural gas would reach 23.7 Tcf by 

2030. Increases in domestic production in the future would mainly come from Alaska and 

unconventional onshore resources, including coalbed methane, tight sandstones, and shale gas. 

However, natural gas from Alaska is currently shut in, although there are plans for a future 

natural gas pipeline from Alaska.11 Bolstered by on-shore shale gas, most notably from the 

Marcellus and Haynesville shale plays, production of natural gas from the continental United 

States rose 5.6 percent for the last year on record, from 19.7 Tcf in 2007 to 20.8 Tcf in 2008 

(Beswick 2009). The Marcellus shale is found in the Appalachian Basin of the Northeastern 

United States, while the Haynesville shale is found in northwest Louisiana and east Texas. 

Therefore, there are no existing direct interstate pipelines from these new sources to the Pacific 

Coast. Texas led the nation in natural gas production between the first quarter of 2007 and first 

quarter of 2008, with a growth rate of 15 percent, spearheaded by supplies from the Barnett shale 

(EIA 2008b). The El Paso pipeline system provides a link between the Permian Basin of west 

 

8

 The ODE (2008a) indicated that a natural gas pipeline from Alaska was not expected to be built until after 2018. 
1.0 – Introduction 1-13 

Texas and southern California. A representative of the CEC estimated that lower 48-states nonGulf of Mexico natural gas supplies would rise 10 percent in 2009 (Nemec 2008). 

Natural gas production in the Rocky Mountain region has shown steady growth, from 3.6 Bscfd 

in 1995 to 8.6 Bscfd in 2006. The region now represents about 12 percent of the nation’s 

domestic supplies, with Colorado, Utah, and Wyoming combining to produce a total of 3.14 Tcf 

of natural gas in 2006. The Rocky Mountain states account for about 22 percent of the total 

natural gas reserves in the United States, mostly in unconventional tight-gas or coalbed 

formations (EIA 2007f). It is estimated that there are 209 Tcf of recoverable natural gas in the 

Rockies, and by 2030 the region could represent 28 percent of the total production from the 

lower 48 states (API 2009). Production in the Rockies is projected to increase to almost 10 

Bscfd by 2013, and up to 12.2 Bscfd by 2025 (NWGA 2007; ICF 2007). However, several 

factors constrain access to future supplies of Rockies gas. Much of this gas is found under 

federal lands, and over the last 20 years the amount of federal lands open for new gas exploration 

has shrunk from 75 percent to 17 percent (Baker Institute 2008). Also, the existing interstate 

pipeline infrastructure limits the transportation of additional volumes of Rocky Mountain natural 

gas to the western United States. 

New interstate pipeline infrastructure that was recently built or proposed is taking Rocky 

Mountain natural gas to markets in the Midwest. The Western Phase of the Rockies Express 

Pipeline Project (REX), a joint venture between Kinder Morgan Energy Partners and Sempra 

Pipelines and Storage, is a 780-mile-long 42-inch-diameter pipeline between Colorado and 

Missouri, authorized in FERC Docket No. CP06-354-000, that went into service early in 2008. 

The Eastern Phase of REX, in Docket No. CP07-208-000, which extends the pipeline for an 

additional 639 miles to Ohio, was authorized by the Commission at the end of May 2008, and is 

currently under construction. 

In June 2008, TransCanada and Northern Border entered into the FERC Pre-filing process, in 

Docket Nos. PF08-22-000 and PF08-23-000, for their proposed Pathfinder and Bison projects, to 

transport natural gas produced in Wyoming to the Northern Border pipeline in North Dakota for 

ultimate delivery to the Chicago market. To compete with those proposals, a partnership 

between Alliance Pipeline and Questar Overthrust Pipeline announced plans in March 2008 for 

an 800-mile-long pipeline between Wamsutter, Wyoming and Emerson, Minnesota, known as 

the Rockies Alliance Project would transport Rocky Mountain gas to markets in the Midwest 

(Inside FERC 2008b; Parker 2008c). 

There are also plans to bring additional volumes of Rocky Mountain gas to the West Coast in the 

future. Both the Bronco Project, proposed by Spectra Energy, and the Ruby Project, proposed by 

El Paso Corporation (El Paso), would have pipelines extending from the Opal hub in 

southwestern Wyoming to the California border near Malin, Oregon (Inside FERC 2007; Parker 

2008b; Gas Daily 2007; Parker 2008a). The so-called Sunstone Project, proposed by Williams 

Northwest and TransCanada, would consist of a pipeline between Opal, Wyoming and Stanfield, 

Oregon. In partnership with Puget Sound Energy (PSE), Williams Northwest would then use the 

newly proposed Blue Bridge Project pipeline to connect to Seattle, Washington ( Sickinger 2008; 

Davis 2008a; Seay and Jackson 2008). GTN, which can receive Rocky Mountain produced gas 

through its interconnections with Williams Northwest, is planning an expansion of its system in 

Oregon through the newly proposed Palomar project. All of these newly proposed pipelines, 

which are in different stages of development and review, are discussed further in section 3.2.2. 
1-14 1.0 – Introduction

Some recent reports suggest that domestic gas reserves from unconventional sources, mainly 

shale gas, coalbed methane, and tight sandstone, could compensate for production declines in 

conventional fields. However, accurate production estimates are limited by a lack of extensive 

information about reserves and production profiles in unconventional fields limits (True 2008). 

The proposed JCE & PCGP Project would diversify available sources of natural gas in the 

Pacific Northwest, northern Nevada, and northern California, by importing LNG to meet 

estimated future demand in the region, which would contribute to regional natural gas price 

stabilization, and mitigate against the projected decline in Canadian imports. Unlike North 

America, where much of the resource base has already been exploited, there is ample potential 

for growth in LNG supply from countries with large untapped natural gas reserves. World 

natural gas reserves are estimated to be about 6,000 Tcf. There are currently 11 new liquefaction 

export facilities under construction worldwide, and if all of these projects remain on schedule a 

total of about 2.8 Tcf of new LNG production capacity would be available by the end of 2009 

(Fisher 2009). Currently, world LNG liquefaction production is over 25 Bscfd, but by 2025 that 

capacity could reach 80 Bscfd. There are 50 new liquefaction trains in the planning stages 

throughout the world (ICF 2008c). Pacific Basin countries now produce about 3,673 Bscf of 

LNG per year, representing about 40 percent of the world’s capacity. Projects under 

construction in the Pacific Basin would add about 1,294 Bscf in annual capacity by 2010 (ICF 

2008f). 

LNG represented about 14 percent of all natural gas imported into the United States in 2006 

(EIA 2008a). An independent analyst predicted that LNG imports into the United States would 

rise from 0.4 Tcf in 2008 to 1.0 Tcf by 2011 (Beswick 2009). The Baker Institute (2008) 

estimated that by 2030, the United States would rely on imported LNG to account for about 31 

percent of its natural gas consumption. The EIA (2007a) projected that LNG imports into the 

United States will increase from about 584 Bscf in 2006 to 4.5 Tcf by 2030. Even the ODE 

(2008a) has conceded that the United States would have to import LNG from abroad to keep up 

with future natural gas demands. 

The West Coast has historically enjoyed natural gas prices below the national average because of 

its relative proximity to the WCSB and the Rockies, and local competition from hydropower 

plants that provide a significant amount of energy for the region. Since 2002, natural gas prices 

in the Pacific Northwest, as measured by indices at Sumas and Malin, have been less than prices 

at the Henry Hub in Louisiana.12 The EIA (2008e) estimated that the spot price of natural gas at 

the Henry Hub would rise from $7.17 per mcf in 2007, to $7.93 per mcf in 2009. The CEC 

(2007a) predicted that by 2017 the price of natural gas at the Malin, Oregon Hub could exceed 

the price at the Henry Hub. ICF (2008c) believes that natural gas prices in the Pacific Northwest 

will be higher than Henry Hub by 2012, climbing to about $12 per million British thermal unit 

(MMBtu) at Sumas and Malin by 2020. 

Natural gas prices have recently increased dramatically in the Pacific Northwest, and this trend 

will continue unless additional new sources of natural gas can be imported into the region. 

Between 2002 and 2005, the wellhead price of natural gas more than doubled (NWGA 2007). 

Wholesale natural gas prices in Oregon increased 168 percent between 1999 and 2004, and 

between 1999 and 2005 residential rates rose 84 percent (ODE 2005a, 2008a). According to the 

 

12 The Henry Hub is the largest centralized point for natural gas spot and future trading in the United States (EIA, “U.S. Natural 

Gas Markets: Relationship Between Henry Hub Spot Prices and U.S. Wellhead Prices.”) 
1.0 – Introduction 1-15 

Washington Utilities and Transportation Commission (WUTC) (2006), natural gas prices in that 

state have soared as much as 300 percent over the last several years. Nationally, natural gas 

prices increased between 73 to 128 percent from 1999 to 2006 for all end users (EIA 2007c). In 

its 2007 Annual Energy Outlook reference case, the EIA projected that wellhead prices for 

natural gas in the lower 48 continental United States would rise from $5.01 per mcf in 2005 to 

$5.89 per mcf by 2030. 

Higher natural gas prices will have negative impacts on the regional economy. The ODE 

(2008a) admitted that any reduction in the sources of natural gas to Oregon would disrupt the 

state’s economy; particularly the manufacturing segment. Oregonians spend nearly $10 billion 

annually on energy. In 2000, 1.2 percent of total personal income in Oregon was spent on 

purchasing natural gas (ODE 2005a). The EIA (2007c) indicated that higher natural gas prices 

up to 2006 adversely affected LDCs and their residential customers. The number of LDC natural 

gas customers in arrears and the dollar value of their overdue accounts have been rising. The 

U.S. Federal Reserve Bank estimated that a doubling of natural gas prices would result in a 

reduction of gross domestic product growth between 0.6 to 2.1 percent (Baker Institute 2008). 

The U.S. Department of Commerce (2005) found that higher natural gas prices between 2000 

and 2004 reduced national civilian employment by an average of almost one-half million jobs 

per year, with about 79,000 lost jobs in manufacturing. Higher natural gas prices push up 

consumer costs, reduce real disposable income, slow industrial growth, affect the 

competitiveness of American manufacturing, and reduce the number of new jobs created in the 

national economy (U.S. Department of Commerce 2006). A study sponsored by the Interstate 

Natural Gas Association of America (INGAA) Foundation found that a delay of two years for 

installing new natural gas infrastructure, including LNG import terminals, could cost American 

gas consumers in excess of $200 billion (Energy and Environmental Analysis, Inc. 2004). 

According to the NWGA (2007), an LNG import terminal located in the Pacific Northwest 

would promote regional natural gas supply diversity and reliability, lower shipping costs, 

stabilize prices, and may stimulate the economy. The CEC (2007a) believes that the insertion of 

LNG into the West Coast mix could result in natural gas price reductions. ICF (2007) agrees that 

the importation of LNG in the future would put downward pressure on Pacific Northwest natural 

gas prices. ICF (2008c) also believes that any new natural gas infrastructure built to provide new 

sources of natural gas to Oregon, whether it is the JCE & PCGP Project, or the Palomar or Ruby 

pipelines, could reduce regional natural gas prices below that of the Henry Hub. Benefits 

specifically assigned to the Jordan Cove LNG Project include diversifying the supply of natural 

gas, lowering the wholesale price of gas, moderating gas price volatility, improving system 

reliability, enhancing storage deliverability, and increasing gas availability in southern Oregon 

by about 300 Mscfd (ICF 2008e). 

Dr. Philip Romero, of the University of Oregon, analyzed the impact of LNG on the economy of 

the Pacific Northwest. In Dr. Romero’s opinion, an LNG import terminal with a capacity of 1 

Bscfd would increase natural gas supplies to the region by 10.3 to 51.5 percent, depending on 

utilization, and reduce gas prices by between 6.7 and 33.7 percent. A stable supply of natural 

gas in the future would benefit manufacturing and other industries, and result in higher 

disposable incomes for Northwest households. His “top-down” macroeconomic estimates 

suggested that a 10 percent reduction in natural gas prices could result in an increase in regional 

gross domestic product in 2012 between $222 million and $826 million, increase regional 

employment by between 5,100 to 20,300 jobs, and raise total household incomes between $54 
1-16 1.0 – Introduction

million and $214 million (Romero 2007). ICF (2008e) pointed out that the JCE & PCGP Project 

would be a $2 billion construction project, resulting in about 1,000 construction jobs, with a 

annual payroll of about $3.7 million. While in operation, the Project would generate up to $10 

million in local tax revenues annually. 

A recent study by the ODE (2008b) indicated that natural gas from imported LNG may cost 

more than natural gas produced in North America and transported to the Pacific Northwest by 

interstate pipelines. According to the ODE, Atlantic Basin LNG imported to East and Gulf 

Coast existing LNG terminals is generally priced 8 to 9 percent higher than North American 

produced natural gas. The EIA (2008a) indicated that in 2006 prices for LNG imported into the 

United States (virtually exclusively from the Atlantic Basin to the existing Gulf and East Coast 

terminals) averaged $6.81 per MMBtu, while the price of natural gas imported via pipeline 

(mostly from Canada) averaged $6.70 per MMBtu. The cost of Pacific Basin LNG may even be 

higher. The ODE cited a case where a contract between Indonesia and Japan priced LNG at 

twice the cost of North American natural gas. The same report by the ODE stated that: “natural 

gas use in Oregon is likely to rise over the next twenty years. New sources of natural gas will be 

needed to meet this demand.” However, if new interstate pipelines are authorized and built, and 

transport domestically produced gas at substantially lower costs than imported LNG, then the 

market may not support the construction of LNG import terminals in Oregon. 

Another LNG developer has challenged the contentions of the ODE that imported LNG would 

not be price competitive with domestically produced natural gas. First, East Coast markets may 

out-bid West Coast markets for Rockies gas. Second, right now, the only existing new pipelines 

out of the Rockies transport gas to Midwest markets.13 Some of the newly proposed pipelines 

from the Rockies to the West Coast are currently speculative, and there is no guarantee that any 

of these would be authorized or built in a time frame that would satisfy regional demand. Lastly, 

in fact, imported LNG may be priced below domestic natural gas, depending on such variables as 

supply and demand. The cost to land LNG on the West Coast is estimated to be $4.50 per 

MMBtu, whereas the current price of domestic gas is $11.00 per MMBtu. In another example, 

China recently signed a long-term contract for LNG from Australia paying the equivalent of 

$3.13 per MMBtu (NorthernStar 2008). Independent research by the FERC staff found that 

between January and May 2008 domestic natural gas prices at the Henry Hub ranged between 

$7.93 and $11.23 per MMBtu while LNG imported into the United States fluctuated in price 

between $8.02 and $10.76 per MMBtu. Therefore, LNG at particular times could cost more or 

less than domestic natural gas, depending on market conditions. 

ICF calculated the delivered cost of Rocky Mountain natural gas to be about $7.79 per MMBtu, 

including the wellhead price, gathering, delivery to a regional hub, and transportation to the 

Pacific Northwest via an interstate pipeline. However, the total future delivered cost of Pacific 

Basin LNG was estimated be $6.50 per MMBtu, including the costs of liquefaction and 

transportation to the Pacific Northwest via ocean-going LNG carriers. The ICF study assumed 

that additional sources of LNG would be available by 2012 from LNG export facilities currently 

under construction in Australia, Indonesia, Russia, Papua New Guinea, and Peru (IFC 2008b; 

ICF 2008f). A recently released report by Pace (2009), an independent energy consulting firm, 

indicated that in the long term delivered LNG prices are expected to be lower than incremental 

 

13 The existing Kern River pipeline, which was recently expanded, transports Rocky Mountain natural gas to southern California. 

However, the JCE & PCGP Project does not propose to service markets in southern California. 
1.0 – Introduction 1-17 

North American production, because of high costs associated with exploration and production of 

natural gas from unconventional sources. 

1.4 PURPOSE AND SCOPE OF THIS ENVIRONMENTAL IMPACT STATEMENT 

1.4.1 Purpose and Scope 

This EIS discloses and assesses the potential environmental impacts that are likely to result from 

the construction and operation of the JCE & PCGP Project. The EIS also addresses potential 

socioeconomic impacts and regional economic benefits of the proposed Project. 

A draft EIS was prepared and issued for public review and comment on August 29, 2008. This 

document is a final EIS that has been prepared to respond to comments received on the draft EIS. 

The distribution list for this final EIS is provided in Appendix A. 

Our principal purposes for preparing this EIS are to: 

• identify and assess the potential direct, indirect, and cumulative impacts on the natural 

and human environment that would result from the implementation of the proposed 

actions; 

• describe and evaluate reasonable alternatives to the proposed actions that would avoid or 

minimize adverse effects on the environment; 

• identify and recommend specific mitigation measures, as necessary, to avoid or minimize 

significant environmental effects; and 

• encourage and facilitate involvement by the public and interested agencies in the 

environmental review process. 

The Coast Guard will base its LOR on the environmental analysis contained in this EIS, in 

addition to its review of Jordan Cove’s Waterway Suitability Assessment (WSA). The COE will 

use this EIS, and comments it receives from its notices of applications, in its review of the Port’s 

and Pacific Connector’s applications for permits pursuant to section 404 of the CWA and section 

10 of the RHA. 

One of the purposes of the EIS, for the federal land managing agencies, would be to assess 

conformance with the management plans for each affected BLM District and National Forest. 

While the BLM believes that no plan amendments would be necessary for this Project to comply 

with the respective December 2008 RMPs, the USFS may have to amend its National Forest 

LRMPs. The USFS indicated that it could adopt the FERC EIS to account for the environmental 

impacts of the construction and operation of the proposed pipeline across National Forest System 

(NFS) lands, but would need a separate review of the significance of the Forest Plan amendments 

that is consistent with 36 CFR 219. The EIS would also be the basis for issuing other permits 

necessary for construction and operation of the Pacific Connector pipeline on federal lands if the 

Right-of-Way Grant is issued. 

Our analysis in this EIS focuses on facilities and actions that are under the FERC’s jurisdiction. 

This EIS also includes the facilities and proposed actions that come under the jurisdiction of the 

cooperating agencies that would be integral elements of the Project. In addition, the EIS 

addresses the potential environmental impacts associated with the construction and operation of 

facilities and related activities not regulated by the FERC. These non-jurisdictional facilities 
1-18 1.0 – Introduction

include the NGL storage and rail car loading facilities adjacent to the LNG terminal, power and 

phone service to the Pacific Connector meter stations and compressor station, LDC facilities that 

would be constructed by Avista to transport gas it receives from Pacific Connector, and the 

interconnection between the Pacific Connector pipeline and the existing facilities of PG&E. 

(The non-jurisdictional facilities are discussed in more detail in section 2.2) The waterway to the 

LNG terminal is included to address the Coast Guard’s proposed action of issuing an LOR for 

the Project. 

The topics addressed in this EIS include a detailed description of the Project (chapter 2); 

alternatives (chapter 3); geology, including hazards (section 4.1); soils and sediments (section 

4.2); water resources and wetlands (section 4.3); upland vegetation and timber (section 4.4); 

wildlife and aquatic resources including essential fish habitat (EFH) (section 4.5); threatened, 

endangered, and special status species (section 4.6); land use, recreation, and visual resources 

(section 4.7); socioeconomics (section 4.8); transportation (section 4.9); cultural resources 

(section 4.10); air quality and noise (section 4.11); reliability and safety (section 4.12); and 

cumulative impacts (section 4.13). This EIS describes the affected environment as it currently 

exists, discusses the environmental consequences of the proposed Project, and compares the 

Project’s potential impacts to the potential impacts of a reasonable range of alternatives. This 

EIS also presents the FERC conclusions and recommended mitigation measures (chapter 5). The 

information and analyses presented in this EIS is also intended to support subsequent 

conclusions and decisions made by the cooperating agencies. 

1.4.2 Changes Since the Draft EIS 

As noted in the text box on page 1-2, changes in the text made since the draft EIS are marked 

with a vertical line in the margin. In general, the final EIS has been updated to include new 

information from the applicants that has been filed with the FERC, and new information and 

comments made on the draft EIS by cooperating agencies. The final EIS has also been revised in 

some sections to include additional analysis requested by commentors on the draft EIS. The 

final EIS has also been revised as necessary to correct errors or omissions found in the draft EIS. 

Since publication of the draft EIS, Pacific Connector has changed its proposed route at 18 

segments (see table 3.4.2.1), in response to our recommendations on pipeline route variations 

analyzed in the draft EIS, and continued consultation with land management agencies and new 

information on locations of rare plants. The environmental analysis in this final EIS has been 

revised as necessary to incorporate these changes in the proposed route. 

Since publication of the draft EIS, the RMPs for the BLM districts that would be crossed by the 

Pacific Connector pipeline have been revised as a result of the December 2008 ROD for the 

WOPR. Therefore, designated land use allocations on the BLM lands crossed by the pipeline 

have changed. The final EIS has been revised to incorporate and evaluate potential impact on 

the new land use allocations as defined in the respective December 2008 RMPs. 

1.5 PERMITS, APPROVALS, AND REGULATORY REQUIREMENTS 

1.5.1 Other Federal Environmental Laws 

Besides the NGA, EPAct, and the NEPA, the FERC and other federal cooperating agencies, 

including the Coast Guard, COE, BLM, BOR, and USFS, are required to comply with other 

federal laws that involve consideration of the Project’s potential impact on a range of 
1.0 – Introduction 1-19 

environmental resources. This includes compliance with the Endangered Species Act (ESA), the 

Magnuson-Stevens Fishery Conservation and Management Act (MSA), the Marine Mammal 

Protection Act (MMPA), Migratory Bird Treat Act (MBTA), and the National Historic 

Preservation Act (NHPA). As the lead federal agency for the JCE & PCGP Project, the FERC 

has undertaken the lead role for consultations under these statutes for itself and the cooperating 

agencies. The status of compliance with those acts is described in this EIS. 

There are other federal agencies that must be consulted, or would issue permits or approvals 

based on these federal environmental laws, before this Project could be constructed. For 

example, the FWS must be consulted regarding compliance with the ESA and MBTA, and the 

U.S. Department of Commerce National Oceanic and Atmospheric Administration National 

Marine Fisheries Service (NMFS) must be consulted regarding compliance with the ESA, MSA, 

and MMPA. In order to comply with section 106 of the NHPA, the FERC must give the 

Advisory Council on Historic Preservation (ACHP) an opportunity to comment on the 

undertaking. 

Other federal laws or regulations that require permits and approvals before this Project could be 

constructed include compliance with the RHA, CWA, CAA, Coastal Zone Management Act 

(CZMA), and Coast Guard regulations relating to LNG waterfront facilities. Some of these 

federal permits or approvals, such as section 401 of the CWA, CAA, and CZMA, have been 

delegated to state agencies, as discussed below. For example, the Oregon Department of 

Environmental Quality (ODEQ) has delegated responsibilities under the CWA and CAA, and the 

Oregon Department of Land Conservation and Development (ODLCD) has delegated 

responsibilities under the CZMA. 

In accordance with section 313(d) of the EPAct, the FERC has responsibility to keep a complete 

consolidated record of all actions or decisions made by agencies undertaking federal 

authorizations. On October 19, 2006, in Order No. 687, the FERC issued implementing 

regulations regarding the maintenance of a consolidated record. Section 313(c) of the EPAct 

requires that the FERC establish a schedule for federal authorizations. Pursuant to Order No. 

687, the FERC issued an initial Notice of Schedule for this Project on June 12, 2008. A revised 

Notice of Schedule was issued on February 23, 2009. 

While the EPAct amended the NGA to give exclusive authority to the FERC to approve or deny 

an application for the siting, construction, expansion, or operation of an LNG terminal, it 

specified that nothing in the Act was intended to overrule other federal authorities. This includes 

the protection of the rights of states with federally delegated responsibilities under the CZMA, 

CAA, and CWA. 

Table 1.5-1 lists the major federal, state, and local permits, approvals, and consultations 

identified for construction and operation of the JCE & PCGP Project. 

TABLE 1.5-1 

Major Permits, Approvals, and Consultations for the JCE & PCGP Project

Agency 

Authority/Regulation/

Permit Agency Action Status 

FEDERAL 

FERC Sections 3 and 7 of the 

NGA 

Section 311 of the 

Issue Approval of Place of Import and 

Authorization of Siting, Construction, and 

Operation of LNG Terminal Facilities 

On September 4, 2007, Jordan 

Cove and Pacific Connector 

filed applications with the 
1-20 1.0 – Introduction

TABLE 1.5-1 

Major Permits, Approvals, and Consultations for the JCE & PCGP Project

Agency 

Authority/Regulation/

Permit Agency Action Status 

EPAct 

18 CFR 153, 157, 375, 

and 385 

Order No. 687 

(section 3a of NGA). 

Issue Certificate of Public Convenience 

and Necessity to construct, install, own, 

operate, and maintain a pipeline (section 

7c of NGA). 

FERC. 

FERC decision is pending until 

after the final EIS is issued. 

NEPA 

40 CFR 1500-1508 

18 CFR 380.12 

Prepare EIS. On August 29, 2008 FERC 

issued the draft EIS. 

ACHP Section 106 of the 

NHPA 

36 CFR 800 

Has opportunity to comment on the 

undertaking. 

Pending FERC review of final 

cultural resources reports, 

after consultations with Oregon 

State Historic Preservation 

Officer (SHPO). 

Federal 

Communication 

Commission 

License for fixed 

microwave stations and 

service 

Review proposals for new or additions to 

existing communication station. 

Pending. 

U.S. Department of 

Agriculture (USDA), 

Natural Resources 

Conservation Service 

(NRCS) 

Farmland Protection 

Policy Act 

Determine if the project would result in the 

permanent conversion of prime farmland. 

Pending. 

USFS NEPA 

Special Use Permit 

Amendments to Forest 

Plan 

Timber Sale 

Agreements 

Timber Clearing 

Permits 

Road Use Permits 

Mineral Sale Permits 

Fire Season Waivers 

Snow Plow Permit 

Special Use Permits 

Overload/Oversize 

Permit 

ROW Easement Grant 

Adopt EIS. 

Review Permit. 

Amend Forest Plans. 

Reach Timber Sale Agreement. 

Issue Timber Clearing Permit. 

Issue Road Use Permits. 

Mineral Sale Permit. 

Fire Season Waivers. 

Permit plowing of access roads 

Permit use of Staging Areas, Industrial 

Camping, and disposal sites. 

Permit oversize loads on NFS roads. 

Consent to issue Right-of-Way Grant on 

NFS lands. 

Pending. 

June 12, 2006 Special Use 

Survey Permit issued. 

Anticipated for 2009. 

Apply in 2009. 

Apply in 2009. 

Apply in 2009. 

Apply in 2009. 

Apply in 2010. 

Pending. 

Apply in 2010. 

Pending. 

Pending. 

COE 

 

Section 10 of the RHA 

33 CFR 320 to 330 

Issue permit for activities that will occupy, 

fill, or grade land in a floodplain, 

streambed, or channel of a stream or 

other waters of the United States. 

On April 22, 2008 the Port 

submitted a revised JPA.. 

In a letter dated October 6, 

2008 the COE stated it will 

jointly evaluate the Jordan 

Cove, Pacific Connector, and 

Port projects. 

On November 19, 2008 COE 

issued letters indicating it was 

holding its review in abeyance 

until the Port provides 

additional information. 

 Section 404 of the 

CWA 

Issue permit for the placement of dredged 

or fill material into waters of the United 

States, including wetlands. 

On April 22, 2008 the Port 

submitted a revised JPA. 

On November 19, 2008, COE 

issued letters indicating it was 

holding its review in abeyance 

until the Port provides 

additional information. 
1.0 – Introduction 1-21 

TABLE 1.5-1 

Major Permits, Approvals, and Consultations for the JCE & PCGP Project

Agency 

Authority/Regulation/

Permit Agency Action Status 

NMFS Section 7 of the ESA Consider lead agency determination of 

effects on federally listed species and their 

habitat. Provide a biological opinion (BO) 

if the project is likely to adversely affect 

such species or their habitat. 

The FERC will submit its BA 

and EFH Assessment to 

NMFS at about the same time 

the final EIS is issued. NMFS 

would issue its BO pending 

review of the FERC’s BA and 

EFH Assessment. 

 MMPA 

50 CFR 216 

Consult on protected marine mammals. Pending review of this EIS and 

the FERC’s BA and EFH 

Assessment. 

 MSA Provide conservation recommendations 

for projects that may adversely impact 

EFH. 

Pending review of the FERC’s 

EFH Assessment. 

U.S. Department of 

Defense (DOD) 

Section 311(f) of the 

EPAct and Section 3 of 

the NGA 

Consult with the Secretary of Defense to 

determine whether an LNG facility would 

affect the training or activities of an active 

military installation. 

On July 6, 2006, the FERC 

sent letters about the Project 

to the COE, Air Force Real 

Property Agency, Office of the 

Under Secretary of Defense, 

and Office of the Assistant 

Secretary of the Navy. 

On August 15, 2006, the Office 

of the Under Secretary of 

Defense responded indicating 

no objections to the Project. 

DOE, Bonneville Power 

Administration (BPA) 

Encroachment Permit 

for Electric 

Transmission Line 

Crossing 

Permit review. Pacific Connector anticipates 

submitting this permit request 

in 2009. 

EPA Section 404 of the 

CWA 

Section 309 of the CAA 

Can veto wetland permits issued by the 

COE. 

Review EIS for compliance with CAA and 

the NEPA. 

EPA review pending COE 

permit issuance and FERC 

issuance of EIS. 

33 CFR 127 Captain of the Port (COTP) issues an LOR 

determining the suitability of the waterway 

for LNG marine traffic. 

On April 10, 2006 Jordan Cove 

submitted Letter of Intent (LOI) 

to Coast Guard. 

LOR pending completion of the 

NEPA review. 

33 CFR 165 Establish safety and security zones for 

LNG vessels in transit and while docked. 

July 1, 2008 Coast Guard 

issued Waterway Suitability 

Report (WSR). . 

Ports and Waterway 

Safety Act 

Ensure navigation safety. Pending. 

Maritime 

Transportation Act 

33 CFR 101, 103, 104, 

105 

Develop LNG Vessel Management and 

Emergency Plan. Review and approve 

Facility Security Plan. 

Pending. 

Coast Guard 

Navigation and Vessel 

Inspection Circular – 

Guidance on 

Assessing the 

Suitability of a 

Waterway for Liquefied 

Natural Gas Marine 

Traffic (NVIC 05-05) 

Validate WSA and produce WSR. On April 10, 2006 Jordan Cove 

submitted initial draft WSA to 

Coast Guard, and revised 

WSA on September 4, 2007. 

On July 1, 2008 Coast Guard 

issued WSR. 

BLM Section 28 of Mineral 

Leasing Act of 1920 

43 CFR 2880 

Issue Right-of-Way Grant for crossing 

federal lands for construction, operation, 

maintenance, and termination of 36-inch 

diameter natural gas pipeline. 

Road construction and use of BLM roads 

(may be authorized in Right-of-Way 

Grant). 

Offsite compensatory mitigation (may be 

authorized in Right-of-Way Grant). 

On April 17, 2006 Pacific 

Connector submitted its Rightof-Way Application to the BLM, 

which was accepted on May 5, 

2006. 

On May 5, 2006, BLM 

approved Casual Use 

activities. 

ROD pending FERC issuance 
1-22 1.0 – Introduction

TABLE 1.5-1 

Major Permits, Approvals, and Consultations for the JCE & PCGP Project

Agency 

Authority/Regulation/

Permit Agency Action Status 

of final EIS. 

 Timber Harvest and 

Sale Authorization 

43 CFR 5400 

Authorize removal and sale of timber and 

other forest resources associated with 

land clearing for construction of the 

pipeline and ancillary facilities (may be 

authorized in Right-of-Way Grant). 

Pending. 

 Federal Land Policy 

and Management Act 

of 1976, as amended 

43 CFR 1610 

Land Use Plan Amendments - BLM must 

offer a 90-day comment period following 

the draft EIS and a 30-day protest period 

following issuance of final EIS and resolve 

protests prior to issuing the ROD. 

Pending. 

 Archaeological 

Resources Protection 

Act of 1979 (ARPA) 

16 USC 470aa-470,, 

Cultural Resources Use Permit. In June 2007 BLM approved 

survey permits. 

BOR NEPA 

Right-of-Way 

Easement Grant 

Adopt EIS or conduct own analysis. 

Consent to issue Right-of-Way Grant. 

Pending. 

Pending. 

Section 7 of the ESA Consider lead agency determination of 

effects on federally listed species and their 

habitat. Provide a BO if the project is 

likely to adversely affect such species or 

their habitat. 

The FERC will submit its BA to 

the FWS at about the same 

time the final EIS is issued. 

FWS would issue its BO 

pending review of the FERC’s 

BA. 

FWS 

Fish and Wildlife 

Coordination Act 

Provide comments to prevent loss of and 

damage to wildlife resources. 

FWS has participated in 

interagency meetings, 

provided comments on the EIS 

as a cooperating agency, and 

will review BA. 

 Migratory Bird Treaty 

Act (MBTA) 

Consultation regarding compliance with 

the MBTA. 

Pending review of this EIS and 

the FERC’s BA. 

DOT, PHMSA Natural Gas Pipeline 

Safety Act 

49 USC 601 

49 CFR Parts 190-199 

Administer national regulatory program to 

ensure the safe transportation of natural 

gas. 

Pending. 

DOT, Federal Aviation 

Administration (FAA) 

18 CFR Subchapter E 

FAR Part 77 

Notice of Proposed Construction Possibly 

Affecting Navigable Air Space. 

Jordan Cove claims to have 

submitted draft Notice. 

U.S. Department of the 

Treasury, Bureau of 

Alcohol, Tobacco, and 

Firearms 

Explosives User Permit 

27 CFR 555 

Issue permit to purchase, store, and use 

explosives during project construction. 

Permits to be obtained by 

Jordan Cove and Pacific 

Connector, as necessary, 

before construction. 

STATE – OREGON

Oregon Department of 

Agriculture (ODA) 

Oregon Endangered 

Species Act 

Oregon Senate Bill 533 

and Oregon Revised 

Statute (ORS) 564 

Consult on Oregon listed plant species, 

and ODA would review botanical survey 

reports covering non-federal public lands 

prior to ground-disturbing activities where 

state listed botanical species are likely to 

occur. 

On September 15, 2006, ODA 

responded to Jordan Cove that 

it was in compliance with state 

laws, and no species should 

be adversely affected. 

ODA provided Pacific 

Connector with a list of state 

species on July 24, 2006. 

Pacific Connector included 

botanical survey report in its 

September 4, 2007, 

application to the FERC. A 

second botanical report was 

submitted in November 2008, 

ODA review of those report is 

pending. 

Oregon Department of 

Energy (ODE) 

Section 311 of the 

EPAct 

Furnish an advisory report on state and 

local safety and security issues to the 

FERC, and conduct operational safety 

inspections. 

ODE filed its safety and 

security report to the FERC on 

October 4, 2007. 

ODEQ Section 401 of the 

CWA 

Water quality certification. Issue National 

Pollutant Discharge Elimination System 

Review of the JPA is on hold 

pending additional information 
1.0 – Introduction 1-23 

TABLE 1.5-1 

Major Permits, Approvals, and Consultations for the JCE & PCGP Project

Agency 

Authority/Regulation/

Permit Agency Action Status 

(NPDES) permits for discharge of 

hydrostatic test water, submerged 

combustion vaporizer (SCV) condensate, 

and stormwater. 

to be provided by the Port in 

March 2009, 

 CAA Issue air quality permit. Pacific Connector submitted a 

draft Standard Air Contaminant 

Discharge Permit application 

to ODEQ on August 31, 2007. 

Jordan Cove submitted its air 

quality permit application to the 

ODEQ in September 2007. 

Jordon Cove intends to submit 

a Prevention of Significant 

Deterioration permit 

application by June 2009. 

 Water Pollution Control 

Facility Permit under 

Oregon Administrative 

Rule (OAR) 340-045 

Issues permit for the disposal of solid 

wastes and waste water into public 

waters. 

Pending. 

 ORS 468B.300 et seq. ODEQ to review and approve LNG vessel 

and facility spill contingency plans. 

Pending. 

Fish and Wildlife 

Coordination Act and 

the Oregon 

Endangered Species 

Act under 

ORS 496, 506, and 

509 

and OAR 635 

Consult on sensitive species and habitats 

that may be affected by the project and, in 

general, regarding conservation of fish 

and wildlife resources. 

Fish passage approval from ODFW 

needed for stream crossings. 

Jordan Cove initiated 

consultations with ODFW on 

November 1, 2006. 

In May 2007, Pacific 

Connector consulted with 

ODFW regarding preliminary 

habitat categorization. 

ODFW participated in State 

and Federal Task Force. 

ODFW review pending 

issuance of this EIS. 

Fish and Wildlife HMP, 

OAR 345-022-0060 

Consult on and approve fish and wildlife 

mitigation plan. 

Pacific Connector filed revised 

habitat categorizations on July 

24, 2008. ODFW provided 

comments and concurrence on 

February 15, 2009. 

ORS 509.140, et al Consider issuance of in-water blasting 

permits 

Applications by Pacific 

Connector pending. 

Oregon Department of 

Fish and Wildlife 

(ODFW) 

635-412-0005 through 

0040 

Review temporary stream crossing plans 

consistency with Oregon fish passage law 

and ODFW fish passage rules 

pending 

Oregon Department of 

Forestry (ODF) 

Easement on State 

lands 

Oregon Forest 

Practices Act 

OAR 629 

ORS 477 

ORS 527 

Management of State Forest lands for 

Greatest Permanent Value, develops 

Forest Management Plans, stewardship 

under State’s Land Management 

Classification System, monitors harvests 

of timber on private lands, and protects 

non-federal public and private lands from 

wildfires. 

Pacific Connector anticipates 

submittal in 2009. 

ODLCD CZMA 

15 CFR Part 930 

ORS 196.435 

Determine consistency with CZMA 

program policies. 

Pacific Connector and Jordan 

Cove submitted draft requests 

for consistency to the ODLCD 

and the ODLCD indicated the 

applications were incomplete. 

Jordan Cove stated it would 

resubmit an application after 

the Port provides additional 

information in 2009. 
1-24 1.0 – Introduction

TABLE 1.5-1 

Major Permits, Approvals, and Consultations for the JCE & PCGP Project

Agency 

Authority/Regulation/

Permit Agency Action Status 

SHPO Section 106 of the 

NHPA 

ORS 338.920 

Review cultural resources reports and 

comment on recommendations for 

National Register of Historic Places 

(NRHP) eligibility and project effects. 

Issue permits for excavation of 

archaeological sites on non-federal public 

and private lands. 

On October 2, 2006, the 

SHPO wrote a letter to Jordan 

Cove commenting on the LNG 

terminal inventory report and 

requesting revisions. 

On May 28, 2008, SHPO 

commented on report of a 

survey covering the proposed 

Port Commercial Sand 

Stockpile area. 

On July 11, 2008, SHPO 

commented on Pacific 

Connector pipeline inventory 

report for archaeological 

resources. 

On December 30, 2008, SHPO 

commented on potential 

Project effects on aboveground resources.. 

Submerged and 

Submersible Land 

Easement 

OAR 141-122 

Grant submerged land easements (e.g., 

waterbody crossings). 

Pacific Connector anticipates 

submitting this permit 

application to the ODSL in 

2009. 

Joint Removal-Fill 

Permit, ORS 196.795-

990 

OAR 141-85-25-31, 

115, 121, 126, 131 

136, 141, 151 

Approve removal or fill of material in 

waters of the state. 

ODSL must determine that proposed 

removal and fill activity would not be 

inconsistent with protection, conservation, 

and best use of water resources in the 

state. 

Compensatory mitigation required for 

projects that would impact wetlands or 

waters of the state. 

Pacific Connector submitted its 

JPA in September 2007, Port 

submitted revised JPA in April 

2008. 

On October 4, 2007, ODSL 

reviewed the Port’s original 

JPA and found it incomplete. 

The Port intends to revise JPA 

with new mitigation plan to be 

submitted in 2009. 

ODSL informed Pacific 

Connector that it would not 

review the pipeline JPA 

pending documentation of 

landowner permission for 

waterbody crossings. 

Oregon Department of 

State Lands (ODSL) 

Compensatory Wetland 

Mitigation Rules 

OAR 141-085-0121 

Review and approve wetland mitigation 

plans. 

Draft Mitigation Plan under 

review. 

Section 303(c) DOT 

Act 49 CFR 303 

Consultation and clearance letter 

regarding recreational land disturbance 

and construction-related traffic impacts. 

Oregon Department of Pending. 

Transportation (ODOT) 

Access Permit 

ORS 184, OAR 734-

051 and 55 

Issue permits to cross state funded 

roadways. 

ODOT sent letter to the FERC 

commenting on the project on 

April 9, 2008. 

Permit submittal is pending. 

ORS 537, OAR 690-

310 

Issue permits to appropriate surface water 

and groundwater during project operation. 

Pacific Connector anticipates 

submitting permit application in 

2010. 

Pending for Jordan Cove. 

Oregon Department of 

Water Resources 

(ODWR) 

ORS 537, OAR 690-

340 

Issue limited licenses for temporary use of 

surface waters for hydrostatic testing and 

suction dredging. 

Pending. 

Oregon Department of 

Geology and Mineral 

Industries 

Building Code Section 

1802.1 and ORS 

455.446 

Review per regulations on development in 

a tsunami inundation zone. 

Pending 

OR 517 Review per regulations on mining and 

reclamation activities. 

Pending 

Oregon Public Utilities 

Commission (OPUC) 

OAR 860-031 Inspect the natural gas facilities for safety. Pending. 
1.0 – Introduction 1-25 

TABLE 1.5-1 

Major Permits, Approvals, and Consultations for the JCE & PCGP Project

Agency 

Authority/Regulation/

Permit Agency Action Status 

LOCAL

Multiple Land-use 

Permits and Approvals 

under CWA, CAA, and 

CZMA responsibilities 

delegated to the State 

of Oregon 

Review consolidated applications for 

compliance. Issue permits and approvals. 

On November 7, 2007, Coos 

County approved Jordan 

Cove’s application for an 

Administrative Conditional Use 

Permit. 

On July 15, 2008 the Land Use 

Board of Appeals remanded 

the application back to Coos 

County for wetlands and 

archaeological issues. 

Pacific Connector to submit its 

application for a LUCS in 

2009. 

Coos County 

Section 311 of EPAct Review and provide consultation 

regarding Jordan Cove’s Emergency 

Response Plan (ERP). 

Jordan Cove to submit ERP 

prior to construction. 

 Shoreline Management 

Act 

Issue Shoreline Development Permit to 

cross waterbodies covered by the 

Shoreline Management Act. 

Pending. 

Douglas County Land use permits 

required as part of the 

NPDES permit 

application delegated 

to the Sate of Oregon 

under section 402 of 

the CWA 

Douglas County has stated to Pacific 

Connector at it will not require a land use 

process and will affix a statement to the 

LUCS. 

Pending. 

Jackson County Land use permits 

required as part of the 

NPDES permit 

application delegated 

to the Sate of Oregon 

under section 402 of 

the CWA 

Land use permits necessary for the Shady 

Cove Meter Station and the Butte Falls 

Compressor Station. 

Permit applications submitted 

by Pacific Connector early in 

December 2007. 

Klamath County Land use permits 

required as part of the 

NPDES permit 

application delegated 

to the Sate of Oregon 

under section 402 of 

the CWA 

Klamath County has stated to Pacific 

Connector that it will not require a land 

use process and will affix a statement to 

the LUCS. 

Pending. 

Road Crossing Permits Review permits to cross county roads. Pending. 

Grading Permits Review permits for excavation and grading 

activities. 

Pending. 

All Counties 

Solid Waste Disposal Review permits for disposal of solid waste 

generated by construction. 

Pending. 

1.5.1.1 Endangered Species Act 

Section 7 of the ESA, as amended, states that any project authorized, funded, or conducted by a 

federal agency should not “jeopardize the continued existence of any endangered species or 

threatened species or result in the destruction or adverse modification of habitat of such species 

which is determined...to be critical” (16 USC section 1536(a)(2)(1988)). The lead federal 

agency, or the applicant as a non-federal party, is required to consult with the FWS and the 

NMFS to determine whether any federally listed or proposed endangered or threatened species or 

their designated critical habitat occur in the vicinity of the proposed Project. If, upon review of 

existing data or data provided by the applicant, one (or both) of the two federal agencies 

determine that these species or habitats may be affected by the proposed Project, the FERC is 

required to prepare a BA to identify the nature and extent of adverse impacts, and to recommend 
1-26 1.0 – Introduction

measures that would avoid the habitat and/or species, or would reduce potential impacts to 

acceptable levels. 

Jordan Cove and Pacific Connector filed an applicant-prepared draft BA on March 10, 2008, 

followed by subsequent revisions to address questions and data gaps identified by the FERC staff 

and reviewing agencies. The FERC will submit its BA for the JCE & PCGP Project to the 

NMFS and FWS at about the same time the final EIS is issued. Because we have found that the 

Project is likely to adversely affect some listed species our BA requests that the FWS and NMFS 

each develop a BO as to whether authorizing the JCE & PCGP Project may jeopardize the 

continued existence of any species under their jurisdiction or adversely modify or destroy 

designated critical habitat. See section 4.6 of this EIS for details of our ESA analysis. 

1.5.1.2 Magnuson-Stevens Fishery Conservation and Management Act 

The MSA, as amended by the Sustainable Fisheries Act of 1996 (Public Law 104-267), 

established procedures designed to identify, conserve, and enhance EFH for those species 

regulated under a federal fisheries management plan. The MSA requires federal agencies to 

consult with the NMFS on all actions or proposed actions authorized, funded, or undertaken by 

the agency that may adversely affect EFH (MSA section 305(b)(2)). Although absolute criteria 

have not been established for conducting EFH consultations, the NMFS recommends 

consolidated EFH consultations with interagency coordination procedures required by other 

statutes, such as the NEPA, the Fish and Wildlife Coordination Act, or the ESA to reduce 

duplication and improve efficiency (50 CFR 600.920(e)). As part of the consultation process for 

this Project, we consolidated an EFH Assessment with the BA, on behalf of the federal 

cooperating agencies for this Project. The FERC will submit its BA and EFH Assessment for the 

JCE & PCGP Project to the NMFS at about the same time the final EIS is issued. See section 

4.5.2.1 of this EIS for the status of the MSA review. 

1.5.1.3 Marine Mammal Protection Act 

All marine mammals are protected under the MMPA of 1972. This act was amended by the U.S. 

Congress in 1994. The MMPA prohibits, with certain exceptions, the taking of marine mammals 

in U.S. waters and by U.S. citizens on the high seas and the importation of marine mammals and 

marine mammal products into the United States. The term “take,” as defined in section 3 of the 

MMPA, means “to harm, hunt, capture, or kill, or attempt to harass, hunt, capture or kill any 

marine mammal” (16 USC section 1362(13)). “Harassment” is also defined in the MMPA (at 

USC section 1362(18)) and in regulations promulgated by the NMFS (at 50 CFR 216.3). 

Sections 101(a)(5)(A) and (D) of the MMPA direct the U.S. Secretary of Commerce, through the 

NMFS, to allow, upon request, the incidental, but not intentional, taking of small numbers of 

marine mammals of a species or population stock by U.S. citizens who engage in a specified 

activity (other than commercial fishing) within a specific geographic region if certain findings 

are made and either regulations are issued or, if the taking is limited to harassment, a notice of 

authorization is provided to the public for review. Authorization would be granted by the NMFS 

if it finds that the taking will have a negligible impact on the species or stock, will not have an 

unmitigatable adverse impact on the availability of the species or stock for subsistence uses 

(where relevant), and it prescribes permissible methods of taking, and requirements pertaining to 

the mitigation, monitoring, and reporting of such taking. NMFS has defined “negligible impact” 

as “an impact resulting from the specified activity that cannot be reasonably expected to, and is 
1.0 – Introduction 1-27 

not reasonably likely to, adversely affect the species or stock though effects on annual rates of 

recruitment or survival.” 

The NMFS may use relevant portions of this EIS during its review, and may adopt measures to 

protect marine mammals outlined in this EIS. It may also require additional mitigation and 

monitoring measures to ensure that the taking result in the least practicable adverse impact on 

affected marine mammal species or stocks. The public would have an opportunity to comment 

to the NMFS in response to its Notice of Receipt of an application for an Incidental Harassment 

Authorization, or a request for the implementation of regulations governing incidental taking, 

and following the publication of the proposed rule. 

Impacts from the JCE & PCGP Project on marine mammals are discussed in sections 4.5.1, 

4.5.2.1, and 4.6.1.1. In addition, marine mammals listed under the ESA are discussed in detail in 

the BA and EFH Assessment (see section 1.5.1.1). 

1.5.1.4 National Historic Preservation Act 

Section 106 of the NHPA requires that federal agencies take into account the effects of their 

undertakings on historic properties and afford the ACHP an opportunity to comment. Historic 

properties include prehistoric or historic sites, districts, buildings, structures, objects, or 

properties of traditional religious or cultural importance listed on or eligible for listing on the 

NRHP. The FERC has requested that Jordan Cove and Pacific Connector, as non-federal parties, 

assist in preparing the necessary information and analyses as required by the ACHP procedures 

in 36 CFR 800. 

As the lead federal agency, it is the FERC’s responsibility, under section 106 and its 

implementing regulations, to consult with the Oregon SHPO, identify historic properties within 

the area of potential effect (APE), and make determinations of NRHP eligibility and project 

effects, on behalf of all the cooperating agencies. See section 4.10 of this EIS for a detailed 

discussion of compliance with the NHPA. 

1.5.1.5 Rivers and Harbors Act 

Section 10 of the RHA (33 USC section 403) regulates any work or structures that potentially 

affect the course, condition, or capacity of a navigable waterway. It requires authorization from 

the COE for building any wharfs, piers, jetties, or other structures or excavating or filling in any 

port, navigable river, or other waters of the United States. 

The Port (as the applicant for the proposed access channel and slip) and Pacific Connector 

submitted JPA under section 10 of the RHA to the COE in September 2007. However, the Port’s 

application was later withdrawn, and resubmitted in April 2008. In a letter to the Port, dated 

November 19, 2008, the COE indicated it would hold review of the application in abeyance until 

additional data are submitted. In a filing with the FERC on January 23, 2009, Jordan Cove stated 

that the Port’s application to the COE would be resubmitted after it completes its new mitigation 

plan later in 2009. Section 4.3 of this EIS discusses impacts on water resources that may be 

applicable to compliance with the RHA. 

1.5.1.6 Clean Water Act 

The CWA (33 USC section 1344) addresses the issue of managing developments to improve, 

safeguard, and restore the quality of the nation’s waters, including coastal waters, and to protect 
1-28 1.0 – Introduction

the natural resources and existing uses of those waters. Under section 404 of the CWA, the COE 

issues permits (after notice and opportunity for public hearings) for the discharge of dredged or 

fill material into waters of the United States at specified disposal sites. The EPA has the 

authority to review and veto COE decisions on section 404 permits. 

Jordan Cove and Pacific Connector must obtain Water Quality Certifications pursuant to section 

401 of the CWA and NPDES permits pursuant to section 402 of the CWA. The federal authority 

to issue these certifications and permits has been delegated to the ODEQ in Oregon. 

In addition, the ODSL would need to issue a removal and fill permit, which is currently being 

prepared as a JPA with the section 404 and section 10 permits. The applications for permits 

under 401 of the CWA and the ODSL removal and fill permit are part of the JPAs that were 

submitted by Pacific Connector in September 2007 and the revised application submitted by the 

Port in April 2008. For other projects in Oregon, the ODEQ indicated that it would not begin 

processing of permit applications until after the COE has issued its notice of applications, and the 

applicants provide Land Use Compatibility Statements (LUCS) issued by the affected counties 

(ODEQ 2007a). The COE indicated that it would notice the applications after the FERC issues 

its EIS. Section 4.3 of this EIS discusses impacts on water resource that may be applicable to 

compliance with the CWA. 

1.5.1.7 Clean Air Act 

The primary objective of the CAA, as amended, is to establish federal standards for various 

pollutants from both stationary and mobile sources, and to provide for the regulation of polluting 

emissions via state implementation plans. In addition, the CAA is designated to prevent 

significant deterioration in certain areas where air pollutants exceed national standards and to 

provide for improved air quality in areas that do not meet federal standards (non-attainment 

areas). 

The EPA has regulatory authority under the CAA. Section 309 of the CAA directs EPA to 

review and comment in writing on environmental impacts associated with all major federal 

actions. The EPA has delegated permitting authority under the CAA to the ODEQ in Oregon. 

Emissions from all phases of construction and operation of the proposed LNG terminal and 

pipeline would be subject to applicable federal and state air regulations. 

Pacific Connector submitted a draft application for a Standard Air Contaminant Discharge 

Permit to the ODEQ on August 31, 2007. Jordan Cove submitted its air quality permit 

application to the ODEQ on September 4, 2007. In a filing with the FERC on January 23, 2009, 

Jordan Cove stated that it would review all air emission calculations and pursue a Prevention of 

Significant Deterioration (PSD) permit, with a new application to be submitted to the ODEQ by 

June 2009. For other projects in Oregon, ODEQ has indicated it would not begin to process 

applications until after it receives a LUCS from the affected counties. Section 4.11.1 of this EIS 

has a detailed discussion of air quality issues. 

1.5.1.8 Coastal Zone Management Act 

In 1972, Congress passed the CZMA to “preserve, protect, develop, and where possible, to 

restore or enhance, the resources of the nation’s coastal zone for this and succeeding 

generations” and to “encourage and assist the states to exercise effectively their responsibilities 

in the coastal zone through the development and implementation of management programs to 
1.0 – Introduction 1-29 

achieve wise use of the land and water resources of the coastal zone” (16 USC section 1452, 

section 303 (1) and (2)). 

Section 307 (c)(3)(A) of the CZMA states that “any applicant for a required federal license or 

permit to conduct an activity, in or outside the coastal zone, affecting any land or water use or 

natural resource of the coastal zone of that state shall provide a certification that the proposed 

activity complies with the enforceable policies of the state’s approved program and that such 

activity will be conducted in a manner consistent with the program.” In order to participate in 

the coastal zone management program, a state is required to prepare a program management plan 

for approval by the U.S. Department of Commerce, National Oceanic and Atmospheric 

Administration, Office of Coast and Ocean Resource Management (OCRM). Once the OCRM 

has approved a plan and its enforceable program policies, a state program gains “federal 

consistency” jurisdiction. This means that any federal action (e.g., a project requiring federally 

issued licenses or permits) that takes place within a state’s coastal zone must be found to be 

consistent with state coastal policies before the federal action can take place. 

All components of the Jordan Cove LNG terminal, and the Pacific Connector pipeline from MP 

0.0 to approximately MP 46 are within the designated Oregon coastal zone and are subject to 

federal CZMA review. The ODLCD is the state’s designated coastal management agency and 

has established the Oregon Coastal Management Program (OCMP). The program’s mission is to 

work in partnership with coastal local governments, state and federal agencies, and other 

stakeholders to ensure that Oregon’s coastal and ocean resources are managed, conserved, and 

developed consistent with statewide planning goals. To accomplish this mission, the program 

combines various state statutes for managing coastal lands and waters into a single, coordinated 

package. These include: 1) the 19 Statewide Planning Goals, which are Oregon’s standards for 

comprehensive land use planning; 2) city and county comprehensive land use plans; and 3) state 

agencies and natural resource laws such as the Oregon Beach Bill and the Removal-Fill Law. 

Under the provisions of the CZMA, Jordan Cove and Pacific Connector must provide a 

certification to the FERC and the ODLCD that their projects comply with and would be 

conducted in a manner consistent with the state's approved management program (15 CFR 

930.50 Subpart D). Jordan Cove and Pacific Connector each submitted draft requests for 

consistency determinations to the ODLCD in September 2007. The ODLCD has indicated that 

these applications are currently incomplete. See section 4.7.3.2 of this EIS for further 

information regarding compliance with the CZMA. 

1.5.1.9 Migratory Bird Treaty Act 

Migratory birds are species that nest in the United States and Canada during the summer and 

migrate south to the tropical regions of Mexico, Central and South America, and the Caribbean 

for the nonbreeding season. Migratory birds are protected under the MBTA (16 U.S.C. 703–

711) and Executive Order [EO] 13186 (66 FR 3853). Destruction or disturbance of a migratory 

bird nests, or any eggs or young contained within it, is a violation of the MBTA. The MBTA 

also prohibits the taking of migratory birds without authorization from FWS. Because the FERC 

is not within the executive branch of the federal government it is not bound by any EO. The 

FERC does, however, consider the intent of EO 13186 in its evaluation of Project impacts and 

assessment of measures to avoid impacts on migratory birds. See additional discussion in 

section 4.5.1.3 of this EIS. 
1-30 1.0 – Introduction

1.5.2 Federal Agency Reviews 

1.5.2.1 Coast Guard Review 

The Coast Guard exercises regulatory authority over LNG facilities that affect the safety and 

security of port areas and navigable waterways under EO 10173; the Magnuson Act (50 USC 

section 191); the Ports and Waterways Safety Act of 1972, as amended (33 USC section 1221 et 

seq); and the Maritime Transportation Security Act of 2002 (46 USC section 701). The Coast 

Guard is responsible for matters related to navigation safety, vessel engineering and safety 

standards, and all matters pertaining to the safety of the facilities or equipment located in or 

adjacent to navigable waters up to the last valve immediately before the receiving tanks. The 

Coast Guard also has authority for LNG facility security plan review, approval, and compliance 

verification as provided in 33 CFR 105, and siting as it pertains to the management of vessel 

traffic in and around the LNG facility. As required by its regulations, the Coast Guard is 

responsible for issuing an LOR as to the suitability of the waterway for LNG marine traffic. The 

LOR would be based on, among other things, the following items: 

• physical location and description of the facility; 

• the LNG vessel’s characteristics and the frequency of LNG shipments to or from the 

facility; 

• waterway channels and commercial, industrial, environmentally sensitive, and residential 

areas in and adjacent to the waterway used by LNG vessels en route to the facility, within 

25 kilometers (15.5 miles) of the facility; 

• density and character of marine traffic in the waterway; 

• locks, bridges, or other manmade obstructions in the waterway; 

• depth of water; 

• tidal range; 

• protection from high seas; 

• natural hazards, including reefs, rocks, and sandbars; 

• underwater pipes and cables; and 

• distance of berthed vessels from the channel and the width of the channel. 

In accordance with 33 CFR 127.007, each applicant must submit a LOI to the local COTP to 

begin the LOR process. Jordan Cove submitted an LOI to the Coast Guard for the Project on 

April 10, 2006. On April 27, 2006, the Coast Guard notified Jordan Cove that the LOI 

submission was complete and the Coast Guard would begin the process of assessing the safety 

and security issues associated with LNG traffic. 

On June 14, 2005, the Coast Guard issued a Navigation and Vessel Inspection Circular – 

Guidance on Assessing the Suitability of a Waterway for Liquefied Natural Gas (LNG) Marine 

Traffic (NVIC 05-05). The purpose of the NVIC 05-05 is to provide Coast Guard 

COTPs/Federal Maritime Security Coordinators, members of the LNG industry, and port 

stakeholders with guidance on assessing the suitability of a waterway for LNG marine traffic that 

takes into account conventional navigation safety/waterway management issues contemplated by 

the existing LOI/LOR process, but in addition, will also take completely into account maritime 

security implications. In accordance with this guidance, each LNG project applicant is to submit 

a WSA to the cognizant COTP. On December 22, 2008, the Coast Guard published a second 

Navigation and Carrier Inspection Circular – Guidance Related to Waterfront Liquefied Natural 

Gas (LNG) Facilities (NVIC 05-08). The purpose of NVIC 05-08 is to revise the format of the 
1.0 – Introduction 1-31 

LOR to conform to its intended affect of being a recommendation of the waterway suitability to 

the FERC. The NVIC 05-08 is further discussed in section 4.12.5.5. Jordan Cove submitted a 

preliminary WSA to the Coast Guard on April 10, 2006, and a revised WSA on September 4, 

2007. The Coast Guard reviewed the WSA and produced its WSR on July 1, 2008. The public 

portion of the WSR is attached to this EIS as Appendix B. See sections 4.12.5 through 4.12.8 of 

this EIS for additional discussion of marine safety. 

1.5.2.2 U.S. Army Corps of Engineers Review 

The COE is the primary agency responsible for issuing dredging and wetland permits pursuant to 

section 404 of the CWA and section 10 of the RHA. Pacific Connector and the Port submitted 

their JPA to the COE in September 2007. In an October 23, 2007 letter to the Port, the COE 

acknowledged submittal of the JPA, but indicated it would only review the permit application if 

it could be demonstrated that the Port’s proposal was independent of the Jordan Cove LNG 

Project. In a letter to the Port dated December 19, 2007, the COE indicated that the application 

was put in abeyance by the Port. The Port submitted a revised JPA to the COE on April 22, 

2008. On November 19, 2008, the COE wrote a letter to the Port indicating that it would hold its 

review of the applications in abeyance until requested information is provided. 

The COE would process the applications in accordance with its regulations at 33 CFR Parts 320 

through 330. Once the COE deems the applications complete, it would issue a notice of 

applications, and hold joint public meetings with the ODEQ and ODSL to take comments on the 

applications. We discuss issues pertaining to the COE permits under water resources and 

wetlands in section 4.3. 

1.5.2.3 U.S. Environmental Protection Agency Review 

The EPA has the authority to overrule the COE decision with regard to issuing a permit under 

section 404 of the CWA. In addition, section 309 of the CAA directs EPA to review and 

comment on an EIS issued by a federal agency regarding actions that may affect air quality. 

Also, under its own policies and procedures, the EPA would evaluate a federally issued EIS for 

adequacy in meeting the requirements of the NEPA. Section 4.3 of the EIS discusses issues 

related to water quality relevant to compliance with the CWA, while section 4.11 discusses air 

quality issues relevant to compliance with the CAA. 

1.5.2.4 Federal Land-Managing Agencies 

Portions of the Pacific Connector pipeline would cross lands administered by the BLM, USFS, 

and BOR. Because these agencies must comply with the Standards and Guidelines of their 

respective LRMPs, as amended, and the requirements of the NEPA before granting or amending 

rights-of-way across lands under their management, these agencies have elected to act as 

cooperating agencies in preparing this EIS. Table 1.5.2.4-1 lists each LRMP that the Pacific 

Connector pipeline would be required to comply with. This EIS incorporates each of these 

LRMPs by reference. 

The BLM, USFS, BOR would use the EIS to meet their NEPA responsibilities in considering 

Pacific Connector’s application for a Right-of-Way Grant and obtain a Temporary Use Permit 

for the portion of the Project on federal lands. The BLM and USFS would also use the EIS to 

consider amending their respective local land use plans, which would be necessary for pipeline 

construction across BLM-, BOR-, and USFS-administered lands. As cooperating agencies, the 
1-32 1.0 – Introduction

BLM, BOR, and USFS would adopt the EIS per 40 CFR 1506.3(c) if, after an independent 

review of the document, they conclude that their comments and suggestions have been satisfied. 

TABLE 1.5.2.4-1 

BLM, USFS, and BOR Land Use Plans the Pacific Connector Project Must Comply With 

and that are Incorporated into this EIS by Reference

BLM District, USFS National Forest, or 

BOR Region 

Approximate MP Range 

of Pacific Connector 

Project Applicable Land Use Plans 

BLM a/ 

Coos Bay District - Umpqua and Myrtlewood 

Resource Area 

17.04 -27.48, 

28.4 – 45.7 

Coos Bay District Record of Decision and Resource 

Management Plan (June 1995) 

Roseburg District - South River Resource 

Area 

46.8 – 102.3 Roseburg District Record of Decision and Resource 

Management Plan (June 1995) 

Medford District - Ashland and Butte Falls 

Resource Area 

115.1 – 141.9, 

148.8 – 153.8 

Medford District Record of Decision and Resource 

Management Plan (June 1995) 

Lakeview District – Klamath Falls Resource 

Area 

176.0 – 216.7 Lakeview District Record of Decision and Resource 

Management Plan (June 1995) 

USFS 

Umpqua National Forest – Tiller Ranger 

District 

99.3 – 113.2 Umpqua National Forest Land and Resource 

Management Plan (1990) 

Rogue River-Siskiyou National Forest – 

Ashland Ranger District 

153.8 – 167.9 Rogue River National Forest Land and Resource 

Management Plan (1990) 

Freemont-Winema National Forest – Klamath 

Ranger District 

167.9 – 175.4 Winema National Forest Land and Resource 

Management Plan (1990) 

BOR 

MP Region 200.5 – 214.18 Klamath Office Management Plan 

a/ All of the RMPs for the BLM districts crossed by the Pacific Connector pipeline have been revised in accordance with the 

December 2008 ROD for the WOPR. 

Under section 185(f) of the MLA, the BLM has the authority to issue Right-of-Way Grants for 

all affected federal lands. This would be in accordance with 43 CFR Parts 2800 and 2880, 

subsequent 2800 and 2880 Manuals, and Handbook 2801-1. The BLM would consider factors 

including conformance with land use plans and impacts on resources and programs to determine 

whether to issue a Right-of-Way Grant. 

Pacific Connector submitted its Right-of-Way Application to the BLM on April 17, 2006. At the 

same time, Pacific Connector requested approval of a Casual Use Permit, and entered into a Cost 

Reimbursement Agreement with the BLM, USFS, and BOR. On May 31, 2006, Pacific 

Connector applied for cultural resources survey permits under the FLMPA. The BLM approved 

the Casual Use permit application on May 5, 2006, and approved the cultural resources survey 

permit on June 6, 2006. Before the BLM would issue its Right-of-Way Grant, Pacific Connector 

would have to submit a complete Plan of Development (POD). The BLM would consult with 

the other federal land-managing agencies before making a decision to issue the Right-of-Way 

Grant. The BLM’s decision would be documented in a ROD. The Right-of-Way Grant would 

include, among other things, standard and site-specific stipulations obtained from the BLM, 

BOR, and USFS; conditions and mitigation measures identified in the EIS or subsequent NEPA 

documents; and terms and conditions contained in the BOs issued by the FWS and NMFS. 

Table 1.5-1 summarizes the permits or approvals that would be issued by the BLM, BOR, and 

USFS. Details of land ownership are presented in section 4.7.3.1 of this EIS. Consistency with 

LRMPs is discussed in section 4.7.4.4. 

The BOR could adopt this EIS, or conduct its own analysis, as part of its decision to issue, or not 

issue, the Right-of-Way Grant/Temporary Use Permit on BOR-administered lands to construct 
1.0 – Introduction 1-33 

the pipeline. Depending on the decision, the BOR would issue a letter to the BLM that would 

concur or not concur with the issuance of a Right-of-Way Grant across its lands. 

The USFS would use the EIS to concur or not concur with the issuance of the Right-of-Way 

Grant by the BLM. The USFS would also use the EIS to issue Temporary Use Permits on NFS 

lands. These permits may be incorporated into the BLM Right-of-Way Grant as “standard and 

site-specific stipulations,” but they would in fact be separate permits detailing stipulations, 

responsibilities, and costs to Pacific Connector (commensurate share – either collections or 

maintenance) associated with all aspects of the pipeline construction project, including the 

hauling of cleared timber, as spelled out in 36 CFR 212.5(c) and (d) and 36 CFR 228.47(e) (July 

2005 edition). These permits would include Road Use Permits, Special Use Permits to conduct 

timber sales, and Snow Plowing Permit. In April 2006, Pacific Connector applied for a Special 

Use Permit and Survey Permit from the USFS. These were approved by the USFS on June 12, 

2006. 

At this time, the USFS has not disclosed exactly how any specific National Forest LRMP would 

be amended for this Project. The USFS indicated it would conduct a separate review to 

determine the significance of its proposed amendments to individual Forest Plans. The USFS 

would prepare a ROD to document the Regional Forester’s decision to amend any National 

Forest LRMP. 

1.5.2.5 U.S. Department of Defense Consultation 

We have consulted with the DOD, as required by section 311(f) of the EPAct and section 3 of 

the NGA, to determine if there would be any impacts associated with the Project on military 

training or activities on any active military installations. No comments or concerns were 

received from any branch of the military or a military installation in response to the FERC's 

Notice of Intent to Prepare and Environmental Impact Statement (NOI) issued June 23, 2006. 

In letters dated July 6, 2006, to appropriate property managers and installation supervisors at the 

Pentagon, representing the U.S. Army, U.S. Air Force, and U.S. Navy, we informed various 

offices of the DOD about the JCE & PCGP Project and requested any information on potential 

impacts on military installations. In response, we received a letter, dated August 15, 2006, from 

Dr. Get Moy, Director of Installations Requirements and Management in the Office of the Under 

Secretary of Defense, stating that there were no objections from the DOD to the Project, pending 

approvals by the COE. 

1.5.3 Other State Agency Permits and Approvals 

In addition to the federal permitting authorities that have been delegated to the states, as 

discussed above, various laws and regulations promulgated by the state of Oregon have 

relevance to the JCE & PCGP Project. The Coast Guard also worked with representatives of the 

state of Oregon in reviewing the WSA for the Project. 

The FERC encourages cooperation between applicants and state and local authorities, but this 

does not mean that state and local agencies, through application of state and local laws, may 

prohibit or unreasonably delay the construction or operation of facilities approved by the FERC. 
1-34 1.0 – Introduction

Any state or local permits issued with respect to FERC-regulated facilities must be consistent 

with the conditions of any Certificate the FERC may issue.14 

Oregon permits and authorizations relevant to the JCE & PCGP Project are listed in table 1.5-1. 

Major Oregon permits and authorizations are discussed below. 

1.5.3.1 Oregon Department of Energy 

According to the EPAct, the Governor of a state in which an LNG terminal is proposed is to 

designate an appropriate state agency to consult with the Commission. That state agency should 

provide the FERC with an advisory report on state and local safety concerns, within 30 days of 

the FERC’s notice of an application for an LNG terminal, for the Commission to consider prior 

to making a decision. The ODE has been designated by the Governor of Oregon as the state 

agency to coordinate the review of proposed LNG projects by other state agencies and consult 

with the FERC. 

On May 9, 2006, we wrote a letter to the ODE requesting participation in the production of this 

EIS as a cooperating agency. The ODE responded, in a letter dated May 18, 2006, that while it 

would cooperate in the Pre-filing review of the proposed JCE & PCGP Project, it could not agree 

to be a cooperating agency for the production of the EIS, because it wanted to retain its right to 

intervene. On July 20, 2006, the ODE presented comments on the Project, in response to the 

FERC’s NOI issued June 23, 2006. On October 4, 2007, ODE filed a motion to intervene. That 

same day, the ODE provided the FERC with its Safety Advisory Report. We address the Safety 

Advisory Report is section 4.12.9 of this EIS. In addition, we have attached a copy of the ODE 

Safety Advisory Report and our responses as Appendix C of this EIS. In a letter dated December 

4, 2008, the Governor of Oregon conveyed to the FERC consolidated comments from state 

agencies on the draft EIS. This letter, and our responses to comments, is included in Appendix J. 

1.5.3.2 Oregon Department of State Lands 

Under Oregon’s Removal-Fill Law (ORS 196.795-990), permits are issued by the ODSL for: 

• projects requiring the removal or fill of 50 cubic yards or more of material in waters of 

the state; 

• the removal or fill of any material regardless of the number of cubic yards affected in a 

stream designated as essential salmon habitat; and 

• the removal or fill of any material from the bed and banks of scenic waterways regardless 

of the number of cubic yards affected. 

All permits include standard and special design and operating conditions that are intended to 

ensure the protection, conservation, and best use of the state’s water resources and to prevent 

harm to fishery and recreational uses of the waters. A common condition is that the project be 

conducted during the "in-water work period" established by the ODFW for the specific 

waterbodies. For projects involving impacts on wetlands, compensatory mitigation to offset loss 

of wetland resources is required per OAR 141-085-0121. 

 

14 See, e.g., Schneidewind v. ANR Pipeline Co., 485 U.S. 293 (1988); National Fuel Gas Supply v. Public Service Commission, 

894 F.2d 571 (2n Cir. 1990); and Iroquois Gas Transmission System, L.P., et al., 52 FERC 61,091 (1990) and 59 FERC 61,094 

(1992). 
1.0 – Introduction 1-35 

A JPA is used to obtain an Oregon Removal-Fill Permit from the ODSL, and COE permits under 

section 10 of the RHA and section 404 of the CWA as described above. The Port and Pacific 

Connector submitted their original JPAs to both the ODSL and the COE in September 2007. On 

October 4, 2007, the ODSL informed the Port that its JPA was incomplete. The Port resubmitted 

its JPA in April 2008, and the ODSL deemed the application incomplete due to lack of purpose 

and need, alternatives analysis, and mitigation. The ODSL indicated to Pacific Connector that it 

would not process an application for a removal and fill permit for the pipeline pending 

documentation of landowner permission for crossing waterbodies. This EIS addresses issues 

relevant to compliance with the RHA and CWA that also relate to Oregon’s Removal and Fill 

Law, under the discussion of potential issues on water resources and wetlands in section 4.3. 

1.5.3.3 Oregon Department of Agriculture 

The ODA maintains the state list of endangered and threatened species, in accordance with OAR 

Chapter 603, Division 73, and reviews reports of botanical surveys under Oregon Senate Bill 533 

and its corresponding ORS 564. These state laws and regulations require surveys for state listed 

species on non-federal public lands prior to ground-disturbing activities, unless habitat for the 

species does not exist in the Project area. 

In June 2005, Jordan’s Cove’s consultant, SHN Consulting Engineers & Geologists, Inc. (SHN), 

consulted with ODA about protocols for botanical surveys, and obtained a list of state-listed 

plants and their blooming periods for the Project area. In July, August, and October 2006, 

Jordan Cove submitted botanical survey reports to the ODA. On September 15, 2006, ODA 

wrote a letter indicating that the botanical survey of the proposed LNG terminal site met its 

requirements, that the JCE & PCGP Project would probably not have any adverse effects on 

state-listed species, and no further consultations were necessary. 

Pacific Connector initiated consultations with the ODA in July 2006, to obtain a list of statelisted plant species that may occur along the pipeline route. Pacific Connector’s botanical survey 

report was included with its application to the FERC. In November 2008, Pacific Connector 

filed with the FERC the results of its second season of biological surveys. However, Pacific 

Connector has not yet filed the ODA review of those reports. Section 4.6 of this EIS addresses 

potential project impacts on protected botanical resources. 

1.5.3.4 Oregon Department of Fish and Wildlife 

The ODFW is responsible for keeping the state sensitive fish and wildlife list and developing the 

state’s Wildlife Diversity Plan. The purpose of the Fish and Wildlife Habitat Mitigation Policy 

(OAR 345-022-0060) developed by the ODFW is to apply consistent goals and standards to 

mitigate impacts on fish and wildlife habitat caused by land and water development actions. The 

policy provides goals and standards for general application to individual development actions, 

and for the development of more detailed policies for specific classes of development actions or 

habitat types. In implementing this policy, the ODFW will recommend or require mitigation for 

losses of fish and wildlife habitat resulting from development actions. Priority is given for native 

species. Both Jordan Cove and Pacific Connector have voluntarily agreed to categorize habitat 

on lands affected by the Project and seek mitigation of impacts on wildlife in a manner consistent 

with the ODFW’s policies. 

Jordan Cove requested a list of state sensitive fish and wildlife species from the ODFW in a 

letter dated August 24, 2006. Jordan Cove’s consultants sent outlines of survey strategies to the 
1-36 1.0 – Introduction

ODFW in August 2005. On May 10, 2006, JBJ Enterprises, on behalf of Jordan Cove, produced 

a report of wildlife surveys conducted at the proposed LNG terminal in 2005-2006. Alice Berg 

& Associates produced a Fisheries Report for Jordan Cove in October 2006. Copies of these 

reports were included in Jordan Cove’s application to the FERC. Jordan Cove provided copies 

of their fish and wildlife studies to the ODFW in July 2006, but has not yet filed the ODFW 

comments on these reports. On March 6, 2009, Jordan Cove filed with the FERC minutes of an 

upland habitat mitigation meeting held with ODFW and FWS on January 13, 2009, and in those 

minutes provided details of proposed mitigation for impacts on terrestrial habitats at the LNG 

terminal site. See discussion in section 4.5.1.2 of this EIS. 

Pacific Connector included copies of biological survey reports with its application to the FERC. 

These reports were supplemented, in a filing with the FERC on November 25, 2008 with 

biological survey data incorporating results from the 2008 field season. However, Pacific 

Connector has not yet documented that these reports were reviewed by the ODFW. Appendix 

3G of Pacific Connector’s environmental Resource Report 3 presented its ODFW Habitat 

Categorization Process. In a July 24, 2008 filing with the FERC, Pacific Connector revised its 

habitat characterization for federal and non-federal lands crossed by the pipeline, presented 

example mitigation measures that it would implement to comply with ODFW policies and 

minimize impacts on upland habitats. Pacific Connector’s habitat characterization was accepted 

by the ODFW, with comments, in an email sent to the FERC staff on February 15, 2009. 

Finalization of Pacific Connector’s upland habitat mitigation plan to comply with ODFW 

policies is pending. See discussion in section 4.5.1.3 of this EIS. Representatives of ODFW 

participated in the State and Federal Interagency Task Force for this Project, as discussed below 

in section 1.6. 

1.5.3.5 Oregon Department of Forestry 

The ODF manages State Forests for the Greatest Permanent Value. The ODF has created a 

Forest Management Plan to provide strategic direction and guide management activities. Part of 

the plan is to identify multi-purpose objectives, and protect sensitive resources according to the 

state’s Land Management Classification System. The ODF also monitors the commercial 

harvest of forest products from private timber lands, according to the Oregon Forest Practices 

Act. The ODF is responsible for protection of non-federal and private forest lands from 

wildfires. This EIS discusses potential Project-related impacts on forest in section 4.4. 

1.5.3.6 State Historic Preservation Office 

The FERC, as the lead federal agency, on behalf of the cooperating agencies, must consult with 

the SHPO regarding the identification, evaluation, and determination of effects on historic 

properties, in accordance with the ACHP’s regulations at 36 CFR 800 for implementing section 

106 of the NHPA. The SHPO also has authorities, under ORS 358.920, to issue permits for 

cultural resources surveys on non-federal public land, and for the excavation of archaeological 

sites on non-federal public and private lands. Consultations with the SHPO and compliance with 

the NHPA are discussed in section 4.10. 

1.6 PUBLIC REVIEW AND COMMENT 

The environmental review of the JCE & PCGP Project began with the initiation of the FERC’s 

Pre-filing Review Process. On April 11, 2006, Jordan Cove and Pacific Connector requested 

that the FERC initiate the Pre-filing Review Process for the Project, and the FERC agreed on 
1.0 – Introduction 1-37 

May 1, 2006, selecting Tetra Tech EC, Inc. (Tetra Tech) as our third-party environmental 

contractor. 

On May 21, 2006, the BLM published a notice in newspapers of local circulation (The 

Oregonian, Roseburg News Review, The World [Coos Bay], Mail Tribune and Daily Courier

[Medford], and the Herald and News [Klamath Falls]) announcing the receipt of the Pacific 

Connector right-of-way application and the availability of the documents for public review. The 

BLM also sent similar notices to the Governor of Oregon, the heads of each local or tribal 

government or jurisdiction within which the pipeline is located, and the heads of other federal 

agencies whose jurisdiction includes lands within the pipeline project. On May 8, 2006, the 

BLM notified the Chairman of the Committee on Energy and Natural Resources of the United 

States Senate of receipt of the Pacific Connector right-of-way application. Congressional 

notification is required for pipelines 24 inches or more in diameter. 

Jordan Cove and Pacific Connector hosted a series of open houses in the project area, on June 

12, 2006 in North Bend, Oregon; on June 13, 2006, in Canyonville, Oregon; on June 14, 2006, in 

Klamath Falls, Oregon; and June 15, 2006, in Shady Cove, Oregon, to inform the public about 

their Project. In addition, the FERC issued a notice, on June 2, 2006, inviting the public to 

participate in site visits with staff on June 9 and 13, 2006, and notifying the public that staff 

would be attending the open houses conducted by Jordan Cove and Pacific Connector between 

June 12 and 15, 2006. 

The FERC staff also attended initial interagency meetings to discuss the Project, in Portland and 

Salem, Oregon, on June 8, 2006, and in Roseburg, Oregon, on June 9, 2006. Agencies that had 

representatives at these meetings included the Coast Guard, BLM, USFS, COE, EPA, NMFS, 

FWS, Oregon Department of Geology and Mineral Industries (DOGAMI), OPUC, Oregon 

Department of Parks and Recreation (ODPR), ODWR, ODLCD, ODEQ, ODE, ODFW, Douglas 

County, City of North Bend, City of Coos Bay, and the Cow Creek Tribe. Notes from all 

interagency meetings were placed into the FERC’s public record for the Project. 

On June 23, 2006, the FERC issued a Notice of Intent to Prepare an Environmental Impact 

Statement for the Proposed Jordan Cove LNG and Pacific Connector Gas Pipeline Projects, 

Request for Comments on Environmental Issues, and Notice of a Joint Public Meeting. The 

NOI, issued jointly with the Coast Guard, was sent to more than 1,000 interested parties 

including federal, state, and local officials; agency representatives; conservation organizations; 

local libraries and newspapers; and property owners within 0.5 mile of the proposed LNG 

terminal and along the proposed pipeline route. Issuance of the NOI officially opened the public 

comment period and established a closing date, of July 24, 2006, for receiving written comments. 

In total, more than 280 letters were received in response to the NOI by that closing date. 

However, the FERC considered all comments received during the Pre-filing review period, prior 

to the date when Jordan Cove and Pacific Connector filed their official applications, in shaping 

the scoping issues to be addressed in this EIS. 

The FERC’s NOI stated that the USFS had identified the possible need to amend the existing 

Umpqua, Rouge River, and Winema National Forest LRMPs, and the BLM had identified the 

possible need to amend the existing RMPs of the Coos Bay, Roseburg, and Medford Districts 

and the Klamath Falls Resource Area. Subsequently, with the issuance of the WOPR in 
1-38 1.0 – Introduction

December 2008, the BLM now believes that it may not have to amend any of its revised RMPs 

for the districts crossed by the pipeline. 

The NOI, the FERC conducted four public scoping meetings in the Project area to provide an 

opportunity for the public to learn more about the proposed Project and to provide comments on 

environmental issues to be addressed in this EIS. Public meetings were held on July 10, 2006, at 

the Umpqua Community College in Roseburg; on July 11, 2006, at the Southwestern Oregon 

Community College in Coos Bay; on July 12, 2006, at the Red Lion Inn in Medford; and on July 

13, 2006, at the Oregon Institute of Technology in Klamath Falls. The meeting in Coos Bay was 

held jointly with the Coast Guard. Statements were made by 94 speakers at the public meetings 

and a transcript of the scoping meetings and all written comments provided at the meeting have 

been entered into the public record for the JCE & PCGP Project. 

On January 8, 2007, the FERC issued a Notice of Informational Meetings for the Proposed 

Jordan Cove LNG and Pacific Connector Gas Pipeline Projects. Also participating in the 

meetings were staff from agencies that are cooperating with the FERC in the production of the 

EIS, including the BLM and USFS. Public meetings were held on January 23, 2007 at the 

Umpqua Community College in Roseburg; on January 24, 2007 at the North Bend Community 

Center in North Bend; and January 25, 2007 at the Red Lion Inn in Medford. Notes from these 

meetings were placed into the FERC’s public record for the Project. 

In addition to the public notice and scoping process discussed above, the FERC staff conducted 

agency consultations and participated in interagency meetings with other key federal and state 

agencies to identify issues that should be addressed in this EIS. During the Pre-filing Review 

period, five interagency meetings were held in Portland, Oregon; six interagency meetings were 

held in Roseburg, Oregon; and one interagency meeting was held in Salem, Oregon. Interagency 

meetings held during the Pre-filing period that were attended by the FERC staff are listed in 

table 1.6-1. 

Throughout the public scoping period (coinciding with the Pre-filing Review Process) we 

received comments on a wide variety of environmental issues. Between June 23, 2006 and 

September 4, 2007, we received 332 letters commenting on the Project, including 277 letters 

from individuals, 37 letters from organizations, 2 letters from Indian tribes, 4 letters from federal 

agencies, 11 letters from state and local agencies, and 2 letters from U.S. Congressional 

Representatives. In these letters, the most frequently mentioned environmental topics were 

Reliability and Safety (27 percent of comments); Cumulative Impacts (15 percent of comments); 

and Biological Resources and Alternatives (each 10 percent of the comments). Table 1.6-2 

summarizes the environmental issues identified during the Pre-filing public scoping process for 

the JCE & PCGP Project. 

TABLE 1.6-1 

Public and Interagency Meetings for the JCE & PCGP Project Attended by the FERC Staff

Date Location Purpose Attendees 

PRE-FILING MEETINGS 

6/8/06 Portland, OR Interagency Meeting FERC, Jordan Cove, Pacific Connector, BLM, USFS, EPA, 

Coast Guard, NMFS, DOGAMI 

6/8/06 Salem, OR Meeting with State Agencies FERC, Jordan Cove, Pacific Connector, OLCD, ODE, 

ODEQ, OPUC, ODFW, ODWR 

6/9/06 Roseburg, OR Interagency Meeting FERC, Jordan Cove, Pacific Connector, BLM, USFS, COE, 

ODFW, ODEQ, Douglas County, City of North Bend, City 
1.0 – Introduction 1-39 

TABLE 1.6-1 

Public and Interagency Meetings for the JCE & PCGP Project Attended by the FERC Staff

Date Location Purpose Attendees 

of Coos Bay, Cow Creek Tribe 

6/9/06 Roseburg, OR Site visit FERC, Pacific Connector, public 

6/12/06 North Bend, OR Open House FERC, Jordan Cove, Pacific Connector, public 

6/13/06 North Bend, OR Site visit FERC, Jordan Cove, Pacific Connector, public 

6/13/06 Canyonville, OR Open House FERC, Jordan Cove, Pacific Connector, public 

6/14/06 Klamath Falls, OR Open House FERC, Jordan Cove, Pacific Connector, public 

6/15/06 Shady Cove, OR Open House FERC, Jordan Cove, Pacific Connector, public 

7/10/06 Portland, OR Interagency Meeting FERC, Jordan Cove, Pacific Connector, BLM, USFS, EPA, 

Coast Guard, NMFS, DOGAMI 

7/10/06 Roseburg, OR Public Scoping Meeting FERC, Jordan Cove, Pacific Connector, USFS, BLM, 

public 

7/11/06 Roseburg, OR Interagency Meeting FERC, Jordan Cove, Pacific Connector, BLM, USFS, EPA, 

Coast Guard, NMFS, DOGAMI 

7/11/06 Coos Bay, OR Public Scoping Meeting FERC, Jordan Cove, Pacific Connector, Coast Guard, 

USFS, BLM, public 

7/12/06 Medford, OR Public Scoping Meeting FERC, Jordan Cove, Pacific Connector, USFS, BLM, 

public 

7/13/06 Medford, OR Site Visit FERC, Pacific Connector, USFS, public 

7/13/06 Klamath Falls, OR Public Scoping Meeting FERC, Jordan Cove, Pacific Connector, USFS, BLM, 

public 

10/4/06 Portland, OR Interagency Meeting FERC, Jordan Cove, Pacific Connector, BLM, USFS, EPA, 

Coast Guard, NMFS, DOGAMI 

10/5/06 Roseburg, OR Interagency Meeting FERC, Jordan Cove, Pacific Connector, BLM, USFS, 

ODFW, ODEQ, Douglas County, City of North Bend, City 

of Coos Bay 

1/22/07 Portland, OR Interagency Meeting FERC, Jordan Cove, Pacific Connector, BLM, USFS, EPA, 

Coast Guard, NMFS, DOGAMI 

1/23/07 Roseburg, OR Interagency Meeting FERC, Jordan Cove, Pacific Connector, BLM, USFS, 

ODFW, ODEQ, Douglas County, City of North Bend, City 

of Coos Bay 

1/23/07 Roseburg, OR Public Informational Meeting FERC, Jordan Cove, Pacific Connector, USFS, BLM, 

public 

1/24/07 Coos Bay, OR Public Informational Meeting FERC, Jordan Cove, Pacific Connector, USFS, BLM, 

public 

1/25/07 Medford, OR Public Informational Meeting FERC, Jordan Cove, Pacific Connector, USFS, BLM, 

public 

4/5/07 Medford, OR Interagency Meeting FERC, USFS, BLM, FWS 

5/2/07 Portland, OR Interagency Meeting FERC, Jordan Cove, Pacific Connector, BLM, USFS, FWS, 

ODFW 

5/3/07 Roseburg, OR Interagency Meeting FERC, Jordan Cove, Pacific Connector, BLM, USFS, 

ODFW, ODEQ 

5/4/07 Coos Bay, OR Site/Waterway Visit FERC, Jordan Cove, Port, Coast Guard, BLM, FWS 

POST-APPLICATION MEETINGS 

9/25/07 Salem, OR State-Federal Task Force 

Meeting 

FERC, Port, Jordan Cove, Pacific Connector, BLM, USFS, 

FWS, NMFS, ODE, ODFW, ODLCD, ODPR 

9/26/07 Portland, OR Interagency Meeting FERC, Coast Guard, BLM, USFS, FWS, EPA, ODE 

9/27/07 Roseburg, OR Interagency Meeting FERC, BLM, USFS, FWS, NMFS, Douglas County, Cow 

Creek Tribe 

11/8/07 Salem, OR State-Federal Task Force 

Meeting 

FERC, Port, Jordan Cove, Pacific Connector, BLM, USFS, 

FWS, NMFS, ODE, ODFW, ODLCD, ODSL 

12/11/07 Coos Bay, OR Site Visit FERC and public 

12/12/07 Coos Bay, OR Cryogenic Conference FERC, Jordan Cove, Tuna Guys, Oregon Citizens Against 

the Pipeline, and Harry and Holly Stamper 

5/1/08 Salem, OR State-Federal Task Force 

Meeting 

FERC, Jordan Cove, Pacific Connector, BLM, USFS, FWS, 

NFWS, ODE, ODFW, ODCLD, ODSL 

9/22/08 Coos Bay, OR Open House/Town Hall Meeting FERC, Jordan Cove, Pacific Connector, public 

9/23/08 Klamath Falls, OR Open House/Town Hall Meeting FERC, Jordan Cove, Pacific Connector, public 

9/24/08 Shady Cove, OR Open House/Town Hall Meeting FERC, Jordan Cove, Pacific Connector, public 

9/25/08 Canyonville, OR Open House/Town Hall Meeting FERC, Jordan Cove, Pacific Connector, public 

10/27/08 North Bend, OR Public Meeting on the draft EIS FERC, public, interested agencies 

10/28/08 Roseburg, OR Cooperating Agencies Meeting FERC, BLM, BOR, USFS, DOT, Coast Guard, and 

Douglas County 

10/28/08 Roseburg, OR Public Meeting on the draft EIS FERC, public, interested agencies 
1-40 1.0 – Introduction

TABLE 1.6-1 

Public and Interagency Meetings for the JCE & PCGP Project Attended by the FERC Staff

Date Location Purpose Attendees 

10/29/08 Medford, OR Public Meeting on the draft EIS FERC, public, interested agencies 

10/30/08 Klamath Falls, OR Public Meeting on the draft EIS FERC, public, interested agencies 

1/28/09 Portland, OR Cooperating Agencies Meeting FERC, BLM, USFS, and Pacific Connector 

TABLE 1.6-2 

Environmental Issues Identified During the Pre-filing Public Scoping Process for the JCE & PCGP Project

Specific Issue/Comment 

EIS Section Where 

Comments are 

Addressed 

Purpose and Need (3 percent of comments) 1.0 

 Purpose and need for proposed project, economic viability of LNG, natural gas market. 

 Environmental costs versus need; local benefits. 

 Need for multiple LNG import facilities. 

Alternatives (10 percent of comments) 3.0 

 Comments urging that investments be redirected towards renewable, domestic energy sources 

such as wind, solar and wave power. 

 Site the terminal and pipeline in California. 

 Siting the LNG facility near a populated area is inappropriate. Remote or offshore locations 

should be given more consideration. 

Geology (5 percent of comments) 4.1 

 Regional seismic activity (earthquake and/or tsunami) on the LNG terminal or pipeline. 

 Liquefaction at the LNG terminal site as a result of seismic activity. 

Soils and Sediments (3 percent of comments) 4.2 

 Soil and slope stability along the pipeline route (mud and landslides are common during the rainy 

season in southeast Oregon). 

Water Resources (5 percent of comments) 4.3 

 Impacts of construction and operation of the project elements, including LNG terminal facilities 

and pipeline crossings, on surface water and groundwater, especially drinking water and salmon 

spawning habitat. 

 Concerns over horizontal directional drilling under streams and rivers along the pipeline route. 

 Impacts on water quality due to increased dredging in Coos Bay. 

Wetlands (1 percent of comments) 4.3 

 Impacts to sensitive wetland and dune ecosystems near the LNG terminal. 

Biological Resources (10 percent of comments) 4.5 and 4.6 

 Impacts to threatened and endangered species. 

 Impacts to fisheries and EFH. 

 Impacts of increased dredging on marine ecosystems and species. 

 Impacts of pipeline construction on forestlands, including sensitive forest types. 

 Introduction and propagation of noxious weeds in the pipeline right-of-way. 

Land Use and Recreation (7 percent of comments) 4.7 

 Impact on existing users of Coos Bay. 

 Opposition to use of eminent domain to acquire pipeline easements, especially when some land 

uses would not be allowed once the pipeline is installed. 

 Comments supporting and opposing the use of federal lands for the pipeline corridor. 

 Comments making specific pipeline alignment adjustments (generally to avoid private properties, 

also to avoid resources including the Umpqua River. 

Visual Resources (1 percent of comments) 4.7 

 Concerns over the aesthetic impacts of both the 160-foot-tall LNG storage tanks and the 230-

mile-long cleared pipeline right-of-way. 

Socioeconomics (9 percent of comments) 4.8 

 The few jobs created by the project are not worth the safety and environmental risks that are 

involved. 

 The project would create jobs and would spur economic growth in the area. 

 Impacts to the local economy, including anticipated drop in tourism (fishing, golf) and families 

relocating over safety concerns. 

 Concerns over decreased property values, eminent domain. 

 Concerns over what taxes would be collected, and to go towards which services/protections. 

Transportation (1 percent of comments) 4.9 

 Impacts to harbor traffic, including recreational and commercial boating and fishing. 
1.0 – Introduction 1-41 

TABLE 1.6-2 

Environmental Issues Identified During the Pre-filing Public Scoping Process for the JCE & PCGP Project

Specific Issue/Comment 

EIS Section Where 

Comments are 

Addressed 

Cultural Resources (1 percent of comments) 4.10 

 Impacts to Great Blue Heron rookery and other known traditional use areas near the project site 

should be avoided. 

 Request the presence of a tribal representative or Tribe-approved archaeologist. 

Air Quality and Noise (2 percent of comments) 4.11 

 Concerns over operations emissions of the LNG carriers and terminal on the communities of 

Coos Bay, North Bend and Charleston (respiratory health). 

 Concerns over unodorized natural gas, leaked from the pipeline and becoming trapped under 

inversion layer—a common occurrence in SE Oregon. 

 Concerns over noise from the project. 

Reliability and Safety (27 percent of comments) 4.12 

 Risk of catastrophic events, either accidental, intentional (terrorism) or as a result of a natural 

disaster on the LNG terminal, LNG carriers or the pipeline. 

 Availability and readiness of emergency response personnel in the event of a catastrophic 

incident. 

 Concerns over the health impacts of spilled or leaked gas on nearby communities. 

 Risks faced by LNG carriers in this particular area, given history of high winds and shipwrecks. 

 All parts of the project create targets for terrorists. 

 LNG is inherently dangerous and should not be located so close to populated areas. 

 Siting the LNG terminal so close to the airport is inappropriate due to safety concerns (accidental 

or intentional crash of airplane into the terminal). 

 Worst case scenario should be used for analysis of project safety. 

 Questions over where the LNG would be coming from (no LNG tankers currently fly under the US 

flag). 

Cumulative Impacts (15 percent of comments) 4.13 

 Cumulative impacts to biological resources, including threatened and endangered species 

(terrestrial, aquatic and marine), vegetation and domestic animals. 

 Habitat fragmentation as a result of the 95-foot-wide cleared pipeline right-of-way. 

 Cumulative impacts from emissions from construction and operations of the total project on 

climate change. Some comments even bring up the emissions from the mining of LNG abroad. 

 Cumulative impacts of the project on the economy of Coos Bay, especially the fishing and 

recreation industries. 

 Presumably negative impacts of the project elements on property values over time (especially 

the pipeline running through private land). 

 Anticipated impacts from LNG carrier traffic (safety zone, harbor closure). 

 Decrease in water quality as a result of increased dredging required for LNG carrier traffic. 

On September 4, 2007, Jordan Cove and Pacific Connector formally filed applications with the 

FERC seeking authorizations under sections 3 and 7 of the NGA to construct and operate their 

respective parts of the JCE & PCGP Project. They also sent copies of their applications to public 

libraries in communities along the route. The FERC issued its Notice of Application on 

September 13, 2007. In response to that notice, a total of 37 parties submitted motions to 

intervene. Late motions to intervene were filed by four other parties. 

After the applications were filed, the FERC staff continued to consult with various federal, state, 

and local agencies that have regulatory or permitting authorities. The FERC staff participated in 

a number of post-application interagency meetings and site visits, as shown in table 1.6-1. 

On November 19, 2007, the FERC issued notices that staff would be conducting a site visit to the 

location of the Jordan Cove LNG terminal on December 11, 2007, and would be convening an 

engineering technical conference in Coos Bay, Oregon, on December 12, 2007, to discuss the 

terminal’s engineering design and technical aspects of Jordan Cove’s application. All of the 

post-application interagency meetings were related to the production of the EIS, and the 

participation of staff with parties was therefore exempt from the Commission’s ex-parte rules, 
1-42 1.0 – Introduction

pursuant to section 385.2201(e)(1)(vi). In keeping with the FERC’s regulations, notes of all 

post-application meetings and site visits were placed into the public record for this proceeding. 

At the request of Pacific Connector and the FWS, FERC staff participated in a State and Federal 

Interagency Task Force formed to address potential Project-related impacts on threatened and 

endangered species, and to assist Pacific Connector and Jordan Cove in the production of the 

draft BA. FERC staff attended Task Force meetings in Salem, Oregon on September 25 and 

November 8, 2007, and May 1, 2008. FERC staff representatives attended all other Task Force 

meetings as well as some resource-specific subgroup meetings formed from the Task Force. The 

applicants filed their draft BA with the FERC on March 10, 2008. 

Pacific Connector and Jordan Cove sponsored two other series of public meetings, with open 

houses held in Coos Bay, Canyonville, Shady Cove, and Klamath Falls between April 21 and 24, 

2008, and town hall-style meetings held in Coos Bay, Klamath Falls, Shady Cove, and 

Canyonville between September 22 and 25, 2008. FERC representatives attended those open 

houses, as did the BLM and USFS. 

Between September 5, 2007, and June 2, 2008, the FERC received 42 individual letters 

commenting on the Project that were not form letters. Twenty five of those letters were from 

private citizens, four were from non-governmental organizations, three were from state and local 

government agencies, one from the Governor of Oregon, one from a federal agency, and one 

from a U.S. Senator. These post-application letters were taken into consideration by the FERC 

staff during production of the draft EIS. 

The FERC issued a Notice of Availability (NOA) of the draft EIS on August 29, 2008. The 

NOA established a 90-day period for comments on the draft EIS, ending on December 4, 2008. 

The 90-day comment period was established because the draft EIS disclosed that federal land 

managing agencies may need to amend their LRMPs, and to satisfy public review requirements 

of the agencies for possible input into plan amendments. However, because the USFS has not 

yet disclosed exactly how it intends to amend any specific National Forest Plan for this Project, it 

may have to issue a subsequent notice, conduct scoping, and review the significance of the 

amendments. 

A formal notice was also published by the EPA in the Federal Register on September 5, 2008, 

indicating that the draft EIS was available. The FERC mailed approximately 1,900 copies of the 

draft EIS to interested parties, including federal, state, and local officials and agencies; special 

interest groups; parties to the proceedings; area libraries and newspapers; and individuals and 

affected landowners who requested a copy of the draft EIS. 

On September 19, 2008, the FERC issued a notice announcing the time, date, and location of 

four public comment meetings to take comments on the draft EIS. Dates and locations of the 

public meetings are shown in table 1.6-1. Comments were made by 121 speakers at the public 

meetings. Transcripts of the four public meetings are part of the public record for the JCE & 

PCGP Project. 

Comments from the public meetings, as well as written comments on the draft EIS submitted by 

the public and agencies, are provided along with our responses in Appendix J. Excluding the 

oral comments from the public meetings, the FERC received 92 individual written letters 

commenting on the draft EIS by the comment closing date of December 4, 2008, including 3 
1.0 – Introduction 1-43 

letters from federal agencies, 3 letters from Native American tribes, 2 letters from state agencies, 

1 letter from a local government agency, 23 letters from companies and organizations, and 60 

letters from individuals. These numbers do not include attachments, letters expressing 

opposition or support but not commenting on the draft EIS, or filings by the applicants. A few 

letters were received after the closing date, and these are not included in Appendix J, but are in 

the public record for this proceeding. The general issues raised in comments on our draft EIS are 

listed in table 1.6-4. 

TABLE 1.6-4 

General Topics of Comments Filed on the Draft EIS

General Topic of Comment Percentage of Comments 

General, Adequacy of draft EIS 16 

Purpose and Need 3 

Project Description 7 

Alternatives 9 

Geology 5 

Soils 3 

Water Resources 12 

Vegetation 5 

Wetlands 2 

Fish and Wildlife 7 

Threatened and Endangered Species 6 

Land Use 2 

Recreation <1 

Visual <1 

Socioeconomics 4 

Cultural Resources 2 

Air Quality 2 

Noise <1 

Reliability and Safety 5 

Cumulative Impacts 2 

Mitigation and Restoration 4 

We have made changes in this final EIS, from the draft EIS text, both in response to comments 

received on the draft EIS and as a result of updated information that became available after 

issuance of the draft EIS. This final EIS is being mailed to the agencies, individuals, and 

organizations on the mailing list that is provided in Appendix A, and was submitted to the EPA 

for formal issuance of a NOA. 

In accordance with the CEQ’s regulations implementing the NEPA, no agency decision on a 

proposed action may be made until 30 days after EPA publishes an NOA of the final EIS. 

However, the CEQ regulations provide an exception to this rule when an agency decision is 

subject to a formal internal process that allows other agencies or the public to make their views 

known. In such cases, the agency decision may be made at the same time the notice of the final 

EIS is published, allowing both periods to run concurrently. Should the Commission issue an 

Order authorizing the Project, it would be subject to a 30-day rehearing period. Therefore, the 

Commission could issue its decision concurrently with EPA’s NOA. 
1-44 1.0 – Introduction

Prior to the publication of both the draft and final EISs, the FERC prepared administrative 

review draft EISs that were distributed for review as a whole or in part to those agencies who 

formally agreed to be cooperating agencies in the development of the EIS - the Coast Guard, 

COE, BLM, BOR, USFS, EPA, DOT, FWS, and Douglas County. Sections of the draft and final 

EISs were written with the cooperation and assistance of these agencies.