4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-1

4.6 THREATENED, ENDANGERED, AND OTHER SPECIAL STATUS SPECIES 

Federal agencies are required by section 7 of the ESA (Title 19 USC Part 1536[c]), as amended 

(1978, 1979, and 1982), to ensure that any actions authorized, funded, or carried out by the 

agency do not jeopardize the continued existence of a federally listed endangered or threatened 

species, or result in the destruction or adverse modification of designated critical habitat of a 

federally listed species. The action agency (e.g., the FERC) is required to consult with the FWS 

and/or the NMFS to determine whether federally listed endangered or threatened species or 

designated critical habitat are found in the vicinity of the proposed Project, and to determine the 

proposed action’s potential effects on those species or critical habitats. For actions involving 

major construction activities with the potential to affect listed species or designated critical 

habitat, the federal agency must submit its BA to the FWS and/or NMFS and, if it is determined 

that the action may adversely affect a listed species, the federal agency must submit a request for 

formal consultation to comply with section 7 of the ESA. In response, the FWS and/or NMFS 

would issue a BO as to whether or not the federal action would likely jeopardize the continued 

existence of a listed species, or result in the destruction or adverse modification of designated 

critical habitat. Jordan Cove filed an Applicant-prepared draft BA in March 2008. We are 

preparing a final BA and EFH Assessment that we intend to submit to the FWS and NMFS at 

about the same time we issue this final EIS. This section summarizes our BA findings. 

Oregon has its own ESA that requires state agencies to protect and promote the recovery of statelisted endangered or threatened species. In addition to species listed as threatened or endangered 

under the ESA and Oregon ESA, agencies and organizations such as the FWS, BLM, USFS, 

ODA, and ODFW maintain lists of special concern, sensitive, or rare species that are also 

appropriate to consider in this NEPA analysis. 

For purposes of this environmental analysis, special status plants and animals include the 

following: 

• species that are listed by the federal government as endangered or threatened, or are 

candidates for listing; 

• species listed by Oregon as endangered, threatened, or are candidates for listing; 

• species listed under the MMPA; and 

• species identified by federal or state agencies as rare or sensitive with the potential to 

occur in the vicinity of the proposed Project. 

Using data from the Oregon Natural Heritage Information Center (ORNHIC), FWS, NMFS, 

discussions with USFS and BLM specialists, and information reviews of published and 

unpublished information, the applicants prepared lists of threatened, endangered, and special 

status species that potentially occur in the vicinity of the proposed Project, as described in the 

following sections. 

4.6.1 Federally Listed Threatened and Endangered Species 

Twenty-nine federally endangered or threatened species potentially occur in the proposed Project 

area (table 4.6.1-1), and are discussed below. In addition, two species have federally threatened 

status in Oregon: the Canada lynx and bull trout Klamath River DPS. However, these species 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-2 

TABLE 4.6.1-1. 

Federally Listed Species Potentially Occurring in the Proposed Project Area

Federal Species Status State Status 

Portion of the Project 

Area Where Species 

May Occur 

Effect of 

proposed 

Project a/

Mammals 

Steller sea lion 

Eumatopias jubatus 

Threatened- Critical 

Habitat Vulnerable 

LNG carrier route 

Port access channel 

LNG terminal 

NLAA 

Blue whale 

Balaenoptera musculus Endangered Endangered LNG carrier route NLAA 

Fin whale 

Balaenoptera physalus Endangered Endangered LNG carrier route NLAA 

Killer whale –Eastern North Pacific 

Southern Resident stock 

Orcinus orca 

Endangered No listing LNG carrier route NLAA 

Humpback whale 

Megaptera novaeangliae Endangered Endangered LNG carrier route NLAA 

Sei whale 

Balaenoptera borealis Endangered Endangered LNG carrier route NLAA 

Sperm whale 

Physeter macrocephalus Endangered Endangered LNG carrier route NLAA 

Birds 

Short-tailed albatross 

Phoebastris albatraus Endangered No listing LNG carrier route NLAA 

California brown pelican 

Pelecanus occidentalis Endangered Threatened Port access channel 

LNG terminal NLAA 

Western snowy plover 

Charadrius alexandrinus nivosus 

Threatened – Critical 

Habitat Threatened Port access channel 

LNG terminal NLAA 

Marbled murrelet 

Brachyrampus marmoratus 

Threatened – Critical 

Habitat Threatened 

LNG carrier route 

Port access channel 

LNG terminal 

Pacific Connector pipeline 

LAA 

Northern spotted owl 

Strix occidentalis caurina 

Threatened – Critical 

Habitat Threatened LNG terminal Pacific Connector pipeline LAA 

Fishes 

Green sturgeon (Southern DPS) 

Acipenser medirostris 

Threatened – 

Proposed Critical 

Habitat 

No listing Port access channel 

LNG terminal NLAA 

Coho salmon (S. OR/N. CA Coast) 

Oncorhynchus kisutch 

Threatened – Critical 

Habitat Critical Pacific Connector pipeline LAA 

Coho salmon (Oregon Coast ESU) 

Oncorhynchus kisutch

Threatened – Critical 

Habitat Critical 

Port access channel 

LNG terminal 

Pacific Connector pipeline 

LAA 

Lost River sucker 

Deltistes luxatus 

Endangered – 

Proposed Critical 

Habitat 

Endangered Pacific Connector pipeline LAA 

Shortnose sucker 

Chasmistes brevirostris 

Endangered – 

Proposed Critical 

Habitat 

Endangered Pacific Connector pipeline LAA 

Amphibians and Reptiles 

Green turtle 

Chelonia mydas Threatened Endangered LNG carrier route NLAA 

Leatherback turtle 

Dermochelys coriacea Endangered Endangered LNG carrier route NLAA 

Olive Ridley turtle 

Lepidochelys olivacea Endangered Endangered LNG carrier route NLAA 

Loggerhead turtle 

Caretta caretta Threatened Threatened LNG carrier route NLAA 

Invertebrates 

Vernal pool fairy shrimp 

Branchinecta lynchi 

Threatened – Critical 

Habitat No listing Pacific Connector pipeline NLAA 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-3

TABLE 4.6.1-1. 

Federally Listed Species Potentially Occurring in the Proposed Project Area

Federal Species Status State Status 

Portion of the Project 

Area Where Species 

May Occur 

Effect of 

proposed 

Project a/

Plants 

Applegate’s milk-vetch 

Astragalus applegatei Endangered Endangered Pacific Connector pipeline NLAA 

Gentner’s fritillary 

Fritillaria gentneri Endangered Endangered Pacific Connector pipeline NLAA 

Western lily 

Lillium occidentale Endangered Endangered Pacific Connector pipeline No effect 

Large-flowered meadowfoam 

Limanthes floccose ssp. Grandiflora Endangered Endangered Pacific Connector pipeline No effect 

Cook’s lomatium 

Lomatium cookie Endangered Endangered Pacific Connector pipeline NLAA 

Kincaid’s lupine 

Lupinus suphureus var. kincaidii 

Threatened –Critical 

Habitat Threatened Pacific Connector pipeline LAA 

Rough popcornflower 

Plagiobothrys hirtus Endangered Endangered Pacific Connector pipeline No effect 

a/ Impact Key: 

Impact: NLAA = Not likely to adversely affect, LAA = Likely to adversely affect 

are not known or expected to occur within the proposed Project area and are not discussed 

further in this document (Canada lynx: Verts and Carraway 1998, McKelvey et al. 2000, 

ORNHIC 2006a; bull trout Klamath River DPS: FWS 1998a and 2002, ORNHIC 2006a). Table 

4.6.1-1 lists all potentially affected federally listed species, indicates the segment of the proposed 

Project where they are likely to occur, and provides our preliminary determination of effect. 

4.6.1.1 Mammals 

Northern (Steller) Sea Lion (Federal Threatened Species, No State Status) 

Steller sea lions range along the North Pacific Rim from northern Japan to California (Csuti et. al 

2001), but most are found in the Gulf of Alaska and Aleutian Islands. Steller sea lions spend 

most of their time at sea (NMFS 1993). Rookeries, where adults gather during the reproductive 

season, and haul-out sites and surrounding aquatic areas provide foraging habitats, prey 

resources, and refuge for the pinnipeds (NMFS 1993). Major rookeries in Oregon are Pyramid 

Rock at Rogue Reef (about 80 miles south of the waterway to the LNG terminal), and Long 

Brown Rock and Seal Rock at Orford Reef (about 55 miles south of the waterway to the LNG 

terminal). There is also a haul-out site at Cape Arago in Coos County, a few miles south of the 

entrance to Coos Bay (ORNHIC). Steller sea lions occur in Oregon from mid-May through 

September (Verts and Carraway 1998). This species is protected by the MMPA and is included 

on the BLM’s North Spit Plan for wildlife. 

In Oregon, numbers of Steller sea lions utilizing Arch Rock and Orford Reef have been 

significantly affected by human disturbances, including vessel traffic (NMFS 1995a). Although 

commercial harvest (of pups) has not occurred since the 1970s, there may be some continued 

incidence of illegal shooting, though the magnitude of that factor is unknown. Likewise, 

predation by sharks and killer whales occurs but at unknown levels. A total of 5,297 Steller sea 

lions were counted in Oregon in 2002 (NMFS 2008). 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-4 

Steller sea lion critical habitat includes all major Steller sea lion rookeries and associated air and 

aquatic zones. Critical habitat includes an air zone that extends 3,000 feet (0.9 kilometers) above 

areas historically occupied by sea lions at each major rookery in California and Oregon, which is 

measured vertically from sea level. Critical habitat includes an aquatic zone that extends 3,000 

feet (0.9 kilometers) seaward in state and federally managed waters from the baseline or 

basepoint of each major rookery in California and Oregon. According to the NMFS, the 

following are designated as critical habitat in Oregon: 

• Rogue Reef: Pyramid Rock 

• Orford Reef: Long Brown Rock and Seal Rock 

Essential physical and biological features of critical habitat (primary constituent elements or 

PCEs) that support reproduction, foraging, resting, and refuge for Steller sea lion include 

terrestrial habitats used as rookeries and haulouts, aquatic habitats that include nearshore waters 

around rookeries and haulouts, communal rafting sites, food resources and foraging habitats 

(NMFS 1993). Based on the above information, critical habitat for the Steller sea lions is not 

designated within the LNG carrier transit route; however, Steller sea lions could potentially 

occur within all three zones of the LNG carrier transit route on their way to and from northern 

feeding areas and haulouts. 

Impacts and Conservation Measures

The proposed action could affect critical habitat, including a zone 3,000 feet seaward, associated 

with Rogue Reef (Pyramid Rock) and Orford Reef (Long Brown Rock and Seal Rock) near 

Bandon if a spill or release occurred from a LNG carrier. The possibility of spills or releases by 

LNG carriers is impossible to predict since there is no baseline data available. Overall, spills 

from various vessel types within Oregon waters since 2002 have been generally low, mostly 

related to fishing vessels or other harbor craft including recreational vessels. 

Potential direct effects of the proposed terminal would include injury and/or mortality due to 

ship-strikes and potential adverse effects from a carrier spill and/or release of LNG at sea. Spills 

and/or released LNG could indirectly affect Steller sea lions by impacting forage species. 

Similarly, turbidity generated by dredging the Coos Bay estuary could cause indirect effects to 

forage species. These effects are addressed below. 

The population of Steller sea lions in Oregon was estimated at 5,000 in 2002 (NMFS 2006a) 

with an annual rate of increase of 3.1 percent (Pitcher et al. 2007). A simplistic population 

projection with that constant rate of increase predicts an Oregon population of 6,400 Steller sea 

lions in 2012 (6,720 animals if the constant growth rate is 3 percent), the first possible year of 

LNG carrier traffic to and from the LNG terminal. Assuming the statewide population could be 

anywhere within the EEZ along the 326 nautical mile (nmi)-long Oregon coast between the 

California and Washington borders (from Crescent City to the Columbia River), the density of 

Steller sea lions in that 65,200 nmi2

 (86,250 mi2 ) area is 1 per 10 nmi2 (1 per 13.5 mi2 ). 

Consequently, the chance for a Steller sea lion to be struck by an LNG carrier is more likely than 

for strikes to cetaceans, based only on density estimates. However, records of ships striking 

Steller sea lions have not been found and, due to their greater maneuverability than large 

cetaceans, Steller sea lions are assumed to be capable of avoiding collisions with large ships, 

including LNG carriers. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-5

In addition, 150 sand barge trips from the Port’s dredge spoils storage site have been estimated 

through the first 7 years of the Project operation or during a total 7-year period. Tug/barge units 

are assumed to traverse the EEZ offshore beyond the Territorial Sea limit (0 to 12 nmi) but 

within the Contiguous Zone 12 to 24 nmi offshore (U.S. Commission on Ocean Policy 2004). 

From Coos Bay, the barges are expected to haul sand to San Francisco, 451 nmi away (67,650 

ship-miles per year). The additional traffic contributed by tug-barge units would increase the 

overall vessel traffic (added to 141,920 ship-miles per year by LNG carriers in California, 

Oregon, and Washington waters combined) associated with the proposed action to 209,570 

annual ship-miles by transits to San Francisco. The addition of tug-barge units would increase 

vessel traffic by 4.2 percent over vessel traffic estimated in 1998-1999. Barges used to remove 

sand from the Port storage sites to San Francisco would be traveling at slower speeds that are 

recognized by NMFS as a relatively low risk for striking and killing marine mammals. Steller 

sea lions may be more facile avoiding tugs and barges than ships though perhaps more 

susceptible closer to shore than far at sea, but neither assumption has been tested and the 

contribution of barge traffic to Steller sea lion mortality is unknown though likely at least as 

insignificant as potential strikes by LNG carriers. 

There is concern that, if Steller sea lions become attracted to harbors whether by humans feeding 

them directly or by easily obtained food from fish processing stations, there would be an 

increased risk of collisions with ships (NMFS 2007a). However, LNG carriers once inside the 

harbor would not proceed at speeds (in the range of 4 to 10 knots) that would risk striking a 

Steller sea lion if one was present within the Coos Bay Estuary action area. 

Based on the double hulled construction of LNG carriers and the outstanding operating and 

safety record of LNG carriers, the probability of any incidents that could result in the loss of 

LNG cargo are extremely low. Oil spills at sea or offshore can also harm Steller sea lions 

through a variety of pathways (NMFS 2007a). Any potential spills that could occur and that 

could affect the Steller sea lions, would more likely be due to fuels or lubricants associated with 

the operation of the LNG carrier. These products are kept in relatively small quantities on ships 

and would not result in the types of affects associated with a spill from an oil tanker. 

It appears that the background rate of spills off the Oregon coast by fishing vessels, recreation 

vessels, and other vessel types is generally low. If an unignited LNG spill were to occur along 

the LNG carrier transit route in the areas used as migratory routes by marine mammals, the LNG 

would float on the water until it vaporizes and would not have an adverse effect on the mammals, 

unless they come in direct contact with the LNG. Some cooling of the upper water layers closest 

to the LNG spill would be expected, but would not likely cause the overall water column to cool 

to the point of affecting the mammals in the water, given the ambient water temperatures in the 

transit route and the adaptability of marine mammals to varying water temperatures. If the vapor 

from an LNG spill were to come in contact with an ignition source the resulting fire would burn 

back to the spill source and would affect species on the water or in the area that come in direct 

contact with the fire. Mammals in the water would not be affected as the fire would be above the 

water in the area of the spill where the vaporized LNG is flammable. In either case of lower or 

higher water temperatures based on the spill scenario, mobile mammals would move out of the 

area until the water temperatures return to normal. 

Turbidity increases during dredging within the Coos Bay Estuary action area could slightly 

decrease foraging efficiencies for Steller sea lion in the immediate vicinity of the proposed slip. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-6 

Dredging is not expected to cause re-suspension of sediment contaminants at levels that could 

affect Steller sea lions if they were foraging in the Estuarine action area. Any effects would be 

short-term. 

In order to decrease the likelihood of vessel collisions with Steller sea lions, the LNG carriers 

entering Coos Bay would be traveling at speeds between 4 and 10 knots. Transit at these speeds 

would minimize the potential for direct effects (animal strikes), as well as indirect effects due to 

wave action from passing ships. The same Ship-Strike Reduction Plan, including marine 

mammal avoidance guidelines, that is described below for whales to minimize potential ship 

strikes to cetaceans by LNG carriers and sand barges (for a duration of 7 years only) could 

similarly minimize risk of strikes to Steller sea lions within the EEZ action area. Based on 

discussed effects and with implementation of the proposed conservation measures, the proposed 

action is not likely to adversely affect Steller sea lions and is not likely to adversely affect 

designated critical habitat. 

Whales 

Six species of federally listed whales potentially occur off the coast of Oregon, including the 

blue, fin, southern resident killer, humpback, sei, and sperm whales. These species tend to feed 

during the summer in the northern latitudes and migrate to the tropical southern latitudes in the 

winter for breeding. However, whales could be encountered off the coast of Oregon throughout 

the year. The Project area applicable to whales is the EEZ, extending 200 nautical miles offshore 

from the Coos Bay Head. Within the EEZ area, effects to whales would be associated with LNG 

carriers inbound and outbound from the LNG terminal. To date, sources of LNG that would be 

shipped to the LNG terminal have not been identified. All of these whale species are federally 

protected under the MMPA. 

Blue Whale (Federal Endangered Species, State Endangered Species)

Blue whales are distributed from the equator to polar icepacks in both the northern and southern 

hemispheres. The eastern north Pacific population ranges from the Aleutian Islands and the Gulf 

of Alaska to central California during the summer and from central Baja California, Mexico. 

Blue whales are most likely seen off the Oregon coast from late May through June and from 

August through October. This species is a baleen whale that feeds on euphausiids commonly 

referred to as “krill” (Maser et al. 1981). According to Oregon Parks and Recreation Department 

(OPRD 2007) blue whales are occasionally sighted off the Oregon coast. The abundance of 

blue whales off of California has been increasing over the past two decades. However, at least 

some of this increase has been attributed to a shift in distribution from other regions to the 

California area. This is supported by a decrease in whales in areas of former abundance (NMFS 

1998a). Blue whales may be encountered along the LNG carrier transit route between late May 

through June and from August through October. 

Fin Whale (Federal Endangered Species, State Endangered Species)

Fin whales are widely distributed throughout the world’s oceans. Recent observations show fin 

whales to be present year-round in central and southern California and the Gulf of California, 

and in summer and fall off of the Oregon and Washington Coast. Their summer range extends 

from California to the Chukchi Sea in the eastern North Pacific. Acoustic signals from fin 

whales are detected year-round off northern California, Oregon, and Washington, with a 

concentration of vocal activity between September and February (NMFS 2006b). Fin whales are 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-7

reported to return to the same feeding grounds year after year. It is not known if feeding grounds 

are located within the Route. This species primarily feeds on euphausiids and secondly on fishes 

and cephalopods (Maser et al. 1981). According to OPRD (2007) fin whales are occasionally 

sighted off the Oregon coast. This species may be encountered in any of the three zones of the 

LNG carrier transit route from May to September. 

Southern Resident Killer Whale (Federal Endangered Stock, No State Status)

Killer whales have a worldwide distribution but are most common in the subarctic, temperate, 

and subantarctic waters (Maser et al. 1981). Along the north Pacific coast, resident killer whales 

occur from Oregon and Washington to the Bering Sea (NMFS 2006b), with distribution 

correlated to supplies of their primary food, fish and marine mammals (Maser et al. 1981). The 

Southern Resident stock occurs within the inland waters of Washington and southern British 

Columbia. In 2007, there was a Southern Resident killer whale population of three pods, totaling 

about 100 individuals. These pods may travel as far south as California. In Oregon, they have 

been observed only four times between 1999 and 2006, at offshore areas near Depoe Bay, 

Yaquina Bay, and the Columbia River. There is also a West Coast transient population of killer 

whales between California and Alaska of about 320 individuals, and an off-shore killer whale 

population between California and Alaska of about 361 individuals. Transients have been 

reported at the mouth of rivers in Oregon. A single stranding was reported at Bandon, Oregon in 

2004. Killer whales occasionally enter lower Coos Bay but rarely occur as far upstream as the 

LNG terminal. NMFS designated critical habitat for the southern resident killer whale in 

November 2006 that included the San Juan islands, the Straits of Juan de Fuca, and Puget Sound. 

According to Maser et al. (1981), killer whales are the most abundant in the Puget Sound in late 

summer and November. Most southern California killer whale sightings occur in fall, winter, 

and early spring. Based on this information, killer whales are most likely to be encountered in 

Oregon during the fall, with occasional sighting possible throughout the year. Killer whales are 

likely to occur along the LNG carrier transit route. 

Humpback Whale (Federal Endangered Species, State Endangered Species)

The humpback whale is distributed in both the northern and southern hemispheres, from tropical 

waters to the edge of the polar ice. In the eastern Pacific, humpback whales have been observed 

from the Chukchi Sea to southern Mexico. The summer range of the eastern Pacific humpback 

whale is from Chukchi Sea to southern California. During the whaling period, this species was 

harvested off the Pacific Northwest coast between April and October. This species feeds on 

benthic and pelagic euphausiids and small schooling fishes (Maser et al. 1981). 

OPRD (2007) states that humpbacks are sometimes seen off the Oregon coast at the same time as 

gray whales, but are not observed as frequently because their pod size is smaller. In 2002, a 

study was conducted by Oregon State University’s Marine Mammal Program to track the 

movement of humpbacks off the Oregon coast during their summer feeding season (Lagerquist 

and Mate 2002). Between July 29 and August 1 2002 a total of 10 whales were observed from 

approximately Newport, Oregon to Crescent City, California (Lagerquist and Mate 2002). The 

study reports that sighting conditions were poor so it is likely that some humpbacks were missed. 

Humpbacks may be encountered along the LNG carrier transit route from spring through early 

fall. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-8 

Sei Whale (Federal Endangered Species, State Endangered Species)

Sei whales are distributed worldwide including an eastern Pacific stock that is found from Alaska 

to Mexico. They are generally found far from shore and do not appear to approach coastal areas. 

Between 1991 and 2005, there were two sightings of sei whales in the EEZ off the coast of 

Oregon, so it may be present in the analysis area. The density of sei whales off the 

Oregon/Washington coast was recently estimated at 0.02 per 100 km2 (1 per 1,930 mi2). This 

species is also found off the central California coast in the late summer or early fall and appears 

to move farther south and offshore in the winter. Sei whales feed on copepods, euphausiids, 

sauries, anchovies, herring, sardines, squid, and jack mackerel. OPRD does not list the Sei 

whale as one of the species that can be observed off the Oregon Coast. However, based on 

information in Maser et al. (1981), this species may be encountered along the LNG carrier transit 

route during summer months. 

Sperm Whale (Federal Endangered Species, State Endangered Species)

Sperm whales are the largest of the toothed (Odontoceti) whales. The sperm whale diet consists 

of fishes and cephalopods. This species is distributed worldwide except for the pack ice of polar 

regions. Sperm whales migrate toward the polar regions in the summer to temperate regions in 

the winter (Maser et al. 1981). They have been seen off the Oregon/Washington coast yearround except for between December and February. Sperm whales may be encountered along the 

LNG carrier transit route from spring to fall. 

Whale Impacts and Conservation Measures 

Potential direct effects of the proposed Project could include injury and/or mortality due to shipstrikes and potential adverse effects from a ship spill and/or release of LNG at sea. Spills and/or 

released LNG could indirectly affect whales by impacting forage species. 

There is an ongoing threat of ship strikes to whales; however, from available accounts (Laist et 

al. 2001; Jensen and Silber 2003) ship-whale collisions occur fairly infrequently. Ship strikes of 

blue whales averaged 0.6 deaths or injury per year (1 death or injury per 1.67 year) in Pacific 

waters between 2002 and 2006 (Carreta et al. 2008). During 6 years, from 2002 to 2007, one 

blue whale was struck and killed by a ship off the coast of Oregon (Barre 2008). That computes 

to 0.17 blue whale death per year due to ship strikes in Oregon and Washington coastal waters. 

The likelihood of a ship-whale collision varies by species of whale. Researchers have found that 

fin and humpback whales are struck by ships relatively often (Laist et al. 2007), while killer 

whales have only rarely been documented as being injured or killed by a collision (Jensen and 

Silber 2003; NMFS 2008). Table 4.6.1.1-1 illustrates these variable ship strike rates based on 

one study along the Pacific Coast between 2002 and 2006 (Carreta et al. 2008), and the second 

within Oregon and Washington waters between 2002 and 2007 (Barre 2008). However, it is 

assumed that many ship strikes with cetaceans are unknown and unreported. 

Table 4.6.1.1-1 

Ship Strike Rates of Federally Listed Whales Potentially Occurring in the LNG Carrier Transit Route

Species Pacific Coast a/ Oregon and Washington b/

Blue whale 0.6 0.17 

Fin whale 1.6 0.67 

Killer whale 0.2 NA 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-9

Table 4.6.1.1-1 

Ship Strike Rates of Federally Listed Whales Potentially Occurring in the LNG Carrier Transit Route

Species Pacific Coast a/ Oregon and Washington b/

Humpback whale 0 0.17 

Sei whale 0.2 0.17 

Sperm whale 0 0.17 

a/ Based on Carreta et al. 2008 that documented ship strike mortality per year in Pacific Coast waters between 2002 and 2006. 

b/ Based on Barre 2008 that documented ship strike deaths and injuries per year in Oregon and Washington waters between 2002 

and 2007. 

If all LNG carriers maintained an east-west course, the 80 ships expected to enter and exit the 

LNG terminal each year would cross 200 nmi of the EEZ for 160 annual ship transits, equivalent 

to 32,000 ship-miles (one ship traveling one nautical mile) per year. By comparison, shipping 

traffic within coastal Oregon and Washington (Crescent City, California near the Oregon border 

to Cape Flattery at the entrance to the Strait of Juan de Fuca, Washington) was estimated at over 

2 million annual ship-miles per year, based on annual coastal ship transits between 1998 and 

1999 (Pacific States/British Columbia Oil Spill Task Force 2002). Although coastal vessel 

traffic has increased since 1998 to 1999 and would continue to increase (Coast Guard 1999), the 

32,000 ship-miles per year contributed by proposed LNG carriers would amount to a 1.6 percent 

increase in shipping in coastal Oregon and Washington over the 1998-1999 estimates. That 

increase would be less if based on current vessel traffic volumes. That increase could cause an 

increase in the probability of ships striking whales. For example, with 0.17 blue whale deaths 

per year due to ship strikes in Oregon and Washington coastal waters, the increased vessel traffic 

due to LNG carriers would be expected to increase ship strikes to blue whales by 0.003 whales 

per year. Based on this example, the increased ship strikes due to increased vessel traffic from 

this Project for other species would be: 0.011 for fin whale, and 0.003 for humpback, sei, and 

sperm whales. If that number is extrapolated to the expected life of the Project (50 years), the 

cumulative increased risk to whales from ship strike would be 0.55 for fin whales, and 0.15 for 

blue, humpback, sei, and sperm whales. 

Alternatively, LNG has also been imported to the United States (Energy Information 

Administration 2007) from the Caribbean (Trinidad), west and north Africa (Nigeria, Algeria, 

Egypt), and the Middle East (Oman, Qatar, United Arab Emirates). LNG from those countries 

would most likely ship to the proposed LNG terminal around South America or Africa, but not 

through the Panama Canal since LNG carriers are too wide to fit through the canal, which has an 

approximate width limit of 109 feet. 

LNG carriers traveling from the southern hemisphere, especially from the west coast of South 

America, would most likely travel the coastline and EEZ from San Diego, California north to 

Coos Bay. The estimated total coastal vessel traffic within California, Oregon, and Washington 

is over 5 million ship-miles per year. LNG carriers would transit 887 nmi between San Diego 

and Coos Bay and 80 ships per year (160 annual transits) would generate an additional 141,920 

ship-miles per year (assuming that all LNG carriers would return to ports of origin along the west 

coast). With the same assumptions as above, the additional 141,920 ship-miles per year 

contributed by proposed LNG carriers would amount to an increase of 2.8 percent in vessel 

traffic within coastal California, Oregon, and Washington (based on 1998-1999 levels). This 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-10

increased traffic would also cause an increase in the probability of ships striking whales. For 

example, with an assumed constant annual rate of 0.17 blue whale death per year due to ship 

strikes in Oregon and Washington coastal waters and an average 0.6 death or injury per year in 

California coastal waters (averaged from 2000 to 2004), the increase in vessel traffic due to LNG 

carriers would be expected to increase ship strikes to blue whales by 0.022 whale per year. 

In addition, 150 sand barge trips from the Port’s dredge spoils storage site have been estimated 

through the first 7 years of the Project operation or during a total 7-year period. An estimated 75 

barges each year are expected to remove an annual total of 500,000 cubic yards of dredged sand 

stored at the Port spoil storage site. At that rate, the stored material should be removed in 7 

years. Tug/barge units are assumed to traverse the EEZ offshore beyond the Territorial Sea limit 

(0 to 12 nmi) but within the Contiguous Zone 12 to 24 nmi offshore (U.S. Commission on Ocean 

Policy 2004). 

From Coos Bay, the barges are expected to haul sand to San Francisco, 451 nmi away (67,650 

ship-miles per year). The additional traffic contributed by tug-barge units would increase the 

overall vessel traffic (added to 141,920 ship-miles per year by LNG carriers in California, 

Oregon, and Washington waters combined) associated with the proposed action to 209,570 

annual ship-miles by transits to San Francisco. The addition of tug-barge units would increase 

vessel traffic by 4.2 percent over vessel traffic estimated in 1998-1999. 

Tug-towed barges are likely to proceed at slow speeds. Various manufacturers of articulated 

tug/barge units (e.g., Crowley - see www.crowley.com, or Ocean Tug & Barge Engineering - see 

www.oceantugbarge.com) advertise speeds at around 12 knots; articulated units (tug pushing 

barge) are faster than tugs towing barges. To minimize ship collisions with right whales on the 

East Coast, NMFS (2006i) advised reducing vessel transit speeds in known habitats to 10 knots 

or less. Most reports of whale deaths occur when vessel speeds exceed 13 knots (Laist et al. 

2001). Barges used to remove sand from the Port storage sites to San Francisco would be 

traveling at slower speeds that are recognized by NMFS as a relatively low risk for striking and 

killing cetaceans. Whales are expected to be more facile avoiding tugs and barges than ships and 

less susceptible closer to shore, but neither assumption has been tested and the contribution of 

barge traffic to whale mortality is unknown though likely at least as insignificant as potential 

strikes by LNG carriers. 

Oil spills at sea or offshore might harm whales although effects of oil spills on whales have not 

been reported (NMFS 1998a) but effects to krill (euphausiids) food sources could occur. 

However, based on the double hulled construction of LNG carriers and the outstanding operating 

and safety record of LNG carriers, the probability of any incidents that could result in the loss of 

LNG cargo are extremely low. Potential spills that could occur and that could affect whales 

would more likely be fuels or lubricants associated with the operation of the LNG carrier. These 

products are kept in relatively small quantities on ships and would not result in the types of 

affects associated with a spill from an oil tanker. 

Releases of diesel fuel and/or gasoline are possible. According to annual reports published by 

the Pacific States/British Columbia Oil Spill Task Force, ODEQ reported 34 spills from fishing 

vessels or other harbor craft in 2002, 38 spills in 2003, and 7 spills from fishing vessels plus 

spills from 27 other vessel types in 2004. Those relatively consistent incidences apparently 

increased in 2005 with 18 spills from fishing vessels, 20 from recreational vessels, and 27 spills 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-11

by other vessel types. By contrast in 2006, there were three spills from fishing vessels, six spills 

from recreational vessels, and only six spills from other vessel types. Though not known, it 

appears that the background rate of spills off the Oregon coast (incidence of spills in proportion 

to total vessel operation) by fishing vessels, recreation vessels, and other vessel types is generally 

low. 

If an unignited LNG spill were to occur along the LNG carrier transit route in the areas used as 

migratory routes by whales, the LNG would float on the water until it vaporizes and would not 

have an adverse effect on the mammals, unless they came in direct contact with the LNG. Some 

cooling of the upper water layers closest to the LNG spill would be expected, but would not 

likely cause the overall water column to cool to the point of affecting the mammals in the water, 

given the ambient water temperatures in the transit route and the adaptability of marine mammals 

(such as whales) to varying water temperatures. If the vapor from an LNG spill were to come in 

contact with an ignition source, the resulting fire would burn back to the spill source and would 

affect species on the water or in the area that come in direct contact with the fire. Mammals in 

the water would not be affected as the fire would be above the water in the area of the spill where 

the vaporized LNG is flammable. In either case of lower or higher water temperatures based on 

the spill scenario, mobile mammals would move out of the area until the water temperatures 

return to normal. 

LNG carriers have been operating commercially since 1959. Since then there have been more 

than 38,000 LNG carrier voyages, covering more than 60 million miles and transported a total of 

1.5 billion cubic meters of LNG. Currently, approximately 196 LNG carriers safely transport 

more than 287 million cubic meters of LNG annually to ports around the world. There have 

been approximately 11 reportable incidents between 1979 and 2006 worldwide. Since LNG has 

not been transported to the Pacific Northwest, no data are available. However, due to the double 

hulls of LNG carriers, none of the incidents that have occurred with LNG carriers have resulted 

in the loss of LNG cargo or other significant petroleum based spills. Due to the implementation 

of risk mitigation measures, the risk of a release of LNG from a carrier is extremely low. 

Jordan Cove has proposed to provide measures supplied by NMFS to minimize potential ship 

strikes to cetaceans, and possibly other listed (Steller sea lion, sea turtles) and non-listed marine 

species by LNG carriers in a Ship-Strike Reduction Plan. LNG carriers would transit to the slip 

at slow speeds (approximately 4 to 10 knots), which would result in minimal wakes such that 

whales would not be affected by the wakes of passing LNG carriers and the barges used to 

transport the sand temporarily stockpiled at the Port site (7 years total). 

Additional measures in the Ship-Strike Reduction Plan to further reduce the likelihood of 

adverse effects on these species would include the following: 

• Providing training to LNG carrier crews that would include the use of a reference guide 

such as the Marine Mammals of the Pacific Northwest, including Oregon, Washington 

British Columbia and South Alaska by Pieter Folkens. This is a pamphlet that could be 

carried on the LNG carriers. 

• Require LNG carrier crews to maintain a watch for marine mammals and slow the ship to 

avoid striking protected species. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-12

• When marine mammals are sighted, maintain a distance of 90 meters or greater from the 

whale. 

• Attempt to maintain a parallel course to the animal and avoid excessive speed or abrupt 

changes in direction until the animal has left the area. 

• Reduce ship speed when pods or large assemblages of cetaceans are observed near an 

underway ship. 

• When marine mammals are sighted in a ship’s path or in close proximity to a moving 

ship, reduce speed or shift the engine to neutral until animals are clear of the area or path 

of the ship. 

• LNG carrier crews would be asked to report sightings of any injured or dead protected 

species immediately, regardless of whether the injury or death is caused by the ship. If 

the injury or death is caused by a collision with the ship, FERC would be notified within 

24 hours of the incident. Information to be provided would include the date and location 

(latitude/longitude) of the strike, the ship name, and the species or a description of the 

animal, if possible. 

Based on the effects discussed above, and the conservation measures that would be implemented 

to avoid negative impacts, the proposed action is not likely to adversely affect any whale species. 

4.6.1.2 Birds 

Short-tailed Albatross (Federal Endangered Species, No State Status) 

The short-tailed albatross was listed as endangered in Japan on October 13, 1970 (FWS 1970) 

and throughout its range in the United States on July 31, 2000 (FWS 2000). The primary threat 

leading to the species’ decline and ultimate listing was over-harvest for feathers (FWS 2000b). 

Another major threat to the short-tailed albatross is their small population size; there are only 

two breeding populations existing, one of which is threatened by volcanic activity (FWS 2005e). 

Oil development occurs in many parts of the short-tailed albatross’ marine, off-shore range, and 

oil spills are a threat to conservation and recovery. 

The short-tailed albatross nests on flat or sloped sites with sparse or full vegetation on isolated 

windswept offshore islands with limited human access (FWS 2000b). The only terrestrial area 

within United States jurisdiction where the short-tailed albatross is currently attempting to nest is 

the Midway Atoll. In the North Pacific, the coastal habitat for the short-tailed albatross is in 

high-productivity areas with expansive deep water beyond the continental shelf. Short-tailed 

albatrosses eat squid, fish, eggs of flying fish, shrimp, and other crustaceans (FWS 2000b). The 

short-tailed albatross is a pelagic seabird that is now very rare and only breeds in Japan. It has 

the potential to occur off the coast of Coos County. The most recent records from Oregon have 

been at sea 32 miles west of Yachats, Lincoln County, Oregon. The short-tailed albatross could 

potentially be encountered along the LNG carrier transit route. 

Impacts and Conservation Measures

Since the closest breeding population of short-tailed albatross is within the Hawaiian Islands, the 

Project should not have an effect on recovery criteria for the short-tailed albatross. The shorttailed albatross could potentially be encountered within the LNG carrier transit route zones. The 

effects of a cargo spill from an LNG carrier would be quite different from results of spills from 

crude or refined petroleum ships. Based on the double-hulled construction of LNG carriers and 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-13

the outstanding operating and safety record of LNG carriers, the probability of any incidents that 

could result in the loss of LNG cargo is extremely low. Any potential spills that could affect 

short-tailed albatrosses offshore would more likely be fuels or lubricants associated with the 

operation of the LNG carrier. These products are kept in relatively small quantities on ships and 

would not result in the types of effects associated with a spill from an oil tanker. 

If an unignited LNG spill were to occur within the nearshore approach to Coos Bay, the LNG 

would float on the water until it vaporizes and would not have an adverse effect on short-tailed 

albatrosses, unless they come in direct contact with the LNG. They would most likely escape by 

flying away from spilled LNG. 

If the vapor from an LNG spill were to come in contact with an ignition source, the resulting fire 

would burn back to the spill source and would affect species on the water or in the area that 

come in direct contact with the fire. LNG is mostly composed of methane which, when 

vaporized, is less dense than air and would rapidly rise above the water rather remain at the 

surface. A short-tailed albatross on the water’s surface could possibly get burned before it flew 

away if the LNG suddenly flashed up, but such an event is highly unlikely, especially given the 

low density of short-tailed albatross and low potential for LNG spills. 

The short-tailed albatross has not been documented within 2.5 miles of the proposed Project 

(ORNHIC 2006a) nor reported by the National Audubon Society and BBS routes. Therefore, the 

Project is not likely to adversely affect the short-tailed albatross and the species is not discussed 

further. 

California Brown Pelican (Federal Endangered Species, State Threatened Species) 

The California brown pelican is a primarily coastal species, rarely seen inland or far out at sea 

(FWS 2005). They feed mostly in shallow estuarine waters, normally staying within 20 miles of 

shore (FWS 2005). Pelicans make extensive use of sand spits, offshore sand bars, and islets for 

nocturnal roosting and daily loafing, especially by non-breeders and during the non-nesting 

season (FWS 2005). 

Brown pelicans nest in colonies, mostly on small coastal islands in California (FWS 1985 and 

2007c). Brown pelicans generally breed between February and October and are most abundant 

in Oregon during post-breeding migration (FWS 2005i). In Oregon, numbers peak in late 

August through October, and October through early November there is a gradual decline as birds 

move south (Giligan et al. 1994). Since brown pelicans have wettable feathers, they return to 

land daily to roost and dry their feathers (FWS 2005i). Sand islands within three large estuaries 

in Oregon and Washington serve as primary night roosts (Jaques and O’Casey 2006 as cited in 

FWS 2007c). The total number of brown pelicans in Oregon in 2001 was estimated to be 6,095 

(Marshall et al. 2006). 

Increasing numbers of brown pelicans arrive along the Oregon coast and in the bays (ODFW 

2006p) as early as April, becoming more abundant by August and September (Marshall et al. 

2006). Within Coos Bay, brown pelicans are regularly seen in moderate numbers during the 

summer months, and they also occur in small numbers in the winter (Contreras 1998). In May 

1997, BLM documented a brown pelican at the mouth of Coos Bay (BLM 2006), and the species 

has been documented intermittently by the National Audubon Society during annual CBC 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-14

surveys between 1982 and 2003, primarily from Coos Bay though occasionally from the 

Coquille Valley during that same period. 

Impacts and Conservation Measures

Pacific Connector is proposing to construct within Coos Bay between October 1 and February 

15, the ODFW’s recommended in-water construction timing window (ODFW 2000a); however, 

construction may begin on October 15 to avoid a popular recreational fall Chinook salmon 

fishery in Coos Bay. In Oregon, numbers peak in late August through October, and for the 

period of October through early November there is a gradual decline as birds move south 

(Gilligan et al. 1994). It is possible that the brown pelican could be present within Coos Bay 

during the time of construction (Contreras 1998); however, it is not expected that construction 

within Coos Bay would interfere with brown pelican roosting and feeding. 

In the past, California brown pelicans have been impacted by human disturbances at nesting 

colonies and roosting habitats. Existing nesting and roosting habitats within the Coos Bay 

Estuary and proposed LNG terminal area have not been documented. If they occur within the 

estuary during construction and operation of the proposed action, pelicans may be associated 

with on-shore fish-cleaning stations where they possibly feed on offal (Marshall et al. 2006). 

Existing fish-cleaning stations are present at the Empire Boat Ramp, which is in the City of Coos 

Bay, east and across from the North Spit and the Port’s dredge spoils stockpile site though not 

included in the action area surrounding that location. Designated fish-cleaning stations also 

include Oceanside RV Park and Bastendorff Beach County Park, both in Charleston south of the 

Project’s action area. Fish-cleaning could also occur at the Charleston Marina, California Street 

Boat Ramp, and BLM Boat Ramp, though they are not designated as such. 

Noise and human activities associated with construction and operation of the proposed Project is 

likely to be the only direct effect to brown pelicans if they occur within one or more of the 

Project’s action areas. However, the possibility of adverse effect to the species at fish-cleaning 

stations by noise, particularly at the dredge spoils stockpile site is expected to be minimal since 

individual pelicans would already be associated with human-generated sounds at the BLM Boat 

Ramp and Empire Boat Ramp. Noise generated by stockpiling activities would be of lower 

intensity than noise created by pile driving and construction in general. 

Brown pelicans that forage within the LNG terminal action area could ingest low levels of 

contaminants through the food web that are re-suspended from dredging activities. However, 

sediments at the LNG terminal site or pipeline route within the Bay are not expected to contain 

levels of sediment contaminants that could adversely affect brown pelicans. Access channel 

dredging and maintenance dredging would not occur during the period of peak pelican 

abundance in the lower bay. The proposed action would not significantly disrupt normal 

behavior patterns for brown pelicans. Pelicans that travel over the LNG carrier route could be 

affected by LNG spills, but this is unlikely due to the low potential for such a spill. 

There is some evidence in the literature that high intensity continuous anti-collision lights on 

structures may result in an increased number of bird strikes, especially at night or during fog and 

overcast conditions. The number of strikes can apparently be reduced by strobe or blinking the 

anti-collision lights. The LNG storage tanks would not be illuminated with high intensity 

lighting. The intensity and number of lights would be limited to what is required for security and 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-15

operations. With the low-intensity lighting to be used, the likelihood of adverse effects to brown 

pelicans from collisions with the LNG storage tanks is minimal. 

In-water work associated with the proposed action, including initial dredging of the access 

channel (possibly a small portion of the isolation berm that separates the slip construction from 

the Bay), pipeline installation, and future maintenance dredging activities, would be conducted 

during the approved in-water work period for Coos Bay (October 1 to February 15) unless 

approved by the appropriate agencies, based on conditions at the time. Scheduling the in-water 

work period to minimize potential impacts to juvenile salmonids and other fish/invertebrate 

species would also minimize effects to brown pelicans since there is a gradual decline as birds 

move south from October through early November (Gilligan et al. 1994). Additionally, during 

operation of the Pacific Connector pipeline, aerial inspection of the pipeline would occur within 

the permanent right-of-way. Aerial inspections would generally occur during all times of year, 

although they would not impact brown pelicans since they do not nest or breed within Coos Bay. 

Additionally, aerial inspection should not impact migrating, roosting, or foraging brown pelicans 

since air traffic is a constant disturbance within Coos Bay from the existing North Bend 

Municipal Airport. If the pipeline laid within the bay requires maintenance, activities would 

occur in-water and within the permanent easement; therefore, impacts from maintenance 

activities should not impact brown pelicans any time of the year. 

Western Snowy Plover (coastal) (Federal Threatened Species with Critical Habitat, State 

Threatened Species) 

The western snowy plover is a year-round, uncommon resident of the North Spit (BLM 2005). 

The spit supports the most productive snowy plover population segment on the Oregon coast, 

accounting for over 50 percent of all snowy plovers fledged on the Oregon coast (BLM 2008). 

The southwestern portion of the North Spit is designated as critical habitat for the western snowy 

plover. Western snowy plovers may be encountered in the LNG carrier transit route zones from 

nearshore coastal waters to the LNG terminal site. 

The Pacific coast population of the western snowy plover includes the birds that nest adjacent to 

tidal waters, including all nesting birds on the mainland coast, peninsulas, offshore islands, 

adjacent bays, estuaries, and coastal rivers (FWS 1993). Coastal populations, including those in 

Oregon, typically consist of resident and migratory birds. Large concentrations of migratory 

snowy plovers winter primarily in coastal California, Baja California, and along the coastal 

mainland of Mexico (FWS 1993). Preferred nesting sites include sand spits, dune-backed 

beaches, beaches at creek and river mouths, and salt pans at lagoons and estuaries. Less 

frequently, western snowy plovers nest on bluff-backed beaches, dredged material disposal sites, 

salt pond levees, dry salt ponds, and river bars (FWS 2001). 

Based on the Pacific Coast western snowy plover’s requirements for reproduction, feeding, 

forage and shelter, the FWS (2005b) identified the following essential physical and biological 

features of designated critical habitat: (1) sparsely vegetated areas above daily high tides that are 

relatively undisturbed by the presence of humans, pets, vehicles or human-attracted predators; 

(2) sparsely vegetated sandy beach, mud flats, gravel bars or artificial salt ponds subject to daily 

tidal inundation, but not under water, that support small invertebrates; and, (3) surf or tide-cast 

organic debris such as seaweed or driftwood located on open substrates. Critical habitat in the 

vicinity of the project area (Unit OR 9, Coos Bay North Spit), contains expansive, sparsely 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-16

vegetated interdune flats, areas of sandy beach above and below the high tide line with 

occasional surf-cast wrack supporting small invertebrates, and close proximity to tidally 

influenced estuarine areas (FWS 2005b). 

Designated critical habitat within the Project area includes 278 acres on Coos Bay North Spit, 

within 1.5 miles of the proposed LNG terminal facilities. This tract of land includes features 

essential to the conservation of the species, including expansive sparsely vegetated interdune 

flats (used for nesting and foraging), areas of sandy beach above and below the high tide line 

with occasional surf-cast wrack supporting small invertebrates (for nesting and foraging), and 

close proximity to tidally influenced estuarine areas (for foraging). This unit is capable of 

supporting 54 breeding plovers, which is the management goal within the Draft Recovery Plan 

for this CHU (FWS 2001 and 2005b). Currently there are approximately 2 to 36 breeding pairs 

and 0 to 19 wintering adults that inhabit this designated critical habitat (FWS 2001). Along the 

Oregon Coast there are eight main nesting areas. In 2006, nesting success for those breeding 

sites was the highest recorded since monitoring began in 1990, with 110 birds fledging in 2006 

compared to only three birds that fledged in 1990 (FWS 2006c and 2006d). 

In 1990, one western snowy plover nest was documented at Menesha Spoils along the east side 

of Pony Slough at its confluence with Coos Bay (ORNHIC 2006a), approximately 0.4 mile south 

of the pipeline at MP 1.54. Western snowy plovers have also been documented by the National 

Audubon Society from the Coos Bay CBC surveys every year since 2000 (sporadically in earlier 

surveys); 1 was seen in 1994 (0.01 counted per hour of observation), 10 were counted in 2005 

(0.06 per hour of observation), and 2 were reported in 2006 (0.02 per hour of observation). No 

western snowy plovers were detected during field surveys of the Project site (LBJ Enterprises 

2006). 

Threats to the snowy plover within Critical Habitat include introduction of European beachgrass 

that encroaches on the available nesting and foraging habitat, disturbance from humans, dogs, 

and off-highway-vehicles in important foraging and nesting areas, and predators such as the 

American crow and common raven (FWS 2005f). Increased nest predation of western snowy 

plovers by corvids within the Project area and in affected occupied stands is possible, 

particularly if corvids are attracted to construction sites by trash or discarded food (see for 

example, Liebezeit and George 2002). 

Impacts and Conservation Measures

Best Management Practices 

Increased predator density related to increased human presence and habitat removal was 

identified as a potential concern related to terminal construction. Jordan Cove has identified 

measures to minimize impacts, as described below. 

During construction and operation, the LNG terminal would be kept clear of construction debris 

and food wastes that could attract predators such as birds (e.g., American crows) and mammals 

(e.g., rats, raccoons). Covered, animal-proof receptacles would be provided in eating and break 

areas, parking lots, and at appropriate locations around the construction site. During construction 

the site would be policed on a daily basis to remove any food or other debris left by construction 

workers. During operations the facility and grounds would be regularly inspected to assure that 

no garbage is allowed to accumulate. This should minimize predation on snowy plover eggs and 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-17

chicks; however, corvids and other predators could still be attracted to the area due to the 

increased activity. 

Structures associated with the proposed LNG terminal site would be monitored to discourage use 

by avian predator species. Frequent inspections would ensure that nests are not being 

constructed and all nests found would be removed immediately. It is anticipated that there would 

be sufficient inspections and other activities mandated by safety and security requirements to 

keep the structures nest free. However, in the unlikely event that a nest becomes established and 

it is not discovered until young birds are present, the disposition of the nest would be handled in 

accordance with the provisions of the MBTA. 

The stockpile and dredged spoil disposal locations would be regularly inspected to insure that no 

denning is occurring in the hillocks. If necessary, nylon mesh or other exclusion fencing would 

be installed around the perimeter of the stockpile to prevent the establishment of coyote or skunk 

dens. 

Double layers, at a minimum, of silt fence placed at the toe of the berms would be used to 

contain the movement of the sand at the Port site by wind or water forces. The exterior of the 

berms would be covered in erosion control matting and seeded with native grasses in April - May 

or September. The interior faces of the berms within the site would be controlled in two ways, 

i.e., inundation with wet material and the height of the berms acting as a barrier to windblown 

debris. As placement cells are filled and no longer receiving wetted material, finger dikes, silt 

fence or similar structures not more than 200 feet on center, would be installed in all directions to 

limit migration. Silt fence placed at 100 feet ± on center would generate small berms. If the 

material begins to move, the small berms would limit transport distance and potential movement. 

At final or long-term condition, the entire area would be hydroseeded. Hydroseeding would be 

limited to March–June and September–November, as December–February is typically too cold 

for germination. The months of July–August are typically too dry and seed blows away. Interim 

methods such as spraying tackifier on bare soils have limited effectiveness, but could be utilized 

for short-term stabilization. 

Areas of the site where the stockpiled material is not being disturbed by the shipment for 

commercial sale would be contoured and stabilized with native grasses to achieve conditions that 

are not suitable for snowy plover habitat. No level surfaces devoid of vegetation would be 

allowed to develop. This would serve to minimize the potential for or discourage the use of the 

site by snowy plovers, or specifically those individuals on the North Spit. 

Stormwater would also be controlled by the silt fence placed around the toe of the berms, 

although it is anticipated that storm water flow patterns (quantities and low rates) would be 

appreciably the same present on the site. Noise attenuation would be provided by the berms 

constructed to temporarily contain the stockpiled sand. No additional noise attenuation is 

presently anticipated as the loading would not be a continuous activity. Mobile loading 

equipment would be refueled at the LNG terminal site, thereby minimizing the potential for 

spills. The conveyor system would not be refueled adjacent to the Bay. Spill kits would be 

maintained on each piece of equipment as well as in the supervisor’s truck, such that rapid 

response to accidental spills can be achieved (also see discussion of LNG spills under shorttailed albatross, above). 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-18

Education and Outreach 

Surveys conducted in 2002 indicated that 76 percent of beach visitors were unaware of 

restrictions associated with snowy plovers (OPRD 2007). This indicates that increased education 

could have a significant impact on public awareness of issues surrounding snowy plovers. 

Furthermore, the USFS at the Oregon Dunes NRA and the BLM staff have reported that the 

majority of contacted individuals are more willing to comply with beach-use restrictions after 

better understanding the reasons for them (FWS 2007e). 

Jordan Cove would train all construction and operations staff on the need for snowy plover 

conservation; current snowy plover regulations and recreational use restrictions; and the 

importance of conservation measures, including: litter control, avoidance of nesting and foraging 

areas, keeping pets on-leash, and remaining on established roads and trails. The training 

program would be developed based on guidance provided in Appendix K of the 2007 Plover 

Recovery Plan, or would be contracted for through state/local agencies or organizations (such as 

the Oregon Coast Aquarium, National Park Service, Western Snowy Plover Working Team, or 

Oregon Coast Community College) who may have pre-existing plover education and outreach 

programs. Prior to implementation, the training program would be submitted for comment to 

members of the Western Snowy Plover Working Team. 

The training would be administered concurrently with safety training provided to all staff at the 

beginning of their employment. Training would emphasize the need for snowy plover 

conservation; current snowy plover regulations and recreational use restrictions; and the 

importance of conservation measures, including: litter control, avoidance of nesting and foraging 

areas, keeping pets on-leash, and remaining on established roads and trails. Environmental 

training would also be provided to operational personnel to ensure that all personnel are aware of 

and comply with the management tools in place to affect the recovery and maintenance of the 

snowy plover population on the North Spit. Printed educational materials would be posted at the 

proposed facilities for the life of the LNG terminal. Materials would also be distributed to 

existing North Spit employers for their use in training their personnel. The types of educational 

materials may vary, but could include posters, table tents, maps, brochures, or fact sheets. 

Numerous sources for existing educational materials are provided in Appendix K of the plover 

recovery plan (FWS 2007e). 

Monitoring 

Intensive biological monitoring of snowy plover on the CBNS is presently being conducted by 

ORNHIC. The CBNS snowy plover population is one of the most closely monitored snowy 

plover populations on the West Coast. ORNHIC monitoring is conducted following a field 

manual (Castelein et al 2003), which details specific monitoring tasks including: survey methods, 

exclosure set-up, egg and nest monitoring procedures, trapping and banding methods, brood 

monitoring, data recording and database maintenance procedures. Monitoring has been 

conducted to varying degrees since 1990, and the current monitoring program is very 

comprehensive. This program is expected to continue into the foreseeable future. 

Jordan Cove would fund one additional entry-level Oregon Wildlife Services position dedicated 

to snowy plover predator monitoring and control during the 36-month construction period. This 

staff member would be employed by Oregon Wildlife Services, which is administered by the 

U.S. Department of Agriculture and Animal and Plant Health Inspection Services. The specific 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-19

duties of this additional staff member would be determined by Oregon Wildlife Services based 

on Coos Bay North Spit management needs, but would concentrate on predator management. 

This additional position would allow Oregon Wildlife Services to better evaluate predator 

densities and more quickly and effectively respond in the unlikely event that predator pressure on 

the CBNS increases during the LNG terminal construction. 

To ensure that the sand stockpile does not create an area for predator denning, Jordan Cove 

would conduct twice-yearly den surveys of the stockpile. Any predator dens identified would be 

reported to Oregon Wildlife Services for appropriate predator control actions. A wildlife 

biologist would conduct the den surveys. 

In the event that a clearly demonstrable and sustained decrease in snowy plover productivity is 

detected by the ongoing ORNHIC monitoring, Jordan Cove would coordinate with ORNHIC, 

BLM, OPRD, Oregon Wildlife Services, ODFW, FWS and other interested parties to identify 

adaptive management strategies, as appropriate, to help reverse any such trend. 

During the plover nesting season, March 15 to September 15, activity within or in the vicinity of 

nesting habitat is restricted (FWS 2001). Construction of the Pacific Connector pipeline would 

not likely affect nesting western snowy plovers because pipeline construction within Coos Bay 

would occur between October 1 and February 15, the ODFW recommended in-water 

construction window (ODFW 2000a), which is outside of the nesting and fledging season for the 

species on the Oregon coast (early April through August; FWS 2001). It is not possible to 

anticipate any local occurrence of western snowy plover in the area of the pipeline at the time of 

construction. Human activities and disturbance that may adversely affect plovers include sand 

deposition or spreading, beach cleaning, construction of breakwaters and jetties, dune 

stabilization/restoration using native and nonnative vegetation or fencing, beach leveling, and 

off-highway vehicles driven in nesting areas or at night (FWS 2001). 

During operations of the Pacific Connector pipeline, aerial inspection of the pipeline would 

occur within the permanent right-of-way. Nesting snowy plovers are not expected to be 

impacted since the closest nesting population is over 3 miles from proposed aerial inspections 

and air traffic is a constant disturbance with the existing Southern Oregon Regional Airport 

within less than 3 miles of the nesting habitat on North Spit. If the pipeline installed within the 

bay requires maintenance, activities and repair would occur in-water and within the permanent 

easement; therefore, impacts from maintenance activities should not impact snowy plovers any 

time of the year. 

Additional Conservation Measures 

In addition to measures described above, Jordan Cove would provide funding to a group 

designated by agencies to provide for fencing, signage, application of shell hash, tree removal, 

maintenance, and beach grass elimination research. 

Based on the effects discussed above, and the conservation measures that would be implemented 

to avoid negative impacts, the proposed action is not likely to adversely affect the western snowy 

plover. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-20

Marbled Murrelet (Federal Threatened Species with Critical Habitat, State Threatened 

Species) 

While MAMUs may nest up to 50 miles inland, they spend a majority of their life on the ocean 

(FWS 2007a). The species is considered uncommon to rare and a year-round resident on the 

Oregon coast (Marshall et al. 2003), and Coos Bay is within the zone of highest density (Strong 

et al. 1995). The MAMU nests on Elliott State Forest and probably in the Coos Bay area as well 

(Adamus et al. 2001). The MAMU could be encountered in the nearshore region; it is 

considered an uncommon, year-round, offshore resident on the North Spit (BLM 2005). 

Marbled murrelets primarily nest in old growth forests, characterized by large trees, multi-storied 

stands and moderate-to-high canopy coverage from Alaska to Monterey Bay, California (FWS 

2006l). These small seabirds feed in shallow off-shore and inland saltwater areas on a variety of 

small fish and invertebrates, including large pelagic invertebrates (Marshall 1988a, 1988b, and 

1989; Becker 2001). Nesting adults make daily foraging trips to near-shore coastal waters. 

Marbled murrelet breeding season occurs between April and September. These birds are 

generally non-migratory and remain near nesting areas year-round in Oregon (Huff et al. 2006). 

Limited research suggests that MAMUs demonstrate site tenacity (Huff et al. 2006). 

There are two components of MAMU habitat that are biologically important: 1) marine foraging 

habitat, including prey spawning and concentration areas, and 2) terrestrial nesting habitat and 

associated stands. Since FWS is unable to define specific marine areas essential to the 

conservation of the species, terrestrial habitat is only considered for designation as critical 

habitat. Throughout the forested portion of their range, MAMU habitat use is positively 

associated with the presence and abundance of mature and old-growth forests, large core areas of 

old-growth, low amounts of edge and fragmentation, proximity to the marine environment, and 

increasing forest age and height; although the presence of platforms is the most important 

characteristic of nesting habitat (FWS 2006l). As a result, the FWS designated the following as 

primary constituent elements (FWS 2006l): 1) forested stands containing large-sized trees, 

generally greater than 32 inches in diameter with potential nesting platforms at sufficient height, 

generally greater than or equal to 33 feet in height; and 2) surrounding forested areas within 0.5 

mile of these stands with a canopy height of at least one-half the site-potential tree height. In 

Oregon, trees with platforms have been greater than 19 inches diameter-at-breast-height and are 

greater than 98 feet tall (FWS 2006l). 

The FWS (2006a) indicated that MAMUs could occur near the proposed Pacific Connector 

pipeline. Additionally, the FWS has designated MAMU CHU OR-06-d within the pipeline area 

(FWS 1996), which coincides with USFS LSRs and BLM LSMA that were designed to support 

the habitat needs of species which depend on mature/old growth habitat. Ten MAMU occupied 

stands have also been defined within the pipeline area and several auditory observations of 

MAMUs within 3 miles of the proposed pipeline have been documented (BLM 2006). The 

Project area is within the zone of highest density along Oregon’s coast, although the largest 

populations of murrelets are in Puget Sound and Strait of Juan de Fuca of Washington (Huff et 

al. 2006). 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-21

Impacts and Conservation Measures

Direct Effects 

MAMUs can be directly affected by 1) noise disturbance associated with timber removal, 

construction, and operation and maintenance of the Pacific Connector pipeline, 2) diminished 

reproductive success and survival (if behavioral response to construction makes them more 

vulnerable to injury), and 3) removal of nest trees or potential nest trees during the nesting 

season (April 1 through September 15). 

Noise

Noise associated with timber clearing, construction, and operation of the proposed Pacific 

Connector pipeline could disturb nesting murrelets and negatively affect productivity. However, 

there has been limited research on visual or decibel (dB) levels or distances from sounds and/or 

visual stimuli at which murrelets react or flush from the nest, or the effect of such disturbance on 

productivity (FWS 2003b). Most data gathered for disturbance on murrelets are obtained from 

observations incidental to other research (e.g., Long and Ralph 1998 as cited in FWS 2003b). 

Studies from other bird species suggest that disturbance can affect productivity through nest 

abandonment, egg and hatchling mortality due to exposure and predation, longer periods of 

incubation, premature fledging or nest evacuation, depressed feeding rates of adults and 

offspring, reduced body mass or slower growth of nestlings, and avoidance of otherwise suitable 

habitat (Henson and Grant 1991 and Rodgers and Smith 1995 as cited in BLM and USFS 2008). 

Based on analysis of published literature and anecdotal accounts of harassment of murrelets, the 

FWS (2003b) established distances within which sound levels for various activities may result in 

injury or harassment of murrelets by significantly disrupting the normal behavior pattern of 

individuals or breeding pairs. Additionally, FWS provided distances that activities may 

“disturb” nesting murrelets but not result in harm. The FWS has determined that activities that 

occur beyond these disturbance distances are not likely to cause adverse effects to MAMUs and 

are often applied as seasonal buffers to minimize impacts of projects on nesting murrelets 

(Disturbance Threshold Distance; table 4.6.1.2-1). Likewise, activities that occur beyond the 

disruption distances should minimize effects to MAMUs. Table 4.6.1.2-1 provides the 

disturbance/disruption distances for MAMUs during the breeding period (April 1 though 

September 15). FWS (2003b) did not analyze injury threshold distances for blasting or large 

helicopters. A conservative assumption was used for blasting with charges of 2 pounds or less 

(table 4.6.1.2-1), and for larger blasts (greater than 2 pounds), a conventional 1-mile distance 

was considered due to the lack of dB information. In informal consultation with FWS (2006), a 

1-mile disturbance threshold distance for the use of large helicopters to remove large timber and 

transport pipe to the construction right-of-way was also considered. However, FWS also 

suggested that if additional studies could demonstrate that use of larger blasts (greater than 2 

pounds) and large helicopters attenuated to less than 92 dB, and preferably 70 dB (disturbance 

threshold versus 92dB disruption threshold) within a mile, to provide a report and additional data 

would be considered to reduce the disturbance threshold distances for those activities (FWS 

2006). 

Pacific Connector has prepared a noise report that analyzes the distances at which conventional 

blasting required for trenching within rock substrate for pipeline construction and transport 

helicopters attenuate to 92 dB. Under the worst case conditions with common and appropriate 

mitigation measures applied to trench blasting operations, it is expected that blasting noise would 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-22

Table 4.6.1.2-1 

Threshold Distances Where Noise Disturbances Are Unlikely to Occur to Nesting Marbled Murrelets during the Breeding 

Season a/

Disruption Threshold Distances From 

Occupied or Presumed Occupied Stand 

Disturbance Threshold Distance From 

Occupied or Presumed Occupied Stand 

Activity 

Marbled Murrelet 

Critical Breeding 

Season b/

Marbled Murrelet 

Late Breeding 

Season b/ 

Marbled Murrelet 

Critical Breeding 

Season b/ 

Marbled Murrelet 

Late Breeding 

Season b/ 

Existing Road Use 35 yards (105 feet) No Disruption 

Anticipated 

0.25 mile No Disruption 

Anticipated 

Chainsaws 45 yards (135 feet) No Disruption 

Anticipated 

0.25 mile No Disturbance 

Anticipated 

Heavy equipment c/ 35 yards (105 feet) No Disruption 

Anticipated 

0.25 mile No Disturbance 

Anticipated 

Blasting – less 92 dB 120 yards (360 feet) No Disruption 

Anticipated 

0.25 mile No Disturbance 

Anticipated 

Blasting – more than 92 dB 0.25 mile 0.25 mile 0.25 mile 0.25 mile 

Small Helicopter/Airplanes 120 yards (360 feet) No Disruption 

Anticipated 

0.25 mile No Disturbance 

Anticipated 

Large/Transport Helicopters d/ 0.25 mile 0.25 mile 0.25 mile 0.25 mile 

a/ Sources: FWS 2003b, Michael Minor & Associates 2008. 

b/ Marbled murrelet breeding period is from April 1-September 15; critical breeding period is considered from April 

1-August 5; late breeding season is considered from August 6 – September 15. 

c/ Heavy equipment includes: back hoes, side-booms, caterpillars, semi-trucks, pneumatic hammers. 

d/ Transport helicopters proposed for this project include: Boeing Chinook (CH-47) and Boeing Vertol 107-II (CH46) 

attenuate to 92 dB within 200 feet of the source, and 70 dB within 1,025 feet of the blast source 

in soft rock. Likewise, large transport helicopters will attenuate to 92 dB within 700 feet. 

Additionally, FWS (2003b) provided some evidence that suggests that noise that builds 

gradually, such as a helicopter approaching from a distance, may result in less risks than sudden 

noises. Analyses for MAMUs in this biological assessment considers the distances for larger 

blasts and large helicopters to be more conservative than what the noise report1 suggests and 

assumes that use of larger blasts and large helicopters within one-quarter mile of an occupied or 

presumed occupied stand may adversely affect nesting murrelets during the breeding period 

(table 4.6.1.2-1). 

In addition to the temporal and spatial restrictions presented in table 4.6.1.2-1, FWS also 

recommends limiting project-related disturbance to 2 hours after sunrise until 2 hours before 

sunset. Adhering to this daily timing restriction minimizes the potential to affect adult murrelets 

delivering the majority of meals to chicks at dawn and dusk. 

Pacific Connector is aware of the temporal and spatial restrictions recommended by FWS to 

protect nesting murrelets, but due to construction constraints, safety of construction crew, and 

adherence to the November in-service date, timber clearing and construction activities within the 

range of the MAMU are proposed to occur during the temporal and spatial restrictions. 

Therefore, acoustic disturbances from the proposed action are expected to affect MAMU nesting 

and rearing activities. Timber removal in occupied stands and within a quarter-mile of those 

 

1

 Blasting and Helicopter Noise Analysis and Mitigation Plan is included in Appendix P of the applicant-prepared Draft 

Biological Assessment, which Pacific Connector filed with the FERC in March 2008. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-23

stands would occur Year 1 after the critical breeding season (April 1 to August 5) with daily 

timing restrictions considered through September 15 (activities would occur 2 hours after sunrise 

and 2 hours before sunset). However, if biologists identify a nest tree or potential nest tree 

within the area to be cleared, timber clearing activities would not occur until after the entire 

breeding season (after September 15). Construction in Year 1 would occur in three occupied 

stands that do not require timber removal because construction activity would be constrained to 

in-road work. Daily timing restrictions (2 hours after sunrise and 2 hours before sunset) would 

be considered during activities from May 1 to September 15. Construction in Year 2 would 

occur in occupied stands and within a quarter-mile of those stands during the breeding season 

(May 1 through November 30), although daily timing restrictions would be adhered to in 

occupied stands and their associated quarter-mile buffer. Forest Plan Standards and Guidelines 

FW-022 and FW-024 also restrict logging by ground-based equipment to the dry season, June 1 

through October 31. 

Table 4.6.1.2-2 shows the number of occupied or presumed occupied stands within areas of 

proposed Project activities that are likely to experience noise disturbance. For more detail on 

each stand that would be affected and the timing of proposed Project activities, see Table 1 of 

Appendix Q in the BA. 

TABLE 4.6.1.2-2. 

Number of Occupied or Presumed Occupied stands within the Marbled Murrelet Zones with Expected Disturbances from 

Noise Associated with Activities Proposed

Year 1 Activities Year 2 Activities Year 3+ Activities 

Status of Marbled Murrelet Stand 

Total 

Number of 

Stands 

Adverse 

Affect 

No 

Adverse 

Affect 

No 

Effect

Adverse 

Affect 

No 

Adverse 

Affect 

No 

Effect 

Adverse 

Affect 

No 

Adverse 

Affect 

No 

Effect

Marbled Murrelet Zone 1

Occupied Stand 35 13 20 2 11 21 3 0 1 34 

Presumed Occupied 52 0 51 1 28 4 (24) 20 0 0 52 

Unlikely to Be Occupied 7 0 6 1 0 1 6 0 0 7 

Total Murrelet Zone 1 96 13 77 4 39 26 29 0 1 93 

Marbled Murrelet Zone 2

Occupied Stand 2 1 1 0 1 1 0 0 0 2 

Presumed Occupied 0 0 0 0 0 0 0 0 0 0 

Unlikely to Be Occupied 2 0 2 0 0 2 0 0 0 2 

Total Murrelet Zone 2 4 1 3 0 1 3 0 0 0 4 

Total Murrelet Zones

Occupied Stand 37 14 21 2 12 22 3 0 1 36 

Presumed Occupied 52 0 51 1 28 4 (24) 20 0 0 52 

Unlikely to Be Occupied 9 0 8 1 0 3 6 0 0 9 

Total Murrelet Zones 98 14 80 4 40 29 29 0 1 97 

Summarized from Table 1 in Appendix Q of the BA. 

Burning and Smoke

Effects on MAMU of smoke that would be generated, whether by prescribed burning as a habitat 

enhancement procedure or by burning slash have not been studied. However, FWS et al. (2007) 

have declared (see table 15, FWS et al. 2007) that “smoke can cause (NSO) adults to move off 

nest sites, therefore leaving eggs or young exposed to predation or resulting in lost feedings 

reducing the young’s fitness.” In the absence of reliable information, one would reasonably 

assume the same effects to apply to MAMU. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-24

According to BLM and USFS (2008, page 35) stated that MAMU “are potentially affected by 

fire control activities and drifting smoke during burning. The threshold distance for disturbance 

from smoke is one-fourth mile for murrelets,” which also would be subject to smoke-related 

disturbance during the critical breeding period. Pacific Connector would not conduct slash 

burning during the critical breeding season within one-quarter mile of an occupied MAMU stand 

during the critical breeding season. 

Habitat Removal During Breeding Season

There would be no habitat within occupied stands removed during the critical breeding season 

(April 1 through August 5). Habitat removed between August 5 and September 15 would adhere 

to daily timing restrictions (2 hours after sunrise and 2 hours before sunset). If nest trees or 

potential nest trees are identified during stand evaluation prior to timber clearing, habitat removal 

would not occur until after the entire breeding season (after September 15). Removing habitat 

after the entire breeding season would eliminate any direct impact to individual murrelets or 

nestlings. 

Indirect Effects 

Project-related effects to MAMUs that are caused by the action and are later in time or farther 

removed in distance, but are still reasonably foreseeable, are indirect effects to MAMUs. The 

primary indirect effect to murrelets would include removal of suitable nesting habitat. Shortterm impact is likely to last from the initiation of timber clearing until 1 to 3 years after 

restoration/revegetation. Long-term impact to murrelets and suitable nesting habitat is expected 

to last 4 years or more. Additionally, secondary indirect effects to MAMUs are expected. 

Potential indirect or secondary effects by a project include increased human presence as a result 

of the requirements of the action itself (the workforce needed to construct or operate the project), 

increased recreation (including OHV use, hunting), habitat degradation, and increased illegal 

harvest (Comer 1982). 

Nesting Habitat Removal/Modification

Removal of suitable nesting habitat by harvest of old-growth timber has been cited as the 

primary reason for the decline of MAMUs (FWS 1992a). Construction of the proposed pipeline 

would remove approximately 97.3 acres of known or potentially suitable habitat within the 

proposed Project, including 61.8 acres in 11 occupied, 18 presumed occupied, and 5 unlikely to 

be occupied stands (table 4.6.1.2-3, table H-2 in Appendix H). Approximately 24.9 acres would 

be permanently lost for the life of the pipeline within the 30-foot pipeline corridor that would be 

maintained free of vegetation greater than 6 feet in height (table 4.6.1.2-4). Removal of 97.3 

acres of suitable or potentially suitable habitat represents approximately 0.7 percent of the 

14,261 acres of potentially suitable habitat in the analysis area (see table 4.6.1.2-5). 

Additionally, 32.4 acres of suitable or potentially suitable habitat have been identified for use by 

the Pacific Connector pipeline project as UCSAs that may be used to store forest slash, stumps, 

and dead and downed log materials that would be removed and scattered across the right-of-way 

after construction during restoration (Modified Column – table 4.6.1.2-3). Use of the UCSAs 

would be a short-term modification of suitable or potentially suitable, unsurveyed habitat. Table 

4.6.1.2-5 summarizes the amount of suitable or potentially suitable MAMU habitat affected by 

the proposed project within the terrestrial nesting analysis area pre- and post-action. 
4.6 – 

4.6-25

TABLE 4.6.1.2-3 

Effects (acres) to MAMU Nesting Habitat by Land Use Allocation and Land Ownership from Construction of the Pacific Connector Pipeline 

Marbled Known Suitable Habitat c/ Potential Suitable Habitat Recruitment Habitat d

Murrelet Zone Land Owner a/ 

Land 

Allocation b/ Removed f/ Modified g/ Removed f/ Modified g/ Removed f/ Modified 

CHU & LSMA (overlap) 0.86 0.00 0.01 0.00 0.02 0.00 CHU only (OR-06-d) 0.03 0.00 0.63 0.00 4.31 0.00 LSMA only 16.16 5.13 0.06 0.00 0.00 0.00 

BLM - Coos Bay 

Other Allocations 6.01 1.30 12.82 0.12 16.97 0.67 

Coos Bay Subtotal 23.06 6.43 13.52 0.12 21.30 0.67 

CHU & LSMA (overlap) 4.21 8.19 0.01 0.02 0.18 0.30 CHU only (OR-06-d) 0.93 1.20 0.30 0.39 6.21 1.75 LSMA only 0.00 0.00 0.00 0.00 0.00 0.00 

BLM - Roseburg 

Other Allocations 0.00 0.00 3.03 0.00 15.20 0.11 

Roseburg Subtotal 5.14 9.39 3.34 0.41 21.59 2.16 Other/Non-Federal None/Non- Federal 0.00 0.00 27.69 0.69 70.16 6.24 

MAMU Zone 1 

Other Subtotal 0.00 0.00 27.69 0.69 70.16 6.24 

CHU & LSMA (overlap) 5.07 8.19 0.02 0.02 0.20 0.30 CHU only (OR-06-d) 0.96 1.20 0.93 0.39 10.52 1.75 LSMA only 16.16 5.13 0.06 0.00 0.00 0.00 Other Allocations 6.01 1.30 15.85 0.12 32.17 0.78 None/NonFederal 0.00 0.00 27.69 0.69 70.16 6.24 

MAMU Zone 1 Total 

Overall 28.20 15.82 44.55 1.22 113.05 9.07 

CHU & LSMA (overlap) 0.00 0.00 0.00 0.00 0.00 0.00 CHU only (OR-06-d) 0.00 0.00 0.00 0.00 0.00 0.00 LSMA only 0.00 0.00 0.00 0.00 0.00 0.00 

BLM - Roseburg 

Other Allocations 14.39 5.02 1.58 1.42 5.48 4.97 

Roseburg Subtotal 14.39 5.02 1.58 1.42 5.48 4.97 

MAMU Zone 2 

Other/Non-Federal None/Non- Federal 0.01 0.02 8.55 8.86 73.95 43.38 
4.6 – 

4.6-26

TABLE 4.6.1.2-3 

Effects (acres) to MAMU Nesting Habitat by Land Use Allocation and Land Ownership from Construction of the Pacific Connector Pipeline 

Marbled Known Suitable Habitat c/ Potential Suitable Habitat Recruitment Habitat d

Murrelet Zone Land Owner a/ 

Land 

Allocation b/ Removed f/ Modified g/ Removed f/ Modified g/ Removed f/ Modified 

Other Subtotal 0.01 0.02 8.55 8.86 73.95 43.38 

CHU & LSMA (overlap) 0.00 0.00 0.00 0.00 0.00 0.00 CHU only (OR-06-d) 0.00 0.00 0.00 0.00 0.00 0.00 LSMA only 0.00 0.00 0.00 0.00 0.00 0.00 Other Allocations 14.39 5.02 1.58 1.42 5.48 4.97 None 0.01 0.02 8.55 8.86 73.95 43.38 

MAMU Zone 2 Total 

Overall 14.40 5.04 10.13 10.28 79.43 48.35 

CHU & LSMA (overlap) 5.07 8.19 0.02 0.02 0.20 0.30 CHU only (OR-06-d) 0.96 1.20 0.93 0.39 10.52 1.75 LSMA only 16.16 5.13 0.06 0.00 0.00 0.00 Other Allocations 20.40 6.32 17.43 1.54 37.65 5.75 None/NonFederal 0.01 0.02 36.24 9.55 144.11 49.62 

OVERALL TOTAL 

OVERALL 42.60 20.86 54.68 11.50 192.48 57.42 

a/ Land Owner: Other/Non-Federal = State or Private 

b/ Land Allocation: CHU = federally designated critical habitat; LSMA = WOPR late successional management areas; CHU & LSMA (overlap) = area tha

Only = area that only CHU occurs; LSMA Only = area that only LSMA occurs; within BLM Other Allocations = other land allocations (i.e., Administratively Management, etc.); within other, Non-Federal landowners, none/non-federal = no CHU. c/ Suitable Habitat includes the following: 1) forest stands that were determined suitable MAMU habitat from LIDAR coverage, 2005 summer aerial photo

reconnaissance, 2) habitat with high potential to provide suitable habitat for MAMU (as determined by LIDAR and aerial photography) but were denied sutruthed, 3) delineated MAMU occupied stands, and 4) potential habitat modeled by Pacific Northwest Research Station – expert opinion and ecological ni

2006). d/ Recruitment Habitat: forested land not currently suitable for MAMU that may be capable of becoming suitable MAMU habitat within the next 25 years (

clearcut or regenerating were not included as recruitment habitat per definition in the proposed critical habitat Federal Register (FWS 2006e). f/ Project components considered in calculation of habitat “Removed”: Pacific Connector construction right-of-way, temporary extra work areas, abovegr

temporary access roads (PAR, TAR), pipe storage yards. g/ Project components considered in calculation of habitat “Modified”: Pacific Connector UCSAs described in the Project Description and would not be c

These areas would be used to store forest slash, stumps and dead and downed log materials that would be removed and scattered across the right-of-wa

restoration and are considered as temporary insignificant habitat modifications. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-27

TABLE 4.6.1.2-4 

Permanent Effects (acres) to MAMU Nesting Habitat by Land Use Allocation and Land Ownership from Maintenance of the 

Pacific Connector 30-foot Corridor within MAMU Habitat Zones 1 and 2 

Marbled 

Murrelet Zone Land Owner a/ Land Allocation b/

Known 

Suitable 

Habitat c/

Potential 

Suitable 

Habitat d/

Recruitment 

Habitat e/ Total Acres 

CHU & LSMA 

(overlap) 0.27 0.00 0.00 0.27 

CHU only (OR-06-

d) 0.01 0.21 1.26 1.48 

LSMA only 4.56 0.00 0.00 4.56 

BLM - Coos 

Bay 

Other Allocations 1.77 3.34 4.75 9.86 

Coos Bay Subtotal 6.61 3.55 6.01 16.17 

CHU & LSMA 

(overlap) 0.98 0.00 0.08 1.06 

CHU only (OR-06-

d) 0.07 0.00 1.37 1.44 

LSMA only 0.00 0.01 0.00 0.01 

BLM - 

Roseburg 

Other Allocations 0.00 0.90 3.36 4.26 

Roseburg Subtotal 1.05 0.91 4.81 6.77 

Other/NonFederal None/Non-Federal 0.00 6.94 17.95 24.89 

MAMU Zone 1 

Other Subtotal 0.00 6.94 17.95 24.89 

CHU & LSMA 

(overlap) 1.25 0.00 0.08 1.33 

CHU only (OR-06-

d) 0.08 0.21 2.63 2.92 

LSMA only 4.56 0.01 0.00 4.57 

Other Allocations 1.77 4.24 8.11 14.12 

None/Non-Federal 0.00 6.94 17.95 24.89 

MAMU Zone 1 Total 

Overall 7.66 11.40 28.77 47.83 

CHU & LSMA 

(overlap) 0.00 0.00 0.00 0.00 

CHU only (OR-06-

d) 0.00 0.00 0.00 0.00 

LSMA only 0.00 0.00 0.00 0.00 

BLM - 

Roseburg 

Other Allocations 3.17 0.41 1.32 4.90 

Roseburg Subtotal 3.17 0.41 1.32 4.90 

Other/NonFederal None/Non-Federal 0.00 2.26 16.49 18.75 

MAMU Zone 2 

Other Subtotal 0.00 2.26 16.49 18.75 

CHU & LSMA 

(overlap) 0.00 0.00 0.00 0.00 

CHU only (OR-06-

d) 0.00 0.00 0.00 0.00 

LSMA only 0.00 0.00 0.00 0.00 

Other Allocations 3.17 0.41 1.32 4.90 

None/Non-Federal 0.00 2.26 16.49 18.75 

MAMU Zone 2 Total 

Overall 3.17 2.67 17.81 23.65 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-28

TABLE 4.6.1.2-4 

Permanent Effects (acres) to MAMU Nesting Habitat by Land Use Allocation and Land Ownership from Maintenance of the 

Pacific Connector 30-foot Corridor within MAMU Habitat Zones 1 and 2 

Marbled 

Murrelet Zone Land Owner a/ Land Allocation b/

Known 

Suitable 

Habitat c/

Potential 

Suitable 

Habitat d/

Recruitment 

Habitat e/ Total Acres 

CHU & LSMA 

(overlap) 1.25 0.00 0.08 1.33 

CHU only (OR-06-

d) 0.08 0.21 2.63 2.92 

LSMA only 4.56 0.01 0.00 4.57 

Other Allocations 4.94 4.65 9.43 19.02 

None/Non-Federal 0.00 9.20 34.44 43.64 

OVERALL TOTAL 

OVERALL 10.83 14.07 46.58 71.48 

a/ Land Owner: Other/Non-Federal = State or Private 

b/ Land Allocation: CHU = federally designated critical habitat; LSMA = WOPR late successional management areas; CHU & LSMA 

(overlap) = area that both land allocations occur; CHU Only = area that only CHU occurs; LSMA Only = area that only LSMA occurs; 

within BLM Other Allocations = other land allocations (i.e., Administratively Withdrawn, Deferred Timber Management, etc.); within 

other, Non-Federal landowners, none/non-federal = no CHU. 

c/ Known Suitable Habitat includes the following: 1) forest stands that were determined suitable marbled murrelet habitat from LIDAR 

coverage, 2005 summer aerial photography, and ground reconnaissance – surveyed, and 2) delineated marbled murrelet occupied 

stands. 

d/ Potential Suitable Habitat includes the following: 1) habitat with high potential to provide suitable habitat for marbled murrelet (as 

determined by LiDAR and aerial photography) but were denied survey access and not ground-truthed – not surveyed, and 2) forested 

potential habitat (old-growth, late successional, and mid-seral) modeled by Pacific Northwest Research Station – expert opinion and 

ecological niche factor analysis (Raphael et al., 2006). 

e/ Recruitment Habitat: forested land not currently suitable for MAMU that may be capable of becoming suitable MAMU habitat within 

the next 25 years (FWS 2006e). Lands recently clearcut or regenerating were not included as recruitment habitat per definition in the 

proposed critical habitat Federal Register (FWS 2006e). 
4.6 – 

4.6-29

TABLE 4.6.1.2-5 

Summary of Effects to Marbled Murrelet Suitable or Potentially Suitable Nesting Habitat within Marbled Murrelet Zones 1 and 2 within the Defi

Action Area as a Result of the Proposed Project 

Suitable Nesting Habitat – Pre-Action 

Suitable Nesting Habitat 

Removed (acres) a/ Suitable Nesting Hab

Land 

Owner 

Total 

Acres 

within 

Analysis 

Area 

Known 

(acres) 

Potential 

(acres) 

Total 

Acres 

Percent 

Available b/

Known 

(acres) 

Potential 

(acres) Total 

Known 

(acres) 

Potential 

(acres) 

Marbled Murrelet Zone 1 

Federal 23208.0 5416.0 4499.8 9915.8 42.7 28.3 16.9 45.2 5387.7 4482.9 

Non-Federal 35274.8 7.8 2288.4 2296.2 6.5 0.0 27.7 27.7 7.8 2260.7 

Total 58482.8 5423.8 6788.2 12212.0 20.9 28.3 44.6 72.9 5395.5 6743.6 

Marbled Murrelet Zone 2 

Federal 1344.2 601.7 288.0 889.6 66.2 14.4 1.6 16.0 587.3 286.4 

Non-Federal 19081.5 1.3 1158.1 1159.4 6.1 0.0 8.6 8.6 1.3 1149.5 

Total 20425.7 603.0 1446.1 2049.1 10.0 14.4 10.1 24.5 588.6 1436.0 

Overall Action Area Total 

Federal 24552.2 6017.6 4787.8 10805.4 44.0 42.7 18.5 61.2 5974.9 4769.3 

Non-Federal 56235.4 9.1 3446.5 3455.6 6.1 0.0 32.2 32.2 9.1 3414.3 

Total 80787.6 6026.7 8234.3 14261.0 17.7 42.7 54.7 97.4 5984.0 8179.6 

a/ Acres of suitable or potentially suitable MAMU nesting habitat removed acquired from table 4.3.4.3-7. 

b/ Percent provided indicates the amount of suitable or potentially suitable habitat available within the defined terrestrial nesting analysis area pre- and po
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-30

Nest predation, primarily by jays, ravens, crows, and magpies that occupy secondary growth 

stands and fragmented forests, is another limiting factor affecting the recovery of MAMU 

populations (Raphael 2006). Significant increasing regional trends of corvids within the Pacific 

Connector pipeline vicinity have been observed during the National Audubon Society Christmas 

Bird Counts. In Oregon, Luginbuhl et al. (2001) found that predator densities and rates of nest 

predation are higher in areas with a variety of tree ages, so nest success is reduced in areas 

intermixed with young trees or brush habitat (Raphael et al. 2006). Creation of a 30-foot 

shrub/grass utility corridor over the long term could increase current corvid densities and access 

to MAMU nests and result in reduced nest success. MAMU nests near existing human 

residences and traveled roads or highways are most likely at higher risk of nest predation 

because corvids are assumed to be attracted to those areas because of garbage and/or road-killed 

carrion. Food enticements associated with human presence during construction activities could 

also increase MAMU predator populations within the vicinity of the Pacific Connector pipeline. 

Four occupied MAMU stands that are within 0.25 mile of the proposed construction area are also 

near residences, and so increased human presence may increase predator activity within these 

stands: C1032, R3026, R3027, and R3021. However, all trash, food waste, and other items 

attractive to crows, jays, and other corvids would be picked up and removed from the project 

area on a daily basis to minimize potential predation of murrelet nestlings. The Pacific 

Connector pipeline would cross four occupied stands within Marbled Murrelet Zone 1, 

fragmenting or further fragmenting the occupied stands, of which three were determined to be 

occupied during 2007 or 2008 surveys: 2,260 feet of C3098 (2008 survey), 545 feet of C3073 

(Coos Bay BLM), 3,900 feet of C3090 (2007 Survey), and 1,550 feet of R3026 (2007 survey). 

Although each occupied stand has an existing road(s) through the stand (except for stand C3090) 

and is adjacent to recent clearcuts and regenerating forest, the roads are not highly traveled or 

used at high speeds (dirt, gravel or dead-end by the stand) and so the likelihood of road garbage 

and/or road-kill presence is low, decreasing the presence of corvids and other predators. Stand 

R3026 is in proximity to a residence (approximately 1,800 feet away) that may have a higher 

presence of corvids and other predators. Therefore, activity within this stand may have a higher 

risk of attracting corvids and other nest predators. However, Pacific Connector would remove 

trash, food waste, and other items attractive to corvids to help minimize potential predation of 

murrelets. 

Fragmentation of MAMU habitat can reduce the amount and heterogeneous nature of the habitat, 

forest patch size, and amount of interior or core habitat, and can increase the amount of edge, 

isolate remaining habitat patches, and create “sink” habitats (FWS 2006e). The ecological 

consequences of these habitat changes to MAMUs can include effects on population viability 

and size, local or regional extinctions, displacement, fewer nesting attempts, failure to breed, 

reduced fecundity, reduced nest abundance, lower nest success, increased predation and 

parasitism rates, and reduced adult survival (FWS 2006e). Within MAMU Zone 1 and Zone 2 

(MP 0.0 – MP 75.64), the Pacific Connector pipeline would be located within or parallel to 

existing corridors for approximately 26.45 miles, thus minimizing fragmentation within known 

or potential suitable MAMU nesting habitat. 

Two stands, with suitable nesting structures that were determined to be unlikely occupied after 

two years of surveys per protocol, would be fragmented by the proposed Project: 1,860 feet of 

survey unit B02 and 4,270 feet of survey unit B14. These stands are near existing roads and a 

mosaic landscape, as well as residences (B12). If MAMUs are present within these stands, the 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-31

risk for nest predation could be increased. Fragmentation would occur within 10 other stands 

that have been identified as potential suitable murrelet habitat but have not been surveyed 

because of landowner survey access denial. A possible increase in predator presence is possible; 

however, maintaining the construction area free of food waste, trash, and other attractive items 

should minimize the presence of potential murrelet predators. Table H-2 in Appendix H, 

provides a brief description of habitat removal and potential fragmentation within each stand 

(occupied, presumed occupied, and unlikely to be occupied) within a quarter mile of the 

proposed Project, as well as a brief description of features (i.e., roads, residences, mosaic 

landscape) that may increase the presence of corvids and other potential murrelet predators. 

Prey/Foraging Habitat

Murrelets forage in shallow off-shore and inland saltwater areas on a variety of small fish and 

invertebrates, including large pelagic invertebrates (Marshall 1988a, 1988b, and 1989; Becker 

2001). In Oregon and Washington, anchovy, sand lance, and smelt appear to be the major prey 

types provided to chicks (McShane et al. 2004). Turbidity effects to forage/prey species and 

their habitat by dredging the access channel and construction of the Project within Coos Bay may 

reduce MAMU food availability. Dredging of the access channel and construction of the 

pipeline across the estuary are planned from October 1 trough February 15 following ODFW’s 

recommendation and timing of these activities should minimize impact to MAMU forage/prey 

species. 

In portions of the Northern California-Southern Oregon coast, researchers have estimated 

densities of MAMUs per square mile from 2000 through 2003. Updated density estimates 

through 2007 were provided by the Marbled Murrelet Effectiveness Monitoring Program of the 

NWFP (2008). The observed trend in MAMUs offshore has been significantly declining (P < 

0.05) from 2000 through 2007 (figure 4.6-1). The observations were used to forecast offshore 

densities through 2011. In that first year of the Project’s operation, 121 murrelets per square 

mile were estimated off the coast of Northern California and Southern Oregon, down from 142 

murrelets per square mile in 2007. Because of the variability in data from 2000 through 2007, 

the forecast of 121 lies within a range between 77 to 165 MAMUs per square mile in 2011 with 

95 percent confidence, shown by the prediction intervals in figure 4.6-1. With that level of 

future uncertainty, the offshore density could be higher or much lower than the 142 per square 

mile estimated in 2007. 

There are no records or any indication that MAMUs offshore are susceptible to ship-strikes. 

During summers in 1992-1993, the majority of MAMUs off the Oregon coast were observed 

within 3,280 feet (1,000 meters) from shore (Strong et al. 1995). Given the distribution of 

MAMUs close to shore, it is not surprising that they are susceptible to adverse effects from 

industrial pollution (Fry 1995) and off-shore oil spills (Carter and Kuletz 1995). Indeed, oil 

released during the grounding and break-up of the New Carissa near Coos Bay likely killed 262 

MAMUs in February 1999 (Skrabis 2005). 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-32

Figure 4.6-1. Trend of MAMU Densities off the Coast of Northern California-Southern Oregon, from 

2000-2007, and Forecast through 2011 (with 95 percent prediction interval) Based on the 

Observed Trend 

Note: The Observed Slope for the Trend is Significantly Different from Zero (P<0.05). 

Source: Miller et al. 2006 and Marbled Murrelet Effectiveness Monitoring Program of the NWFP 2008). 

The potential for similar effects from LNG cargo is quite different from the potential for effect 

by crude or refined petroleum cargo. Based on the double hulled construction of LNG carriers 

and the outstanding operating and safety record of LNG carriers, the probability of any incidents 

that could result in the loss of LNG cargo is extremely low. Any potential spills that could affect 

MAMUs offshore would more likely be fuels or lubricants associated with the operation of the 

LNG carrier. These products are kept in relatively small quantities on ships and would not result 

in the types of effects associated with a spill from an oil tanker. 

If an unignited LNG spill were to occur within the nearshore approach to Coos Bay, the LNG 

would float on the water until it vaporizes and would not have an adverse effect on MAMUs, 

unless they come in direct contact with the LNG. For that to happen, the spill would have to 

occur within the same area occupied by murrelets, within 1 mile or less of the coast. Some 

cooling of the upper water layers closest to the LNG spill would be expected, but would not 

likely cause the overall water column to cool to the point of affecting murrelets in the water, 

given the ambient water temperatures off the coast. Murrelets would most likely escape by 

flying away from spilled LNG. 

If the vapor from an LNG spill were to come in contact with an ignition source the resulting fire 

would burn back to the spill source and would affect species on the water or in the area that 

come in direct contact with the fire. LNG is mostly composed of methane which, when 

vaporized, is less dense than air and would rapidly rise above the water rather remain at the 

surface. A MAMU submerged in the water would not be affected as the fire would be above the 

water. However, a murrelet surfacing to breathe in the center of a burn conceivably could suffer 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-33

from temporary hypoxia or more extreme anoxia if all local oxygen had been consumed by the 

fire. Such an event is highly unlikely, especially given the low density of murrelets. 

Occupied or Presumed Occupied Stands

Research indicates that MAMUs within southern Oregon tend to nest in stands that are generally 

located away from high-contrast edge created from timber stand harvests and adjacent immature 

forests (Ripple et al. 2003; Meyer et al. 2002). Zharikov et al. (2006) found murrelets commonly 

nesting in stands near edges, although when edge increased in the nest patch, more nests failed 

(Zharikov et al. 2007). Increase in edge within occupied or presumed occupied stands with the 

range of MAMUs from construction of the proposed pipeline may result in reduced nest success. 

Also, because murrelets may nest close to the edge of a stand (easier access to nest) removal of 

suitable habitat on the edge of an occupied or presumed occupied stand may result in removal of 

a nest or potential nest tree. Fragmentation of an occupied or presumed occupied stand may also 

result in eventual abandonment of the stand. Recent research suggests that because of nest site 

fidelity, murrelets may continue to utilize a nest stand even though nest success is reduced 

(Meyer et al. in review). 

Nine of 37 known MAMU occupied stands within the terrestrial analysis area would have a total 

of 37.6 acres of suitable nesting habitat removed and/or modified within the stand, removing on 

average 1.2 percent of suitable habitat from the entire occupied stand: C3098 (B04), C3075, 

C3042, C3093 (B06), C3073, C3090 (B08), C3070, C3092, and R3026 (B11). Fourteen of 52 

presumed occupied stands surveyed in 2007 within the terrestrial analysis area would have 10.03 

acres of suitable nesting habitat removed (18.93 acres) and/or modified (0.1 acre) within the 

stand, removing on average 8.5 percent of suitable habitat from the entire presumed occupied 

stand. Five of 9 stands surveyed in 2007 and 2008 that did not have marbled murrelet occupied 

behavior detected would have 25.4 acres of suitable habitat removed (19.5 acres) or modified 

(5.9 acres), removing on average 5.5 percent of potential suitable habitat from the entire unlikely 

to be occupied stand. A summary of potential murrelet nesting habitat removed or modified in 

known occupied and presumed occupied stands (both surveyed and not surveyed) is provided in 

table 4.6.1.2-6 below. 

The proposed pipeline would be within MAMU recovery plan conservation Zone 4, of which the 

recommended management to aid in recovery includes maintaining designated occupied sites 

and minimizing loss of unoccupied but suitable habitat (FWS 1997). Not more than 3.9 percent 

of suitable habitat within an existing occupied stand is removed; therefore, the integrity of 

known occupied stands within the terrestrial analysis area, especially those stands with large 

acreages, should be maintained. Additionally, only 74.2 acres of suitable or potentially suitable 

nesting habitat is removed from currently unoccupied murrelet stands, of which 42.9 acres occur 

in presumed occupied or unlikely to be occupied stands, removing a total of 0.5 percent from 

available suitable habitat (14.3 acres) within the defined terrestrial analysis area. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-34

TABLE 4.6.1.2-6 

Potential MAMU Habitat by Jurisdiction and Known, Presumed Occupied, and Unlikely to be Occupied Stands

Occupied Presumed Occupied Unlikely to Be Occupied Total 

Jurisdiction Removed a/ Modified b/ Removed a/ Modified b/ Removed a/ Modified b/ Removed a/ Modified b/

Marbled Murrelet Zone 1 

Coos Bay BLM 18.8 5.7 0.0 0.0 4.5 0.0 23.3 5.7 

Roseburg BLM 4.6 8.5 2.90 0.0 0.0 0.0 7.5 8.5 

Private 0.0 0.0 16.0 0.0 0.00 0.0 16.0 0.0 

MAMU Zone 1 

Total 

23.4 14.2 18.9 0.0 4.5 0.0 46.8 14.2 

Marbled Murrelet Zone 2 

Roseburg BLM 0.0 0.0 0.0 0.0 15.0 5.9 15.0 5.9 

Private 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 

MAMU Zone 2 

Total 

0.0 0.0 0.0 0.0 15.0 5.9 15.0 5.9 

Overall Total

Coos Bay BLM 18.8 5.7 0.0 0.0 4.5 0.0 23.3 5.7 

Roseburg BLM 4.6 8.5 2.90 0.0 15.0 5.9 22.5 14.4 

Private 0.0 0.0 16.0 0.0 0.0 0.0 16.0 0.0 

Overall Total 23.4 14.2 18.9 0.0 19.5 5.9 61.8 20.1 

a/ Project components considered in calculation of habitat “Removed”: Pacific Connector pipeline construction right-of-way, 

TEWAs, aboveground facilities, PARs and TARs), pipe storage yards. 

b/ Project components considered in calculation of habitat “Modified”: Pacific Connector pipeline UCSAs described in the Project 

Description and would not be cleared of trees during construction. These areas would be used to store forest slash, stumps, and 

dead and downed log materials that would be removed and scattered across the right-of-way after construction during restoration

and are considered as temporary insignificant habitat modifications. 

Most suitable habitat impacted either occurs on the edge of the occupied or presumed occupied 

stand or between the interface of the older occupied stand and an adjacent young, regenerating 

stand. Four occupied stands are further fragmented (i.e., existing roads currently within stands) 

by the proposed pipeline including C3098, C3073, C3090, and R3026. Maps in Appendix Q of 

the applicant’s draft BA2 show location of occupied or presumed occupied stands in relation to 

project disturbance. Rationale for location of the proposed pipeline within each known occupied 

stand is provided in table H-1 in Appendix H. 

Critical Habitat Units and LSRs/LSMAs

The FWS (1996) determined the physical and biological habitat features (PCEs) associated with 

the terrestrial environment that support nesting, roosting, and other normal behaviors essential to 

the conservation of the MAMU. Within areas essential for successful MAMU nesting, FWS 

utilized the following PCEs to identify critical habitat: individual trees with potential nest 

platforms; and forestlands of at least one half site-potential tree height regardless of contiguity, 

within 0.5 mile of individual trees with potential nesting platforms and that are used or 

potentially used by the MAMU for nesting or roosting. 

In 2006, FWS (2006e) proposed changes to critical habitat for the MAMU, but in 2008 (FWS 

2008), determined that it is not appropriate to revise the designation of critical habitat for 

MAMU at this time due to future uncertainties about new BLM RMP revisions and its potential 

implication on the protection of the MAMU (FWS 2008). Therefore, the May 24, 1996 final rule 

designating critical habitat remains in effect. The proposed habitat designation included more 

 

2

 Maps are included in Appendix Q of the Draft Biological Assessment, which Pacific Connector filed with the FERC in March 

2008 
4.6 – Threatened, Endangered, and 

Other Special Status Species 

4.6-35

detailed PCEs based on more current knowledge of the bird’s life history, biology and ecology: 

(1) forested stands containing large-sized trees, generally more than 32 inches in diameter with 

potential nesting platforms at sufficient height, generally greater than or equal to 33 feet in 

height; and (2) the surrounding forested areas within 0.5 mile of these stands with a canopy 

height of at least one-half the site-potential tree height (FWS 2006e). On July 31, 2008, FWS 

proposed another revision to the 1996 critical habitat designation, proposing to remove 

approximately 254,070 acres in northern California and Oregon. This proposal was based on 

new information indicating that these areas do not meet the definition of critical habitat, 

regardless of BLM revisions to its RMPs (FWS 2008h). 

A variety of ongoing or proposed activities that disturb or remove PCEs may adversely affect 

MAMU critical habitat and destruct or adversely modify essential physical and biological 

features. Such activities include, but are not limited to: (1) forest management activities that 

greatly reduce stand canopy closure, appreciably alter the stand structure, or reduce the 

availability of nesting sites; (2) land disturbance activities such as mining, sand and gravel 

extraction, and road building; and (3) harvest of certain types of commercial forest products 

(e.g., moss). 

Those activities have the following effects on the primary constituent elements of murrelet 

critical habitat: (1) Removal or degradation of individual trees with potential nesting platforms, 

or the nest platforms themselves, that results in a significant decrease in the value of the trees for 

future nesting use. Moss may be an important component of nesting platforms in some areas. 

(2) Removal or degradation of trees adjacent to trees with potential nesting platforms that 

provide habitat elements essential to the suitability of the potential nest tree or platform, such as 

trees providing cover from weather or predators. (3) Removal or degradation of forested areas 

with a canopy height of at least one half the site-potential tree height and regardless of 

contiguity, within 0.5 mile of individual trees containing potential nest platforms. This includes 

removal or degradation of trees currently unsuitable for nesting that contribute to the integrity of 

the potential nest area (i.e., trees that contribute to the canopy of the forested area). These trees 

provide the canopy and stand conditions important for MAMU nesting (FWS 1996). 

Within the terrestrial analysis area for the proposed pipeline, federally designated critical habitat 

and NWFP LSR completely overlap, while approximately 24 percent (5.1 acres) of LSMAs 

overlap CHUs. The proposed pipeline crosses one federally designated CHU (OR-06-d) five 

times for a total of 2.77 miles, although not all habitat within the CHU is considered suitable for 

MAMU occupancy (see table 4.6.1.2-3). Overall, the proposed pipeline would remove 7.0 acres 

of suitable or potentially suitable MAMU habitat and 10.7 acres of recruitment habitat within 

CHU OR-06-d (also NWFP LSR unit RO 261; table 4.6.1.2-3 and 4.6.1.2-7), including habitat 

removal from two occupied stands. Critical habitat unit OR-06-d provides 7,964 acres of 

suitable nesting habitat. Removal of 7.0 acres from OR-06-d by the proposed pipeline represents 

0.09 percent of total suitable habitat available within CHU OR-06-d. Additionally, 

approximately 9.4 acres of suitable or potentially suitable habitat and 5.8 acres of recruitment 

habitat within CHU OR-06-d have been identified for use by the Project as UCSAs that may be 

used to store forest slash, stumps, and dead and downed log materials that would be removed and 

scattered across the right-of-way after construction during restoration (Modified Column, table 

4.6.1.2-3). Use of the UCSAs would be a short-term modification of suitable and potentially 

suitable habitat. 
4.6 – 

4.6-36

TABLE 4.6.1.2-7 

Summary of Impacts to MAMU Suitable or Potentially Suitable Habitat within Critical Habitat Units Located within the Terrestrial Nes

Pre-Action (acres) a/ Habitat Removed (acres) b/ Post

CHU 

Number 

Total 

Available 

(acres)

Suitable 

Habitat 

Recruitment 

Habitat 

Suitable 

Habitat 

Recruitment 

Habitat 

Suitable 

Habitat 

R

OR-06-b 52,987 21,621 6,083 0.0 0.0 21,621 OR-06-c 4,765 2,548 990 0.0 0.0 2,548 OR-06-d 17,642 7,964 748 7.0 10.7 7,957.0 a/ Total acres of MAMU suitable, recruitment, and non-suitable habitat was provided by Coos Bay BLM GIS specialist, since those CHUs all occur within b/ Habitat Removed from CHU OR-06-d was obtained from table 4.6.1.2-3. Suitable Habitat considers both Known and Potential nesting habitat. 

TABLE 4.6.1.2-7a 

Summary of Impacts to MAMU Suitable or Potentially Suitable Habitat within Late Successional Management Areas Located within 

Nesting Action Area

BLM Pre-Action (acres) Habitat Removed (acres) a/ Post-Act

District 

LSMA 

Total 

Available 

(acres)

Suitable 

Habitat 

Suitable 

Habitat 

Coos Bay 3,574 3,031 17.1 Roseburg 1,004 909 4.2 a/ Habitat Removed from Late Successional Management Areas was obtained from table 4.6.1.2-3. Suitable Habitat considers both Known anesting habitat. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-37

Within Murrelet Zones 1 and 2 where federal land is checker-boarded, Pacific Connector 

considered locations of NWFP late successional reserves when routing the proposed pipeline and 

tried to avoid those tracts of lands if another constructible route was feasible. As a result, very 

little murrelet suitable or potentially suitable habitat would be removed within LSR RO 261, 

which completely overlaps designated CHU OR-06-d and is crossed by the proposed pipeline. 

Table 4.6.1.2-6 provides an overview of the effect of the proposed project on MAMU CHUs 

(and LSR RO 261) within the defined terrestrial nesting analysis area. 

Indirect effects from construction of the pipeline are also expected within MAMU designated 

CHUs and NWFP late-successional reserves that have interior forest that the murrelet relies on 

for nesting habitat (table H-2 in Appendix H). The conversion of large tracts of old-growth 

forest to small, isolated forest patches with large edge areas can create changes in microclimate, 

vegetation species, and predator-prey dynamics. Such edge effects – magnitude of changes over 

distance from the edge to forest interior – will depend on the general orientation to the sun. Two 

main physical factors affecting and creating an edge microclimate are sun and wind (Forman 

1995; Chen et al. 1995, Harper et al. 2005). Together, sun and wind: 1) desiccate leaves by 

increasing evapotranspiration; 2) influence which plant species survive and thrive along the 

edge, usually favoring shade intolerant species; and 3) impact the soil, insects, and other animals 

along the edge. Compared to the forest interior, areas near edges receive more direct solar 

radiation during the day, lose more long-wave radiation at night, have lower humidity, and 

receive less short-wave radiation. These effects would be minimized or maximized along the 

pipeline route as a function of route orientation and the facing direction of each edge. Because 

the Pacific Connector pipeline generally trends from northwest to southeast, edge effects would 

be most pronounced on the southwest-facing edges and weakest along the northeast-facing edges 

(Chen et al. 1995). 

Fundamental changes in the microclimate of a stand have been recorded greater than 700 feet 

from the forest edge (Chen et al. 1995) and changes in microclimate regimes with forest 

fragmentation can potentially stress old-growth associated species, including the MAMU. 

Effects on humidity, in particular, may extend beyond 700 feet from edges. Effects of strong 

wind, as well, may extend beyond that distance (see Chen et al. 1995). However, such effects 

are dependent on such local conditions as orientation of an edge: the magnitudes of change in 

humidity with distance from an edge are most extreme with south-facing edges, compared to 

east- and west-facing edges (see figure 6 in Chen et al. 1995). 

Using recommendations from the ESA Sub-Task Group and Habitat Quality Subtask Group, 

indirect effects to interior forests that are greater than 80 years old were analyzed, considering 

interior forest to be defined as 300 feet from any existing edge of a contiguous forested stand, 

including edges created by adjacent regenerating stands approximately 10 to 20 years old. In 

their review of effects by forest edges on multiple response variables (including: 1) forest 

processes of tree mortality/damage, recruitment, growth rate, canopy foliage, understory foliage, 

and seedling mortality, 2) forest structure by canopy trees, canopy cover, snags and logs, 

understory tree density, herbaceous cover, and shrub cover, and 3) stand composition by species, 

exotics, individual species and species diversity), Harper et al (2005) reported that the mean 

distance of edge influence on any single response variable did not exceed 300 feet (100 meters). 

There is considerable overlap of interior forest habitat that are within MAMU CHU and within 

LSRs and LSMAs. If Project effects are examined in CHUs and LSR/LSMAs separately, areas 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-38

of affected interior forest would be double-counted. Table 4.6.1.2-8 shows acreage of areas of 

interior forest that is designated MAMU critical habitat as well as an LSR or LSMA that would 

be directly affected by construction, and areas indirectly affected 300 feet interior from newly 

created forest edges. Direct long-term effects from removal of interior forest by the Pacific 

Connector pipeline would include 6.93 acres, whereas indirect effects (extending 300 feet from 

new edge) would include 41.27 acres within CHU OR-06-d (table 4.6.1.2-8). 

TABLE 4.6.1.2-8

Direct and Indirect Effects from Construction of the Pacific Connector Pipeline to Interior Forests ≥80 Years Old within 

MAMU Critical Habitat that Overlaps with NSO Critical Habitat and LSRs 

Critical Habitat Unit Effect Type Effect Component 

Area (acres) of Interior 

Forest Affected a/

Construction Right-of-way 4.68 

TEWA 0.65 

Rock Source/Disposal 1.60 

UCSA b/ 8.64 

Total Direct Effects 15.57 

Direct Effects 

Total Long-term Direct Effects c/ 6.93 

MAMU CHU OR-06-d 

overlap with LSMA 

Indirect Effects Extending 300 feet from new edge d/ 41.27 

Construction Right-of-way 23.96 

TEWA 5.42 

Rock Source/Disposal 5.56 

UCSA b/ 11.44 

Total Direct Effects 46.38 

Direct Effects 

Total Long-term Direct Effects c/ 34.94 

MAMU CHU OR-06-d 

non-overlap with LSMA 

Indirect Effects Extending 300 feet from new edge d/ 211.63 

Construction Right-of-way 28.64 

TEWA 6.07 

Rock Source/Disposal 7.16 

UCSA b/ 20.08 

Total Direct Effects 61.95 

Direct Effects 

Total Long-term Direct Effects c/ 41.87 

MAMU CHU OR-06-d 

TOTAL 

Indirect Effects Extending 300 feet from new edge d/ 252.90 

a/ Interior forest is defined as ≥80-year old forested vegetation ≥300 feet from any existing edge of a contiguous forested stand, including 

edges created by adjacent regenerating stands ≈ 10 to 20 years old. 

b/ Effects to interior forest vegetation by use of UCSAs are assumed to be short-term impacts 

c/ Total Long-term Direct Effects do not include effects within UCSAs. 

d/ Distance of 300 feet extends from edges of Construction Rights-of-way and TEWAs, not from edges of UCSAs. 

Conservation Measures 

Conservation measures have been proposed by Pacific Connector to minimize construction and 

operation impact to the provincial analysis area. Those measures have been compiled in table 2C 

in Appendix N3 of the applicant prepared draft BA and apply to MAMUs. Specific conservation 

measures that would benefit MAMUs include those that: 

• minimize removal of forest by incorporating UCSAs into the project design; 

• minimize soil erosion during and after construction; and 

• minimize potential for establishment of invasive vegetation and control of noxious 

weeds; 

 

3

 Tables are included in Appendix N of the Draft BA, which Pacific Connector filed with the FERC in March 2008. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-39

Pacific Connector has also proposed measures to rectify, repair, and rehabilitate and otherwise 

reduce impact to forested habitats once construction of the Pacific Connector pipeline is 

complete. Those measures have been compiled in table 3C in Appendix N of the applicantprepared draft BA. Specific conservation measures that would benefit MAMUs include those 

that: 

• contribute to re-establishment of native vegetation, including coniferous species, that will 

eventually become mature trees; 

• contribute to forest habitat diversity (snags and downed timber); and 

• minimize potential for increased human use of the reclaimed construction right-of-way 

and intrusion into undisturbed habitats. 

Pacific Connector has modified its proposed route to avoid removing habitat and further 

fragmenting an occupied MAMU stand documented during 2007 surveys (R2036) and removing 

habitat from stands with suitable habitat surveyed for 2 years but no occupied behavior detected 

(B12). Also, to minimize impacts to occupied or presumed occupied MAMU stands and 

potential suitable nesting habitat, Pacific Connector’s current proposed route includes minor 

alignment adjustments or TEWA modifications to nine locations. For additional information, see 

Appendix 1 and Appendix 3 of the Marbled Murrelet and Northern Spotted Owl Avoidance and 

Minimization Plan, November 2008 (see BA). 

Near occupied stands, construction, clearing, and/or ground-disturbing activities would adhere to 

all conservation measures specified in the BO, which would be issued after FERC’s submittal of 

the BA. Such conservation measures could include no timber clearing, construction, and/or 

blasting within 0.25 mile, and no double-rotor helicopter use within 700 feet of an occupied 

stand from April 1 through September 15 (FWS 1997; Mack et al. 2003). However, if no 

occupancy of a site is detected during both years of the surveys, then the site would be 

considered unoccupied for 5 years after the 2-year survey protocol is complete, and timing 

constraints and buffers would not apply (Mack et al. 2003). Timber removal using ground-based 

equipment is also restricted by Forest Plan Standards and Guidelines, which restrict such activity 

to the dry season (June 1 to October 31). 

Prior to timber clearing, Pacific Connector would have experienced MAMU biologists cruise 

both the occupied and unoccupied suitable habitat stands in which habitat would be modified by 

Pacific Connector construction and mark trees that currently have nest platforms or potential. If 

feasible, Pacific Connector would avoid removal of those marked trees. To further minimize 

impact to MAMU habitat, Pacific Connector would clear timber after the critical breeding season 

(after August 5) of Year One, unless a nest tree is identified within the project area to be 

timbered, in which case Pacific Connector would wait until after the entire breeding season (after 

September 15). This scheduling would occur in 9 of the 11 occupied stands slated to have timber 

removed. Additional seasonal and daily timing restrictions would be applied to areas identified 

as potential murrelet habitat within the draft EIS-revised routes if surveys identify suitable 

nesting habitat and/or behavior indicating occupation of a stand during the 2-year surveys. 

Construction of the pipeline within MAMU range is scheduled during Year One between MPs 

0.0 and 30.0 (with the exception of any identified occupied stands in the draft EIS-revised route 

WC1A and the HDD scheduled at the Coos River) and in Year Two between MPs 30.0 through 

62.0 from May 1 to November 30. In Year Two where occupied stands and their associated 0.25 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-40

mile buffer occur, construction would adhere to the daily timing restrictions to minimize risk of 

disturbance to adult murrelets entering and leaving the stand and possible dispersal of juveniles. 

Stands within the analysis area where no occupancy of a site was detected during both years of 

surveys are considered unoccupied for 5 years after the 2-year survey protocol is complete, and 

timing constraints and buffers would not apply (Mack et al. 2003). However, some of the sites 

unlikely to be occupied would have daily and seasonal restrictions applied because of the sites’ 

proximity to known occupied stands with restrictions applied. 

Overall TEWA requirements within forested habitats would be minimized in MAMU range. For 

example, TEWAs used the first year to stage right-of-way logging activities and provide log 

storage and decking would also be used the following year for pipeline construction activities. 

Additionally, to minimize disturbance within forested areas of the pipeline area, Pacific 

Connector has designated approximately 197 acres (table 4.6.1.2-3) of UCSAs within the 

MAMU range that would not be cleared of trees but be used to store forest slash, stumps, and 

dead and downed log materials during construction that would be scattered across the right-ofway after construction and during restoration. The UCSAs would be useful for the construction 

of the Pacific Connector pipeline without requiring removal of trees or understory vegetation, as 

occurs for TEWAs. 

Following construction, affected forested lands (the construction right-of-way and temporary 

extra work areas outside of the 30-foot maintenance right-of-way) would be replanted and 

allowed to return to pre-construction condition with tree species in the approximate proportion to 

those species removed. Tree establishment would be allowed to occur up to 15 feet of either side 

of the pipeline centerline. Over the long-term (80 years or more to become MAMU suitable 

habitat), revegetated areas outside of the 30-foot maintenance corridor may achieve tree 

structural characteristics comparable to trees that would be removed, had they not been affected. 

Because effects by the proposed action cannot be fully mitigated on site, Pacific Connector has 

proposed a Mitigation Plan to compensate for unavoidable impacts (see Appendix L3). Pacific 

Connector would provide mitigation funds to BLM and USFS to permanently reclaim other 

existing disturbances of capable habitat, such as roads within LSRs or LSMAs that are no longer 

required for resource management to mitigate project-related impacts. These mitigation funds 

could also be used to: 1) conduct noncommercial thinning treatments or other silvicultural 

projects to create or accelerate development of old growth characteristic elsewhere on federal 

land; 2) acquire title or easement to private lands adjacent/near the pipeline that could be 

managed/preserved as late successional habitat; and/or 3) acquire title or easement to private 

lands to block up ownership with BLM or NFS lands to increase connectivity, or to fund the 

conversion of Matrix lands to LSR. Alternatively, Pacific Connector may acquire easements or 

properties as conservation parcels in the project area that would preserve/protect suitable, 

dispersal, capable habitat to mitigate for project impacts. These easements or parcels may be 

deeded to a federal agency or a conservation organization or trust. 

Given the presence of MAMUs within the proposed action area, there may be effects to MAMUs 

directly due to noise generated from timber clearing and construction activities, as well as 

indirect effects associated removal of suitable murrelet nesting habitat including increased 

fragmentation and predation and secondary effects associated with increased human presence 

and use of the permanent right-of-way. For these reasons, the proposed action may impair the 

suitability of seasonally or permanently occupied habitat, or impair or degrade unoccupied 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-41

habitat necessary for the survival of MAMUs locally. Incidental take due to those impact 

sources is expected. Based on these evaluations and with implementation of the proposed 

conservation measures, the proposed action is likely to adversely affect MAMUs. 

Based on removal and potential degradation of principal constituent elements defined in the 

Final Rule designating critical habitat for the MAMU (FWS 1996), the proposed action is likely 

to adversely affect designated MAMU CHU OR-06-d. 

Additionally, food enticements associated with human presence during construction activities 

could temporarily increase predator populations within the vicinity of the Pacific Connector 

pipeline. Therefore, in the draft EIS we recommended that Pacific Connector develop a 

management plan that would ensure that the right-of-way and all work areas within marbled 

murrelet suitable habitat be kept clear of construction debris and food wastes that could attract 

marbled murrelet predators. In response, Pacific Connector noted that they would ensure that 

construction contracts include stipulations that ensure the contractor is responsible for cleaning 

work areas of construction debris and food wastes on a daily basis during all construction 

activity periods. Additionally, Pacific Connector’s EIs would be on site and would be 

responsible for overseeing that the construction contractor is adequately removing construction 

debris and food wastes that could attract predators during construction. FERC’s third-party 

Environmental Monitors would also ensure that these construction stipulations are being 

followed. These regulations would not apply to construction materials left on site, for example 

erosion controls and silt fencing; these would be novel items and could attract curious birds 

temporarily, but are not expected to increase local corvid densities to the extent that a new food 

source (i.e., dropped food and garbage from construction personnel) would. 

Northern Spotted Owl (Federal Threatened Species with Critical Habitat, State 

Threatened Species) 

In Oregon, the NSO is found in low- and mid-elevation coniferous forest in the Coast, Siskiyou, 

and Cascade Ranges (Forsman 2003). Suitable habitat for NSOs provides elements necessary for 

nesting, roosting and foraging. NSOs also require habitats that can be utilized during juvenile 

dispersal, which provide sufficient tree cover and canopy cover for protection from predators, as 

well as habitat for prey species. Nesting and roosting habitats have diverse structural 

components. Owls generally nest in forests with a dominant tree canopy of 60 to 80 percent and 

multiple layers provided by large trees (more than 30 inches dbh). Trees with various structural 

deformities (cavities, broken tops and mistletoe infections), large snags and accumulated fallen 

trees and debris are also important habitat features (FWS 1992b). Most nest and roost sites are 

within old growth forest stands, between 100 and 200 years old (FWS 1992b), although nest and 

roost sites can be found in various-aged forests (Courtney et al. 2004). Suitable nesting, 

roosting, and foraging habitat is considered 80 years or older (FWS 2006d). Foraging and 

dispersal habitats may be in younger, more open and fragmented forests than those associated 

with nesting and roosting (FWS 1992a). Foraging habitat may also be consistent with areas that 

NSO prey is found. NSO feed primarily on small mammals, especially northern flying squirrels 

and woodrats in southwestern Oregon (citations in Anthony et al. 2006). 

NSOs have large home ranges and utilize large tracts of land containing significant acreage to 

meet their biological needs and a wide array of forest types and structures are necessary to 

support the various life histories (FWS 1992a). Within the pipeline area, home ranges or 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-42

territories vary depending on physiographic region, forest type and heterogeneity, but usually 

encompass an area within a radius between 1.2 and 1.5 miles from a nest or roost site (FWS 

1992c). Typically, a larger area is required for owls in more fragmented habitats (Courtney et al. 

2004). 

The FWS (2006a,b, 2008) and available data (BLM 2006; ORNHIC 2006a; USFS 2006a) 

indicate that NSOs occur in the vicinity of the proposed Pacific Connector pipeline alignment 

and that designated critical habitat (OR-8 [Southern Oregon Coast Ranges], OR-14 

[Rogue/Umpqua], and OR-17 [Southern Cascades]) for the species is present in each county 

crossed by the pipeline. Additionally, the Pacific Connector pipeline would pass through three 

LSR or LSMs: RO 223 (BLM Roseburg District), RO 227 (Rogue River-Siskiyou National 

Forest), and RO 261 (BLM Coos Bay District and Roseburg District). 

Managed owl conservation areas (MOCAs) are networks of blocks of contiguous suitable NSO 

habitat, located at appropriate dispersal distances from each other that are meant to mimic 

historical spotted owl habitat conditions. MOCAs are discussed in the BA, including expected 

impacts to the MOCAs from the proposed Project. Four MOCAs occur within the provincial 

analysis area, of which two are crossed by the proposed Project and would have habitat removed: 

5.0 miles crossed in Category 24 MOCA-29 in the Klamath Mountains Physiographic Province, 

Douglas County (14,426 acres) and 13.4 miles crossed in Category 15 MOCA-17 in the West 

Cascades Physiographic Province, Jackson County (49,367 acres). Approximately 47 acres of 

suitable NRF habitat would be removed within MOCA-29 and an additional 17.6 acres of 

dispersal only habitat would be removed. This represents approximately 0.4 percent of available 

suitable NRF habitat in MOCA-29. In MOCA-17, approximately 68.3 acres of suitable habitat 

and 62.7 dispersal only acres would be removed from the proposed Project. This represents 

approximately 0.3 percent of available suitable NRF habitat in MOCA-29. 

Within MOCA-29, the proposed route completely follows a ridgeline. Also, approximately 44.0 

percent of the proposed Project (2.2 miles) within MOCA-29 occurs within or adjacent to 

existing rights-of-way or roads. Figure 3.4-12 in section 3.4.2.15 of this EIS shows the Robinson 

Butte to Burton Butte Route variations (MPs 155 to 169) including the originally proposed route 

by Pacific Connector (May 2006; Alternative 1), the route recommended by Rogue RiverSiskiyou National Forest (Alternative 2), and the FERC-filed preferred/compromise route 

(Alternative 3). These alternative routes occur within MOCA-17, approximately MPs 153.8 to 

167.7. The discussion of the Robinson Butte to Burton Butte/Forest Service Roads Route 

Variation in section 3.4.2.15 of this EIS provides a detailed description of the determination of 

the final compromise route (Alternative 3) after consultations with agency biologists and a field 

trip to the USFS-recommended route to discuss the construction issues associated with 

Alternative 2. This route occurs within or adjacent to existing roads, along ridgetops, within 

more recent clearcuts, and within thinned forest. Approximately 32.8 percent of the proposed 

pipeline (4.4 miles) within MOCA-17 occurs within or adjacent to existing rights-of-way or 

roads. 

Two other Category 2 MOCAs, MOCA-27 and MOCA-30 are located within the provincial 

analysis area within the Klamath Mountains and Coast Range Physiographic Provinces, 

 

4

 A Category 2 designated conservation area has the potential to support 1 to 19 NSO pairs. 5

 A Category 1 designated conservation area has the potential to support at least 20 NSO pairs 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-43

consecutively. No MOCAs were identified in the dry-forest located in the East Cascades 

Physiographic Province. More detailed information on MOCAs can be found in the BA. 

The 2008 Final NSO Recovery Plan specifies 34 Recovery Actions, which are recommendations 

meant to guide activities needed to accomplish NSO recovery objectives. Of the 34 Recovery 

Actions, 28 are not applicable to this Project. Of the remaining six, the proposed pipeline is 

consistent with three, not consistent with two, and more research is needed to determine whether 

the pipeline would be consistent with the remaining one. The two Recovery Actions that the 

proposed pipeline is not consistent with are: 1) to manage MOCAs on the West Side for the 

highest amount and quality habitat, and 2) to maintain high-quality habitat outside of MOCAs. 

The proposed pipeline would not be consistent with these Recovery Actions because suitable 

NRF habitat would be removed within and outside of MOCAs. Pacific Connector is in 

consultation with FWS, BLM, USFS, and ODFW regarding appropriate mitigation for these 

permanent impacts to NSO habitat through the Mitigation Plan. The Recovery Action for which 

more research is needed to determine consistency is to manage for more fire-resilient and fireresistant forests in the Klamath Mountains Physiographic Province. Although MOCA 29 would 

be crossed by the pipeline, the MOCA would still be able to support a sufficient number of owl 

pairs to meet the objective for the MOCA. However, due to uncertainties regarding future land 

management approaches in this dry area, the effect of the project on fire dynamics and its 

consistency with this NSO Recovery Action cannot be determined at this time. For more 

information on the consistency of the Pacific Connector Pipeline with NSO Recovery Actions 

from the Final Recovery Plan, see the BA. 

Two areas of concern have been identified by Roseburg BLM District, of which one, the RougeUmpqua portion of the I-5 Area of Concern (AOC; also known as the Cow Creek Area of 

Concern), is located within the proposed analysis area. AOCs were identified as areas where 

NSO dispersal opportunities were limited because of the available forested habitat, land use 

allocations identified by the NWFP (BLM and USFS 1994), and the checkerboard land 

ownership pattern. BLM (2008) indicated that timber harvesting on private lands within these 

identified AOCs has reduced the overall dispersal habitat and would likely decline further as 

harvesting continues. The northern portion of Rogue-Umpqua portion of the I-5 AOC is located 

between Pacific Connector MP 28.12 and MP 62.52, and MP 82.72 and MP 111.12, and 

provides a link between CHUs OR-8 and OR-14, as well as several MOCAs. Of the land 

making up this AOC, 71.8 percent (649,461 acres) is dispersal habitat. Approximately 19.9 

percent of the Rogue-Umpqua portion of the I-5 AOC occurs within the provincial analysis area, 

of which 71.8 percent (121,091.5 acres) provides dispersal habitat. Removal of forested habitat 

within this AOC may further limit the dispersal ability of NSOs; however, within this area, the 

pipeline has been routed generally along existing roads and so should minimize the amount of 

forested habitat removed and/or creation of additional corridors, as well as limit negative impacts 

to NSO dispersal. Additionally, the Beatty Creek Research Natural Area is in the vicinity of the 

proposed pipeline route but is located about 10 miles south; therefore, the proposed pipeline is 

not expected to have impacts on this area. 

Impacts and Conservation Measures

Pipeline-related effects to NSOs could be caused by the action and occur at the same time and 

place, including the following within the provincial analysis area: 1) human and noise 

disturbance due to right-of-way clearing and construction during the breeding period, 2) noise 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-44

due to blasting and helicopter support during construction, and 3) removal of suitable nesting, 

roosting, and foraging habitat during the entire breeding season (March 1 through September 

30). 

Direct Impacts 

Potential direct effects to the NSO may include noise, human-related disturbances, smoke from 

prescribed burnings, and habitat loss. Habitat loss and modification, whether to nesting, roosting 

or foraging habitats, due to forest clear-cutting has been the most significant factor causing 

declines of the NSO (FWS 1992b). Habitat losses and habitat fragmentation have direct impacts 

that can affect survival and reproduction of NSOs. Short-term impacts are likely to last from the 

initiation of timber clearing until 1 to 3 years afterward. Long-term impacts to NSOs and 

suitable nesting, roosting, foraging habitat are expected to last 4 years and more. 

In the late breeding period, potential effects from disturbance decline because juvenile NSOs are 

increasingly more capable of moving away from disturbances. Once capable of sustained flight, 

young owls are presumably able to both distance themselves from disturbance and minimize 

their risk of predation. To ensure that more than 86 percent of juvenile NSOs in the Oregon 

Western Cascades Physiographic Province are able to move away from disturbances without 

increasing their risk of predation or harm, the critical nesting period is considered to be March 1 

through July 15. This is based on fledge data (Turner 1999) and includes an additional two 

weeks to allow for development of flight skills. After July 15, most fledging NSOs are assumed 

to be capable of sustained flight and can move away from harmful disturbances. The critical 

breeding period for the Oregon Western Cascades Physiographic Province is applied to the entire 

provincial analysis area, even though research has provided data that indicate NSOs fledge 

earlier in other physiographic provinces within the analysis area. 

Noise

NSOs would be directly affected by noise and disturbance related to proximate human-related 

activities associated with timber removal, construction, and operation and maintenance of the 

Pacific Connector pipeline that could result in diminished reproductive success and survival (if 

behavior response to construction makes them more vulnerable to injury). In the Northern 

Spotted Owl Status Review, none of these types of disturbance were considered a threat to the 

species (Courtney et al. 2004). However, at the individual level, based on anecdotal information 

and effects to other bird species (Wesemann and Rowe 1987; Delaney et al. 1999; Delaney and 

Grubb 2001; Swarthout and Steidl 2001; FWS 2003b; and FWS 2005f), disturbance to owls is 

inversely related to stimulus distance and positively related to noise level, similar to results 

reported for bald eagles (Grubb and King 1991), gyrfalcon (Platt 1977), and other raptors 

(Awbrey and Bowles 1990). 

Based on available data, FWS (2006f) indicated that the behaviors noted above may occur when 

1) the project-generated sound level substantially exceeds existing ambient noise levels by 20 to 

25 dB; 2) when the total sound level (project and ambient noise levels combined) exceeds 90 dB; 

or 3) when the visual proximity of human disturbance occurs within 130 feet of an active nest 

site. FWS has concluded that significant noise and human presence can result in a disruption of 

breeding, feeding, or sheltering behavior of NSOs such that it creates the potential for injury to 

the individuals (i.e., incidental take in the form of harassment). In a previous biological opinion, 

FWS (FWS 2006f) provided distances from a project boundary within which NSOs could 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-45

potentially be distracted, or “disturbed” from their normal activity. Those distances are often 

applied as seasonal buffers to minimize impacts of projects on nesting NSOs. The FWS 

typically considers the harassment threshold for general noise generating activities within a 0.25-

mile radius (125-acre area) of the activity, or within a 1.0-mile radius (2,176-acre area) for large 

disturbance activities such as open air blasting using more than a 2 pound charge or large aircraft 

(FWS 2003b; Smith et al. 2007; Wille et al. 2006). Additionally, FWS (2003b) provided some 

evidence suggesting that noise that builds gradually, such as a helicopter approaching from a 

distance, may result in less risks than sudden noises. 

Pacific Connector has prepared a report6 that analyzes the distances at which conventional 

blasting required for trenching within rock substrate for pipeline construction and transport 

helicopters attenuate to 92 dB. Under the worst case conditions with common and appropriate 

mitigation measures applied to trench blasting operations, it is expected that blasting noise would 

attenuate to 92 dB within 200 feet of the source, and to 70 dB within 1,025 feet of the blast 

source in soft rock. Likewise, large transport helicopters will attenuate to 92 dB within 700 feet; 

both of these distances are well below the 0.25-mile radius. The greater distance for helicopter 

use is due to the directional aspects of blade slap noise that is directed toward the ground. 

Mitigation for helicopter noise includes operational restrictions, such as maintaining a high 

altitude and flight paths away from noise sensitive areas whenever possible. Table 4.6.1.2-9 

below summarizes the results of the analysis and indicates distance from a blast-related noise 

source to the projected 92 dBA criteria. Blasting and helicopter use within disturbance distances 

from active NSO nests should not be carried out during the critical nesting period. 

TABLE 4.6.1.2-9 

Projections of Distances for Blasting Noise to Attenuate to 92 dBA Under Different Conditions

Distance to Attenuate to 92 dBA Level 

Propagation Conditions Un-Mitigated Soft Rock - Mitigated Hard Rock - Mitigated 

Normal a/ Up to 4,000 feet Less than 125 feet Less than 125 feet 

Moderate b/ Up to 5,000 feet 125 feet Less than 125 feet 

High c/ > 5,500 feet 200 feet 125 feet 

a/ Normal: assumes moderate temperatures and minimal reflective surfaces 

b/ Moderate: assumes colder temperatures, or reflective surfaces, or a low pressures system 

c/ High: assumes combined low temperature with inversion, wind in the direction of the noise sensitive land use and low dense 

cloud cover. 

Human-Related Disturbance

Disturbance (both visual and noise) from construction, maintenance, and operation of the Pacific 

Connector pipeline would include chainsaws and heavy equipment during vegetation clearing 

and pipeline construction, explosives to trench through rock, helicopters and/or small aircraft to 

inspect the pipeline once per year during the life of the project, and brush control (i.e., mowing 

and cutting) within the permanent right-of-way every 3 to 5 years for the life of the pipeline. For 

a significant disruption of NSO behavior to occur, the disturbance and the NSO must be in close 

proximity to one another (FWS 2003b; FWS 2005f). Human presence on the ground is not 

expected to cause a significant disruption of behavior because it does not normally seem to 

startle NSOs (FWS 2005f); however, increased human presence in an area where previously it 

 

6

 Blasting and Helicopter Noise Analysis and Mitigation Plan is included in Appendix P of the applicant-prepared draft BA, 

which Pacific Connector filed with the FERC in March 2008. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-46

was minimal may indirectly negatively affect NSOs. Table 4.6.1.2-10 lists the number of NSO 

nest sites in relation to potential human disturbance from the proposed pipeline activities. 

TABLE 4.6.1.2-10 

Number of NSO Sites within the Action Area 

in Relation to Proposed Pipeline Project Disturbance 

Status of Owl Site 

Nest Patch Within 1/4 Mile Within 1 mile Owl Nest Patch blasting/ helicopter Owls within 1/4 mile of blasting/ helicopter Owls within 1 mile of blasting/ helicopter EAR - Nest Patch EAR - within 1/4 Mile 

Within Critical Breeding Period 3/1-7/15 

Known NSO Site 0 1 3 0 1 3 1 1 

Predicted NSO Site 0 0 1 0 0 1 0 1 

Totals 0 2 8 0 2 8 2 4 

Outside Critical Breeding Period After 7/15 

Known NSO Site 5 4 30 0 5 30 4 9 

Predicted NSO Site 2 4 5 1 2 5 3 2 

Totals 7 8 35 7 8 35 7 11 

Reactions of NSOs to close human presence and excessive noise levels at or in the immediate 

vicinity of owls, are expected to include the following: 1) flushing from the nest site, which 

would leave eggs or young exposed to predation; 2) causing juveniles to prematurely fledge, 

which would increase juveniles’ risk of predation; 3) interrupting foraging activities, which 

would result in the reduced fitness or even mortality of an individual; and/or 4) disrupting 

roosting activities which would cause a NSO to be displaced and possibly relocate. NSOs 

disturbed at a roost site are presumably capable of moving away from disturbance without a 

significant disruption of behavior. Because NSOs are primarily nocturnal predators, projects that 

occur during the day are not likely to disrupt foraging behavior, and the potential for effects is 

largely restricted to breeding behavior at an active nest site. 

Burning and Smoke

Effects on NSO of smoke that would be generated, whether by prescribed burning as a habitat 

enhancement procedure or by burning slash, have not been studied. However, FWS et al. (2007) 

have declared (see Table 15, FWS et al. 2007) that “smoke can cause (NSO) adults to move off 

nest sites, therefore leaving eggs or young exposed to predation or resulting in lost feedings 

reducing the young’s fitness.” According to BLM and USFS (2008, page 34), NSOs “are 

potentially affected by fire control activities and drifting smoke during burning. The threshold 

distance for disturbance from smoke is one-fourth mile for NSOs,” which would be subject to 

smoke-related disturbance during the critical breeding period. Pacific Connector would not 

conduct slash burning during the critical breeding season within one-quarter mile of an occupied 

NSO nest patch, and no direct effects to NSOs due to slash burning are expected. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-47

Habitat Removal and Modification

The decline of NSOs has been linked to the removal and degradation of available suitable NRF 

habitat. Appropriate vegetation and structural components are necessary to maintain suitable 

habitat and the removal of these components can potentially have adverse effects on NSO 

populations, such as displacement from traditional nesting areas, increased concentration of 

NSOs into smaller, fragmented areas of suitable habitat, and diminished reproductive success 

(FWS 2006f). In the provincial analysis area, NSO habitat needs and home ranges vary based on 

physiographic provinces and forest type. In the Coast Range Province, the home range is 

assumed to be circular with a radius of 1.5 miles (extends from MP 0.00 to MP 52.21); within 

the Klamath Mountains province the home range radius is 1.3 miles (from MP 52.21 to MP 

122.61), and in the West Cascades (from MP 122.61 to MP 167.71) and East Cascade provinces 

(from MP 167.71 to MP 191.19) the home range radius is 1.2 miles (FWS 1992b). Although 

differences exist in natural stand characteristics that influence provincial home range size, habitat 

loss and forest fragmentation caused by timber harvest effectively reduce habitat quality in the 

home range. A reduction in the amount of suitable habitat reduces NSO abundance and nesting 

success (Bart and Forsman 1992; Bart 1995) and recent studies have indicated that NSOs’ home 

ranges are substantially larger in more heavily fragmented stands (Courtney et al. 2004). The 

Pacific Connector pipeline would affect NSOs over the long term by habitat removal and 

modifications. 

In total, the pipeline project would remove approximately 732 acres of suitable nesting, roosting, 

and foraging habitat during construction (table 4.6.1.2-11 and table H-3 in Appendix H), 190 

acres of which would be permanently lost to the pipeline corridor that would be maintained in an 

herbaceous/shrub state not to exceed 6 feet in height post-construction. The other 542 acres of 

removed suitable NRF habitat would be revegetated and considered capable of becoming NRF 

habitat in 80 plus years. Removal of 732 acres of NRF represents approximately 0.5 percent of 

the 151,466 acres of suitable NRF habitat in the analysis area. During pipeline construction, 

approximately 882 acres of young, regenerating forest (< 80 years old) would also be cleared of 

vegetation (table 4.6.1.2-11). This would lengthen by decades the amount of time it would take 

for these stands to become suitable NSO habitat, resulting in increased impacts to NSO habitat 

over the long term. Additionally, 397 acres of suitable NRF habitat have been identified for use 

by the Pacific Connector pipeline project as UCSA that may be used to store forest slash, stumps, 

and dead and downed log materials that would be removed and scattered across the right-of-way 

after construction during restoration. Use of the UCSAs would be a short-term modification of 

suitable NRF habitat and habitat function should be maintained. For more detailed information 

on effects to NSO habitat by physiographic province, landowner, and land allocation see table H3 in Appendix H. 

A total of 695 dispersal only habitat acres (1,427 total dispersal acres) within the four 

physiographic provinces crossed would be removed; this represents approximately 0.5 percent of 

all total available dispersal habitat (294,767 acres) within the provincial analysis area. 
4.6 – 

4.6-48

TABLE 4.6.1.2-11 a/

Summary of Effects to NSO Suitable Habitat on Federal and Non-Federal Lands within the Defined Provincial Analysis Area as a Result of 

Suitable Habitat c/ Dispersal Only Habitat d/ Total Dispersal Habitat e/ Capable Habitat f/ Noncapable Ha

Landowner b/ Removed h/ Modified i/ Removed h/ Modified i/ Removed h/ Modified i/ Removed h/ Modified i/ Removed h/ M

Coast Range Physiographic Province Federal 39.60 14.02 98.18 15.28 137.78 29.30 36.61 5.71 21.22 Non-Federal 40.52 4.22 168.90 12.12 209.42 16.34 290.86 28.73 690.83 Total 80.12 18.24 267.08 27.40 347.20 45.64 327.47 34.44 712.05 Klamath Mountains Physiographic Province Federal 234.98 149.15 104.17 30.91 339.35 180.06 45.68 18.44 49.55 Non-Federal 180.03 161.03 120.38 86.42 300.41 247.45 207.15 76.34 1305.14 Total 415.01 310.18 224.55 117.33 639.76 427.51 252.83 94.78 1354.69 West Cascades Physiographic Province Federal 129.74 49.67 97.81 27.3 227.55 77.01 77.25 10.96 82.98 Non-Federal 38.23 10.39 58.81 7.27 96.96 17.65 91.59 6.54 131.85 Total 167.97 60.06 156.62 34.57 324.51 94.66 168.84 17.50 214.83 East Cascades Physiographic Province Federal 53.55 8.32 21.01 4.01 74.56 12.33 16.85 0.84 3.56 Non-Federal 15.50 0.02 25.62 1.05 41.12 1.07 116.58 1.48 53.25 Total 69.05 8.34 46.63 5.06 115.68 13.40 133.43 2.32 56.81 Overall Action Area Total Federal 458.07 221.16 321.17 77.53 779.24 312.71 176.39 34.15 157.31 Non-Federal 274.28 175.66 373.71 106.86 647.71 282.51 706.18 113.04 2181.07 Total 732.35 396.82 694.88 184.39 1426.95 595.22 882.57 147.19 2338.38 a/ More detailed information on BLM Districts and National Forests impacted, as well as critical habitat and NWFP late-successional reserves, is located in tab/ Land Owner: Federal = BLM, USFS, and BOR. Non-Federal = Private, State, State Forest. c/ Suitable Habitat: Forest stands used by NSO for NRF (conifer dominated, 80+ years, multi-storied, sufficient snags and LWD, canopy closure > 60 percenBioMapper model described in section 4.2.5.2 (Habitat subsection) that included mid-seral, late-successional, and old-growth coniferous forest PLUS coniferoyears within the Project area but not included in the model (all late-successional and old-growth within the range of the NSO).

d/ Dispersal Only Habitat (only includes dispersal habitat not located in suitable habitat): support owl movement across landscape but lack structural charact

mixed mature conifer-hardwood, canopy cover ≥ 40 percent, average dbh ≥ 11 inches). This was determined using the GNN model described in section 4.2.5

forested habitat (coniferous, mixed coniferous/deciduous, and deciduous) occurs within the Project area but did not include recent clearcut areas. 

e/ Total Dispersal Habitat (includes dispersal habitat that coincides with suitable habitat): support owl movement across landscape but lack structural charact

mixed mature conifer-hardwood, canopy cover ≥ 40 percent, average dbh ≥ 11 inches). The acres within this column are not included in the Total Acres since 

Dispersal Only. f/ Capable Habitat: not currently NSO habitat (see # 3 and #4) but have the potential to become habitat in the future and includes recent clearcuts, as well as 

forested habitat (plus all seral stages of deciduous forest) not included within the suitable habitat or dispersal habitat models. 

g/ Noncapable Habitat: areas such as lakes, rivers, rock outcroppings, roads. h/ Project components considered in calculation of habitat “Removed”: Pacific Connector construction right-of-way, temporary extra work areas, abovegroun

access roads (PAR, TAR), pipe storage yards. i/ Project components considered in calculation of habitat “Modified”: Pacific Connector UCSAs described in section 3.3.3.2 of the Project description and wo

construction. These areas would be used to store forest slash, stumps and dead and downed log materials that would be removed and scattered across the 

restoration and are considered as temporary insignificant habitat modifications. j/ Total Acres includes only the removed and modified columns within Suitable NRF, Dispersal Only, Capable, and Non-Capable Habitat. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-49

Discussion at the Task Force - ESA Consultation Subgroup meeting on April 2, 2008 indicated 

that NSO dispersal habitat could be considered adequate if at least 50 percent of the analysis area 

(in the Pacific Connector pipeline’s case, the defined provincial analysis area) consisted of 

dispersal habitat. All physiographic provinces are above the recommended threshold of 50 

percent available dispersal habitat; however, East Cascades province is just above threshold at 

50.2 percent. Removal of dispersal habitat from any of the Physiographic Provinces crossed 

would not cause the amount of available dispersal habitat within the defined provincial analysis 

area to drop below the recommended 50 percent dispersal habitat threshold. Although removal 

of dispersal habitat would occur (post-action there would be approximately 50.1 percent of 

dispersal habitat available within the East Cascades Physiographic Province), the reduction is not 

considered significant according to this task group discussion. Additionally, removal of 

dispersal habitat would not be in one locale, but would be removed within 191.2 miles of the 

proposed pipeline in the range of the NSO, including 23.5 miles of proposed pipeline in East 

Cascades. After the project is completed, neither the temporary 95-foot wide construction rightof-way and associated TEWAs nor the permanent 30-foot maintenance corridor should impede 

the movement of juveniles and adults. 

Permanent effects to habitat capable of becoming suitable nesting, roosting, and foraging habitat 

(Capable Habitat), which includes forested habitat less than 80 years of age not previously 

considered suitable and/or dispersal habitat and recently clearcut forest are also included in table 

4.3.5.3-5 in the BA. Approximately 883 habitat capable acres would be removed for 

construction of the proposed pipeline, of which 177 acres would remain in a permanent 

herbaceous/shrub state within the 30-foot operational corridor during the life of the pipeline. 

The total 1,129 acres of impact to suitable NRF habitat (removal and modification) included in 

table 4.6.1.2-11 is probably an over-estimation. Determination of suitable habitat relied heavily 

on using BioMapper to model habitat within the provincial analysis area, and all late 

successional and old-growth forest within the range of the spotted owl was considered suitable 

habitat regardless of whether it was isolated or contiguous. Furthermore, not all habitat 

considered occurs within the home ranges of known or predicted spotted owls. To determine the 

amount of habitat being removed within known and predicted owl home ranges, 11 owl groups 

within the provincial analysis area were created that included all known and predicted owls 

whose home ranges overlapped. The number of owls included in each group varied from 1 to 42 

(table H-4 in Appendix H). If just considering habitat within the known or predicted home 

ranges of NSOs within the analysis area, approximately 546 acres of suitable habitat would be 

removed or impacted over the long term and 444 acres would be impacted over the short term by 

potential use of proposed UCSAs. This is approximately 88 percent of suitable NRF habitat 

removed or modified by the proposed pipeline. 

Indirect Effects 

Indirect effects are pipeline project-related effects to NSOs that are caused by the action (induced 

by the action and by human presence and use increase) and are later in time or farther removed in 

distance, but are still reasonably foreseeable. Some indirect effects to NSOs that are often 

related to habitat loss or modification are increased predation, increased competition, and effects 

on prey utilized by NSOs. In addition, secondary effects (Comer 1982) due to an increased 

human population base are expected, whether resulting from the requirements of the action itself 

(the workforce needed to construct or operate the project) or as consequences of the action (need 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-50

for ancillary goods, services, opportunities resulting from the project). Potential indirect or 

secondary effects by the proposed pipeline include increased recreation demand (including offroad vehicle - OHV - use), increased habitat conversion, habitat degradation by human intrusion 

and encroachment, and increased illegal harvest (Comer 1982). 

Habitat Fragmentation

Indirect effects to NSO habitat would occur from fragmentation of currently contiguous forest 

stands. Construction of the Pacific Connector pipeline would fragment an estimated 38 miles of 

suitable NSO habitat (nesting, roosting, and foraging), creating edge within affected stands. 

Fragmentation of NSO habitat is considered a cause for poor demographic performance, 

although the threat posed by fragmentation is still not fully understood (Courtney et al. 2004). 

FWS (2004) indicated that habitat fragmentation was the “aggregate of effects of historical 

habitat loss, continuing habitat loss due to uncharacteristic wildfire, and continuing timber 

harvest, albeit at reduced levels” and that habitat fragmentation remained a threat in the northern 

part of the NSO’s range but was reduced in the southern portions of the owl’s range. 

Effects of fragmentation on NSO demographic parameters are complex. On one hand, 

reproductive output was found to be greater at sites with more edge between older forest (mature 

and old growth) and other adjacent vegetation reproductive output declined in areas with greater 

amounts of interior forest (Franklin et al. 2000). Alternatively, NSO survival increased with 

more interior forest and increased edge (Franklin et al. 2000). As reviewed by Franklin and 

Gutiérrez (2002), locations in which NSO have high reproduction and high survivorship 

(collectively, high fitness) are a balance between the amounts of interior forest and edges with 

older forest. 

There are 122 patches of interior forest ≥ 80 years old through which the Pacific Connector 

pipeline would be constructed. The minimum patch size is 0.3 acres and the maximum size is 

1,039 acres but the majority of patches are less than 50 acres, shown by the frequency 

distribution in figure 4.6-2, below.

Figure 4.6-2 Frequency Distribution of Patches of Interior Forests ≥ 80 Years Old Affected by the 

Proposed Pacific Connector Pipeline 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-51

Table 4.6.1.2-12 provides the number of home ranges crossed by the proposed Pacific Connector 

pipeline that would experience additional fragmentation. Many of the NSO home ranges 

overlap, so the numbers provided are indicative of the NSO pairs or residential singles that 

would have habitat affected and not the number of patches that would be crossed, since one 

patch crossed may affect multiple owl home ranges. 

TABLE 4.6.1.2-12 

Number of NSO Home Ranges by Physiographic Province that would Experience Additional Fragmentation (i.e., forested 

patches crossed by Pacific Connector pipeline)

Habitat Condition NSO Status Coast Range 

Klamath 

Mountains 

West 

Cascades 

East 

Cascades Total 

1 = >50% core area, Known 3 27 11 3 44 

>40% home range Predicted 2 5 0 0 7 

2 = < 50% core area, > Known 1 5 3 0 9 

40% home range Predicted 1 0 0 0 1 

3 = >50% core area, Known 0 1 1 0 2 

<40% home range Predicted 2 0 0 0 2 

4 = < 50% core area, < Known 4 2 6 1 13 

40% home range Predicted 1 0 1 0 2 

Known 8 35 21 4 68 

TOTAL 

Predicted 6 5 1 0 12 

There is considerable overlap of interior forest habitat that is within NSO CHUs and within 

LSRs. LSMAs completely overlap with NSO critical habitat (BLM 2008). Some NSO critical 

habitat also overlaps with MAMU critical habitat. Those overlaps are discussed below in the 

section Critical Habitat/Late-Successional Reserve. 

Table 4.6.1.2-13 was developed to clearly indicate areas of interior forest that do not coincide 

with LSRs or with NSO or MAMU CHUs, but which would be directly affected by construction, 

and areas 300 feet interior from newly created forest edges that would be indirectly affected. 

TABLE 4.6.1.2-13 

Direct and Indirect Effects from Construction of the Pacific Connector Pipeline to Interior Forests Outside of LSRs and 

LSMAs, Outside of NSO Critical Habitat and Outside of Marbled Murrelet Critical Habitat

Landowner Effect Type Effect Component 

Area (acres) of Interior 

Forest Affected a/

Construction Right-of-way 85.96 

TEWA 25.68 

UCSA b/ 13.26 

Rock Source/Disposal 0 

Hydrostatic Test Discharge 0.23 

Above Ground Facility 0.06 

Total Direct Effects 125.19 

Direct 

Total Long-term Direct Effects c/ 111.92 

BLM 

Coos Bay District 

Indirect Extending 300 feet from new edge d/ 571.32 

Construction Right-of-way 80.10 

TEWA 34.08 

BLM 

Roseburg District 

Direct 

UCSA b/ 85.63 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-52

TABLE 4.6.1.2-13 

Direct and Indirect Effects from Construction of the Pacific Connector Pipeline to Interior Forests Outside of LSRs and 

LSMAs, Outside of NSO Critical Habitat and Outside of Marbled Murrelet Critical Habitat

Landowner Effect Type Effect Component 

Area (acres) of Interior 

Forest Affected a/

Rock Source/Disposal 0.00 

Hydrostatic Test Discharge 0.23 

Above Ground Facility 0.00 

Total Direct Effects 200.04 

Total Long-term Direct Effects c/ 114.41 

Indirect Extending 300 feet from new edge d/ 465.68 

Construction Right-of-way 95.98 

TEWA 32.19 BLM 

Medford District Direct 

UCSA b/ 28.34 

Rock Source/Disposal 0.00 

Hydrostatic Test Discharge 0.15 

Above Ground Facility 0.00 

Total Direct Effects 156.66 

Direct 

Total Long-term Direct Effects c/ 128.32 

BLM 

Medford District 

Indirect Extending 300 feet from new edge d/ 593.09 

Construction Right-of-way 10.59 

TEWA 1.72 

UCSA b/ 0.00 

Rock Source/Disposal 0.00 

Hydrostatic Test Discharge 0.00 

Above Ground Facility 0.00 

Total Direct Effects 12.31 

Direct 

Total Long-term Direct Effects c/ 12.31 

BLM 

Lakeview District 

Indirect Extending 300 feet from new edge d/ 68.53 

Construction Right-of-way 65.17 

TEWA 13.80 

UCSA b/ 23.34 

Rock Source/Disposal 0.00 

Hydrostatic Test Discharge 0.17 

Above Ground Facility 0.00 

Total Direct Effects 102.48 

Direct 

Total Long-term Direct Effects c/ 79.14 

Umpqua National Forest 

Indirect Extending 300 feet from new edge d/ 3 

Construction Right-of-way 0.00 

TEWA 0.00 

UCSA b/ 0.00 

Rock Source/Disposal 0.00 

Hydrostatic Test Discharge 0.00 

Above Ground Facility 0.00 

Total Direct Effects 0.00 

Direct 

Total Long-term Direct Effects c/ 0.00 

Rogue River-Siskiyou 

National Forest 

Indirect Extending 300 feet from new edge d/ 0.00 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-53

TABLE 4.6.1.2-13 

Direct and Indirect Effects from Construction of the Pacific Connector Pipeline to Interior Forests Outside of LSRs and 

LSMAs, Outside of NSO Critical Habitat and Outside of Marbled Murrelet Critical Habitat

Landowner Effect Type Effect Component 

Area (acres) of Interior 

Forest Affected a/

Construction Right-of-way 47.44 

TEWA 5.81 

UCSA b/ 10.26 

Rock Source/Disposal 0.00 

Hydrostatic Test Discharge 0.06 

Above Ground Facility 0.00 

Total Direct Effects 63.57 

Direct 

Total Long-term Direct Effects c/ 53.31 

Winema National Forest 

Indirect Extending 300 feet from new edge d/ 294.25 

Construction Right-of-way 1.86 

TEWA 1.45 

UCSA b/ 0.00 

Rock Source/Disposal 0.00 

Hydrostatic Test Discharge 0.00 

Above Ground Facility 0.00 

Total Direct Effects 3.31 

State of Oregon Direct 

Total Long-term Direct Effects c/ 3.31 

Indirect Extending 300 feet from new edge d/ 15.85 

Construction Right-of-way 531.62 

TEWA 139.13 

UCSA b/ 283.22 

Rock Source/Disposal 0.55 

Hydrostatic Test Discharge 0.97 

Above Ground Facility 0.68 

Total Direct Effects 956.17 

Direct 

Total Long-term Direct Effects c/ 672.95 

Private 

Indirect Extending 300 feet from new edge d/ 3,360.01 

Construction Right-of-way 918.72 

TEWA 253.86 

UCSA b/ 444.05 

Rock Source/Disposal 0.55 

Hydrostatic Test Discharge 1.81 

Above Ground Facility 0.74 

Total Direct Effects 1,619.73 

Direct 

Total Long-term Direct Effects c/ 1,175.67 

Non-LSR, Non-CHU 

TOTAL 

Indirect Extending 300 feet from new edge d/ 5,729.36 

a/ Interior forest is defined as forested vegetation ≥ 300 feet from any existing edge of a contiguous forested stand that includes 

multiple stand ages ranging from regenerating (≈ 10 – 20 years old) through late successional – old growth forest. 

b/ Effects to interior forest vegetation by use of UCSAs are assumed to be short-term impacts 

c/ Total Long-term Direct Effects do not include effects within UCSAs. 

d/ Distance of 300 feet extends from edges of Construction Rights-of-way and TEWAs, not from edges of UCSAs.
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-54

Direct long-term effects from removal of interior forest by the Pacific Connector pipeline would 

include 1,175.67 acres over the long term and 444.05 acres over the short term (effects within 

UCSAs). Indirect effects of construction (extending 300 feet from new edges) would include 

5,729.36 acres of interior forest (table 4.6.1.2-13). Harper et al (2005) reported that the mean 

distance of edge influence on any single response variable did not exceed 300 feet (100 meters). 

In their review of effects by forest edges, response variables included: 1) forest processes of tree 

mortality/damage, recruitment, growth rate, canopy foliage, understory foliage, and seedling 

mortality; 2) forest structure by canopy trees, canopy cover, snags and logs, understory tree 

density, herbaceous cover, and shrub cover; and 3) stand composition by species, exotics, 

individual species, and species diversity. 

NSO’s seldom venture far into non-forested stands to hunt although it is likely they would cross 

the corridor at night to forage on both sides of the right-of-way. Disturbance might attract other 

predators such as other owls, hawks and mammals. This may increase competition for NSOs in 

the treatment area, but the exposure of prey from vegetation removal may also improve prey 

availability for NSOs. Some disturbance of habitat may improve forage conditions of remaining 

stands on both sides of the corridor by bringing more light and resources into the stand, 

stimulating forbs, shrubs and other prey food. Once the initial impact of disturbance recovers (6 

months to 2 years), the understory habitat conditions for prey food would increase over the next 

few years, until shrubs and residual trees respond to again close in the stand. 

NSOs remain on their home range throughout the year. As a result, NSOs have large home 

ranges that provide all the habitat components and prey necessary for the survival and successful 

reproduction of a territorial pair. Home ranges contain three distinct use areas: 1) the nest patch, 

which research has shown to be an important attribute for site selection by NSOs and includes 

approximately 30 acres usually of contiguous forest (200-meter radius around a nest center; FWS 

2007n); 2) the core area, which is used most intensively by a nesting pair and varies considerably 

in size across the geographic range, but on average includes approximately 500 acres (one-half 

mile radius around a nest center) and generally a greater proportion of mature/old forest (FWS 

2007m; Courtney et al. 2004); and 3) the remainder of the home range, which is used for 

foraging and roosting and is essential to the year-round survival of the resident pair (FWS 

2007m). 

Approximately 74 percent of suitable nesting, roosting, and foraging habitat removed by the 

proposed project occurs within known or predicted NSO home ranges. There are 96 known or 

predicted NSO home ranges that overlap the proposed pipeline, including overlap with identified 

existing roads to be used to access the right-of-way. As a result, not all known or predicted owl 

sites within the provincial analysis area would have habitat affected – either removed or 

modified. The effects of habitat changes to these home ranges as a result of the proposed action 

were evaluated at three scales: 1) nest patch, 2) core area, and 3) home range. The pre-action 

and post-action habitat conditions are provided in table H-4 in Appendix H. FWS et al. (2007) 

consider core areas with 50 percent or greater suitable NRF habitat and home ranges with at least 

40 percent suitable NRF habitat to be necessary to maintain NSO life history function. Preaction, 6 of 20 predicted and 20 of 60 known NSO sites are already below the 50 percent 

threshold for NRF habitat in the core area, and 4 predicted and 20 known sites are below the 40 

percent home range NRF threshold. Post-action, no NSO sites would drop from above the 50 

percent core area threshold to below it; however, one predicted and six known NSO sites already 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-55

below the threshold would drop further, but by less than one percent in all cases. Likewise, no 

sites would drop below the 40 percent home range threshold post-action, but 4 predicted and 16 

known NSO sites already below threshold would drop further, but by less than one percent in all 

cases (see table H-4 in Appendix H for more detail). Therefore, the proposed action does not 

bring any known or predicted owl site below the recommended suitable habitat threshold if it 

was previously above it and should not result in any take due to dropping below NRF habitat 

requirements. Note that calculations of habitat conditions for each owl site considered suitable 

habitat located on both federal and non-federal lands. 

Excluding identified existing roads to be used for accessing the right-of-way, the proposed 

pipeline would cross two nest patches. Table H-5 in Appendix H provides rationale for location 

of the proposed Pacific Connector pipeline within each known or predicted owl nest patch. 

Critical Habitat/Late-Successional Reserve. Activities that disturb or remove the primary 

constituent elements within designated CHUs might adversely modify the owl’s critical habitat. 

These activities may include actions that would reduce the canopy closure of a timber stand, 

reduce the average dbh of trees in the stand, appreciably modify the multi-layered stand 

structure, reduce the availability of nesting structures and sites, reduce the suitability of the 

landscape to provide for safe movement, or reduce the abundance or availability of prey species 

(FWS 1992b). 

In contrast, activities that would have no effect on the critical habitat’s PCEs almost certainly 

would not adversely modify the critical habitat. However, even though an action may not 

adversely modify critical habitat, it may still affect NSOs (e.g., through disturbance) and, 

therefore, be subject to consultation under the jeopardy standard of Section 7 of the ESA (FWS 

1992b). 

Almost 19 miles of the proposed pipeline route crosses two of three designated NSO CHUs 

within the provincial analysis area: OR-14 and OR-17 (FWS 2008h). Habitat would not be 

removed from CHU OR-8. In CHU OR-14, which contains 12 NSO sites within the provincial 

analysis area, the Pacific Connector pipeline would remove 46.8 acres and modify 18.3 acres of 

suitable habitat; 12.5 acres would be permanently impacted. In OR-17, which has 17 NSO sites 

in the provincial analysis area, 70.5 acres would be removed and 35.9 acres modified; 21.8 acres 

would be permanently impacted. Based on total areas of each CHU, these affected acres amount 

to 0.04 percent of the suitable habitat removed and 0.02 percent modified in CHU OR-14, and 

0.15 percent removed and 0.04 percent modified in OR-17. In total, approximately 117 acres 

would be removed from CHUs, 34.3 acres permanently. The other 54 acres would be allowed to 

eventually return to their original state. All CHUs that would have habitat impacted occur 

completely within LSRs (LSR units provided in table 4.6.1.2-14) and also completely within 

NSO home ranges. 

Similarly, the Pacific Connector pipeline would remove 5.5 acres and modify 9.1 acres of 

suitable habitat in LSR RO 261; remove 76.9 acres and modify 33.6 acres of suitable habitat in 

LSR RO 223; and remove 70.5 acres and modify 35.9 acres of suitable habitat in RO 227. LSR 

RO 261 covers 70,611 acres and provides 35,583 acres of suitable NRF habitat. The 

proportional amount of all suitable habitat available that would be removed within RO 261 is 

0.02 percent while 0.03 percent would be modified. LSR RO 223 is 66,173 acres, of which 

30,655 acres are suitable habitat. Effects to suitable habitat within LSR RO 223 would amount 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-56

to 0.25 percent removed and 0.11 percent modified. Likewise, RO 227 extends for 101,600 

acres of which 46,700 acres are suitable NRF habitat. Thus, the proposed action would remove 

0.15 percent of all suitable habitat and would modify 0.08 percent. 

There is considerable overlap of interior forest habitat that is within NSO CHUs and LSRs, as 

well as within MAMU critical habitat. If project effects are examined in CHUs and LSRs 

separately, areas of affected interior forest would be double-counted. Consequently, the 

following table 4.6.1.2-14 was developed to clearly indicate areas of interior forest within CHUs 

and LSRs that would be directly affected by construction and areas indirectly affected 300 feet 

interior from newly created forest edges. Direct long-term effects from removal of interior forest 

by the Pacific Connector pipeline would include 309.27 acres, whereas indirect effects 

(extending 300 feet from new edge) would include 1,266.37 acres within NSO CHUs affected: 

OR-14 and OR-17 (table 4.6.1.2-14). Effects to individual CHUs are also provided in table 

4.6.1.2-14. 

TABLE 4.6.1.2-14 

Direct and Indirect Effects from Construction of the Pacific Connector Pipeline to Interior Forests ≥80 Years Old within 

NSO Critical Habitat that Overlaps with Marbled Murrelet Critical Habitat and LSRs

Critical Habitat Unit Effect Type Effect Component 

Area (acres) of Interior 

Forest Affected 1 

Construction Right-of-way 0.17 

TEWA 0.04 

UCSA 2 0 

Total Direct Effects 0.21 

Direct Effects 

Total Long-term Direct Effects 3 0.21 

NSO CHU 14 

only

Indirect Effects Extending 300 feet from new edge 4 0 

Construction Right-of-way 56.90 

TEWA 13.10 

UCSA 2 19.51 

Total Direct Effects 89.51 

Direct Effects 

Total Long-term Direct Effects 3 70.00 

NSO CHU 14 

overlap with

LSR RO 223 

Indirect Effects Extending 300 feet from new edge 4 392.58 

Construction Right-of-way 57.07 

TEWA 13.14 

UCSA 2 19.51 

Total Direct Effects 89.72 

Direct Effects 

Total Long-term Direct Effects 3 70.21 

NSO CHU 14

TOTAL 

Indirect Effects Extending 300 feet from new edge 4 392.58 

Construction Right-of-way 0.18 

TEWA 0.05 

UCSA 2 0 

Total Direct Effects 0.23 

Direct Effects 

Total Long-term Direct Effects 3 0.23 

NSO CHU 17 

only

Indirect Effects Extending 300 feet from new edge 4 0.01 

Construction Right-of-way 136.14 

TEWA 15.38 

UCSA 2 67.89 

Total Direct Effects 219.41 

Direct Effects 

Total Long-term Direct Effects 3 151.52 

NSO CHU 17 

overlap with

LSR RO 227 

Indirect Effects Extending 300 feet from new edge 4 873.78 

Construction Right-of-way 136.32 

TEWA 15.43 

UCSA 2 67.89 

Total Direct Effects 219.64 

Direct Effects 

Total Long-term Direct Effects 3 151.75 

NSO CHU 17

TOTAL 

Indirect Effects Extending 300 feet from new edge 4 873.79 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-57

TABLE 4.6.1.2-14 

Direct and Indirect Effects from Construction of the Pacific Connector Pipeline to Interior Forests ≥80 Years Old within 

NSO Critical Habitat that Overlaps with Marbled Murrelet Critical Habitat and LSRs

Critical Habitat Unit Effect Type Effect Component 

Area (acres) of Interior 

Forest Affected 1 

Construction Right-of-way 193.39 

TEWA 28.57 

UCSA 2 87.40 

Total Direct Effects 309.36 

Direct Effects 

Total Long-term Direct Effects 3 221.96 

NSO Critical Habitat 

Units 

TOTAL 

Indirect Effects Extending 300 feet from new edge 4 1,266.37 

a/ Interior forest is defined as ≥80-year old forested vegetation ≥300 feet from any existing edge of a contiguous forested stand, 

including edges created by adjacent regenerating stands ≈ 10 to 20 years old. 

b/ Effects to interior forest vegetation by use of UCSAs are assumed to be short-term impacts. 

c/ Total Long-term Direct Effects do not include effects within UCSAs. 

d/ Distance of 300 feet extends from edges of construction rights-of-way and TEWAs, not from edges of UCSAs.

Conservation Measures 

Conservation measures have been proposed by Pacific Connector to minimize construction and 

operation impact to the provincial analysis area. Those measures have been compiled in table 2C 

in Appendix N7 of the BA, and apply to NSOs. Specific conservation measures that would 

benefit NSOs include those that: 

• minimize removal of forest by incorporating UCSAs into the project design; 

• minimize soil erosion during and after construction; and 

• minimize potential for establishment of invasive vegetation and control of noxious 

weeds. 

Pacific Connector has also proposed measures to rectify, repair, rehabilitate, and otherwise 

reduce impact to forested habitats once construction of the pipeline is complete. Those measures 

have been compiled in table 3C in Appendix N of the BA. Specific conservation measures that 

would benefit NSOs include those that: 

• contribute to re-establishment of native vegetation, including coniferous species, that will 

eventually become mature trees; 

• contribute to forest habitat diversity (snags and downed timber); and 

• minimize potential for increased human use of the reclaimed construction right-of-way 

and intrusion into undisturbed habitats. 

Construction would begin with vegetation clearing and then Pacific Connector would construct 

the pipeline the following year to minimize overall TEWA requirements within forested habitats. 

For example, TEWAs used during clearing to stage right-of-way logging activities and provide 

log storage and decking would then be used the following year for pipeline construction 

activities. Additionally to minimize disturbance within forested areas of the Pacific Connector 

pipeline area, Pacific Connector has designated nearly 780 acres of UCSAs that would not be 

cleared of trees but be used to store forest slash, stumps, and dead and downed log materials 

 

7

 Tables are included in Appendix N of the Draft Biological Assessment, which Pacific Connector filed with the FERC in March 

2008. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-58

during construction that would be scattered across the right-of-way after construction and during 

restoration. The UCSAs would be useful for the construction of the Pacific Connector pipeline 

while not having to remove trees or understory vegetation as that which is required for TEWAs. 

Following construction, affected forested lands (the construction right-of-way and temporary 

extra work areas outside of the 30-foot maintenance right-of-way) would be replanted and 

allowed to return to pre-construction condition with tree species in the approximate proportion to 

those species removed. Tree establishment would be allowed to occur up to 15 feet of either side 

of the pipeline centerline. Over the long-term (80 years or more to become NSO suitable 

habitat), revegetated areas outside of the 30-foot maintenance corridor may achieve tree 

structural characteristics comparable to trees that would be removed, had they not been affected. 

Because effects by the proposed action cannot be fully mitigated on site, Pacific Connector has 

proposed a Mitigation Plan that would fund off-site measures (Appendix L3). Pacific Connector 

would provide mitigation funds to BLM and USFS to permanently reclaim other existing 

disturbances of capable habitat, such as roads within LSR/LSMAs that are no longer required for 

resource management to mitigate project-related impacts. These mitigation funds could also be 

used to: 1) conduct noncommercial thinning treatments or other silvicultural projects to create or 

accelerate development of old growth characteristic elsewhere on federal land; 2) acquire title or 

easement to private lands adjacent/near the pipeline that could be managed/preserved as late 

successional habitat; and/or 3) acquire title or easement to private lands to block up ownership 

with BLM or NFS lands to increase connectivity, or to fund the conversion of Matrix lands to 

LSR. Alternatively, Pacific Connector may acquire easements or properties as conservation 

parcels in the project area that would preserve/protect suitable habitat to mitigate for project 

impacts. These easements or parcels may be deeded to a federal agency or a conservation 

organization or trust. 

Based on removal and potential degradation of principal constituent elements defined in the 

Final Rule designating critical habitat for the NSO (FWS 1992a), the proposed action is likely to 

adversely affect NSO critical habitat, based on the removal and downgrading of NRF primary 

constituent elements and CHUs OR-14 and OR-17. Therefore, we believe that additional 

measures to reduce the clearing of suitable habitat should be considered by Pacific Connector. 

These measures may include minor route variations or reductions in the right-of-way width for 

short distances through irreplaceable or exemplary tree stands that provide NRF for NSOs. 

Pacific Connector prepared an avoidance and minimization plan, developed through 

consultations with FWS, that identifies additional measures to reduce the proposed impacts to 

NSO habitat. Changes to the project design include minor alignment and TEWA adjustments 

and scheduling strategy alterations. The plan includes 14 alignment adjustments or TEWA 

modifications that reduce effects on NSO habitat. Each is drawn out in detail in the plan. The 

construction schedule was also revised to provide additional protection and minimize effects to 

NSO. This revised schedule eliminates “habitat” removal in NSO nest patches until after the 

entire nesting season (March 1 to September 30). 

Given the potential for adverse consequences by construction and operation of the Pacific 

Connector pipeline, as currently proposed, to NSOs, the proposed Pacific Connector pipeline 

overall is likely to adversely affect NSOs. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-59

4.6.1.3 Fish 

In this section, we summarize the presence, impacts, and conservation measures associated with 

federally listed fish species that could be affected by the projects. The details of existing 

conditions and potential impacts of Project actions and conservation measures to each of the 

ESA-listed fish species are provided in the BA for this Project. The species addressed include 

the North American Green Sturgeon – Southern Distinct Population Segment, Coho SalmonSouthern Oregon/Northern California Coast ESU, Coho Salmon-Oregon Coast ESU, Lost River 

Sucker, and Shortnose Sucker. Impacts to waterbodies by the proposed projects are described in 

section 4.3.2. Impact minimization measures described in that section are directly relevant to 

measures to reduce impacts to threatened and endangered fish species. More detailed 

information on federally listed fish species can be found in the BA. 

Pacific Connector has identified procedures for the preparation and planting of live stakes or 

sprigs and for planting bare root tree seedlings. Forested riparian zones would be planted with 

conifers to within 15 feet of each side of the pipeline centerline. The root network of trees 

adjacent to streambanks is essential to maintaining streambank stability (WDNR 1997). Because 

root strength decreases significantly at distances beyond one-half the tree crown diameter, trees 

promoting streambank stability lie within half a tree crown diameter from the streambank. Trees 

within 25 feet of the streambank are assumed to promote streambank stability (WDNR 1997). 

Generally, trees that must be removed during construction would be cut at ground level with the 

roots left in place, except where located within the trenchline, or where cutting down of the 

banks would be required for the crossing. Although roots would decay overtime, streambank 

stability would be retained by their presence until revegetation is successful. FWS has expressed 

concern about potential negative impacts at stream crossings and has requested site-specific 

plans and pre-construction field data to be gathered. See discussion in section 4.3.2.5. 

For all waterbodies supporting fisheries, the trench within the waterbody would be backfilled 

with material removed from the trench with the upper 1 foot of the trench backfilled with clean 

gravel or native cobbles. Pacific Connector has a modification to Section V.C.1. of FERC 

Staff’s Procedures in fish-bearing streams that do not have gravel, cobble, or other rock 

substrates prior to construction. This modification was proposed because many of the streams 

crossed by the pipeline are remote and are located in steep valley or ravine bottoms, making 

hauling rock to these streams impractical especially where they do not have gravel or cobble 

substrate characteristics prior to construction. The bottom and banks would be returned to 

preconstruction contours; banks would be stabilized; and temporary sediment barriers would be 

installed before returning flow to the waterbody channel. After reviewing the request, we have 

determined that there may be situations in which gravel or cobble backfill may not be necessary. 

However, given the potential presence of sensitive species, we would like to consider the request 

on a stream-specific basis. Therefore, we recommend that:

• Prior to crossing any streams where gravel or cobble would not be used to backfill. 

Pacific Connector should file information on the stream sediment type at the 

crossing location, a characterization of sediments immediately downstream from the 

crossing location, and specify the fill that would be used. The site-specific requests 

to not use gravel or cobbles for backfill at applicable stream crossings should be 

filed with the Secretary, for review and approval by the Director of OEP. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-60

Baseline watershed conditions crossed by the project are lacking in LWD due to historical 

disturbance and LWD presence is typically below benchmark thresholds to be properly 

functioning as fish habitat. LWD is an important habitat feature providing instream structure, 

channel and habitat complexity among other benefits and that which promote salmonid 

productivity. Therefore, Pacific Connector considers installing LWD on site during construction 

as an appropriate habitat enhancement feature to rectify potential project impacts and that would 

benefit watershed conditions that are generally lacking. 

LWD placement would be in addition to the project conservation measures that have been 

designed to minimize the potential project effects, such as utilizing dry open cut crossing 

methods, applying instream construction timing restrictions, and implementing erosion control 

measures and revegetation methods. Because of the overall lack of LWD in the affected 

watersheds, LWD also provides an appropriate mitigation model for the pipeline’s potential 

waterbody crossing impacts that are temporary, short-term, and unavoidable. The LWD would 

also serve to mitigate for potential long-term project impacts, such as the loss of forested riparian 

vegetation within the pipeline’s 30-foot maintained operational right-of-way. Regrowth outside 

of the 30-foot right-of-way would allow nearly full potential replacement of wood supply to 

streams in the long term (see section 4.5.2.3). 

To offset impact from removal of riparian trees (reducing LWD recruitment potential) and to 

provide an overall benefit by enhancing stream habitat with no potential for LWD recruitment, 

Pacific Connector proposes to place LWD based on the following applications: 

• four pieces for each perennial stream crossed with riparian forest removed (two pieces 

instream and/or keyed into the streambank, two pieces within riparian zone on the bank); 

• two pieces for each intermittent stream and unknown stream crossed with riparian forest 

removed (one or both LWD pieces placed instream, keyed into the bank, or placed on the 

bank); 

• two pieces for each perennial, intermittent, and unknown stream crossed but with no 

riparian forest removed (one or both LWD pieces paced instream keyed into the bank, or 

placed on the bank); and 

• one piece each for a perennial, intermittent, and unknown stream not crossed but adjacent 

to the construction right-of-way, with or without riparian forest removed (LWD placed 

on bank).

LWD would also be placed within riparian zones to provide for and/or enhance microsites for 

riparian vegetation and/or vegetation protection during flood events. After construction is 

completed, unutilized LWD would be provided to local watershed conservation organizations or 

agencies for use in local enhancement projects within the affected watersheds. Details of the 

LWD placement and related conditions would be determined through further agency discussion 

and development of Stream Habitat Mitigation Plan as recommended in section 4.5.2. 

North American Green Sturgeon – Southern Distinct Population Segment (Federal 

Threatened) 

On January 23, 2003 (NMFS 2003) NMFS determined that the North American green sturgeon 

comprises two DPSs that qualify as species under the ESA: 1) a northern DPS consisting of 

populations in coastal watersheds northward of and including the Eel River in California; and 2) 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-61

a southern DPS consisting of coastal and Central Valley populations south of the Eel River, with 

the only known spawning population in the Sacramento River. On April 7, 2006, NMFS listed 

the southern DPS as federally threatened under the ESA within California, including spawning 

populations of green sturgeon south of the Eel River, principally the Sacramento River spawning 

population (NMFS 2005). Reasons for listing the southern DPS as threatened were 1) the 

majority of spawning adults were concentrated in one spawning river (Sacramento River), 2) 

threats since the first status review (see NMFS 2003) have not been adequately addressed, 3) 

new evidence of loss of spawning habitat in the upper Sacramento and Feather Rivers, and 4) 

data showing a negative trend in juvenile green sturgeon abundance (NMFS 2005). One factor 

that was not considered a primary factor causing the decline of the southern DPS, but likely 

poses a threat to the southern DPS, was past and present commercial and recreational fishing, 

primarily ocean and estuarine bycatch of green sturgeon in the Oregon and Washington white 

sturgeon and salmonid fisheries; however, recent fishing regulations have reduced the risk for 

southern DPS in Oregon and Washington (NMFS 2005). Actions that may negatively affect the 

southern green sturgeon DPS include water diversion for human use, point and non-point source 

discharge of persistent contaminants, contaminated waste disposal, water quality standards, and 

fishery management practices (NMFS 2005). 

Green sturgeons spawn every 3 to 5 years in deep pools in large, turbulent river mainstems, 

generally from March through July (Tracy 1990; Moyle et al. 1992). Little is known about 

sturgeon feeding, but some studies have found that adults and juveniles feed on benthic 

invertebrates including shrimp, mollusks, amphipods, and even small fish (Moyle et al. 1992; 

Radtke 1966). 

The North American green sturgeon (both northern DPS and southern DPS) occur within Coos 

Bay and its adjacent waterbodies (Israel and May 2006) and are considered abundant in the bay 

(Federal Register Vol. 73, No.174, 52084, September 8, 2008). This fish may also occur in the 

lower portions of the Coos River, since green sturgeon have been taken in almost all of the 

Oregon coastal estuaries from the Chetco River to Nehalem Bay (Environmental Protection 

Information Center – EPIC et al. 2001) and genetic studies indicate that both northern DPS and 

southern DPS occur in the Columbia River (Israel et al. 2004). Also, while white sturgeon 

tagging projects were occurring in Coos Bay and Coos River, green sturgeons were captured and 

tagged. ORNHIC (2006a) reported that adult and juvenile green sturgeons (no DPS specified) 

are considered common in Coos Bay and estuary although the species is more marine-oriented 

(except early juveniles and spawning adults) and spends limited amount of time in fresh water. 

Green sturgeon may also occur in bottom areas along the LNG carrier transit route, in waters 

mostly less than 360 feet deep, which would be primarily only during entry and exit of the 

vessels as they would travel in deeper water during transit between ports. 

Critical Habitat

Proposed critical habitat extends from U.S. marine waters to 110 meters depth (360 feet) from 

Monterey Bay California north to Cape Flattery, Washington, including the Strait of Juan de 

Fuca (Federal Register Vol. 73, No.174, 52084, September 8, 2008). Several rivers in California 

are included such as the Sacramento, lower Feather and lower Yoba Rivers. No rivers in Oregon 

were included in the listing. However many estuaries were part of the critical habitat proposal in 

Washington, Oregon and California. Estuaries in Oregon proposed for inclusion were the 

Columbia River estuary, Winchester Bay, Yaquina Bay, and Coos Bay. Large numbers of this 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-62

green sturgeon DPS are within Coos Bay. Subadults and adults may occupy Coos Bay for 

feeding, optimization of growth, and thermal refuge, and the Bay supplies oversummer habitat. 

Similarly, coastal marine waters 110 meters deep or less, between Coos Bay and San Francisco 

Bay provide food, passage, and water quality as PCEs. The San Francisco Bay supplies habitat 

for rearing and feeding and growth of juveniles prior to their entry to marine waters as well as 

habitat used for subadults and adults as noted for Coos Bay. Within Coos Bay, Federal Register 

(Vol. 73, No.174, 52084, September 8, 2008) noted that in-water construction or alterations, 

point and non-point source pollution, and LNG projects could affect PCEs within the Coos Bay 

estuary portion of proposed critical habitat. 

Impacts and Conservation Measures

The detailed assessment of impacts and conservation measures for green sturgeon is provided in 

the BA as developed by FERC for this Project. A hazardous substance spill or LNG leak could 

affect green sturgeon along the LNG carrier transit route. If an unignited LNG spill were to 

occur along the LNG carrier transit route in the areas where this species is located, the LNG 

would float on the water until it vaporizes and would not have an adverse effect on this species, 

unless individuals come in direct contact with the LNG. Should a fish directly contact the LNG 

when it is first released, before any warming occurs, it could have its flesh frozen because the 

temperature is very low (-260°C). The chance of this occurring would be extremely remote 

because it would require a fish to be at or above the water surface at the direct point of LNG spill 

as rapid warming would occur on contact with the ocean waters. Some cooling of the upper 

water layers closest to the LNG spill would be expected, but would not likely cause the overall 

water column to cool to the point of affecting the fish species in the water, given the ambient 

water temperatures in the transit route. If the vapor from an LNG spill were to come in contact 

with an ignition source, the resulting fire would burn back to the spill source and would affect 

species on the water or in the area that come in direct contact with the fire. Fish in the water 

would not be affected as the fire would be above the water in the area of the spill where the 

vaporized LNG is flammable. LNG density as a gas is less than air and would rise above the 

water as it turns to vapor. In either case of lower or higher water temperatures based on the spill 

scenario, mobile species, such as the green sturgeon, would move out of the area until the water 

temperatures return to normal. Additionally, other spills such as oil from LNG carriers would 

not harm green sturgeon. The quantity of oil and other petroleum products on board an LNG 

vessel is low relative to oil tankers, so any spill is likely to be small and the chance of any spill 

remote. As reported by Pacific States/British Columbia annual reports, the number of oil spills 

reported from fishing and other harbor marine vessels ranged from 9 to 65 per year, which is 

fairly infrequent for a large number of marine vessels. 

Green sturgeon have the potential to be adversely affected by the dredging associated with the 

slip as well as channel maintenance dredging during terminal operation. Although green 

sturgeon do not spawn in Coos Bay, eelgrass beds in the vicinity of the proposed LNG terminal 

provide foraging grounds and rearing habitat. Thus, this species would experience the loss of 

some rearing habitat due the removal of eelgrass and SAV, the direct loss of benthic food source 

from dredging, as well as increased turbidity from dredging for the slip. However, based on the 

critical habitat determination, juveniles (at least early stages) are not considered to be present in 

Coos Bay, so effects would not occur on this critical life stages of the green sturgeon when 

dredging would occur during the proposed in-water construction period (October 1 to February 

15; ODFW 2000a). However subadults and adults may be present in the bay from June through 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-63

October, so some overlap of rearing would occur during dredging. But, the amount of SAV and 

intertidal habitat in the slip and access channel areas is minor Therefore, impacts to green 

sturgeon resulting from dredging operations for the LNG facilities are expected to be negligible. 

However, to compensate for this loss from LNG facility construction, Jordan Cove would 

mitigate the loss of the SAV by replacement of a larger area within Coos Bay. 

During LNG terminal operation, discharge of maintenance dredge spoils to Site F may also 

affect rearing green sturgeon benthic food supply, and possible avoidance due to elevated 

turbidity, on a short-term basis. This is projected to occur in October, a period when only larger 

juveniles and adult sturgeon are likely to be present. As discussed in section 4.5.2.2, about 

350,000 cy of sediment would be deposited at Site F, 1.6 miles off the mouth of Coos Bay in 25 

to 150 feet of water, over an area of 2,700 acres of this EPA-approved disposal site every other 

year. Burial of non-mobile benthic organisms may reduce benthic food sources on a short-term 

basis (see section 4.5.2.2) during the dredge spoils discharge, which would likely occur in 

October. Mobile organisms, including sturgeon, would avoid the area during discharge from the 

elevate turbidity. This habitat and benthic resources are not considered rare or unique. Also, the 

area to be directly affected is very small relative to the available habitat of this kind off the coast, 

and loss of food resources and avoidance on the short-term basis would be insignificant to 

survival and production of green sturgeon. 

In addition to habitat loss, there is the potential for petroleum and other hazardous spills to occur 

from LNG carriers as well as barges transporting sand to San Francisco Bay. However, hazard 

management plans would be developed and carried onboard all ships to reduce this risk. 

Dredging methods would also be selected to minimize effects to fish species in Coos Bay. 

Trenching for the installation of the 2.5 miles of the Pacific Connector pipeline within Haynes 

Inlet would initially disrupt about 86 total estuarine acres, of which about 1.0 acres would be 

important eelgrass habitat in Coos Bay. With a period of recovery and regrowth of attached 

aquatic algae and eelgrass, there would be a short-term reduction in available food sources until 

the habitat is restored by natural regrowth or assisted plantings. The same construction window 

mitigation proposed for the LNG terminal and slip would also be applied to the in-water portion 

of the pipeline (i.e., the in-water work period would correspond to a period of mostly low 

abundance in Coos Bay, except possibly October). Potential for petroleum and other hazardous 

spills impacting green sturgeon remains, although hazard management plans greatly reduce this 

risk (see also discussion under coho salmon). Because green sturgeon do not spawn in the Coos 

River, adult spawning migrations or early juvenile rearing would not be affected by any actions 

within Coos Bay. But the proposed pipeline construction within Coos Bay would occur during 

the recommended ODFW in-water construction period (October 1 to February 15; ODFW 

2000a), when subadult and adult and green sturgeon may be present (typically June through 

October). So some effects could occur from turbidity during October (see Oregon Coast Coho 

salmon ESU section), but would not affect North American southern DPS green sturgeon during 

most of the period when it may be present. After pipeline construction, eel-grass areas affected 

by construction would be replanted to increase recovery of this important habitat for rearing fish. 

The proposed actions are not likely to adversely affect green sturgeon primarily because most 

effects would be short-term food supply, the magnitude of effects would be small or sturgeon 

would not be present during most of the periods of trenching and the size of area affected is 

relatively small. Critical habitat is also not likely to be adversely affected for similar reasons 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-64

noted for the species. Additionally, sediment quality is not likely to be substantially changed and 

potential effects of vessel transport (LNG carriers and sand barges) would be very unlikely. 

Coho Salmon-Southern Oregon/Northern California Coast ESU (Federal Threatened) 

The Southern Oregon/Northern California Coast (SONCC) ESU coho salmon was listed as a 

threatened species on May 6, 1997 between Punta Gorda, California and Cape Blanco, Oregon. 

It includes all naturally spawning populations as well as three artificial propagation programs, of 

which one, the Cole Rivers Hatchery (ODFW stock #52) located on the Rogue River, is within 

the Project area. At the time of listing, less than 10,000 naturally reproducing SONCC coho 

salmon were estimated (NMFS 1997). Historically, this ESU consisted of 59 populations found 

in six major areas including: the Rogue, Klamath, and Eel River basins and within the coastal 

basins and subbasins among three regions (northern, central and southern regions) (Williams et 

al. 2006). The detailed assessment of impacts and conservation measures for SONCC coho 

salmon is provided in the BA developed by the FERC for this Project. 

Five life phases are generally recognized for the coho salmon: juvenile rearing, juvenile 

migration, growth and development, adult migration, and spawning. Juvenile summer and 

winter rearing areas and spawning areas are often located in small headwater streams. Juvenile 

migration corridors, adult migration corridors, and spawning areas are found in tributaries as 

well as mainstream reaches and estuarine zones. Growth and development to adulthood happens 

primarily in near- and off-shore marine waters. Final maturation takes place in freshwater 

tributaries when the adults return to spawn (NMFS 1999). Typically coho salmon begin their 

spawning migration as 3-year olds in late summer and fall and spawn by mid-winter. Eggs 

incubate for 1.5 to 4 months and then hatch. Juveniles rear for about 15 months in freshwater 

before migrating in spring to the ocean. They generally spend two growing seasons within the 

ocean before migrating back to their natal stream to spawn (NMFS 1997). 

Major rivers, estuaries, and bays known to support coho salmon within the range of the SONCC 

ESU include the Rogue River, Smith River, Klamath River, Mad River, Humboldt Bay, Eel 

River, and Mattole River (NMFS 1999), of which the Rogue and Klamath Rivers are within the 

Project area. Many smaller coastal rivers and streams also provide important estuarine habitat 

for this coho salmon ESU, but it is often inaccessible due to seasonal fluctuations in hydrologic 

conditions (NMFS 1997). The Oregon portion of the Klamath River has anadromous fish 

passage blocked by impassable downstream dams. But the Oregon Fish and Game Commission, 

in July 2008, authorized the evaluation of re-introducing anadromous fish into the Oregon 

Klamath River basin. In the Rogue River upstream adult migration occurs between September 

and mid-November, and juvenile out migration occurs between mid-February and mid-July 

(Vogt 2003).

Coho salmon in the Pacific Northwest have declined for reasons similar to other salmonids that 

include (Chase 1998; NMFS 2000): 1) changes in stream morphology; 2) changes in stream 

substrate; 3) loss of LWD in stream channels; 4) loss of estuarine rearing habitat; 5) loss of 

wetlands; 6) loss and degradation of riparian areas; 7) degradation of water quality; 8) changes in 

stream flow; 9) impediments blocking fish passage; 10) elimination of habitat; and 11) direct loss 

(mortality) of fish. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-65

Critical Habitat

Critical habitat for the SONCC ESU has been designated (NMFS 1999) and includes the 

accessible reaches of all rivers (including water, substrate, and adjacent riparian zone of 

estuarine and riverine reaches) between the Mattole River in California and the Elk River in 

Oregon. Within the counties traversed by the proposed Pacific Connector pipeline, critical 

habitat has been designated in USGS hydrologic unit (HU) Middle Rogue (17100308 – Jackson 

County) up to the Emigrant Lake Dam/Emigrant Lake, HU Upper Rogue (17100307 – Jackson, 

Klamath, and Douglas Counties) up to the Agate Lake Dam/Agate Lake, Fish Lake Dam/Fish 

Lake, Willow Lake Dam/Willow Lake, and Lost Creek Dam/Lost Creek Reservoir, HU 

Applegate (17100309 – Jackson County) up to Applegate Dam, and HU Upper Klamath 

(18010206 – Jackson County) up to Irongate Dam (NMFS 1999). The Pacific Connector 

pipeline would cross designated critical habitat within waterbodies of the Upper Rogue HU 

(17100307) below the Lost Creek, Willow Creek, and Fish Lake Dams. 

Critical habitat for SONCC coho salmon is designated based on species requirements such as 

space for growth and behavior, nutritional and physiological requirements, cover and/or shelter, 

reproduction sites, and habitats that are protected from disturbance or are representative of 

historically known population sites (NMFS 1999). Additionally, NMFS uses other known 

essential physical and biological features, referred to as PCEs, that are crucial to species 

conservation and critical habitat. These features include, but are not limited to, spawning sites, 

food resources, water quality and quantity, and riparian vegetation (NMFS 1999a). 

Generally, riparian areas form the basis of healthy watersheds and impacts on them in turn affect 

these primary constituent elements (NMFS 1999). However, the primary constituent elements 

that create healthy salmonid habitat vary throughout the coho salmon’s range. A site-potential 

tree height is a suitable benchmark in some cases, but in order to better assess the features of a 

specific locale, site-specific analyses provide the best means to characterize the riparian zone 

(NMFS 1999). 

Impacts

Direct impact to coho salmon can occur by 1) destruction of juveniles or adults during 

construction, although instream construction would not coincide with intergravel development of 

eggs, and 2) interference with essential life processes of spawning, rearing, or migration. See 

section 4.5.2.3 details of effects of specific actions. 

Ocean-migrating juvenile and adult coho salmon could be in the ocean waters traveled by LNG 

carriers. The SONCC ESU of coho salmon originates in streams south of the Project area and it 

is anticipated that adults or juveniles would only rarely occur in Coos Bay in the vicinity of the 

proposed LNG terminal and slip. However, the Pacific Connector pipeline would cross streams 

within the range of SONCC coho salmon ESU. 

For the same reasons presented for green sturgeon, adverse effects to this coho salmon from a 

LNG spill or other spill in the ocean from the LNG carrier are unlikely. 

Similar also to green sturgeon, discharge of maintenance dredging spoils at site F is unlikely to 

adversely affect these coho salmon directly or indirectly. The discharge would be short term, of 

small magnitude and duration, and would not substantially affect those coho salmon directly that 

may be near the coast because they would avoid the area from the short-term elevation of 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-66

turbidity. Also, benthic organisms, which would be affected from burial of tailings in the short 

term, would have no marked effect on coho salmon food resources because the overall area of 

marine benthic area affected would be small and coho salmon feed primarily on pelagic 

organisms that would generally not be affected by the tailings discharge once they leave estuaries 

and enter the ocean. 

Long-term degradation of salmonid habitats can occur with removal of streamside vegetation 

and/or LWD in the stream at crossing sites (see section 4.5.2.3). Riparian vegetation and LWD 

provide shade necessary to lower water temperatures. However, much of the riparian area would 

be allowed to regrow from plantings with herbaceous plants (all but a 10-foot width would be 

low growth) and conifer trees (all but a 30-foot width over the pipeline). On small streams and, 

to a lesser extent, larger streams, even 10- to 15-foot high trees would supply shade, reducing 

solar heating effects on streams. So, slight effects of solar heating from clearing would gradually 

be reduced or completely eliminated over time. In the long term, most of the supply of LWD 

would also regrow as trees would be planted in all but a 30-foot-wide corridor at riparian stream 

crossings. The effects of water temperature on salmonid life stages have been extensively 

reviewed by McCullough (1999); maximum water temperatures ranging from 22oC to 24oC 

(71.6oF to 75.2oF) limit distribution of many salmonid species. Preferred temperatures for coho 

salmon were addressed in section 4.5.2.3. 

Within the range of coho salmon in the SONCC ESU, construction of the Pacific Connector 

pipeline would affect approximately 113 acres within riparian zones (using one site potential tree 

height as the riparian zone on all streams, perennial and intermittent), most of which would be 

affected by clearing the construction right-of-way. Of that total, the pipeline would remove 48 

acres of riparian forested habitats of which 7 acres would be removed in the Trail Creek 

watershed, 15 acres with the Rogue River-Shady Cove watershed, 12 acres in the Big Butte 

Creek watershed, and 15 acres would be removed in the Little Butte Creek watershed. The 

details of the acres potential affected by stream is presented in the BA for this project. 

Within the pipeline area, SONCC ESU coho salmon have the potential to be within the following 

waterbodies in Jackson County based on the digital distribution data obtained from ODFW in 

2001: Rogue River and tributaries, Little Butte Creek and tributaries, Indian Creek, Trail Creek 

and tributaries, and Elk Creek and tributaries (ORNHIC 2006a). In the Rogue River Basin, an 

increase in naturally spawning SONCC coho salmon and juvenile density has been documented 

(ODFW 2005). 

The Pacific Connector pipeline would cross 13 perennial streams within the range of SONCC 

ESU. If ODFW completes plans to reintroduce this species into the Klamath River basin some 

additional perennial stream crossings (number unknown but would include the main stem 

Klamath River and possibly Spencer Creek) may have this stock present in the future, but likely 

after the pipeline is construction. Eleven perennial streams that currently have this ESU present 

have existing riparian forest at the proposed pipeline crossings, which would result in removal of 

3 acres of riparian forest removed by construction. Two more perennial streams would also be 

crossed, but construction would not affect riparian forest vegetation. An additional perennial 

stream would not be crossed but 2 acres of its associated riparian forest would be removed 

during construction. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-67

In addition, the Pacific Connector pipeline would cross 45 intermittent streams, 34 of which 

support riparian forest of which 29 acres total would be removed. Eleven additional intermittent 

streams with no riparian forest would be crossed as well. Riparian forest (4 acres) associated 

with four intermittent streams would be removed although the streams would not be crossed. 

Three more streams with unknown flow regimes would be crossed, one of which supports 

riparian forest. An additional stream with an unknown flow regime would not be crossed, 

although its riparian forest would be affected. 

Other effects to salmonid habitat could include increased turbidity, frac-out from HDD, nutrient 

loading, decreased fish access, reduction of benthic organisms and LWD, and surface runoff. 

The details of these effects as they relate to salmonids is presented in section 4.5.2.3 and are 

comparable for this coho salmon. 

Construction and operations of above-ground facilities near streams could affect SONNC coho 

salmon. Table 4.5.2.3-2 summarizes facility effects for the entire pipeline project area. Surface 

runoff from pipeline-related facilities and roads could affect listed coho salmon through sediment 

increases or hazardous substances. However, adherence to the BMPs and ECRP will reduce or 

eliminate adverse effects from these related facilities. Road runoff is often a concern. Overall, 

over the length of the pipeline (MPs 8.28 to 225.46), 18 temporary roads totaling 6.06 acres 

would be constructed. Only 7 of these roads would be within 100 feet of wetlands or other 

waterbodies. Most would require little grading because they are in gently sloping areas and 

pastures. Additionally, 16 proposed permanent road, equaling 3.03 acres, would be constructed 

along this route (MP 7.7 to 230.9), most within the existing right-of-way. Five of these would be 

within 100 feet of wetlands or waterbodies. None of these crosses fish-bearing streams, so no 

potential fish passage issues would occur from culvert installation. Some of the facilities would 

slightly reduce future LWD supply to streams because of this proximity. The temporary roads 

would be fully restored after construction and permanent roads would be stabilized with gravel 

and appropriate BMPs. Preeminent aboveground facilities would include about 21 acres, mostly 

among five facilities (e.g. compressor and metering stations) extending from MP 0.00 to 230.90. 

Only one of these is within 500 feet of any stream. Numerous other temporary pipeline-related 

areas would be used, including pipeline storage areas, UCSAs, rock sources, hydrostatic testing 

sites, and TEWAs spread along the pipeline route. All of these would have sedimentation and 

erosion control plans and BMPs in place to reduce or eliminate runoff to streams. Overall, some 

increased sediment would enter some streams possibly from increased vehicle traffic during 

construction and heavy rain events, and increased runoff from hardened surfaces. Also, only 

some of these facilities are along the SONCC coho salmon streams in the pipeline project area. 

Additionally, adverse effects to coho salmon would not occur from these facilities because the 

magnitude would be slight in any specific location. 

Conservation Measures

Conservation measures have been proposed by Pacific Connector to minimize construction and 

operation impact to the estuary (estuarine analysis area), waterbodies, and riparian zones 

(riverine analysis area). Those measures have been compiled in table 2C in Appendix N of the 

applicant-prepared draft BA8 and apply to Southern Oregon/Northern California Coast coho 

salmon. 

 

8

 Tables are included in Appendix N of the Draft BA, which Pacific Connector filed with the FERC in March 2008. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-68

As described in sections 2.4.2.1 and 4.3.2.3, Pacific Connector would implement the measures 

outlined in its ECRP to prevent erosion of exposed soils along the right-of-way between clearing 

and final restoration. To prevent increases in turbidity, Pacific Connector would utilize the dry 

crossing methods (i.e., flume and dam-and-pump) for most of the streams crossed by the 

proposed project. These crossing methods, in addition to adherence to the ECRP, should ensure 

that turbidity at 100 feet downstream of the construction activities would not exceed 10 percent 

over the background turbidity as required by OAR 340-041-0036. 

Certain measures have been developed to further reduce impacts to coho salmon, including 

construction windows, control of hydrostatic water discharges, reduction of blasting impacts, and 

fish capture and salvage, as summarized below and in more detail in section 4.5.2.3. 

Timing 

Construction of the Pacific Connector pipeline from MP 110.75 to MP 166.21, the pipeline 

segments where SONNC coho may be present in the Upper Rogue HU (17100307), would occur 

within the recommended time for in-water construction from June 15 through September 15 for 

all open-cut crossings. Two crossings, an HDD at the Rogue River (MP 122.65), and an 

irrigation water canal (Medford Aqueduct Ditch 3 at MP 133.38) may occur outside of this 

period. The Rogue River (MP 122.65) would be crossed by HDD, which is planned for Year 

One beginning May 15 to October 15 and expected to be completed in approximately 45 to 60 

days, but could extend longer if technical difficulties are encountered during the drilling. ODFW 

has recommended timing for in-water construction of the Rogue River from June 15 to August 

31, though use of HDD is expected to not require in-water construction. Use of HDD to 

construct across the Rogue River would avoid in-stream effects or impact to upstream migration 

of coho salmon, unless a frac-out were to occur. The aqueduct crossing would be a conventional 

bore, again not affecting surface waters or fish. 

Blasting 

There are seven waterbodies (2 in the Trail Creek watershed, 2 in the Rogue River-Shady Cove 

watershed, 3 in the Big Butte Creek watershed) that are likely to be crossed using blasting 

because the streambed substrate is bedrock. Given that adult coho salmon and/or redds are 

unlikely to be affected by the shock wave farther than 25 feet downstream of a disturbance 

(distance based on Alaska Department of Fish and Game 1991), blasting during dry open-cut 

construction is not expected to adversely affect adult coho salmon or redds. However, effects on 

juvenile coho salmon could occur during blasting if they were within 25 feet of the 25-foot 

buffer around dry blast sites (i.e., within 50 feet of blasting occurring on dry land). See 

additional discussion in section 4.5.2.3. 

Fish Salvage 

All waterbodies that would be crossed by dry open-cut construction would be done prior to adult 

coho salmon upstream migration, within ODFW instream construction windows. Pacific 

Connector has developed a specific fish salvage plan. The methods are modeled on fish salvage 

methods developed by Washington State Department of Transportation for use in regions where 

ESA listed salmonids may be present (WSDOT 2008). The protocol specifies procedures for 1) 

isolating the work area; 2) removing fish and dewatering the work area; 3) handling, holding, 

and releasing fish; 4) documenting fish that have been captured, handled, held, and released; and 

5) notifying NMFS and FWS. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-69

Elements of the plan are expected to include initially seining and dip netting once upstream and 

downstream dams are in place and before positioning of flume pipe(s). Only if seining, dip 

netting, and other methods are unsuccessful at removing all fish would electrofishing be used. 

Electrofishing studies have documented fish injury even under good conditions so its use should 

be minimized. Only qualified individuals with extensive experience would use the electrofisher 

to also aid in reduction of potential fish injury. Electrofishing equipment would use low 

frequency (≥30 Hz) pulse-DC settings during one or two passes through the construction. 

Additional netting may occur as water is pumped to upland dissipation sites. Fish screens would 

be used on all water intakes and monitored for impinged fish. Fish salvage crews would check 

all remaining pools and undercut banks using dip nets to salvage any residual fish. Fish salvaged 

and any mortality would be monitored and reported to ODFW, NMFS, and FWS. 

Permits to capture fish would be required for each fish salvage effort since species subject to the 

ESA and NMFS regulations (50 CFR parts 222-226) would be potentially salvaged (SONCC 

coho salmon). The permits would be for non-lethal take of SONCC coho salmon. Captured fish 

would first be identified and counted by species then be transported to the lower dam and 

released downstream from the flume. Because the flume would maintain stream flow, fish may 

move upstream through the flume. NMFS has requested that fish be released upstream from the 

flume to avoid any downstream turbidity and sedimentation plumes that could occur with the 

removal of the flume. Turbid water remaining in or seeping into the dammed construction site is 

removed by pumping to upland sites, off the construction right-of-way, that are isolated by 

surrounding them with straw bales, filter fabric, and/or filter bags that trap sediment while water 

infiltrates at the site rather than flowing back to the waterbody. 

Hydrostatic Testing 

Generally, water quality of discharged water from hydrostatic testing is similar to the quality of 

water when filled. Water for hydrostatic testing would be obtained from commercial or 

municipal sources or from surface water right owners. If water for hydrostatic testing is acquired 

from surface water sources, Pacific Connector would obtain all necessary appropriations and 

withdrawal permits. Procedures have been developed by NMFS (1997e) to reduce entrainment 

and impingement of fish at pump intakes. Those procedures would be applied to any instream or 

surface water withdrawals needed for hydrostatic testing. The pipeline would be tested in 

approximately 74 sections; each with varying lengths and water volume requirements. During 

the test, it may be necessary to discharge water at each of the section breaks; however, Pacific 

Connector would conserve water as much as practical and minimize discharge where feasible by 

cascading water between test sections. 

In several instances, mitigation would contribute to restoring an indicator’s functional level, such 

as placement of LWD within and/or adjacent to streams and placing LWD on floodplains, where 

appropriate, to provide microsites for riparian vegetation and/or vegetation protection during 

flood events. Placement of LWD in streams and/or on streambanks has been one focal point of 

recent stream rehabilitation procedures (Slaney and Martin 1997; Cederholm et al. 1997; EPA 

2001) as well as a central consideration in the Conservation Plan. 

Revegetation 

Pacific Connector has identified procedures for planting live stakes or sprigs and for planting 

bare root tree seedlings. Forested riparian zones would be planted with conifers to within 15 feet 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-70

of each side of the pipeline centerline. Construction of the Pacific Connector pipeline would 

remove 48 acres of currently forested riparian vegetation within watersheds inhabited by 

SONCC coho salmon: 14 acres of Late Successional (Mature) Old Growth, 34 acres of MidSeral Forests, and an additional 6 acres of Forested/Non-forested Wetlands. Of these acres of 

forested riparian vegetation, 7 acres would be removed in the Trail Creek watershed, 15 acres 

from the Rogue River-Shady Cove watershed, 12 acres in the Big Butte Creek watershed, and 15 

acres from the Little Butte Creek watershed. After replanting conifers in each affected forested 

riparian zone, about 12 acres would be left permanently unforested during the life of the pipeline. 

Other Mitigation Measures 

In all, Pacific Connector proposes 150 pieces of LWD for placement within the four fifth-field 

watersheds that coincide with SONCC ESU coho salmon and are designated critical habitat. 

Placement of LWD is subject to approval by each affected landowner. If a landowner rejects the 

proposed placement of LWD, the number of pieces that would have been applied on site would 

be reserved and provided to appropriate watershed councils for their use and placement, 

preferably elsewhere within the affected fifth field watershed. 

There is a strong possibility that various life stages of coho salmon in the SONCC ESU would be 

present within streams crossed by the Pacific Connector pipeline. Adult upstream migration may 

be affected during dry open-cut construction. Adult coho salmon and juveniles subject to fish 

salvage within isolated construction sites could be injured or killed if electrofishing is used and 

stressed if seining is used. Incidental take of coho salmon is possible. The proposed action may 

1) have adverse effects to critical habitat by removing forested riparian vegetation, and 2) impair 

the suitability of seasonally or permanently occupied habitat by increasing local turbidity over 

the short-term and limiting recruitment of LWD over the long term. Based on these evaluations 

and with implementation of the proposed conservation measures, the proposed action is likely to 

adversely affect coho salmon in the SONCC ESU. 

Coho Salmon-Oregon Coast ESU (Federal Threatened) 

On February 11, 2008 the NMFS listed the Oregon Coast coho salmon ESU as threatened (73 FR 

7816). The Oregon Coast ESU includes all naturally spawned populations of coho in Oregon 

coastal streams south of the Columbia River and north of Cape Blanco, including the Cow Creek 

(ODFW stock # 37) coho salmon hatchery program (NMFS 1995). In the early 1900s, 

escapement of Oregon Coast coho was estimated to number at least one million, which supported 

a harvest of nearly 400,000 fish. Recent spawning escapement estimates indicated that less than 

30,000 adults return to this ESU, representing less than 5 percent of historical abundance 

(60FR38011). Critical habitat for Oregon Coast coho, designated February 2008 (73FR7816) 

includes these river basins and subbasins: Necanicum, Nehalem, Wilson/Trask/Nestucca, 

Siletz/Yaquina, Alsea, Siuslaw, Siltcoos, North Fork Umpqua, South Fork Umpqua, Umpqua, 

Coos, and Coquille. The detailed assessment of impacts and conservation measures for Oregon 

Coast coho salmon is provided in the BA developed by FERC for this Project. 

Life stage requirements of coho salmon within freshwater habitats in the Oregon Coast ESU are 

expected to be similar to those described above for coho salmon in the SONCC ESU. Within the 

entire ESU, adults generally enter coastal streams in the fall and spawn from November, possibly 

through March. Peak spawning is during December or January (NMFS 2004). After hatching in 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-71

spring, parr inhabit areas of slow flows and spend a second winter in freshwater before 

outmigration to the ocean as smolts, generally March through June (NMFS 2004). 

Specific timing of life history phases for Oregon Coast coho salmon within the instream portion 

of the Project area are partially available for individual rivers or tributaries near waterbodies 

crossed by the Pacific Connector pipeline. Smolt outmigration in Sixes River lasts from March 

through June with peak outmigration in early to mid May. Similarly, peak outmigration in the 

Coquille and Coos Rivers is from mid-March to mid-May, and April through May in the 

Umpqua River and tributaries (Gray 2003). 

Peak timing of river entry by adults to the Umpqua, Coos, and Coquille is October. The 

spawning run takes place between approximately mid-October and late January (Streamnet 

2008). Specifically, spawning in the Umpqua River lasts from late October through early 

January, peaking in early December. Spawning in the Coos River lasts from mid-November 

through late January, peaking in mid December. Timing in the Coquille River is similar, though 

spawning there persists through early February (Weitkamp et al. 1995). 

Critical Habitat

Critical habitat for Oregon Coast coho salmon was also designated on February 11, 2008 and 

includes water, substrate, and adjacent riparian zones of estuaries and rivers within the range of 

the Oregon Coast ESU. Similar to critical habitat designated for coho salmon in the SONCC 

ESU, critical habitat includes stream channels laterally to the ordinary high water mark (or 

bankfull elevation or bankfull width). NMFS defined critical habitat in estuarine and nearshore 

marine zones as areas contiguous with the shoreline from the extreme highwater mark out to a 

depth no greater that 30 meters (98 feet) below the mean low water mark (NMFS 2004). Within 

these areas, NMFS (2004) identified PCEs that are essential to supporting one or more life 

stages: 1) freshwater spawning sites (spawning, incubation and larval development), 2) 

freshwater rearing sites (with physical and biological properties to support juvenile 

development), 3) freshwater migration corridors (with physical and biological properties to 

support juvenile and adult movements), 4) estuarine areas (with physical and biological 

properties to support smoltification, juvenile and adult growth and survival), 5) nearshore marine 

areas (with physical and biological properties to support growth and survival), and 6) offshore 

marine areas (with physical and biological properties to support growth and survival). There are 

three CHUs that coincide with the proposed Project: Unit 9 – South Umpqua Subbasin (HU 

17100302) and Unit 12 – Coquille Subbasin (HU 17100305) crossed by the proposed Pacific 

Connector pipeline and Unit 11 – Coos Subbasin (HU 17100304 which includes the Coos Bay 

estuary) which includes the proposed LNG terminal and slip and the in-water portion of the 

Pacific Connector pipeline. 

Impacts and Conservation Measures

Similar to the SONCC coho salmon juvenile and adult ocean-going stages of this coho salmon 

ESU could be in the ocean waters traveled by LNG carriers. The Oregon Coast ESU uses 

eelgrass beds within Coos Bay for foraging. Critical habitat has been designated for the Oregon 

Coast ESU of coho salmon in Coos Bay. The Pacific Connector pipeline would cross designated 

critical habitat within waterbodies of the Upper Rogue HU (17100307) below the Lost Creek, 

Willow Creek, and Fish Lake Dams. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-72

For the same reasons presented for green sturgeon, adverse effects to this Oregon Coast coho 

salmon from an LNG spill or other spill in the ocean from the an LNG carrier are unlikely. 

Similar also to green sturgeon and SONCC coho salmon, discharge of maintenance dredging 

spoils at Site F is unlikely to adversely affect these coho salmon directly or indirectly. The 

discharge would be short term, of small magnitude and duration, and would not substantially 

affect those coho salmon directly that may be near the coast because they would avoid the area 

from the short-term elevation of turbidity. Also, benthic organisms, which would be affected 

from burial of tailings in the short term, would have no marked effect on coho salmon food 

resources because the overall area of marine benthic area affected would be small and coho 

salmon feed primarily on pelagic organisms that would generally not be affected by the tailings 

discharge once they leave estuaries and enter the ocean. 

There are 140 waterbodies within the range of Oregon Coast coho salmon ESU proximate to the 

Project. One of these is the Coos Bay estuary, 87 are perennial streams, 51 are intermittent 

streams, and 1 is a stock pond. The pipeline would actually cross 124 waterbodies, 119 of them 

by dry open-cutting. The South Umpqua River would be crossed twice by diverted open-cuts at 

MPs 69.02 and 94.73, Catching Slough would be crossed by a conventional bore at MP 11.11, 

and the Coos River would be crossed using HDD at MP 8.18. The Coos Bay estuary would be 

crossed by using a wet open-cut procedure. Sixteen of the waterbodies would not be crossed by 

the pipeline but are adjacent to the pipeline centerline. Blasting may be necessary to construct 

across 20 streams that would be crossed by dry open-cut methods since the streambed of each is 

bedrock. Coho salmon are known to occur in 40 of the waterbodies and are assumed to be 

present in 24 others based on connectivity to perennial streams known to support coho salmon, 

the presence of resident salmonids, and/or information provided by fisheries biologists. 

Project-related effects to coho salmon in the Oregon Coast ESU would be caused by the action 

and occur at the same time and place, including the following direct impacts within the estuarine 

analysis area: 1) turbidity effects from dredging the slip and access channel, 2) turbidity effects 

from constructing the Pacific Connector pipeline within the estuary, 3) acoustic impact from pile 

driving, and 4) effects by operational lighting. 

Dredging of the access channel and possibly a small portion of the berm that isolates the slip 

construction from the Bay would increase turbidity levels in the estuarine analysis area. 

Likewise, construction of the Pacific Connector pipeline across Coos Bay would generate 

turbidity. Turbidity plumes generated by dredging activities would be subjected to large tidal 

influences (both water velocity and direction of flow). The details of the potential sediment 

plume and effects to fish area presented in section 4.5.2.3. 

Generally, narrow and elongated plumes (approximately 3,000 feet wide) can be expected during 

an ebb tide headed southwest of the site, and wide rising plumes (approximately 4,000-6,000 

feet) can be expected during a flood tide, northeast of the site (Moffatt and Nichol 2006). 

Salmonids avoid elevated sediment, likely in the range of 20 to 70 mg/l (Lloyd et al. 1987; 

Newcombe and Jensen 1996) or possibly lower. So, juvenile coho salmon would likely avoid 

most areas of potentially harmful concentrations (possibly as low as 17 mg/l, Wheeler 2008). 

Also, normal fall concentrations in Coos Bay have naturally elevated suspended sediment so 

some increase in the fall when dredging occurs would not be out of the normal range of 

conditions at this time. These strong tidal influences combined with the discontinuous nature of 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-73

most dredging operations, reduces potential turbidity impacts by decreasing the exposure of 

individual aquatic organisms that may be present in the analysis area. Low levels of turbidity 

and short-term pulses of moderate turbidity levels may not harm aquatic biota, but prolonged 

exposure to moderate and high turbidity levels can cause a number of negative environmental 

conditions, including 1) reduction in light penetration affecting phytoplankton production, 

damage to eelgrass beds, and potential reactive distance of fishes to prey and predators; and 2) 

forcing coho salmon to relocate from preferred habitat. 

After a review of dredging studies done through 1998, Reine et al. (1998) concluded that “much 

of the available evidence suggests that entrainment is not a significant problem for many species 

of fish and shellfish in many bodies of water that require periodic dredging.” Based on a lack of 

evidence indicating that coho salmon are susceptible to entrainment during dredging, it is not 

anticipated that maintenance dredging would impact Oregon Coast coho salmon populations 

regardless of dredging method used. 

Turbidity plumes created by spud deployment are expected to be small and localized to the LNG 

terminal site. Propwash generated during clamshell dredging activities could cause short-term, 

temporary sediment disturbances at the project site, particularly when the dredge is operating in 

shallow water habitat. 

Maintenance dredging activities would be conducted with relatively shallow draft tugs and 

barges. Maintenance dredging that would occur near the LNG site biennially would have lower 

turbidity and less distribution than pipeline construction, likely with elevated levels extending 

0.2 to 0.3 miles (see section 4.5.2.3). Any propeller wash effects associated with situating the 

barge or removing the barge would be short-term, temporary sediment disturbances. However, 

turbidity increases are expected to quickly dissipate. Propwash can result in small turbidity 

increases within the slip as ships dock at the new marine facilities. The berths are designed to be 

sufficiently deep to minimize turbidity effects due to propeller wash. Overall effects to coho 

salmon in Coos Bay from turbidity and suspended sediment due to LNG site construction and 

propeller wash are likely to be low and typically short term, and primarily consist of avoidance 

of areas with higher sediment concentrations. 

Turbidity Effects – Pacific Connector Pipeline and Related Upland Facilities 

Turbidity would also be generated during pipeline construction across the Coos Bay estuary. A 

trench would be excavated (open cut), the pipeline installed, and the trench backfilled with the 

excavated trench spoils that were placed on the bottom adjacent to the trench. Turbidity 

generated by trench excavation, installation, and backfilling is expected to be less than that 

generated by “clamshell” dredge across the Coos Bay Channel during construction of the 

proposed LNG terminal (Moffatt and Nichol 2006). Maximum concentrations of suspended 

sediment modeled at the dredge location were 6,000 mg/l with no current, and under moderately 

low velocity (about 0.3 feet/sec) at the dredge site suspended sediment is estimated to be about 

800 mg/l, dropping to about 100 mg/l at 660 feet from the site. 

Generally, considering that clamshell dredging methods would be used and possible high current 

velocity, turbidity would be elevated (greater than 25 mg/l) in a narrow (likely 50 to 100 feet) 

and elongated plume up to 2.5 to 3.5 miles in length based on models developed for dredging at 

the LNG terminal site (Moffatt and Nichol 2006) (see section 4.5.2.2). Potential for scour along 

the pipeline route on the bottom of Coos Bay was evaluated by Coast and Harbor Engineering 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-74

(2007). Sediments have the smallest grain sizes (0.04 to 0.05 mm) in the upper bay region (Coos 

River, Cooston Channel) and grow larger (0.24 to 0.31 mm) closer to the proposed LNG 

Terminal (Coast and Harbor Engineering 2007). It is expected that the new pipeline location 

would likely have sediment similar to the smaller grain size, which would be more likely to stay 

in suspension than that found near the LNG terminal site. Turbidity levels in Coos Bay are 

generally higher during the fall and winter months due to high runoff events and stream erosion 

(Arneson 1976), which would coincide to some degree with adult upstream migration and 

spawning. Because normal fall-winter concentrations in Coos Bay have naturally elevated 

suspended sediment, some increase in the fall when dredging occurs would be in the normal 

range of conditions that coho salmon encounter in Coos Bay at this time. Spawning would not be 

affected by construction of the Pacific Connector pipeline in the estuarine analysis area because 

this area does not provide suitable spawning habitat for coho salmon. Similar to construction of 

the LNG terminal and roads noted above, effects of elevated turbidity are likely to be low and 

typically short term, and primarily consist of avoidance of areas with higher sediment 

concentrations during the one season of construction. 

Additionally, potential effects of sediment runoff into streams and vegetation effects noted for 

SONCC coho salmon for construction and operation of roads, TEWAs, pipeline storage areas, 

and other aboveground facilities would be similar and generally non-significant due to 

implementation of sedimentation erosion control plans and BMPs, and the small extent of areas 

near riparian areas where these fish may be present. 

Acoustic Effects 

Pile driving would be required to install pile-supported piers, berthing/breasting dolphins, and 

other pilings associated with the LNG terminal, and tug docks. Most of the pile driving would 

be conducted while the slip is isolated from the Bay by a berm left in place. At least a few 

mooring dolphins would be installed after connection of the slip with the Bay regardless of the 

construction scenario selected. 

NMFS’s current pile driving noise thresholds for fish are a peak sound pressure of 180 dB re: 1 

μPa, for physical harm and an impulse pressure, or root mean square (rms), of 150 dBrms re: 1 

μPa for behavioral disruption (WSDOT 2007). Based on this, the “harm” zones for fish would 

be those areas around each pile that experience 180 dB re: 1 μPa, while the harassment zones 

would be the areas within the 150 dBrms re: 1 μPa contour in the following analysis. 

Pile driving, while open to the Bay, would use a vibratory hammer, to the extent practicable, to 

reduce acoustic impacts to marine aquatic resources. If impact drivers are required, the smallest 

feasible or practical driver and the minimum force necessary would be used to complete the job. 

A diesel hammer or a hydraulic impact hammer would be used, when necessary, and the drop 

height would be set to the minimum necessary to drive the piling. Pile driving would also be 

conducted inside a bubble curtain. Further information on noise effects to fish can be found in 

section 4.5. 

The distances calculated for the harm zone and harassment zones for fish without mitigation is 

approximately 34 meters and 341 meters, respectively. With an assumed 15 dB reduction 

achieved through the use of an unconfined bubble curtain and a wooden hammer cushion, the 

harm zone is reduced to 3 meters and that harassment zone is reduced to 34 meters. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-75

The estimated harm zone for fish when a bubble curtain is used (i.e., 3 meters) is very small. 

The potential impacts due to pile driving noise would be further reduced through the observance 

of the in-water work period, in-water noise monitoring and adaptive management. These 

measures should eliminate any potential physical harm to Oregon Coast coho salmon. 

Effects of Operational Lighting 

Localized changes in light regime have been shown to affect fish behavior in a variety of ways 

(Simenstad et al. 1999; Valdimarsson et al. 1997; Tabor et al. 2004). Disorientation may cause 

delays in migration, while avoidance responses may cause diversion of migratory routes into 

deeper, less protected waters. In some cases, increased light may attract both predators and 

potential prey species (Simenstad et al. 1999; Valdimarsson et al. 1997; Tabor et al. 2004). 

Depending on their reaction, coho salmon may have migration delayed, be moved into less 

protected deepwater habitat, or they may become more susceptible to predation because light 

increases predators’ ability to see fish and also because predators may be attached to the area. 

The location of the facility, set back from the main channel, would reduce coho salmon 

encountering any shoreline lighting effects. Lighting at the terminal and onshore facilities would 

likely include a mixture of low-power fluorescent lighting and higher intensity security lighting 

that would primarily be located on shore, in and adjacent to the slip. The reduced lighting levels 

near the water would reduce or eliminate any behavioral effects to coho salmon in the proposed 

project vicinity. However, some adverse modification in fish behavior could occur from the 

lighting present at the site, possibly delaying migration, moving coho salmon to less desirable 

habitat conditions, or subjecting juvenile coho salmon to greater nighttime predation. The final 

details of the lighting arrangement would be determined through consultation with resource 

agencies to reduce these potential adverse effects. 

Ship Wake and Propeller Wash Effects on Turbidity 

Ship wakes and propeller wash can cause bank erosion and increase suspended sediment levels 

in rivers, bays, and channels that may affect food supply and feeding ability of juvenile coho 

salmon, and if high enough, inhibit oxygen exchange or weaken individuals. Propeller wash 

from LNG carriers and tug boat propellers associated with the proposed terminal and slip, as well 

as ship wakes breaking on shore could cause increased erosion along the shoreline and resuspend 

the eroded material within the water column. As discussed in section 4.5.2.1, models (Jordan 

Cove Energy, December 2008) indicate maximum vessel-generated wave height would be about 

1.1 feet, similar to wind waves that naturally occur in the bay. Some increase in wave 

occurrence (0 to 3.1 percent depending on location) and intensity would also occur but effects on 

erosion and turbidity would be slight relative to current conditions and increased sedimentation 

and disruption of aquatic nearshore habitat are unlikely because of the factors noted (see section 

4.5.2.1). Some larger waves may be generated in the outer mile of Coos Bay from greater vessel 

speed, but this area naturally would have greater size waves from it proximity to the ocean. 

Similarly, propeller wash was modeled. These results indicated that maximum velocity would 

be similar to high current velocity and elevated velocity would be near the bay bottom. 

Generally, along most of route no marked bottom disturbance or sediment suspension would 

occur, as the increased velocity would be similar to maximum tidal currents other than very near 

(about one-quarter to one-half mile) the docking site. Overall, some loss of benthic organisms 

that may be food sources for coho salmon may occur during each transport trip near the slip 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-76

approach, but the magnitude would be small, the frequency would be low, and the result would 

be inconsequential to the Oregon Coast coho salmon. 

Ship Wake Effects on Fish Stranding 

Fish stranding can occur when fish become caught in a vessel’s wake and are deposited on shore 

by the wave generated by the vessel wake. The potential for fish stranding as a result of an LNG 

carrier is discussed in section 4.5.2.1. Stranding from vessel-generated waves is a function of 

several factors including tide level, beach slope, vessel morphology, fish species and size, and 

vessel speed. For example Pearson et al. (2006) observed a total of 126 vessel passages in the 

Columbia River, which resulted in 46 juvenile stranding events, with year 0 (young of the year) 

Chinook salmon accounting for 50 to 91 percent of the stranded individuals. No strandings were 

observed as a result of vessels traveling at speeds under 9 knots (10.4 mph). But Hinton and 

Emmett (1994) did not find stranding to be a significant cause of mortality to juvenile salmonids 

in the Columbia River. Considering the conditions including boat entering and leaving at high 

slack tide, low boat speed (most speeds in Coos Bay would be 6 knots or less), and wave height 

within normal range, and infrequent occurrence of susceptible fish (coho salmon are less 

susceptible than Chinook salmon), it appears unlikely that LNG carrier traffic would contribute 

to juvenile coho salmon stranding. 

Entrainment and Impingement 

As discussed in section 4.5.2.2 there is the possibility of entrainment and impingement of 

juvenile outmigrating coho salmon from ballast and cooling water intake during each of the 24 

hours LNG offloading events that would occur about 80 times annually. Water intake may be as 

high as 285,000 m3 each trip (75 million gallons). As noted, no direct screening system that 

meets screening criteria is being developed, although an alternative stand-off pre-filtered water 

supply is being proposed by Jordan Cove. If the proposed screening system did not function 

based on range of flows and screening area of typical ship intakes, the estimated velocity at the 

opening of the water intakes would range from 0.5 to 1.8 feet/sec (0.15 to 0.54m/s) during 

loading from water intake for both ballast and cooling water. This velocity would occur for 

about 13 hours. While during the remainder of the dock time (about 11 hours) the velocity at the 

opening would range from 0.2 to 1.3 feet/sec (0.05 to 0.39 m/sec) depending on the flow. NMFS 

recommended approach velocity to screening systems for salmonids under 60 mm is 0.33feet/ 

sec, and 0.8 feet/sec for larger juvenile salmonids (NMFS 1997). These guidelines also include 

other requirement such as sweeping velocity and type and size of openings that are not present 

on these screens. The result, if the water jet system does not work, is that fish at least up to fry 

size salmonids near the intakes may be entrained or impinged during at least offloading and 

assuming the higher flow volumes also during just cooling water intake. Larger juvenile 

salmonids could also be susceptible during the whole 24-hour period of entrainment under the 

higher flow assumptions. In the case of coho salmon, few would be as small as 60mm, as most 

would be outmigrating as age 1+ likely greater than 120mm. So many of the juvenile coho 

salmon would actively be able to avoid being entrained or impinged if the proposed prevention 

method is not completely effective. Also, the location of the intake would be near the inner 

portion of the slip away from the main channel, which would likely reduce overall abundance of 

coho salmon in the intake area. 

Loss of juvenile coho salmon could relate to reduced adult coho salmon returns. NMFS (2008) 

in their assessment of effects of loss of juvenile coastal coho salmon from local airport expansion 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-77

assumed a 4 percent Coos Bay coho salmon smolts to returning adult survival. Even so, the 

extremely small portion of total water intake relative to the volume of Coos Bay suggests that the 

relative portion of juvenile salmonids that would suffer direct mortality would be small. Also 

there is no reason to suggest that the intake area would have any higher abundance of juvenile 

salmonids than the rest of the bay area, and in fact may be lower as the fish would have to enter 

the off-channel slip that is out of the main flow region. Coho salmon migrating to the ocean 

would likely be more closely associated with the main channels than the nearshore area and the 

inset slip, reducing their chance of encountering the intakes. 

Overall, the loss of listed coho salmon, relative to numbers in Coos Bay would likely be very 

small, but it is difficult to estimate because of the lack of specific data. Loss of zooplankton and 

other pelagic food organisms would also occur but overall loss, based on the relatively small 

volume used, would be small and likely would not substantially reduce food supply. However, 

due to limitations on available data concerning distribution and abundance of organisms at this 

site, as noted in section 4.5.2.2, Jordan Cove has proposed initial and follow-up monitoring to 

determine effects. 

Indirect Effects – Estuarine Analysis Area

Project-related effects to coho salmon in the Oregon Coast ESU that are caused by the action 

(induced by the action as human presence and use increase) and are later in time or farther 

removed in distance, but are still reasonably foreseeable include the following indirect effects: 1) 

turbidity effects to forage/prey species and habitat by dredging the access channel, 2) turbidity 

effects to forage/prey species and habitat by construction of the Pacific Connector pipeline, 3) 

shading effects on marine plants, 4) introduction of exotic species, 5) windblown sand, and 6) 

ship wake. 

Habitat Effects – Slip and Access Channel

Benthic and epibenthic invertebrates that presently inhabit shallow intertidal and subtidal regions 

within the boundaries of the proposed access channel dredging area would be removed with the 

dredged material. Much of the shallow intertidal habitat proposed for dredging is presently 

dominated by a colony of burrowing shrimp (likely sand or ghost shrimp), which were observed 

during site visits in November 2006. Although not observed, ghost shrimp and sand shrimp 

(adults, juveniles and larvae) are important prey for a variety of fish species and have been 

documented along intertidal habitats at the LNG terminal site (Gaumer et al. 1978). Therefore, 

the loss of ghost shrimp and/or sand shrimp at the access channel would result in a reduction in 

fish food available to coho salmon in those areas affected by the terminal. Ghost and sand 

shrimp typically are unlikely to colonize the deep-water channel habitat created by dredging. 

However, other benthic organisms would likely colonize the newly dredged area and would 

compensate, in part, for the loss of shrimp. 

Maintenance dredging within the access channel and slip would also result in the loss of benthic 

and epibenthic organisms. The proposed access channel is adjacent to the existing navigation 

channel, which is subject to periodic maintenance dredging. There is limited information on the 

densities of icthyoplankton, zooplankton, phytoplankton, and planktonic shellfish larvae for 

Coos Bay but large numbers of these life stages could be entrained if dredging occurs during 

seasonal periods of high abundance. Juvenile coho salmon in Coos Bay do not likely utilize 

zooplankton to a large degree, but rather feed primarily on benthic invertebrates, terrestrial 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-78

insects, and small fish such as Pacific sand lance (Nicholas and Lorz 1984). Therefore, the 

removal of even large numbers of these organisms would be unlikely to impact Oregon Coast 

coho salmon. In addition, benthic communities in Coos Bay inhabiting mud substrates recovered 

to pre-dredging conditions in four weeks (Newell et al. 1998). Although the substrate proposed 

for maintenance dredging in the access channel and berth would largely be sand and silt, it is 

anticipated that recovery would occur within a similar time frame, resulting in only short-term 

effects to the benthic community and potential food resources for coho salmon. 

Construction of the pipeline across the Coos Bay estuary would span 2.5 miles and disturb 

approximately 86 acres of subtidal (41 acres) and intertidal (45 acres) habitats as they were 

defined in 1987 for ODLCD Coastal Management Program Dynamic Estuary Management 

Information System, or DEMIS (ODLCD 1998). All disturbances by construction rights-of-way 

and TEWAs within the subtidal zone would be to unconsolidated bottom habitats associated with 

the main channel through Coos Bay. 

Most construction-related disturbances in the intertidal zone would be to sand or mud shore and 

flats habitats; approximately 17 acres of sand/mud flats would be affected by construction rightsof-way and TEWAs. Based on the most recent survey of the route, 1 acre of eelgrass would be 

affected (Ellis Ecological Services 2008). Construction, most likely using a marsh excavator or 

similar low-impact equipment, would affect 3 acres of low salt marsh, 1 acre of high salt marsh, 

and 4 acres of undifferentiated tidal marsh. 

Refugia habitats for coho salmon in the lower bay are generally limited to shallow water flats 

habitat and eelgrass beds. Tidal marsh provides outstanding refugia for juvenile salmonids and 

other fish species, but is more common in upper bay sloughs and inlets. Ellis Ecological 

Services, Inc. conducted a survey of eelgrass beds within Coos Bay along the pipeline route in 

2007. Eelgrass beds were placed into three categories based on density - low, medium and high. 

From that survey, there was 1 acre of eelgrass beds that would be directly affected by the 

construction right-of-way (including TEWAs). 

Eelgrass may be adversely affected by turbidity generated during trenching. Generated turbidity 

is not expected to limit light to eelgrass beds proximate to construction sites and should not 

contribute additional indirect source of impact to eelgrass habitats, dependent fish species, 

invertebrates, and EFH. Construction of the pipeline across the estuary is planned from October 

1 through February 15 following ODFW’s recommendation. During most of that period, 

eelgrass in Coos Bay would be dormant, coinciding with low temperatures and short 

photoperiods (Fonseca et al. 1998). 

Shading Effects 

Shading from over-water structures reduces the amount of light available to phytoplankton and 

aquatic macrophytes. However, the area where shading from project facilities would occur is 

intended for industrial uses and not the creation of new habitat. The water areas are being 

created from upland areas and no net loss in productivity due to shading would occur. Project 

facility components that potentially could shade the open water created by the construction of the 

slip include: 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-79

• At the proposed slip, the access gangway to the LNG facility is narrow and well above 

the water surface. Shade produced by the gangway is expected to be biologically 

insignificant. 

• The tug dock would be connected from shore by a narrow gangway. The dock would be 

12 feet in width and located at +12 feet NAVD88. Consequently, shading impacts would 

be small and probably insignificant. 

Most fish, including coho salmon, have developed countershading as an adaptation to avoid 

predation (Moyle and Cech 2000) from above (dark dorsal surface blends with bottom substrate) 

and from below (light ventral surface blends with light from the surface). Fish within a shaded 

area would be more easily detected by a predator, especially from below since light colored 

ventral surfaces would stand out against a shaded water surface. There are numerous predators 

of coho salmon smolts in estuarine habitats (Sandercock 1991) including dogfish, lampreys, 

sharks, mammals (seals, sea lions), and birds (gulls, loons, mergansers). The extent to which any 

of these or other predators affect coho salmon in shaded areas created by the proposed action is 

unknown. Given the small area shaded, this impact should be minimal. 

Exotic Species 

The proposed action may result in the potential for introduction of exotic species by increased 

ship traffic to Coos Bay. The primary pathway for ship-borne introductions of exotic species is 

through the discharge of ballast water. In June 2004, the Coast Guard published mandatory 

regulations for ballast water in the waters of the United States, which includes requirements to 

clear fouling organisms from ship hulls and to rinse anchors and anchor chains. LNG carriers 

would be importing cargo and would not discharge ballast water, but would take on ballast 

water. 

Windblown Sand 

Moffatt & Nichol (2007) concluded that wind-blown sand from the stockpile locations would be 

transported north and south (based on the season). North to south sand transport would 

essentially eliminate discharge of sand from the stockpile to the Bay. Moffatt & Nichol conclude 

that, “If the [stockpiled] material is vegetated sufficiently to provide a vegetation cover similar to 

or slightly less than that currently present over much of the site, the aeolian sand transport rate 

would remain similar to or decrease slightly compared to existing conditions. This would 

represent a slight improvement compared to existing conditions.” Based on the results of this 

modeling and the proposed mitigation of the pile (establishment of vegetation stands and sand 

fencing as needed), windblown sand is not expected to negatively impact coho salmon in the 

Bay. 

Indirect Effects – Riverine Analysis area

Project-related effects to coho salmon in the Oregon Coast ESU that are caused by the action 

include indirect effects to coho salmon through direct effects to salmonid habitat. The Pacific 

Connector pipeline would actually cross 84 perennial streams within the range of Oregon Coast 

coho salmon. Of those, 47 have existing riparian forest, 31.33 acres of which would be removed 

by construction. Thirty-seven more perennial streams would also be crossed, but construction 

would not affect riparian forest vegetation. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-80

In addition, the Pacific Connector pipeline would cross 43 intermittent streams, 36 of which 

support riparian forest, of which 24 acres would be removed. Seven additional intermittent 

streams with no riparian forest would be crossed as well. Riparian forest associated with four 

intermittent streams (2 acres) would be removed although the streams would not be crossed. 

Four more streams with unknown flow regimes would be crossed, one of which supports riparian 

forest, and seven other unknown streams would not be crossed although their riparian forests 

would be affected. The details of the acres potentially affected by stream are presented in the 

BA for this project. 

Because riparian zones are defined as the distance from each streambank equivalent to one sitepotential tree height (Moore et al. 2005), or two site-potential tree heights for fish-bearing 

streams within Riparian Reserves on NFS land (USFS and BLM 1994a), removal of riparian 

forested vegetation is expected to remove shade trees. This would contribute to the further 

degradation of existing riparian conditions in the watersheds crossed by the Pacific Connector 

pipeline, which have already been affected by past land uses. Part of Jordan Cove’s and Pacific 

Connector’s mitigation measures regarding forest removal in riparian areas includes replanting 

of appropriate, native species, including conifers. Therefore, the effects of right-of-way clearing 

would be undetectable once vegetation had the chance to regrow on site, possibly in as little as 

10 years, especially for smaller streams. The 10-foot-wide area would be left in a lowherbaceous condition, but trees and shrubs on either side of the area would most likely be 

sufficient to shade narrow streams. 

Other effects to salmonid habitat could include increased water temperature and turbidity, fracout from HDD, nutrient loading, decreased fish access, reduction of benthic organisms, reduction 

of pelagic organisms from entrainment, reduction of LWD, and surface runoff (see section 

4.5.2.3 for these effects). 

Conservation Measures 

The Port has proposed conservation measures to minimize construction and operation impact to 

fisheries and the estuarine analysis area. Those measures have been compiled in the description 

of the Mitigation Plan and apply to Oregon Coast coho salmon. 

Without repeating the components proposed by the Port that are in the Mitigation Plan, they 

include measures related to: 

• Timing of Dredging Activities - to minimize potential impacts to juvenile salmonids and 

other fish/invertebrate species through the avoidance of vulnerable life stages and peak 

migration periods; 

• Dredging and Disposal Activities – use of dredge equipment and techniques to minimize 

the potential for turbidity and contaminant releases to the water column; 

• Use of Upland and In-Water Disposal of Dredge Materials - includes removal of dredged 

spoils by barge; 

• Control of Turbidity and Contaminants – includes monitoring, corrective actions, and 

dredging technique; 

• Timing of Some Terminal Construction Components - minimizes potential impacts to 

juvenile salmonids and other fish/invertebrate species through the avoidance of 

vulnerable life stages and peak migration periods; 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-81

• Control of Acoustic Disturbance – includes monitoring and implementation of a noise 

mitigation plan; 

• Riprap Installation; 

• Lighting – includes limiting and design; and 

• Spill Prevention and Control – includes development and implementation of a SPCCP. 

Pacific Connector has proposed conservation measures to minimize construction and operation 

impact to the estuary (estuarine analysis area), waterbodies, and riparian zones (riverine analysis 

area). Those measures have been compiled in the description of the Mitigation Plan and apply to 

Oregon Coast coho salmon. 

Pacific Connector has also proposed measures to rectify, repair, and rehabilitate and otherwise 

reduce impact to waterbodies and riparian zones once construction of the Pacific Connector 

pipeline is complete. 

The same summary of conservation measures related to erosion control that was provided above 

for coho salmon in the SONCC ESU also applies to coho salmon in the Oregon Coast ESU. 

Blasting, Fish Salvage and Hydrostatic Testing

The same measures that Pacific Connector would use for the SONCC coho salmon would also be 

used to reduce effects of these activities on Oregon Coast coho salmon. See description above. 

Revegetation

Pacific Connector would use the same methods described for SONCC coho salmon for restoring 

lost vegetation. Construction of the Pacific Connector pipeline would initially remove 60 acres 

of currently forested riparian vegetation within watersheds inhabited by Oregon Coast coho 

salmon: 15 acres of Late Successional (Mature) Old Growth, 49 acres of Mid-Seral Forests, and 

an additional 17 acre of Forested/non-forested Wetlands). Of these acres of forested riparian 

vegetation, 14 acres would be removed in the Coos Bay Frontal watershed, 1 acre from the 

Lower Coquille River watershed, 8 acres in the North Fork Coquille River watershed, 1 acre 

from the East Fork Coquille River watershed, 11 acres from the Middle Fork Coquille River 

watershed, 5 acres from the Olalla Creek-Lookingglass Creek watershed, 4 acres from the 

middle South Umpqua River watershed, 5 acres from the Myrtle Creek watershed, 7 acres from 

the South Umpqua River watershed, and 4 acres from the Upper Cow Creek watershed. After 

replanting conifers in each affected forested riparian zone, an estimated 13 acres would be left 

permanently unforested during the life of the Project. 

In several instances, mitigation would contribute to restoring an indicator’s functional level, such 

as placement of LWD within and/or adjacent to streams and placing LWD on floodplains, where 

appropriate, to provide microsites for riparian vegetation and/or vegetation protection during 

flood events. Pacific Connector considers installing LWD on site during construction as an 

appropriate habitat enhancement feature to rectify potential project impacts, which would benefit 

watershed conditions that are generally lacking. The proposed protocols for implementing LWD 

as mitigation are described under the SONCC ESU. 

In all, Pacific Connector proposes 373 pieces of LWD for placement within the 10 fifth field 

watersheds that coincide with Oregon Coast ESU coho salmon and designated critical habitat. 

However, placement of LWD is subject to approval by each affected landowner. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-82

There is a strong likelihood that various life stages of coho salmon in the Oregon Coast ESU 

would be present within the Coos Bay Estuary during construction of the slip and access channel, 

the LNG terminal, and in freshwater streams crossed by the Pacific Connector pipeline. Adults 

and smolts in the estuarine analysis area may be affected by dredging, pile driving, and other 

actions required for construction. In the riverine analysis area, adult upstream migration may be 

affected during dry open-cut construction and in particular, construction commencing later than 

the ODWF in-water construction timing guidelines. Adult coho salmon and juveniles subject to 

fish salvage within isolated construction sites could be injured or killed if electrofishing is used 

and stressed if seining is used. Incidental take of coho salmon is possible. The Project may 1) 

have adverse effects to critical habitat by removing forested riparian vegetation, and 2) impair 

the suitability of seasonally or permanently occupied habitat by increasing local turbidity over 

the short-term and limiting recruitment of LWD over the long-term. Based on these evaluations 

and with implementation of the proposed conservation measures, the proposed Project is likely to 

adversely affect coho salmon in the Oregon Coast ESU and its designated critical habitat. 

Lost River Sucker (Federal Endangered, State Endangered) 

The Lost River sucker was listed as a federally endangered species on July 18, 1988 because of a 

variety of factors including: loss of habitat and access to historical range, over-fishing, degraded 

water quality, lack of significant recruitment, inadequate regulatory mechanisms, and a variety of 

other reasons resulting in declining populations (FWS 1988). Since listing, some of the factors, 

including over harvest and lack of regulatory protection, have been removed; however, many of 

the other factors remain (ISRP 2005 as cited in BOR 2007). The Lost River sucker is a lakedwelling fish that migrates into streams to spawn. It is a long-lived species, reaching ages over 

30 years. Historically, Lost River suckers were found in the Lost River watershed, Tule Lake, 

Lower Klamath Lake, and Sheepy Lake. The present distribution of the Lost River sucker 

includes Upper Klamath Lake and its tributaries, Clear Lake Reservoir and its tributaries, Tule 

Lake and the Lost River, the Klamath River, and Copco, Iron Gate, and J.C. Boyle Reservoirs 

(BOR 2007). In the Upper Klamath Lake watershed, the Lost River sucker spawning runs are 

primarily limited to Sucker Springs in Upper Klamath Lake, and the Sprague and Williamson 

Rivers. Spawning runs also occur in the Wood River and in Crooked Creek in this watershed. 

An additional run may occur in Sheepy Lake in the Lower Klamath Lake watershed and 

spawning has been documented in the Clear Lake watershed (FWS 1988 and 1993a). 

The Lost River sucker has lost habitat from pollution, dam building, irrigation system 

development, marshes being filled, streams being dammed, and water supplies being diverted. 

Water turbidity from soil erosion degrades habitat and is an on-going threat to the species (FWS 

1988). Additional water quality issues including hypereutrophication from high nutrients, both 

from internal and external sources, such as runoff from various land activities (e.g. agriculture, 

timber harvest). This condition causes high algae growth resulting in reduced oxygen levels in 

many of the reservoirs, contributes to fish die offs and other adverse conditions, and causes an 

ongoing impact on populations (BOR 2007). 

Critical Habitat

Five CHUs for the Lost River sucker were proposed by FWS in 1994 and include the majority of 

known populations of Lost River suckers (FWS 1994a): 1) Williamson and Sprague Rivers, 

extending from the mouth of the Williamson River at Upper Klamath Lake upstream to the 

confluence of the Sprague River, and the Sprague River; 2) Upper Klamath Lake and Watershed, 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-83

which includes the waters of Upper Klamath and Agency Lakes below the high water line, portions 

of the watershed on the west side of the Upper Klamath Lake; 3) Clear Lake and Watershed, which 

lies mostly within California, 6.4 miles south of the Pacific Connector pipeline area and includes 

the waters of Clear Lake Reservoir below the high water line and large portions of the two 

tributaries to Clear Lake; 4) Tule Lake, which includes waters within Tule Lake below the high 

water line and the Lost River up to Anderson-Rose Dam where spawning has been documented 

(although, spawning is intermittent and recruitment has not been documented); and 5) Klamath 

River, which extends from Iron Gate Dam in California to Link River Dam on Upper Klamath 

Lake in Oregon. CHUs proposed provide or have the ability to provide the primary constituent 

elements essential to maintaining stable and well-distributed populations over the range of the Lost 

River sucker. Proposed CHUs that could potentially be affected by construction of the Pacific 

Connector pipeline include Clear Lake and its watershed, Tule Lake, and Klamath River. 

Proposed critical habitat focuses conservation activities by identifying areas that contain essential 

habitat features, regardless of whether the areas are currently occupied by the Lost River and 

shortnose sucker (FWS 1994a). FWS (1994a) determined the PCEs that support spawning, 

foraging, cover, refugia, corridors between these areas, and growth and dispersal are essential to 

the conservation of the species. These essential elements are (FWS 1994a): 

• Water—To provide conditions for life stages of the species, consisting of sufficient 

quantity of suitable quality, including temperature, dissolved oxygen, flow rate, pH, 

nutrients, lack of contaminants, and turbidity. 

• Physical Habitat—Areas of the Upper Klamath Basin watershed that are inhabited or 

potentially habitable for use as refugia, spawning, nursery, feeding, rearing areas, or as 

corridors between these areas. 

• Biological Environment—Components include food supply, predation scheme, 

parasitism, and competition. Food supply is a function of nutrient supply, productivity, 

and availability for each life stage. Predation may be out of balance due to introduced 

species or lack of refugia. Competition from non-native fish species may be elevated due 

to degraded habitats. 

Depending on the season of occurrence, management activities that could adversely modify Lost 

River and shortnose sucker proposed critical habitat include, but are not limited to, timber 

harvest, forest management, flood control, road construction and upgrades, pipeline construction 

activities, and development (FWS 1994a). The proposed action would only have a short-term 

effect on the water component of essential habitat elements. Turbidity would be generated 

during dry open-cut construction across the Lost River but, for reasons discussed in the 

applicant-prepared draft BA, turbidity produced over the short-term is not expected to adversely 

affect water quality suitable for Lost River suckers or shortnose suckers. 

Impacts and Conservation Measures

Within the Pacific Connector pipeline area, the Lost River sucker has been documented within 

Klamath River from Klamath Falls to Keno Reservoir, located 4.3 and 15.1 miles north of the 

pipeline respectively. The Pacific Connector pipeline would cross the Klamath River by HDD at 

MP 199.38. The sucker is also known from Tule and Clear Lakes in northern California, which 

are connected by the Lost River. The Lost River sucker has not been documented out of Clear 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-84

Lake; however, they are known to migrate out of Tule Lake to spawn at the base of AndersonRose Dam, about 3 miles southeast of Merrill, Oregon (ORNHIC 2006a). 

Pacific Connector proposes to use HDD for the Klamath River crossing, which would have no 

effect on this species. There are no timing restraints at this location and this HDD would not 

affect riparian vegetation. The Pacific Connector pipeline would cross Lost River 6.8 miles 

upstream of the dam, using a dry, open cut method. This method is expected to increase 

turbidity downstream from the crossing; however, it would be short-term and localized. 

Depending on the season of occurrence, management activities that could adversely modify Lost 

River and shortnose sucker proposed critical habitat include, but are not limited to, timber 

harvest, forest management, flood control, road construction and upgrades, pipeline construction 

activities, and development (FWS 1994a). The proposed action would only have a short-term 

effect on the water component of essential habitat elements. Turbidity would be generated 

during dry open-cut construction across the Lost River but is not expected to adversely affect 

water quality suitable for Lost River suckers or shortnose suckers. 

Spawning is likely to occur within the Lost River, although in limited areas (BOR 2007), 

possibly including the riverine analysis area where the Pacific Connector pipeline would cross at 

MP 212.05. Adults and juveniles subject to fish salvage within the isolated construction site at 

the Lost River could be injured or killed if electrofishing is used and stressed if seining is used. 

Incidental take of a Lost River sucker is possible. But salvage operations within the crossing 

would follow the latest Handling Guidelines for Klamath Basin Suckers developed as part of the 

Klamath Project Operations Biological Opinion (BOR October 2008; these guidelines may be 

updated frequently). Pacific Connector has included these guidelines in their Fish Salvage Plan 

that would be use in the vicinity of listed suckers. Some of the main factors in handling are the 

requirement of having a 0.5 percent saline solution of un-chlorinated well water to place any 

captured listed sucker in should it be collected during fish salvage operations. Aeration would 

also be supplied and the container a sucker is placed into would have been coated with a 

commercially available slime coat. Fish would be retained in this solution until released 

upstream of the capture site unless otherwise indicated through agreement with FWS. Because 

the details of the protocol for handling of any listed sucker changes frequently, we recommend 

that:

• Pacific Connector, in consultation with appropriate resource agencies, should 

develop a salvage plan outlining procedures that would be followed to capture any 

federally-listed sucker species during stream crossings. The final salvage plan, 

including documentation of agency review, should be filed with the Secretary prior 

to pipeline construction, for review and approval by the Director of OEP. 

Despite these measures, however, it is still possible that Lost River suckers could be killed by 

salvage operations. Therefore, the proposed action is likely to adversely affect Lost River 

suckers. The proposed action would not have adverse effects on proposed critical habitat or 

impair the suitability of seasonally or permanently occupied habitat; or impair or degrade 

unoccupied habitat necessary for the survival of Lost River suckers locally. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-85

Shortnose Sucker (Federal Endangered, State Endangered) 

The shortnose sucker was listed as a federally endangered species on July 18, 1988 (FWS 1988). 

The final rule (FWS 1988) to list the shortnose sucker as endangered suggested several reasons 

for their decline, including the construction of dams, water diversions, over-fishing, competition 

and predation by exotic species, water quality problems associated with timber harvest, removal 

of riparian vegetation, livestock grazing, lack of significant recruitment, inadequate regulatory 

mechanisms and agricultural practices. Since listing, some of the factors, including overharvest 

and lack of regulatory protection, have been removed; however, many of the other factors remain 

(ISRP 2005 as cited in BOR 2007). Additional water quality issues include hypereutrophication 

from high nutrients, both from internal and external sources, such as run off from various land 

activities (e.g. agriculture, timber harvest). This condition causes high algae growth resulting in 

reduced oxygen levels in many of the reservoirs, contributes to fish die offs and other adverse 

conditions, and has an ongoing impact on populations (BOR 2007). 

The historical range included all of the upper Klamath basin, except for higher colder streams, 

which were dominated by trout, and the upper Williamson, which was isolated by Williamson 

Canyon. Currently, shortnose suckers are present in upper Klamath Lake and tributaries, Lost 

River, Clear Lake Reservoir, the Klamath River, and three large Klamath reservoirs (BOR 2007). 

They have also recently been found in Tule Lake and Gerber Reservoir. 

Shortnose suckers live in lakes and spawn in rivers, streams or springs associated with the lake 

habitats, generally from early February through mid-April. After hatching, larval suckers 

migrate out of spawning substrates, which are usually gravels or cobbles, and drift downstream 

into lake habitats from early May to mid-June (FWS 1988 and 1993a). 

Critical Habitat 

Six CHUs for the shortnose sucker were proposed by FWS in 1994 (FWS 1994a) and are limited 

to occupied or potentially habitable water bodies that are considered essential to conservation of 

the species. The Clear Lake and Watershed CHU lies mostly within California, 6.4 miles south 

of the Project area, and includes the waters of Clear Lake Reservoir below the high water line 

and large portions of the two tributaries to Clear Lake: Willow Creek and Boles Creek. The Tule 

Lake CHU includes waters within Tule Lake below the high water line and the Lost River up to 

Anderson-Rose Dam where spawning has been documented. Anderson-Rose Dam lies 4.3 miles 

southeast of the Lost River pipeline crossing. Shortnose suckers have been documented within 

reservoirs located along the Klamath River system between Upper Klamath Lake and Iron Gate 

Reservoir. As a result, the Klamath River CHU includes waters of the Klamath River from Iron 

Gate Dam in California to the Link River Dam on the Upper Klamath Lake. The other proposed 

CHUs (Upper Klamath Lake and Watershed, Williamson and Sprague Rivers, and Gerber 

Reservoir and Watershed) are more than 7 miles from the pipeline. 

All existing and proposed CHUs for the shortnose sucker are located more than 4 miles from the 

pipeline. Therefore, any construction related impacts which would be temporary and localized 

(e.g., minor reductions in water quality) would not affect these CHUs. For a discussion of 

primary constituent elements of shortnose sucker habitat, see section above under Lost River 

sucker. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-86

Impacts and Conservation Measures

Within the Pacific Connector pipeline area, the shortnose sucker may occur within the Klamath 

River above Keno. This species has also been documented within the Lost River, but north of 

the Project area near Bonanza, Oregon (ORNHIC 2006a). There is a slight chance they occur in 

the Lost River within the Pacific Connector pipeline area (FWS 1994a). 

Pacific Connector proposes to use HDD for the crossing of the Klamath River at MP 199.38, so 

there are no timing restraints. This HDD is not expected to affect riparian vegetation adjacent to 

Klamath River, but would remove 0.57 acres of riparian habitat within the 100-foot riparian 

zone. No impacts to the shortnose sucker are expected in the Klamath River, unless there is a 

frac-out. If there is a frac-out, both the fish and the emergent riparian vegetation could be 

temporarily affected. 

Use of HDD is considered an effective technique for avoidance of instream impacts by 

eliminating the need for instream excavation (Reid et al. 2004). Even with this technique there is 

a potential for impact with the HDD process. Drilling requires use of a drilling mud for 

lubrication of the bit and removal of cuttings. Bentonite clay would be used as the drilling mud. 

Because the drilling mud is under pressure during drilling, if the bit encounters substrate 

fractures or channels it is possible for bentonite to escape from the hole to a visible surface 

(termed a “frac-out”). Bentonite can escape to the surface if the fractures lead to and through the 

drilled substrate. 

Bentonite, by itself, is non-toxic (Breteler et al. 1985; Hartman and Martin 1984; Sprague and 

Logan 1979) but as with any fine particulate material, it can interfere with oxygen exchange by 

gills (EPA 1986), and the degree of interference generally increases with water temperature 

(Horkel and Pearson 1976). This is a localized effect, and if any impacts do occur, those impacts 

would be limited to individual fish in the vicinity of the leak. Fish move away from turbidity 

spots and plumes such as described above, after instream pipeline construction. 

Minimization of impacts due to potential frac-out relates to locating the drill entry and exit points 

away from the waterbody. The probability of a frac-out may increase when the drill bit is 

working nearest the surface, but that chance is dependent on numerous factors including 

substrate characteristics, head pressure of the drilling mud, topography, elevation, and subsurface 

hydrology. Pacific Connector would design each HDD such that areas of greatest risk from fracout are on uplands and not adjacent to the waterbodies where much greater depth would be 

achieved and frac-out potential is reduced. 

Pacific Connector would minimize disturbance to shortnose suckers by constructing in 

waterbodies where the shortnose sucker has been documented between July 1 and March 31, the 

ODFW preferred in-water work period (ODFW 2000a), with the exception of the Klamath River 

which would be crossed using an HDD method. 

There is a possibility that shortnose suckers could occur within the Lost River when it would be 

crossed by the Pacific Connector pipeline. Adults and juveniles subject to fish salvage within the 

isolated construction site at the Lost River could be injured or killed if electroshocking is used 

and stressed if seining is used. Incidental take of a shortnose sucker is possible. Pacific 

Connector would implement the Fish Handling Guidelines developed as part of the Klamath 

Project Operations (BOR 2007) as discussed above for the Lost River sucker. However, despite 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-87

these measures, it is still possible that Shortnose Suckers could be killed by salvage operations. 

Therefore, the proposed action is likely to adversely affect Snortnose Suckers. 

The proposed action would not have adverse effects on proposed critical habitat or impair the 

suitability of seasonally or permanently occupied habitat; or impair or degrade unoccupied 

habitat necessary for the survival of shortnose suckers locally. 

4.6.1.4 Amphibians and Reptiles 

Sea Turtles 

Green Turtle (Federal Threatened Species, State Endangered Species)

Green turtles have been sighted from Baja California to southern Alaska, but most commonly 

occur from San Diego south (NOAA 2007). Green turtles primarily use three types of habitat: 

oceanic beaches (for nesting), convergence zones in the open ocean, and benthic feeding grounds 

in coastal areas (NOAA 2007). Reports of strandings suggest that the green turtle is a frequent 

visitor off of California. Based on this data, green turtles are likely infrequent visitors to the 

Oregon Coast, but may occasionally be found in the EEZ action area. Sightings offshore of the 

Pacific Coast have occurred but there are no known sea turtle nesting sites on the West Coast of 

the United States (NMFS 1998c). The East Pacific green turtle was the most commonly 

observed hard-shelled sea turtle on the United States Pacific Coast (NMFS 1998c), but most of 

the sightings (62 percent) were reported from northern Baja California and southern California. 

The northernmost known resident population of East Pacific green turtles occurs in San Diego 

Bay, in the warm effluent of a power plant (NMFS 1998c). Fifteen green turtles have been 

reported stranded, alive or dead, in Oregon and Washington since the beginning of 1997 through 

2007 (NMFS unpublished data). 

Leatherback Turtle (Federal Endangered Species, State Endangered Species)

The leatherback sea turtle is the most common sea turtle in United States waters north of Mexico 

(NMFS and FWS 1998b). Leatherbacks occur as far north as Alaska, and numerous sightings 

have been documented off the Oregon Coast. Green et al. (1992) observed 16 Pacific 

leatherback turtles off the Oregon and Washington coasts, all of them north of a point due west 

of Pacific City, Tillamook County, Oregon. Sixty-two percent of the sightings occurred over the 

continental slope, with the remainder occurring over the continental shelf. Incidental catch of 

leatherback turtles has also occurred in gill-nets off the coasts of Washington, Oregon, and 

California. Adult leatherback turtles are highly migratory and available information indicates 

that eastern Pacific migratory corridors exist along the west coast of the United States (NMFS 

and FWS 1998b). The west coast of the United States may represent some of the most important 

foraging habitat in the world for the leatherback turtle (NMFS and FWS 1998b). The importance 

of the EEZ action area to leatherback turtles is unknown though they are expected to occur; 

however, new data indicate that leatherbacks are entering the US EEZ from the west as well as 

transiting coastally (NMFS unpublished data). 

Olive Ridley Turtle (Federal Threatened Species, State Threatened Species)

At-sea occurrences in waters under United States jurisdiction are limited to the west coast of the 

continental United States and Hawaii, where the species is rare, but possibly increasing. Olive 

ridleys have occasionally been killed by gill-nets and boat impacts as well as cold-stunning (or 

cold-stranding due to hypothermia by rapid decline of water temperatures) in Oregon and 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-88

Washington (NMFS and FWS 1998c). Based on sightings off the Oregon Coast, olive ridley 

turtles may occasionally occur in the EEZ action area. Five olive ridley turtles have been 

reported stranded, alive or dead, in Oregon and Washington since the beginning of 1997 through 

2007 (NMFS unpublished data). 

Loggerhead Turtle (Federal Threatened Species, State Threatened Species)

Loggerheads occupy three different ecosystems during their lives—the terrestrial zone, the 

oceanic zone, and the neritic zone (NOAA 2007b). Loggerhead turtles are circumglobal in 

distribution, occurring throughout the temperate and tropical regions of the Atlantic, Pacific, and 

Indian Oceans (NOAA 2007b). Loggerhead sea turtles are the most abundant species of sea 

turtle found in United States coastal waters (NOAA 2007b). In the United States, occasional 

sightings are reported from the coasts of Washington and Oregon, but most records are of 

juveniles off the coast of California (NOAA 2007b). Juveniles are captured incidentally in 

longlines and driftnets in the pelagic Pacific indicating that the species’ range includes coastal 

and pelagic waters (NMFS and FWS 1998e). The potential importance of Oregon waters and the 

EEZ action area to loggerhead turtles is unknown, although two loggerhead turtles have been 

reported stranded, alive or dead, in Oregon and Washington since the beginning of 1997 through 

2007 (NMFS unpublished data). 

Sea Turtle Impacts and Conservation Measures 

Direct effects of the proposed action include injury and/or mortality due to ship-strikes and 

potential adverse effects from a carrier spill and/or release of LNG at sea. Spills and/or released 

LNG could indirectly affect green turtles by impacting forage species. These effects are 

addressed, below. 

Ship Strikes

The proposed action would result in increased shipping traffic and may increase potential vessel 

strikes to turtles within the EEZ action area. Sea turtles can be injured or killed when struck by a 

boat, especially by an engaged propeller. Eighty percent of the Chelonia deaths reported recently 

in San Diego Bay and Mission Bay, California were associated with evidence of boat collision. 

A considerable amount of shipping traffic currently occurs within the EEZ action area. The 

proposed action is expected to increase traffic by 160 additional ship transits through the EEZ 

action area each year of operation. Given the low population and occurrence of sea turtles in 

Oregon coastal waters and current estimate of vessel traffic, the addition of 160 LNG carrier 

transits through the EEZ action area is not expected to result in measurable additional ship strikerelated mortality or injury to sea turtles. However, lack of ship-strike incidences to sea turtles in 

general or frequencies of collision precludes any estimate of effects to sea turtles of additional 

vessel traffic due to LNG carriers. 

Ship Strikes by Tug/Barge Units. In addition, 150 sand barge trips from the Port’s dredge spoils 

storage site have been estimated to occur during a total 7-year period following construction. An 

estimated 75 barges each year are expected to remove an annual total of 500,000 cubic yards of 

dredged sand stored at the Port spoil storage site. At that rate, the stored material should be 

removed in 7 years. Tug/barge units are assumed to traverse the EEZ offshore beyond the 

Territorial Sea limit (0 to 12 nmi) but within the Contiguous Zone 12 to 24 nmi offshore (U.S. 

Commission on Ocean Policy 2004). From Coos Bay, the barges are expected to haul sand to 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-89

San Francisco, 451 nmi away (67,650 ship-miles per year). The additional traffic contributed by 

tug-barge units would increase the overall vessel traffic (added to 141,920 ship-miles per year by 

LNG carriers in California, Oregon, and Washington waters combined) associated with the 

proposed action to 209,570 annual ship-miles by transits to San Francisco. The addition of tugbarge units would increase vessel traffic by 4.2 percent over vessel traffic estimated in 1998-

1999. 

Spills and Releases 

Oil spills at sea or offshore can also harm sea turtles (NMFS and FWS 1998a). However, 

untoward LNG carrier incidents are impossible to predict and any petroleum products released 

would be engine oil or lubricating oils, diesel fuel, and/or gasoline. As discussed above for blue 

whales, it appears that the background rate of spills off the Oregon coast by fishing vessels, 

recreation vessels, and other vessel types is generally low. If an unignited LNG spill were to 

occur along the LNG carrier transit route in the areas used as migratory routes by sea turtles, the 

LNG would float on the water until it vaporizes and would not have an adverse effect on the 

turtles, unless they come in direct contact with the LNG. 

Measures to reduce ship speeds inside the harbor in the range of 4 to 6 knots and within the EEZ 

when pods or large assemblages of cetaceans and possibly Steller sea lions are observed near an 

underway ship would benefit sea turtles. However, it is highly unlikely that sea turtles would be 

seen from a LNG carrier. Nevertheless, the same Ship-Strike Reduction Plan that was described 

to minimize potential ship strikes to cetaceans by LNG carriers and barges used to transport the 

sand temporarily stored at the Port site (total of 7 years duration) could similarly reduce risk of 

strikes to sea turtles. Based on the effects described above in conjunction with the proposed 

conservation measures, the proposed action may affect but is not likely to adversely affect any of 

the potentially affected species of sea turtles. 

4.6.1.5 Invertebrates 

Vernal Pool Fairy Shrimp (Federally Threatened Species with Critical Habitat, No State 

Status) 

This crustacean inhabits vernal pools, or seasonal wetlands that fill with water during fall and 

winter rains, in California and southwestern Oregon. They are known to occupy a variety of 

vernal pool habitats, from small, clear, sandstone rock pools to large, turbid, alkaline, grassland 

valley floor pools. Vernal pools in which the shrimp has been collected have water temperatures 

ranging from 40° to 73° F, with low to moderate amounts of salinity or total dissolved solids 

(FWS 2005g). The vernal pool fairy shrimp was just recently discovered (1998) in Oregon at 

two distinct vernal pool habitats within the Agate Desert, located in the Rogue/Illinois River 

Valley region of the Klamath Mountains ecoregion in Oregon: on alluvial fan terraces associated 

with Agate-Winlo soils, and in the Table Rocks area on Randcore-Shoat soils underlain by lava 

bedrock (FWS 2005g). In Oregon, the vernal pool fairy shrimp is associated with the same 

vernal pool habitats as the large-flowered meadowfoam and Cook’s lomatium. The Agate Desert 

comprises the northern extent of the vernal pool fairy shrimp’s range (FWS 2005g). 

Critical Habitat

In 2003, FWS designated 7,500 acres of critical habitat for this species within the following 

quadrangles in Jackson County: Shady Cove, Eagle Point, Boswell Mountain, Brownsboro, and 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-90

Sams Valley (FWS 2003a). The primary constituent elements described by FWS (2003a) 

include 1) vernal pools, swales, and other ephemeral wetland features of appropriate sizes and 

depths that typically become inundated during winter rains and hold water for sufficient lengths 

of time necessary for life cycles and 2) the geographic and topographic features that support 

aggregations or systems of hydrologically interconnected pools, swales, and other ephemeral 

wetlands and depressions within a matrix of surrounding uplands that together form 

hydrologically and ecologically functional units called vernal pool complexes. 

When determining areas of critical habitat for the vernal pool fairy shrimp, FWS focused on the 

principal biological or PCEs that are essential to the conservation of the species (FWS 2003c). 

PCEs may include, but are not limited to, nesting grounds, spawning sites, feeding sites, seasonal 

wetland or dryland, water quality or quantity, host species of plant pollinator, geological 

formation, vegetation type, tide, and specific soil types. 

One direct effect of the pipeline on vernal pool fairy shrimp could be disturbance to pools from 

driving or storing equipment or pipes near or on pools or wetlands. These actions could directly 

destroy or disturb vernal pool fairly shrimp cysts during the dry season, or live shrimp during the 

wet season. Possible indirect effects include increased road use (along Avenues F, G, and 

Antelope and Agate Roads) to access the pipeyard storage sites adjacent to the designated critical 

habitat in the area. Increased road use, and the associated dust created, might impact vernal pool 

habitat as dust settles, affecting associated vegetation and vernal pool physical or chemical 

properties (pH, water quality, turbidity, sedimentation, temperature). No changes to pool 

hydrology are expected to occur. 

Impacts and Conservation Measures

Six temporary pipe storage yards for the Pacific Connector pipeline were proposed to be located 

within the Eagle Point and Sams Valley quadrangles, and ten designated CHUs are within 3 

miles of these proposed yards. Two of the proposed yards (Burrill Lumber and Burrill Real 

Estate – Medford Industrial Park) are adjacent to two CHUs, identified as VERFS 3A and 3B 

(FWS 2006m), and the Burrill Lumber yard contains shallow depressions that could support 

hydrophytic species through seasonal ponding. Medford Industrial Park has not been surveyed, 

but appears to contain some low potential vernal pool habitat, with the remainder of the site 

currently used as industrial storage. A seasonal emergent wetland is present in the Oregon 

Opportunities proposed yard, and large-flowered meadowfoam has been previously documented 

within VERFS 3A and 3B, and Cook’s lomatium has been previously documented within VERFS 

3B, and both of these federally-threatened plants are associated with the vernal pool fairy shrimp. 

Neither of these plant species was located in the proposed yards during botanical surveys in 2007. 

Siskiyou BioSurvey conducted botanical surveys within 196 acres on three proposed pipeyard 

storage areas near or in the action area. Three additional storage areas totaling 123 acres were 

not surveyed (permission for access was denied), but are considered as potential sites for 

pipeyard storage activities. Of the 196 surveyed acres, 30 acres were found to be suitable vernal 

pool habitat. Six of the 30 acres are located on one taxlot (Burrill Lumber), with 5 acres of high 

quality and 1 acre of low quality vernal pool habitat that should be protected during pipeyard 

use. Of the 5 acres of suitable vernal pool habitat, approximately 50 percent, or 2.5 acres are 

actual vernal pools. The remaining 24 acres are located on a second taxlot (Elite Cabinet & 

Doors). This site includes disturbed seasonal wetland habitat that has been filled and graded in 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-91

the past (SBS 2008). Of the 24 acres, approximately 50 percent is seasonally saturated or 

seasonal wetlands. Neither of these two sites will be considered further for use, in order to avoid 

potential effects to suitable vernal pool habitat. 

The third proposed storage area that was surveyed (Rogue Aggregates) covered a total of 117 

acres but included no potential vernal pool or seasonal wetland habitat. The site includes a 

mixture of pasture, mixed hardwoods, a gravel pit, and two ephemeral streams. 

The additional 123 acres, considered for pipeyard storage but not surveyed, includes three taxlots 

with a range of vernal pool habitat suitability. Habitat suitability was assessed via aerial photo 

interpretation, prior wetland delineations, and a “drive-by assessment.” One taxlot (Medford 

Industrial Park) covers 92 acres and appears to include some low potential vernal pool habitat - a 

mosaic of seasonal wetlands occurs in the western portion of this site. The remaining portion of 

the site appears to be currently used as industrial storage, and the habitat is disturbed, modified 

industrial land with areas of seasonal saturation. The second unsurveyed area is a 26-acre taxlot 

(Avenue F and 11th Street) and appears to be modified, disturbed unsuitable habitat; the area is 

actively used industrial land, and shows no sign of seasonal saturation. The third unsurveyed 

taxlot (Oregon Opportunities) includes 5 acres that appear to also have been previously 

disturbed; the site is unsuitable habitat and is currently used as an industrial storage area with no 

indication of seasonal saturation. 

Because of the rarity of vernal pool fairy shrimp, any direct or indirect impact resulting in 

species take or habitat loss would be a significant hindrance to its recovery. The proposed use of 

pipe storage yards near vernal pool habitats would occur on lands where past heavy industrial 

uses have occurred. Direct and indirect effects vary on the 3 unsurveyed and 3 surveyed sites 

considered for pipeyard storage. Within the surveyed sites, possible minimal direct effects to 

vernal pool fairy shrimp habitat are expected on the 5 acres of high quality suitable habitat 

(Burrill Lumber). On the second, larger, taxlot (Elite Cabinet & Doors), more extensive direct 

effects to vernal pool fairy shrimp and habitat are possible. On the third site (Rogue 

Aggregates), no suitable habitat is present, and no effects are expected. 

At the first taxlot (Burrill Lumber), the 5 acres of vernal pool habitat occur on the northeast 

corner of the property, away from the proposed pipeyard storage area, and opposite the road 

access. The vernal pool habitat is located approximately 900 feet from the perimeter of the 

industrial use area on a slightly elevated bench formation with a small drainage between the 

habitat and the industrial area. All activities associated with the pipeyard storage would occur in 

the industrial area (an area with historical disturbance) and away from the suitable habitat. There 

are no direct impacts expected to affect the vernal pool habitat from Pacific Connector’s 

pipeyard storage activities in the industrial area (no changes to hydrology, soils, or vegetation, 

and/or alteration of the connection to critical habitat). A possible indirect effect includes 

creation of dust from pipeyard storage activities and the settling of dust into the vernal pool 

habitat, which could adversely affect vernal pool physical or chemical properties (pH, water 

quality, turbidity, sedimentation, temperature). 

At the second taxlot (Elite Cabinet & Doors), the 24-acre site includes a mixture of seasonal 

wetland habitat. While the area is highly disturbed (it was graded at some time in the distant 

past), pools are developing again where native habitat likely previously occurred. The seasonal 

wetlands include 1) shallow depressions with intermittent standing water, 2) seasonal pools, and 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-92

3) an artificial ditch with standing water. Surveys for vernal pool fairy shrimp have not been 

conducted at this site. No direct or indirect effects to vernal pool fairy shrimp should occur at 

this site, as Pacific Connector has eliminated it from further consideration. The third surveyed 

site (Rogue Aggregates) includes no potential vernal pool or seasonal wetland habitat and no 

direct or indirect effects are expected at this site. 

The first unsurveyed site (Medford Industrial Park) appears to include some seasonal wetlands 

and saturated areas as potential habitat. Surveys for vernal pool fairy shrimp have not been 

conducted at this site. While the pools are currently low quality vernal pool fairy shrimp habitat, 

the species is capable of occupying artificial seasonal wetland habitats (Vollmar 2002). 

Therefore, without surveys to confirm non-occupancy, direct effects from pipeyard storage 

activities to vernal pool fairy shrimp and their habitat are possible. Direct effects include 

possible disturbance to pools from driving or storing equipment or pipes near or on pools or 

wetlands. Those actions could directly destroy or disturb vernal pool fairy shrimp cysts (during 

the dry season) or live shrimp (during the wet season). Indirect effects include changes to vernal 

pool physical or chemical properties (pH, water quality, turbidity, sedimentation, temperature). 

An additional indirect effect is the impact of increased road use (along Avenue G) to access this 

site with possible increased generation of fugitive dust. Dust settling into the vernal pool habitat 

could adversely affect associated vegetation and vernal pool physical or chemical properties (pH, 

water quality, turbidity, sedimentation, temperature). The two remaining unsurveyed sites 

(Avenue F and 11th Street and; Oregon Opportunities) both appear to have no potential vernal 

pool or seasonal wetland habitat and no direct or indirect effects are expected at these sites.

Once Pacific Connector has determined which sites in Jackson County would be used for storage 

of pipe for the pipeline, surveys for this species would be conducted per FWS interim survey 

protocol (FWS 1996b) in expected habitat by a certified surveyor (applying either two full wet 

season surveys completed within a 5-year period or two consecutive seasons of one full wet season 

survey and one dry season survey, or visa versa). Surveys have not been conducted in storage 

yards yet to minimize “take” of the species, which could potentially occur if the shrimp are present 

(per protocol – survey and collect specimens). If this species is noted during survey efforts, 

Pacific Connector would implement proper sedimentation control barriers (FWS 2005d) to 

minimize potential impacts to vernal pool fairy shrimp and associated vernal pools would be 

avoided. Based on the potential effects described above, Pacific Connector’s proposed action 

may affect but is not likely to adversely affect vernal pool fairy shrimp. However, we 

recommend that: 

• Pacific Connector should confirm the presence or absence of vernal pool fairy 

shrimp at all pipe storage yards containing potential habitat. For yards that contain 

the species, Pacific Connector should file with the Secretary for the review and 

approval of the Director of OEP, a plan to avoid both direct and indirect impacts to 

vernal pool fairy shrimp habitat, prior to the use of the yards. 

4.6.1.6 Plants 

A botanical analysis area applies to the extent of project-related effects on listed plant species 

within a general 400 foot-wide corridor, 200 feet on each side of the proposed Pacific Connector 

pipeline centerline. That area corresponds to areas that were surveyed by Pacific Connector for 

sensitive and listed plant species in 2007. The survey areas were expanded beyond the 400 foot 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-93

width to include TEWAs, and UCSAs associated with the construction right-of-way. The 

botanical analysis area also includes all temporary extra work areas, rock source and disposal 

sites, and proposed storage yards either on federal or state lands or that have potential for listed 

plant species. Under these criteria, nearly all of the proposed Pacific Connector pipeline route in 

Douglas and Jackson Counties was designated for survey and is included in the botanical 

analysis area. A limited area of private lands in Coos County immediately adjacent to Coos Bay 

was included as potential habitat for western lily. In Klamath County, a large area of private 

land was included for on-the-ground evaluation in order to detect small areas of potential habitat 

for Applegate’s milk-vetch although the analysis area for that species is the same 400 foot-wide 

corridor as for the other species. Since there are areas of potential suitable habitat for federally 

listed plant species along the proposed pipeline route that have not yet been surveyed, and the 

FWS has concerns about salvaging techniques for various species, we recommend that:

• Prior to pipeline construction, Pacific Connector should file with the Secretary, for 

review and approval by the Director of OEP, a Plant Conservation Plan developed 

in consultation with the FWS and ODA, which outlines avoidance and minimization 

measures, propagation, restoration, and other compensatory mitigation measures 

for impacts on federally-listed plant species. 

Applegate’s Milk-vetch (Federally Endangered Species, State Endangered Species) 

Applegate’s milk-vetch was listed as endangered on July 28, 1993 (FWS 1993b). It was 

believed to be extinct until its rediscovery in 1983 and at the time of listing was only known 

from two extant sites. Applegate’s milk-vetch grows only in flat-lying, seasonally moist, 

alkaline soils with underlying clay hardpans. The species’ habitat was historically characterized 

by sparse, native bunch grasses and patches of bare soil, allowing for some seed dispersal by 

wind. Today, dense coverage of the habitat by introduced grasses and weeds means seed 

dispersal is highly localized, with most seedling establishment found adjacent to mature plants 

(FWS 1998b). Flowering usually begins in early June and ends in August. Reproduction takes 

place exclusively by seeds, which are shed soon after flowering. Pollination is thought to be 

mediated by butterflies and polylectic bees, although the plant is also capable of seed production 

through self-fertilization. The plant is endemic to Klamath County, Oregon (FWS 1998b). 

This species has a narrow range, known only in the Lower Klamath Basin (the plain containing 

Lower Klamath Lake), near the City of Klamath Falls in southern Oregon. At the time of the 

recovery plan, there were three known extant populations, all in Klamath County, numbering 

about 12,000 plants (FWS 1998b). Currently, the number of individuals is estimated to be 

33,800 plants on six known sites (FWS 2008c). The largest population is located near the 

Klamath Falls Airport (21,049 plants in 2008). Two sites are known to have been extirpated 

(FWS 2008c). 

Impacts and Conservation Measures

A historical population site (1937; ORNHIC 2006a) is located along the proposed Pacific 

Connector pipeline alignment between MPs 191.7 and 194.1, 2 miles east of Keno, Oregon. This 

area is now dominated by agricultural development, including roads and drainage ditches. Pacific 

Connector would consult with the FWS to determine if habitat within the vicinity of the historical 

site and its surrounding land uses is suitable to reestablish this population within the permanent 

pipeline right-of-way. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-94

Surveys for Applegate’s milk-vetch and its habitat were conducted by Siskiyou BioSurvey, LLC 

(SBS) for Pacific Connector in 2007; no plants were located. A site located within and adjacent 

to the botanical analysis area (the “Collins Tract site”) was first discovered in 1998, and field 

surveys conducted by ORNHIC in 2007 discovered two large sub-populations, each several acres 

in size (Roninger 2008). Expanded survey efforts by FWS and SBS in 2008 discovered several 

sub-populations clusters on the Collins Tract site, including plants within the FERC-filed 

construction right-of-way between MP 195.35 and 196.5 (Roninger 2008; SBS 2008). The entire 

Collins Tract site currently has 10,143 plants that occupy 32.3 acres which occur within a larger 

250-acre area. There are seven sub-population clusters with a total of 1,093 plants that occur 

within the botanical analysis area. In the 1998 Recovery Plan (FWS 1998b), the site was named 

a self-sustaining population. Pacific Connector has revised its proposed route slightly in this 

area to avoid direct impacts to the plants identified in 2008. 

Approximately 1,303 acres of potentially suitable habitat were identified in 2007 along the 

proposed route between MPs 191.8 and 214.6. Plants have also been documented south and 

north of the proposed pipeline alignment within and near the Klamath Wildlife Management 

Area (ORNHIC 2006a). 

Conservation measures have been developed to avoid or minimize impacts to plants identified 

during future surveys prior to pipeline construction. These include: 1) construction activities 

would occur in the fall and winter outside the critical growing, flowering, and seeding periods, 2) 

topsoil would be segregated during construction to maintain a potential seedbank and 

microrhyzoids with which the species root system is associated, 3) wetland mats would be used 

in travel areas in saturated soil areas to minimize soil rutting and soil compaction and protect 

existing plants that may be present, 4) the construction right-of-way would be restored to its 

original contours and reseeded with an appropriate seed mixture recommended by FWS prior to 

the following growing season, and 5) noxious weeds would be controlled by controlled 

application of herbicides or mechanically (see the BA). Additionally, Pacific Connector has 

stated that when it acquires access to the construction right-of-way, it would conduct surveys in 

potential habitat (previously surveyed or unsurveyed) and additional plants located during 

surveys would be avoided, if feasible. Measures of avoidance may include necking down the 

construction right-of-way in that area, excluding a portion of an identified temporary extra work 

space or pipe storage yard, or erecting a protective fence to avoid impact to plants from 

construction debris. If it is determined that avoidance is not possible, participants of the July 24, 

2008 Habitat Quality Subtask Group suggested digging up the plant(s), transplanting, and 

monitoring; however, Applegate’s milk-vetch is difficult to transplant because of the long 

(approximately five-foot) tap root. Also, no or minimal successful out-planting has been 

recorded in greenhouses or other locations. Prior to construction, Pacific Connector would 

collect and bag seeds in June and/or July if plants are identified within the proposed alignment 

and provide seeds to a suggested, repository. If permission is granted by the property owner, 

Pacific Connector would use the collected seed to plant outside of the permanent right-of-way 

after construction. 

Prior to construction, plants adjacent to the construction right-of-way would be protected through 

the appropriate installation of safety and silt fence as determined by Pacific Connector’s EIs. 

Because the route has been relocated in order to avoid populations of Applegate’s milk-vetch and 

suitable habitat found during surveys during summer 2008, no direct effects to this species are 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-95

expected; therefore, no mitigation plan is necessary. There may be impacts to suitable habitat 

with some potential to negatively affect the recovery of the plant, although those effects are 

likely to be insignificant (impact does not reach a level where take occurs) to the point where no 

meaningful measurement, detection, or evaluation of impact would be possible. The Project is 

not likely to adversely affect the Applegate’s milk-vetch.

Gentner’s Fritillary (Federally Endangered Species, State Endangered Species) 

Gentner’s fritillary is found in small, scattered locations in Jackson and Josephine Counties in 

Oregon, with one small population recently discovered in northern California (FWS 2003d). It is 

often found in grassland habitats within, or on the edge of dry, mixed forest types where 

overstory can be dominated by Oregon white oak, madrone, Douglas-fir, and ponderosa pine. It 

occurs at a wide range of elevations, from 1,000 to 5,100 feet, in the rural foothills of the Rogue 

River Valley of Josephine and Jackson Counties (FWS 2003d and SBS 2008). It is usually 

associated with shrubs that provide protection from the wind and sun. 

The distribution of Gentner’s fritillary is characterized by distinct clusters. The species is highly 

localized, with 73 percent of known plants occurring within a 7-mile radius of Jacksonville Cemetery 

in Jacksonville, Oregon. 

According to the species recovery plan (FWS 2003d), Gentner’s fritillary was estimated at 1,696 

flowering individuals in Jackson and Josephine Counties, and just south of the border in 

California. An informal count using information currently available indicates a total number of 

about at least 3,000 mature, flowering plants (SBS 2008). The largest number of plants occur on 

BLM lands, with 1,653 counted in 2005 during annual monitoring of 56 known sites (SBS 2008). 

Inventories on other monitored sites counted 940 plants on private lands in Jacksonville (SBS 

2008) and 424 at Pickett Creek (Thorpe et. al. 2006 in SBS 2008). 

The analysis area crosses the plant’s range at approximate MP 113 through 155, and the 

proposed pipeline crosses an area known as Recovery Unit 3. One of the most vigorous plant 

populations in Recovery Unit 3 is closest to the analysis area, located 1.2 miles southeast of the 

proposed pipeline alignment near Obenchain Mountain and MP 134.4 (Friedman 2006; ORNHIC 

2006a; SBS 2008). Also, pipe storage yards in Jackson County are located more than 3 miles 

away from several documented populations in Sam’s Valley (Friedman 2006). 

The analysis area between MP 132 and MP 138 could be the most likely area to find Gentner’s 

fritillary based on previous surveys and known sites (SBS 2008). During 2008 survey efforts, this 

plant was located in three locales within the analysis area: two sites were documented along an 

existing access road (one plant 50 feet from EAR 128.05 north of the proposed construction rightof-way and four plants 100 feet from EAR 128.05 south of the proposed construction right-ofway), and one site (one plant) was identified on the edge of a proposed TEWA (TEWA 142.07-N). 

Impacts and Conservation Measures

Four recovery units for Gentner’s fritillary have been created to delineate areas that are 

considered necessary for the viability and recovery of this plant. The recovery strategies for the 

units include rehabilitation of habitat, restoration of historical sites, and augmentation of existing 

populations including expansion into nearby suitable habitat. The Pacific Connector pipeline 

would cross through Recovery Unit 3 but would not impact any known or documented 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-96

populations (Friedman 2006; FWS 2003d). To be a population considered to be contributing to 

the recovery of the species, it should contain at least 100 flowering plants and must occur within 

0.5 mile of another population. 

Potential effects to the three known populations of Gentner’s fritillary found in the action area, 

such as trampling, habitat alteration, and introduction of invasive weeds, would be possible as a 

result of the proposed action. However, Pacific Connector has modified its proposed route in 

this location in order to avoid direct impacts to these plants identified during the 2008 surveys. 

Therefore, no mitigation plan is required by the FERC. Prior to construction, any plants adjacent 

to the construction right-of-way would be protected through the appropriate installation of safety 

and silt fence as determined by Pacific Connector’s EIs. Therefore, the Project is not likely to 

adversely affect the Gentner's fritillary. 

Impacts to suitable habitat in the analysis area would be re-evaluated upon completion of the 

second year of surveys. The impacted habitat in the analysis area represents a very small 

percentage of total suitable habitat in the species’ range (SBS 2008). More plants could be 

located within the analysis area during forthcoming surveys; the effect of the Project upon the 

recovery of the species would depend upon the number of plants being impacted and their 

proximity to management areas within Recovery Unit 3 (SBS 2008). 

Western Lily (Federally Endangered Species, State Endangered Species) 

The western lily inhabits 31 small, widely separated populations in sphagnum bogs, coastal scrub 

and prairie, and other poorly drained soils along the coast of southern Oregon and northern 

California. Western lilies have an extremely restricted distribution within 2 miles of the coast 

from Hauser, Coos County, Oregon to Loleta, Humboldt County, California. The plant occurs in 

seven widely separated regions along the coast within 4 miles of the Pacific Ocean. Such 

populations are densely clumped and mostly on isolated wetlands that are fewer than 10 acres 

(FWS 1994c, 1998c). 

In the final rule to classify the western lily as an endangered species, FWS identified agricultural 

conversion and use, urban and rural development on public and private lands, and forest 

encroachment as threats that destruct, modify, or curtail the plant’s habitat or range. The western 

lily occupies a very limited range of habitat near the coasts of Oregon and Northern California. 

Coincidentally, these areas are desirable regions for private land residential development and the 

plant’s habitat during the time of listing was threatened by intense pressure from current and 

future development. FWS noted that overutilization for commercial and recreation uses, disease, 

predation, grazing, and other natural or manmade factors affecting the plant are threats to the 

western lily’s continued existence (FWS 1994c). 

The plant’s range occurs along the pipeline route from approximately MP 7.5 to MP 11.5 (SBS 

2008). The closest known western lily occurrence to the LNG terminal is approximately 5.5 

miles northeast of the project at Hauser Bog (ORNHIC 2005). The western lily has not been 

documented within the botanical analysis area (ORNHIC 2006a). At the time of the Final 

Recovery Plan for the western lily, 139 plants were known to occur in Recovery Area 1, where the 

proposed pipeline would be located (FWS 1998c). Pacific Connector conducted botanical surveys 

for this species during its flowering season (June or July 2007) in early successional bogs and 

coastal scrub on poorly drained soils to determine presence or absence. Four areas of potential 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-97

suitable western lily habitat (i.e., poorly drained bogs with acidic organic soils and within 6 miles 

of the coast below 300 feet elevation), totaling 24.4 acres, have been identified within the revised 

proposed route (draft EIS alternative WC-1A-2A) based on review of aerial photography. These 

areas are located between MP 0.88 and 1.10, 4.16 and 4.22, 8.30 and 8.34, and 10.43 and 11.0. 

On-the-ground reconnaissance would be necessary to determine whether these areas are suitable 

western lily habitat. Review of NRCS soil survey data indicates that the potential suitable 

habitat areas along the proposed pipeline route do not have the combination of soil 

characteristics that support the known western lily populations; however, these potential suitable 

habitat areas would be addressed in the contingency plan developed by Pacific Connector in 

cooperation with the FWS. Therefore, given the potential for the western lily to be located on 

the unsurveyed proposed route, and the corresponding Plant Conservation Plan, we believe that 

the western lily may be affected but is not likely to be adversely affected. 

Large-Flowered Meadowfoam (Federally Endangered Species, State Endangered Species) 

The large-flowered meadowfoam is an annual herb endemic to the Agate Desert area in southern 

Oregon. It grows on the wetter, inner edges of vernal pools mostly in the Rogue River Valley. 

The plant is capable of self-fertilization and self-pollination. Flowering occurs between March 

and May, with flowers producing nutlets. These nutlets may be dispersed by water, normally for 

only short distances. Thus, it is likely that they do not disperse beyond their pool or swale of 

origin. Large-flowered meadowfoam populations are currently known to occur at 20 sites in the 

area between Medford and Shady Grove (FWS 2006i). In the Rogue River Valley, largeflowered meadowfoam is found in the same vernal pool habitats as Cook’s lomatium and the 

vernal pool fairy shrimp. 

A major factor in FWS listing the large-flowered meadowfoam was the present or threatened 

destruction, modification, or curtailment of its habitat and range. Due to recent rapid human 

population increases in the region, the primary threats to the plant’s habitat and range in the 

Agate Desert (Jackson County, Oregon) are industrial, commercial, and residential development 

and their residual road and utility construction and maintenance. These important residual 

impacts include mowing, herbicide use, firebreak construction, and hydrologic alteration (mostly 

for agriculture). 

Impacts and Conservation Measures

Critical habitat has not been designated for this species, but much of the large-flowered 

meadowfoam habitat and populations overlap with critical habitat designated for the vernal pool 

fairy shrimp (FWS 2006m). Six patches of large-flowered meadowfoam have been identified 

within 100 to 900 feet from one proposed pipe storage yard (Burrill Real Estate-Medford 

Industrial Park). Additional patches have been identified over 0.25 mile from the Burrill Real 

Estate-Medford Industrial Park pipe storage yard and 0.25 mile from two other pipe storage 

yards (Oregon Opportunities and Ave C & 7th – Elite Cabinets & Doors) (Friedman 2006). 

Pacific Connector conducted botanical surveys for this species during the flowering season 

(April 2007) in expected habitat at three of the six pipe storage yards proposed for Jackson 

County. Permission to access the other three storage yards was denied. Thirty acres were 

surveyed for this species, and four small patches were located in vernal pool habitat located in 

approximately 3 acres of suitable habitat in the northeast corner of a proposed pipe storage yard 

(Burrill Lumber Yard). The majority (83 percent) of this population is out of the area that would 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-98

be used for pipe storage and within areas not suitable for use (i.e., undulating topography of 

vernal pool habitat and no access roads to this section). Pacific Connector is no longer 

considering the Burrill Lumber Yard for project use. Based on indirect surveying techniques, 

two of the unsurveyed yards are expected to be unsuitable habitat; the third yard may have some 

low quality habitat. See the Vernal Pool Fairy Shrimp section, above, for more details about 

each yard considered. We have concluded that the Pacific Connector Project would have no 

effect on the large-flowered meadowfoam based on the fact that no suitable habitat would be 

affected. 

Cook’s Lomatium (Federally Endangered Species, State Endangered Species) 

Cook’s lomatium is a small perennial in the parsley family. Its range is on seasonally wet soils 

limited to two areas: 1) along vernal pools in the Agate Desert area of the Rogue River Valley, 

Jackson County, and 2) in alluvial floodplains within the Illinois River Valley area near Cave 

Junction, Josephine County. The Jackson County populations occur in vernal pool habitats 

within a 20,510 acre landform known as the Agate Desert. The plant flowers from late March to 

May and is pollinated entirely by insects. In the Rogue River Valley, Cook’s lomatium is found 

in the same vernal pool habitats as the large-flowered meadowfoam and the vernal pool fairy 

shrimp. 

Impacts and Conservation Measures

Six proposed pipe storage yards occur within the Agate Desert and its associated vernal pools 

and could potentially affect this species. Several patches of Cook’s lomatium have been 

documented in Denman Wildlife Management Area and Agate Desert Preserve, 0.25 mile and 

0.5 mile south/southwest of two proposed pipe storage yards (Oregon Opportunities and Ave C 

& 7th – Elite Cabinets & Doors), respectively (Freidman 2006). 

Pacific Connector conducted botanical surveys for this species in expected habitat at three of the 

pipe storage yards proposed for Jackson County where access was permitted and in potentially 

suitable habitat in Douglas County. Approximately 280 acres were surveyed, of which 48 acres 

were considered suitable, but no plants were documented. If this species is noted during 

additional survey efforts, results would be provided in an addendum report and the appropriate 

agencies would be contacted for mitigation and conservation measures to be implemented. Such 

measures could include Pacific Connector preventing sedimentation and preventing spread of 

competing exotic species such as Centaurea solstitialis (yellow starthistle), Taeniatherum caputmedusae, Poa bulbosa, and Erodium cicutarium (FWS 2006m). Additionally, Pacific Connector 

would not use portions of pipe storage yards if the species is identified. We have concluded that 

the Pacific Connector Project is not likely to adversely affect the Cook’s lomatium. 

Kincaid’s Lupine (Federally Endangered Species, State Endangered Species) 

Kincaid’s lupine is a long-lived perennial herb inhabiting native prairies and foothills (FWS 

2000c). In Douglas County, Oregon, it occupies sites that are more shaded, occurring in areas 

with tree (i.e., Douglas-fir, Pacific madrone, ponderosa pine, incense cedar) and shrub canopy 

cover of 50 to 80 percent (FWS 2006j). The plant was historically found from Lewis County, 

Washington in the north, south to the foothills of Douglas County, Oregon; however, most of the 

known and historical populations are found in Oregon’s Willamette Valley (FWS 2006j). 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-99

In Douglas County, Kincaid’s lupine appears to tolerate more shaded conditions, where it occurs 

at sites with canopy cover of 50 to 80 percent. In contrast to the open prairie habitats of the more 

northerly populations, in Douglas County sites, tree and shrub species dominate the sites, 

including Douglas-fir, California black oak, Pacific madrone, Ponderosa pine, incense cedar, 

hairy manzanita, and poison oak. 

Flowering typically occurs from April through June. Pollinators include small native 

bumblebees, solitary bees, and occasionally European honey bees. Insect pollination appears to 

be critical for successful seed production. Seeds are dispersed from fruits that open explosively 

upon drying (FWS 2006j). Kincaid’s lupine is also a host plant for the endangered Fender’s blue 

butterfly (SBS 2007). 

Human alteration of the plant’s native prairie in Oregon’s Willamette Valley has destroyed over 

99 percent of its habitat (FWS 2000c). At the time of listing there were 88 remnants of the 

native prairie habitat, with Kincaid’s lupine occurring at 54 sites. Eighty percent of this 

remaining prairie habitat is rapidly disappearing because of agricultural practices, development 

activities, forestry practices, grazing, roadside maintenance, and commercial Christmas tree 

farming (FWS 2000c). The remaining Kincaid’s lupine populations in prairie habitat are 

essentially relegated to small, isolated patches of habitat. Habitat loss is likely to continue as 

private lands are developed. 

In the Willamette Valley, Kincaid’s lupine is currently found at about 57 sites, comprising about 

395 acres of total coverage (FWS 2006j). Surveys for this plant were conducted in potentially 

suitable habitat in 2007 and 2008. Three populations were located in Douglas County on private 

lands near or in the proposed Project area, at MPs 57.9, 59.6, and 96.7 (SBS 2007). Monitoring 

the size of populations is challenging because the plant’s pattern of vegetative growth makes it 

difficult to distinguish individual plants (FWS 2006j). 

Critical Habitat

The PCEs of Kincaid’s lupine critical habitat are those that provide: (1) early seral upland prairie 

or oak savanna habitat, with a mosaic of low growing grasses, forbs, and spaces to establish 

seedlings or new vegetative growth under an absence of dense canopy vegetation and 

undisturbed subsoils; and (2) the presence of insect outcrossing pollinators, with unrestricted 

movement between existing population patches (FWS 2006k). 

Management activities that could adversely modify critical habitat are those that alter PCEs to an 

extent that the conservation value for Kincaid’s lupine is appreciably reduced (FWS 2006k). 

These activities that may affect critical habitat include, but are not limited to: (1) removal or 

destruction of prairie habitat supporting Kincaid’s lupine populations by grading, leveling, 

plowing, mowing, burning, motorized equipment operation, or herbicide spraying; and (2) 

actions that further isolate or reduce genetic interchange among populations within a unit or 

between subunits, including road construction and expansion, housing and building 

development, and infrastructure construction (FWS 2006k). The proposed Pacific Connector 

pipeline would not affect any of the PCEs because no critical habitat would be affected. 

Conservation Agreement Goals and Impacts

A Conservation Agreement was signed with three timber companies in Douglas County 

including Lone Rock Timber Management Company, Roseburg, and Seneca Jones Timber 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-100

Company. This voluntary agreement for Kincaid’s Lupine in Douglas County (2006) includes 

reporting guidelines and an agreement for road maintenance and minimizing disturbance along 

roads. The objective of the voluntary agreement is “to promote functioning meta-populations” 

and there is some language about coordinating propagation activities for establishing new sites 

and extending known populations, so it is likely that the signatories would be interested in 

managing populations. All three of the signatories own land that is crossed by the proposed 

pipeline; Lone Rock owns two parcels, Seneca Jones owns nine parcels and Roseburg owns ten 

parcels. Only Roseburg granted permission for Pacific Connector to survey the proposed 

pipeline route on its property. In March 2008, a management plan for Kincaid’s lupine in 

Douglas County was developed between the Roseburg BLM District, the Umpqua National 

Forest, and the FWS, addressing the populations and habitat of Kincaid’s lupine on BLM and 

NFS lands in Douglas County (BLM et al. 2008). 

The Pacific Connector pipeline route has been relocated to avoid all of the plants identified at 

MP 57.9. The population at MP 57.9 totals 2,500 m2 within a 4-acre area and the population at 

MP 59.6 is approximately 500 m2 within a one-half acre area. Total cover at these populations is 

high due to the vigor and age of these plants and may even approach 60 m2 in the MP 57.9 

population. These sites are 3 miles from a weak known site near Ten Mile but far from other 

known sites so are unlikely to be part of an eventual meta-population for meeting conservation 

agreement goals. They do, however, contribute significantly to the “additional” populations 

goal. These sites are unique for Douglas County in that they occupy Valley-Floor 

pasture/meadow habitat similar to Willamette Valley populations but very different from the 

other Douglas County populations. They therefore may be preserving high value genetic 

information. The population at MP 59.6 is outside of the construction right-of-way, and project 

activities would not impact these plants. At its closest point to the project, this population lies 30 

feet from an access road. Pacific Connector’s EIs would determine if it is necessary to install 

protection measures for this population, such as silt or safety fence on the edge of the road during 

construction. 

The proposed construction footprint for the Pacific Connector pipeline would involve combined 

direct effects to 13 percent of the MP 95.6 population. This population is an important element 

in the recognized Stouts Creek-Callahan Ridge meta-population within. It is 2.5 miles eastnortheast of the large known population cluster on BLM and Roseburg lands at Stouts Creek, 

approximately 3 miles west-northwest from the population on USFS and private land at Callahan 

Ridge, and approximately 3.7 miles from the population at Callahan Meadows. It occurs in a 

central location between these populations thus forming an important genetic link and increasing 

the possibility of developing a successful South Umpqua “meta-population” per recovery goals. 

The population consists of 28 patches within an area of 20 acres, occurring in transitory and 

natural openings in 45-year old forest. The total cumulative area of the patches is approximately 

2,300 m2

 with the largest patch 380 m2. An estimate for actual “cover” for this population (leaf 

cover only) is 23 m2

. This population could be considered therefore to be quite significant in 

meeting the goals of the South Umpqua meta-population. The proposed route would impact 254 

plants in the construction right-of-way and 80 plants within TEWA 96.66-W. Further surveys on 

adjacent lands could detect more populations in this general area. Because the proposed route at 

MP 95.6 is located on a narrow ridgeline, there are no feasible routing alternatives to realign the 

pipeline and to completely avoid this documented population. However, to minimize impacts to 

this population, Pacific Connector has proposed to modify the construction right-of-way and 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-101

TEWA 96.66-W, avoiding impacts to 61 plants within three subpopulations and partially 

avoiding plants within a fourth subpopulation by narrowing the construction right-of-way (see 

map 4.6.6-3, draft EIS-revised route). At least 157 plants are still expected to be directly 

impacted with these revisions. A number of the identified subpopulations (totaling 58 plants) 

occur along the identified access roads in this area, including EAR 96.29 and EAR 96.67. 

Project maintenance activities during construction associated with the existing roads, including 

filling pot-holes, blading/grading, and brushing, may directly impact the documented Kincaid’s 

lupine plants. However, Pacific Connector’s EIs would ensure that potential impacts to the 

lupine plants along the proposed access roads are avoided or minimized by flagging and fencing 

known populations and monitoring maintenance activities during construction. 

Impacts and Conservation Measures

Proposed construction and operation of the Pacific Connector pipeline would impact one 

population of Kincaid’s lupine. The presence of Kincaid’s lupine in the Pacific Connector 

pipeline construction right-of-way would result in a known take of at least 157 plants. 

Approximately 522 acres of land within the construction right-of-way were unsurveyed due to 

denied access by landowners. On those lands, an estimated 111 additional plants could be 

removed by construction (based on known densities of Kincaid’s lupine within known occupied 

habitats). In the draft EIS we recommended that Pacific Connector develop a mitigation plan 

that would avoid or minimize adverse impacts to known locations of Kincaid’s lupine. Pacific 

Connector provided such a plan in Attachment M to its December 4, 2008 comments on the draft 

EIS. Mitigation for proposed damage to these plants would include: 

1) Construction methods ― When feasible, EIs would ensure protection of Kincaid’s lupine 

plants adjacent to project activities. Known plants would be protected by safety and silt 

fences. Equipment would be inspected and cleaned of potential noxious weeds prior to 

working within known Kincaid’s lupine habitat. Topsoil salvaging would take place 

within affected population, and salvaged topsoil would be returned to its original location 

during restoration. 

2) Plant salvage ― If landowner approval is obtained, a qualified botanist would attempt to 

salvage Kincaid’s lupine plants in the construction right-of-way that cannot be avoided 

and attempt to transplant them immediately off-site in suitable habitat. Transplanting this 

species is expected to be difficult; therefore, the feasibility of this mitigation effort would 

be determined during the salvage effort by Pacific Connector’s environmental staff and 

the salvaging botanist. 

3) Seed collection ― Prior to construction, seeds would be collected from local populations 

and stored for later restoration efforts. Seeds from other sources, such as Willamette 

Valley populations, may lack locally adapted genotypes required for successful 

establishment and growth in Douglas County. Future propagation efforts for the taxon as a 

whole would likely depend on availability of seed sources from all extant populations. 

These Douglas County populations may host unique genetic resources that could contribute 

to the genetic viability of restored population. With so little known about genetics in this 

taxon, it is important to maintain all extant populations. 

4) Site restoration/habitat enhancement ― After trench backfilling and topsoil replacement, 

all disturbed areas where Kincaid’s lupine populations are known to occur would be 

reseeded with native grasses and forbs gathered locally. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-102

5) Monitoring ― Success of revegetation efforts would be monitored near Kincaid’s lupine 

populations annually for 3 years after construction. Plant surveys would include 

monitoring for noxious weeds, which would be controlled if encountered, using methods 

specific to protecting existing and dormant Kincaid’s lupine plants. 

Due to the fact that individual plants would be removed, we have concluded that the Pacific 

Connector pipeline is likely to adversely affect Kincaid’s lupine. 

Rough Popcornflower (Federally Endangered Species, State Endangered Species) 

The rough popcornflower is found in seasonal wet meadows or wet prairies in poorly drained clay or 

silty clay loam soils at elevations ranging from 100 to 900 feet. It generally blooms June through 

July. Rough popcornflower grows in scattered groups and reproduces largely by insect-aided crosspollination and partially by self-pollination (FWS 2008d). The herbaceous plant occurs in the 

vicinity of Sutherlin and Yoncalla, mostly on private lands in the Umpqua River drainage (FWS 

2003e). 

There are 15 known naturally-occurring sites of the rough popcornflower within its limited range, as 

found in the Oregon Natural Heritage Program database. In addition to the naturally occurring 

populations, rough popcornflower transplants have been introduced at two sites on the BLM North 

Bank Habitat Management Area (FWS 2003e). Five population patches are considered protected, 

two of which are on State of Oregon lands managed by The Nature Conservancy as part of the 

Popcorn Swale Preserve (FWS 2003e). 

Pacific Connector conducted botanical surveys for the rough popcornflower between MP 48 to 89 in 

the Umpqua Foothills and Valley region between mid-May and mid-June. Of the area surveyed, 4 

acres were considered suitable for this species, although no plants were documented. SBS identified 

and surveyed 43 acres of potentially suitable habitat for rough popcornflower between MPs 50.2 and 

60.0 in the Olalla area in 2007; no plants were documented. As this plant has only been documented 

more than 20 miles north of the pipeline area, in northern Douglas County; it was not documented 

during botanical surveys; and very little potential habitat occurs within the Pacific Connector pipeline 

area (i.e., wet meadows and vernal pools in Douglas County). Therefore, construction or operation 

of the proposed Pacific Connector pipeline would have no effect on rough popcornflower. 

4.6.2 State-Listed Threatened or Endangered Species 

In addition to species that are federally threatened or endangered, the State of Oregon has a 

designation as threatened or endangered for 13 species that could potentially occur in the Project area 

(table 4.6.2-1). 

TABLE 4.6.2-1. 

State-Listed Species Potentially Occurring in the Proposed Project Area

Species FWS Status ODFW Status 

Portion of the Project Area Where 

Species Potentially Occur 

Mammals 

Kit fox 

Vulpes macrotis 

None Threatened Pacific Connector pipeline 

Wolverine 

Gulo gulo luteus 

Species of Concern Threatened Pacific Connector pipeline 

Gray whale None Endangered LNG carrier route 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-103

TABLE 4.6.2-1. 

State-Listed Species Potentially Occurring in the Proposed Project Area

Species FWS Status ODFW Status 

Portion of the Project Area Where 

Species Potentially Occur 

Eschrichtius robustus

Birds 

Bald eagle 

Haliaetus leucocephalus 

None Threatened LNG terminal 

Pacific Connector pipeline 

Plants 

Pink sand verbena 

Abronia umbellata ssp. Breviflora

Species of Concern Endangered LNG carrier route 

Point Reyes bird’s-beak 

Cordylanthus maritimus ssp. 

palustris

Species of Concern Endangered LNG carrier route 

LNG terminal 

Pacific Connector pipeline 

Wayside aster 

Eucephalis vialis (Aster vialis)

Species of Concern Threatened Pacific Connector pipeline 

Peck’s milk-vetch 

Astragalus peckii 

None Threatened Pacific Connector pipeline 

Pumice grape-fern 

Botrychium pumicola 

None Threatened Pacific Connector pipeline 

Cox’s mariposa-lily 

Calochortus coxii 

Species of Concern Endangered Pacific Connector pipeline 

Umpqua mariposa-lily 

Calochortus umpquaensis 

Species of Concern Endangered Pacific Connector pipeline 

Dwarf wooly meadowfoam 

Limnanthes floccose ssp. pumila 

Species of Concern Threatened Pacific Connector pipeline 

Silvery phacelia 

Phacelia argentea

Species of Concern Threatened LNG terminal 

Wolf’s evening primrose 

Oenothera wolfii

Species of Concern Threatened LNG terminal 

Pacific Connector pipeline 

4.6.2.1 Mammals 

Kit Fox (No ESA Status, State Threatened Species) 

The kit fox reaches its northern limit in southern Oregon. In Oregon, it is found in arid desert 

valleys dominated by halophytic plants like greasewood and shadscale, intermingled with 

sagebrush. Kit foxes are opportunistic nocturnal carnivores, feeding on rodents (especially 

kangaroo rats), rabbits, birds, reptiles and insects. Home ranges for this species are one to two 

square miles. Preferring easily worked soil, they dig shallow dens with several entrances. 

During the breeding season, they often use more than one den (Csuti et al. 2001). Although the 

proposed Project may affect suitable kit fox habitat, the expected distribution of this species does 

not include the Project area. Because kit foxes have not been recently observed within the 

Project area (Verts and Carraway 1998), the Project is not expected to affect this species. 

Wolverine (Federal Species of Concern, State Threatened Species) 

In western North America, wolverines extend through California’s Sierra Nevada Mountains and 

the Rocky Mountains. This rare species may be found in open forests at higher elevations and in 

alpine areas. They avoid, quickly cross, or skirt open areas. Their diet consists of small to 

medium sized rodents, marmots, hares and carrion. Additionally, they eat birds and their eggs, 

insects, fish, roots and berries. These carnivores are solitary animals with large home ranges (up 

to hundreds of square miles). Wolverines are active at any time of day or night. Denning occurs 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-104

in rock crevices, caves, or hollow logs (Csuti et al. 2001). Due to their large home range and 

habitat preference, wolverines may be present in the Project area, but they are not expected. 

There have been no verified historical or recent records of the species occurring in the Project 

vicinity (Verts and Carraway 1998), therefore the Project is not expected to affect this species. 

Gray Whale (No ESA Status, State Endangered Species) 

The gray whale is not listed under the Endangered Species Act, but does have federal protection 

under the MMPA. The gray whale is a large baleen whale that is distributed in the northern 

Pacific Ocean in western and eastern stocks. The eastern Pacific stock feeds in the summer in 

Chukchi Sea, western Beaufort, and the northern Bering Sea. They migrate from November 

through early February south to lagoons on the Pacific coast of central and southern Baja 

California. Northward migration occurs after the calving and breeding season, from early 

February to May. These whales have the longest known migration of any mammal. Gray 

whales feed on infaunal benthic species that are buried in sediments (Maser et al. 1981). 

According to OPDR (2007), gray whales are the most predominant whales seen along the 

Oregon coast. They migrate twice a year, winter and spring as stated above, and about 200 of 

them feed along the coast during the summer months. Gray whales may be encountered in any 

of the three zones of the LNG carrier transit route during their southern migration from 

November through early February or from early February to May during the northern migration. 

Measures that Jordan Cove would implement to avoid or minimize impacts on federally listed 

whales as discussed in section 4.6.2.1 would also serve to avoid or minimize impact on the gray 

whale. Gray whales have been known to be struck by ships, and based on data in Pacific waters 

between 1999 and 2003, they are struck at a rate of 1.2 whales annually (Angliss and Outlaw 

2007). The 32,000 ship-miles per year contributed by proposed LNG carriers would amount to a 

1.6 percent increase in shipping in coastal Oregon and Washington over the 1998-1999 

estimates. That increase would be less if based on current vessel traffic volumes. That increase 

could cause an increase in the probability of whales being struck by ships. 

4.6.2.2 Birds 

Bald Eagle (No ESA Status, State Threatened Species) 

The recently delisted bald eagle remains protected under the Bald and Golden Eagle Protection 

Act (16 U.S.C. 668-668d) that prohibits “take” of bald and golden eagles, which includes 

disturbances. The alternative land route (WC-1A) has two known bald eagle nests within a 

quarter mile of the proposed project on private lands: Echo Valley and Mettman Ridge. The 

Mettman Ridge pair has alternate nest sites 930 and 1,325 feet from the WC-1A centerline. The 

Echo Valley nest is 590 feet from the WC-1A centerline. One bald eagle nesting site, Spencer 

Creek, is located within 0.6 mile of the proposed Pacific Connector pipeline alignment. Another 

eagle nesting site (Buck Lake) is located approximately 1 mile from the Pacific Connector pipeline at 

MP 171.67. Three nests are on private lands (Echo Valley, Spencer Creek, and Mettman Ridge) and 

one is located on the Fremont-Winema National Forest (Buck Lake) (Isaacs and Anthony 2007). 

The Echo Valley nest site was recently discovered in 2004 (Isaacs and Anthony 2004), and it has 

produced nestlings in 2004, 2005, and 2006 (Isaacs and Anthony 2007). As of 2006, the Spencer 

Creek nest site has been active and young have been observed. Buck Lake nest site location is well 

established (10 years) and as of 2006, has been active with evidence of eggs within the last two years, 

and one young observed in 2006 (Isaacs and Anthony 2007). Eleven other bald eagle sites are 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-105

located within 3 miles of the Project area. Another potential nest was identified on ODOT land near 

MP 69, just east of the South Umpqua River crossing (Chris Foster, personal communication, 2008). 

This potential nest occurs approximately 300 feet from the right-of-way centerline and on the edge of 

a TEWA. The TEWA has been minimized to avoid clearing of the nest tree, but disturbance would 

still be occurring in the area. According to the National Bald Eagle Management Guidelines, 

activities that could disturb nesting eagles must be conducted 660 feet away from a nest if there is a 

clear line of sight, and 330 feet from a nest if it would not be visible (USFWS 2007o). In order to 

comply with the Bald Eagle Management Guidelines, we recommend that;

• Pacific Connector should survey the bald eagle nest near MP 69 prior to each year 

when construction is scheduled, and if the nest is active, no construction activities 

should be conducted during the breeding season, January 1 to August 31, within 

0.25 mile of the nest. A report on the survey results should be filed with the 

Secretary, for review by the Director of OEP, before any construction would be 

allowed between MPs 68 and 70. 

Impacts and Conservation Measures

Bald eagles are sensitive to human disturbances during nesting periods (Fraser et al. 1985; 

Johnson 1990; Grubb et al. 1992) and at other times of the year (Stalmaster and Newman 1978; 

Knight and Knight 1984; McGarigal et al. 1991). 

Adherence to FWS and the State of Oregon Management Guidelines would minimize 

disturbance to nesting bald eagles. Nest data were obtained from Frank Isaacs (Issacs and 

Anthony 2007), a biologist with Oregon Cooperative Fish and Wildlife Research Unit, 

Department of Fisheries and Wildlife, Oregon State University to determine nest status and 

locations of new nests within the Project area. 

If the potential nest site at MP 69, at the South Umpqua River crossing proves to be active in the 

breeding months it could be disturbed by Project activities. It would not adhere to FWS and 

State of Oregon Management Guidelines as it occurs within approximately 300 feet of the 

proposed pipeline centerline and on the edge of a TEWA in a relatively open area. The South 

Umpqua River would be crossed using a diverted open cut during the in-water work period (July 

1 through August 31) to avoid ESA-listed fish species. The crossing is estimated to take 

approximately 4 weeks during this period, which falls toward the end of the breeding season for 

bald eagles; however, eagles could still be tending chicks in the nest. 

National Bald Eagle Management Guidelines recommends that blasting within one-half mile of 

active nests be avoided during the breeding season (January 1 to August 31). Portions of the 

proposed pipeline route where blasting may be required are within 1 mile of two active and one 

inactive bald eagle nests. Pacific Connector would survey recently active nest sites documented 

by Isaacs within 1 mile of the specific blasting sites prior to pipeline construction to determine if 

these nests are active. Based on those surveys, if the site(s) are determined to be active bald 

eagle nests, Pacific Connector would implement a site management plan describing specific 

construction methods and/or mitigation based on agency consultation and recommendations. 

Helicopter use should also be avoided within 1,000 feet of active nests during the breeding 

season. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-106

Based on available data, there are no active bald eagle roosting sites known within the Project 

area; the nest site at MP 69 remains to be investigated further. If communal roosts are located 

within the Pacific Connector pipeline area, determined either from additional data or during 

biological surveys, Pacific Connector would minimize disturbance when operating within or near 

a bald eagle roosting site by adhering to the following protection measures (OAR 629-665-

0230), if feasible: 1) retain active roost tree(s), 2) retain staging trees, 3) retain a forested buffer 

not less than 300 feet around the outermost active roost tree, and 4) during the critical period of 

use, avoid disturbance within 0.25 mile of active roost trees unless eagles have line-of-sight 

vision from these trees, then avoid disturbance within 0.5 mile of roost trees. The critical period 

within the Klamath Basin is from October 31 through March 31; all other areas have a seasonal 

constraint from November 15 through March 15. Timing of construction should eliminate 

disturbance to winter roosting bald eagles within the Pacific Connector pipeline area. 

Construction within the Klamath Basin (MP 188 to 230) is proposed to begin late in the year and 

may impact winter roosting bald eagles if present near the pipeline. 

Pacific Connector operation and maintenance activities, including aerial inspection of the 

pipeline would be conducted only within the permanent easement, so activities associated with 

operation and maintenance should not affect nesting bald eagles. 

4.6.2.3 Plants 

Pink Sand Verbena (Federal Species of Concern, State Endangered Species) 

Pink sand verbena only inhabits the littoral sandy beach areas and unstablized sand dunes of the 

coastal strip (ORNHIC 2006c). Of the twelve reported occurrences in Oregon, only two have 

more than 50 plants; many of the populations consist of only one plant and would probably not 

persist. The pink sand verbena’s present range is along miles of coastal beach and foredune, 

predominantly from Cape Blanco (Curry County), southern Oregon to Point Reyes National 

Seashore in Marin County, California. Additionally, they sporadically occur along Oregon’s 

northern and central coast. No pink sand verbena plants have been reported within the Pacific 

Connector pipeline area (ORNHIC 2006a), although Jordan Cove identified suitable habitat for the 

plant along the eastern portion of the proposed LNG terminal site in areas of actively moving 

dunes and European beachgrass. However, surveys for the plant did not locate any individuals. 

The Pacific Connector pipeline would not affect coastal sand dune habitat; therefore, botanical 

surveys for this species were not conducted for the pipeline and no incidental documentations of 

this species occurred. The Project is not expected to affect this species. 

Point Reyes Bird’s-beak (Federal Species of Concern, State Endangered Species) 

Point Reyes bird’s-beak inhabits salt marshes along the coast, sometimes growing just above 

tidewater in wet areas. Its habitat requirements are specific: approximately 7.5 to 8.5 feet (2.28 to 

2.59 meters) above MLLW, soil salinity of 34 to 55 ppt, sandy substrate covered by 1 to 10 cm (0.39 

to 3.93 inches) organic silt, and less than 30 percent bare soil in summer. This plant flowers from 

June to October. Point Reyes bird’s-beak is found in Coos County. 

Several occurrences of Point Reyes bird’s-beak are located in the vicinity of proposed facilities, 

and there is suitable habitat along the pipeline route (ORNHIC 2005). Populations with 1,000 to 

10,000 plants are located along the margins of Coos Bay and on sand salt marshes near the edge 

of high water marks (ORNHIC 2006a). The closest documented occurrence to the Jordan Cove 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-107

LNG terminal site is located on the western edge of geographic Jordan Cove. The population 

extends approximately 150 feet in length, varies from 30 to 50 feet in width, and is located 

within a portion of saltmarsh with frequent tidal influence. Another population of about 1,000 

Point Reyes bird’s-beak plants was located on a spoils island crossed that is owned by the Port of 

Coos Bay. Pacific Connector has shifted is proposed pipeline alignment to avoid all known 

occurrences of the Point Reyes bird’s-beak by adopting the modified WC-1A-2A route. Plants 

adjacent to the construction right-of-way would be protected through the appropriate installation 

of safety and silt fence as determined by Pacific Connector’s EIs. 

Wayside Aster (Federal Species of Concern, State Threatened Species) 

The wayside aster is a federal Species of Concern, is listed as threatened by the ODFW, and is a 

BLM and USFS Sensitive species. This species' range is limited to central, southern, and 

western Oregon and the northern California state line (ORNHIC 2006c). About 100 populations 

are known, totaling fewer than 9,000 individuals. Threats to this species include fire 

suppression, logging activities, exotic weed invasion, habitat fragmentation/inbreeding 

depression, browsing, roadside maintenance, and recreation (Wogen 1998). Many populations 

are along roadsides and in areas of residential development; none are protected. Wayside aster 

occurs in areas of natural and man-made disturbance, edges and openings in woodlands and 

forests, in second and old-growth, and in shaded roadsides. Most populations are centered in the 

southern Willamette Valley of Lane County or in southern Jackson and Josephine Counties. A 

few populations exist in the adjacent counties of California (ORNHIC 2006c). 

An historical site (1938) is located along the proposed Pacific Connector pipeline alignment near 

MP 50; relocation attempts at this site in 1980 were unsuccessful. The Pacific Connector 

pipeline would be located adjacent to a site where a single plant was locate in 1998 within the 

Roseburg BLM district, and at the time this plant’s viability was documented as poor. Larger 

populations have been identified about 1.3 miles northeast of MP 77.5 and about 2.1 miles 

southwest of MP 77.5 of the proposed Pacific Connector pipeline (ORNHIC 2006a). 

Surveys conducted by Pacific Connector for the wayside aster in 2007 did not document this 

plant’s presence. Based on the absence of this species, construction and operation of the Pacific 

Connector pipeline within those areas surveyed would not be expected to impact the wayside 

aster. Surveys for approximately 10 percent of proposed existing roads to be used to access the 

pipeline have not been conducted, and it is possible that suitable habitat and/or this plant could 

occur along the remaining roads. The wayside aster has been located during surveys along 

access roads on Roseburg BLM District lands. See final botanical report. Pacific Connector 

would consult with the Roseburg BLM District to determine appropriate avoidance and/or 

minimization measures. 

Peck’s Milk-vetch (Federal Species of Concern, State Threatened Species) 

Most populations of Peck’s milk-vetch are centered in three separate areas: one in north-central 

Deschutes County, another in north-central Klamath County, and the third in south-central 

Klamath County (ORNHIC 2006e). These populations total about 300,000 individuals. The 

plant occurs in very dry sites, on loose, sandy soil or pumice. Peck’s milk-vetch is often found 

in or along dry water courses, in sagebrush or rabbitbrush openings in lodgepole pine forests (in 

the south) or in western Juniper woodlands (in the north), and occasionally on barren flats. 

Peck’s milk-vetch has not been documented within the vicinity of the Pacific Connector pipeline 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-108

area (ORNHIC 2006a). No suitable habitat for Peck’s milk-vetch occurs within the areas 

crossed by the proposed Pacific Connector pipeline; therefore, Pacific Connector has not 

conducted botanical surveys for this species. It is not expected that this species or its habitat 

would be impacted by construction and operation of the Pacific Connector pipeline. 

Pumice Grape-Fern (No ESA Status, State Threatened Species) 

This species is one of the rarest grape-ferns, and in Oregon is found only within the Crater Lake 

area and Paulina Mountains in Deschutes and Klamath Counties. Most known populations are 

found in fine pumice gravel (without humus) at elevations above 7,800 feet (2,400 meters). It 

has also been located within frost pockets in lodgepole pine forests with bitterbrush, in areas with 

deep, sterile pumice. In Oregon, pumice grape-fern is typically associated with Brewer’s sedge 

and buckwheat species (Eastman 1990; ORNHIC 2006c). The Pacific Connector pipeline would 

not be in the vicinity of the known sites for this plant, and no suitable habitat for this plant occurs 

within the areas crossed by the proposed Pacific Connector pipeline; therefore, Pacific Connector 

has not conducted botanical surveys for this species. It is not expected that this species or its 

habitat would be impacted by construction and operation of the Pacific Connector pipeline. 

Cox’s Mariposa Lily (Federal Species of Concern, State Endangered Species) 

The Cox’s mariposa lily is limited to a small area (30 m2), and it is only found on a small portion of a 

narrow geologic formation in Douglas County, Oregon. Individuals number less than 10,000 

(ORNHIC 2006c). All populations are on serpentine soils, mostly on shady, north-facing, mesic sites 

near ridgelines. Typically it grows in serpentine grasslands and forest margins. The Pacific 

Connector pipeline would cross one population near MP 75 and is within 0.4 mile of another; both of 

these populations were documented in 1992 (ORNHIC 2006a). Pacific Connector conducted 

botanical surveys for this species in April 2007 within the documented site crossed and within other 

serpentine soils crossed by the proposed pipeline. In all, 32 acres were surveyed for this species, of 

which 20 were considered suitable habitat. 

The proposed pipeline crosses a documented population of Cox’s mariposa lily (500 to 5,000+ 

plants) on BLM-administered land in the Roseburg District. The last observation of this plant in 

this area was in 1992. A population of this plant was also documented near this location in 1992 

about 0.5 miles south of the proposed right-of-way (ORNHIC 2006a). Botanical surveys 

conducted in this area in 2007 by Pacific Connector located approximately 500 plants on both 

sides of an existing BLM roadbed within about a 0.3 mile length of the proposed construction 

right-of-way. Due to populations of this species in the vicinity of the pipeline, we recommended 

in the draft EIS that Pacific Connector develop a mitigation plan to avoid or minimize adverse 

impacts on known locations of Cox’s mariposa lily. Pacific Connector developed such a plan 

(attachment M to its December 4, 2008 comments on the draft EIS) and has revised its proposed 

pipeline reroute in this area to follow an existing road to minimize direct impacts to the Cox’s 

mariposa lily. The mitigation plan also describes how the construction right-of-way would be 

narrowed in this area, and a portion of a USCA eliminated. Appropriate barriers would be 

installed along this stretch to ensure that the lily populations are not impacted by sediments and 

debris from the right-of-way. Slopes where this species was found would also be protected from 

erosion and caving to the extent possible. To accommodate the reroute and changes in 

construction techniques in this area, three TEWAs would be added or modified. Additional 

mitigation techniques that would be employed to protect these populations of Cox’s mariposa 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-109

lily include seed collection and bulb salvage, site restoration and monitoring, and some habitat 

enhancement for this species at UCSAs in the area. 

Umpqua Mariposa Lily (Federal Species of Concern, State Endangered Species) 

The Umpqua mariposa-lily is known from 17 localities with total plants numbering fewer than 

25,000 (ORNHIC 2006c). None of the 17 sites are protected. This plant grows in both forests 

and meadows, but it is the most vigorous in margins between forests and meadows. In 

southwestern Oregon, it is associated with a diverse array of plants, and it is found in diverse 

soils, aspects and slopes. Several large populations of this plant (5,000+) are between 1.3 and 

2.5 miles east of the proposed pipeline alignment near MP 99.55. These were identified between 

1990 and 1992 in a variety of habitats (ORNHIC 2006a). No known populations occur within 

0.1 mile of the proposed Pacific Connector pipeline area, although potential suitable habitat 

could occur within the Pacific Connector pipeline area (serpentine soils in ecotone between 

forest and grassland sites at low elevations less than 2,500 feet). Pacific Connector conducted 

botanical surveys for this species in May and early June 2007 in potential habitat within 200 feet 

of the proposed pipeline in lands administered by the Roseburg BLM District and Umpqua 

National Forest. No plants were located during the survey effort, although suitable habitat was 

identified within the proposed pipeline right-of-way near the site where Cox’s mariposa-lily was 

documented (see above). 

Dwarf Wooly Meadowfoam (Federal Species of Concern, State Threatened Species) 

Dwarf wooly meadowfoam’s range is restricted to two small protected areas, totaling about 2 

square miles with at least 10,000 individuals (ORNHIC 2006c). Dwarf wooly meadowfoam 

inhabits small depressions in thin clay soil overlying old basalt at the edges of deep vernal pools, 

which are dry by mid-summer and generally exposed to full sunlight. The only known 

occurrences are on Table Rock in Jackson County. Table Rock is located over 12 miles 

southwest of the proposed Pacific Connector pipeline. There is no documentation of dwarf 

wooly meadowfoam within the vicinity of the proposed Pacific Connector pipeline (ORNHIC 

2006a). Because the dwarf wooly meadowfoam is endemic to vernal pools at Table Rocks, 

Pacific Connector did not conduct botanical surveys for this species. The Pacific Connector 

pipeline would not impact this species. 

Silvery Phacelia (Federal Species of Concern, State Threatened Species) 

The silvery phacelia is known from thirty occurrences, totaling 3,500 individuals (ORNHIC 

2006c). It is the only phacelia growing along the coastline in open sand or on dunes along the 

south coast of Oregon. It inhabits sandy beach dunes and bluffs near the coast, and some 

partially-stabilized or unstabilized dunes. Silvery phacelia occurs along the coastline of Coos 

and Curry Counties and in adjacent northern California, Del Norte County (near Crescent City). 

Silvery phacelia has not been documented in the vicinity of the proposed LNG terminal or 

Pacific Connector pipeline (ORNHIC 2006a). No suitable habitat would be affected by the 

Project, therefore botanical surveys for this species were not conducted. It is not expected that 

the Project would impact this species. 

Wolf’s Evening Primrose (No ESA Status, State Threatened Species) 

Wolf’s evening primrose occurs in sandy soils with adequate moisture in coastal bluff scrub, 

coastal prairie, and coastal dune habitats (Tibor 2001). This species is associated with a high 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-110

disturbance regime and several occurrences in California are located along roadsides with sandy 

soil (CNDDB 2005). Wolf’s evening primrose is typically associated with low elevation coastal 

habitats, but there have been reported occurrences in lower montane coniferous forest in 

California, at elevations greater than 2,500 feet above MSL (Tibor 2001). The closest known 

occurrence of Wolf’s evening primrose to the proposed LNG terminal site and Pacific Connector 

pipeline is in Port Orford, Oregon approximately 50 miles to the south of the proposed Jordan 

Cove site. Therefore, it is not expected that the Project would impact this species. 

4.6.3 Other Special Status Species 

In addition to the federal and state threatened and endangered species or candidate species 

described above, there are 585 additional species that have been given special status designations 

by federal or state agencies that could potentially occur in the Project area (see tables H-6, H-7, 

and H-8 in Appendix H). The FWS and NMFS maintain a list of federal species of concern, 

which are species whose conservation standing is of concern but for which status information is 

still needed. The ODFW also assigns special status to fish species. State special status 

designations, prefaced by “S,” include critical (SC), vulnerable (SV), peripheral or naturally rare 

(SP) and undetermined (SU) (ORNHIC 2006c). Critical refers to species with pending 

threatened or endangered status or species that should be listed as threatened or endangered if 

immediate conservation actions are not taken. Vulnerable species are not believed to be at 

immediate risk for listing as threatened or endangered and such listing can be avoided through 

continued or expanded use of adequate protective measures and monitoring. Peripheral species 

refer to species whose Oregon populations are on the edge of their range and naturally rare 

species that have had historically low population numbers in Oregon due to naturally limiting 

factors. Undetermined species have an unclear status; they may be susceptible to population 

decline of sufficient magnitude and could qualify for endangered, threatened, critical or 

vulnerable status, but a judgment cannot be made without scientific research. 

U.S. Fish and Wildlife Service 

The FWS (2006a and 2006b) listed 66 wildlife species that potentially occur in counties 

coinciding with the JCE & PCGP Project that are candidates (5 species) for listing under the 

ESA, of which three have been documented within the Project area (see discussion below), and 

others that are species of concern (61 species) whose conservation standing is of concern but for 

which status information is still needed. The list includes 14 mammals, 22 birds, 4 reptiles, 9 

amphibians and 17 invertebrates. These species are listed in table H-6 in Appendix H, with the 

exception of the wolverine, which is a state-threatened species and is discussed above. Expected 

habitat for each species is described within table H-6 in Appendix H. In comments on the 

administrative final EIS, the FWS noted that the Umpqua chub may be present in the Umpqua 

River, and this species is of concern because it has rapidly decreased in abundance. This species 

is discussed in the BE included with this final EIS. 

Oregon Department of Fish and Wildlife 

The ODFW identified 72 species with special status that potentially occur in counties coinciding 

with the JCE & PCGP Project area, of which the majority are also considered federal species of 

concern. This list includes 14 mammals, 39 birds, 10 fish, 4 reptiles, and 15 amphibians. The 

ODFW does not assign special status for invertebrates. Table H-6 in Appendix H provides the 

following information for each state special status species: expected habitat and documentation 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-111

within each county, BLM district, and National Forest crossed by the proposed Pacific 

Connector pipeline and vicinity. 

Although the species listed in table H-6 may occur in counties noted by FWS (2006a and 2006b) 

and ODFW (ORNHIC 2006c), distributions and/or habitat associations of some preclude their 

potential occurrence in the Project area. 

See below for a summary of species that are potentially present in the Project area, and effects of 

the Project on these species. USFS and BLM special status species that would potentially be 

impacted by the proposed action are addressed in more detail in the Biological Evaluation, which 

is appended to this EIS. 

4.6.4 Environmental Effects on Federal Lands 

The BLM maintains lists of special status species as required by national policy to ensure that 

BLM actions do not contribute to a loss of viability or cause a trend toward listing under the 

ESA. The BLM recognizes two status categories for management purposes: Sensitive and 

Strategic. According to Instruction Memorandum No. OR-2007-072, Sensitive species are those 

that are documented or suspected endangered or threatened at the federal or state level, federal 

de-listed species, are Oregon Heritage List 1 or List 2, and have been documented on at least one 

Oregon BLM district. These species should be managed to ensure that activities on BLM lands 

do not contribute to their listing. Strategic species are not federal candidates or federal or statelisted threatened or endangered, but are Oregon Heritage List 1 or List 2 and are documented or 

suspected on at least one Oregon BLM district. 

Like the BLM, the USFS is required by USFS Manual 2760 to maintain a list of sensitive species 

for each region, including species listed as federally threatened, endangered or proposed under 

the ESA, as well as species that are threatened by human activities. Activities on NFS lands 

must be managed to ensure that current federally listed species are not extirpated or that 

activities do not result in ESA listing for other sensitive species. 

The Regional Forester’s Sensitive Species list, which includes federally listed, federally 

proposed, and sensitive species, was updated on January 31, 2008; however, because this Project 

was initiated before the update, the analysis of special status species for this Project is based on 

the Regional Forester’s Sensitive Species list from 2004. The 2005 field investigation had 

commenced before updates occurred (USFS 2004a; Per BLM Instruction Memorandum OR2007-072, dated July 25, 2007: “Where pre-project clearances have already been conducted for a 

project, there are no requirements to conduct pre-project clearances or address the newly added 

Bureau Sensitive species in your National Environmental Policy Act of 1969 (NEPA) project”). 

Species on the updated 2008 list that were not addressed in this EIS are listed in table H-9 in 

Appendix H. Collectively, these species are referred to in this EIS as Special Status Species. 

Special Status Species that are likely to be impacted by the Project and are not discussed in this 

section are discussed in the BE (Appendix H-11) and listed below in table 4.6.4-1. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-112

TABLE 4.6.4-1 

BLM and USFS Sensitive Species that would likely be Impacted by the Project and 

are Addressed in the Biological Evaluation 

Common and/or Scientific Name USFS status a/ BLM status b/

Mammals 

Pallid bat 

Antrozous pallidus 

Sen Sen 

Townsend’s big-eared bat 

Corynorhinus townsendii 

Sen Sen 

Fringed myotis 

Myotis thysanodes 

Sen Sen 

Spotted bat 

Euderma maculatum

Sen 

**Pacific fisher 

Martes pennanti pacifica 

Sen Sen 

Birds 

Red-necked grebe 

Podiceps grisegena

Sen Sen 

Horned grebe 

Podiceps auritus

Sen Sen 

Fork-tailed storm petrel 

Oceanodroma furcata

Str 

American white pelican 

Pelecanus erythrorhynchos

Sen 

Western least bittern 

Ixobrychus exilis hesperis

Str Str 

Trumpeter swan 

Cygnus buccinator

Sen 

Aleutian Canada Goose 

Branta canadadnsis leucopareia

Sen 

Dusky Canada goose 

Branta canadensis occidentalis

Sen 

Tule goose 

Anser albifrons elgasi

Str 

Harlequin duck 

Histrionicus histrionicus

Sen Sen 

Bufflehead 

Bucephala albeola

Sen Sen 

Upland sandpiper 

Bartramia longicauda

Sen Sen 

White-tailed kite 

Elanus leucurus

Sen 

Merlin 

Falco columbarius

Str 

American peregrine falcon 

Falco peregrinus anatum 

Sen Sen 

Greater Sage Grouse 

Centrocercus urophasianus 

Sen Sen 

White-headed woodpecker 

Picoides albolarvatus

Sen Sen 

Lewis' woodpecker 

Melanerpes lewis

Sen Sen 

Streaked horned lark** 

Eremophila alpestris strigata

Sen 

Purple martin 

Progne subis

Sen Sen 

Oregon vesper sparrow 

Pooecetes gramineus affinis3

Sen 

Tricolored blackbird 

Agelaius tricolor 

Sen Sen 

Reptiles 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-113

TABLE 4.6.4-1 

BLM and USFS Sensitive Species that would likely be Impacted by the Project and 

are Addressed in the Biological Evaluation 

Common and/or Scientific Name USFS status a/ BLM status b/

Northwestern pond turtle 

Actinemys marmorata marmorata 

(formerly Emys marmorata marmorata)

Sen Sen 

Amphibians 

Foothill yellow-legged frog 

Rana boylii

Sen Sen 

Terrestrial Invertebrates 

Evening fieldslug 

Deroceras hesperium

Sen Sen 

Oregon shoulderband 

Helminthoglypta hertleini

Sen Sen 

Tillamook westernslug 

Hesperarion mariae

Sen Sen 

Chace’s sideband 

Monadenia chaceana

Sen Sen 

Traveling sideband 

Monadenia fidelis celeuthia

Sen Sen 

Klamath taildropper 

Prophysaon sp. Nov.

Str Str 

Siskiyou hesperian 

Vespericola sierranas

Sen 

Siskiyou short-horned grasshopper 

Chloealtis aspasma 

Sen Sen 

Johnson’s hairstreak 

Callophrys johnsoni 

(Mitoura johnsoni) 

Sen Sen 

Insular blue butterfly 

Plebejus saepiolus littoralis 

Sen Sen 

Mardon skipper butterfly** 

Polites mardon 

Sen Sen 

a/ USFS Status: Sen= Sensitive, Str = Strategic 

b/ BLM Status: Sen = Sensitive, Str = Strategic 

The National Forest Management Act requires each National Forest to identify Management 

Indicator Species (MIS) in the planning process and for fish and wildlife habitats to be managed 

to maintain and improve habitat of selected MIS. MIS are “plant and animal species, 

communities, or special habitats selected for emphasis in planning, and which are monitored 

during forest plan implementation in order to assess the effects of management activities on their 

populations and the populations of other species with similar habitat needs which they may 

represent” (Forest Service Manual 2620.5). Pacific Connector has prepared an assessment of 

Management Indicator Species that could be affected by the proposed pipeline (see Appendix 

H13). 

BLM Special Status Species 

In all, there are 28 terrestrial invertebrate species documented or suspected in at least one of the 

four BLM districts crossed by the proposed pipeline that are designated Sensitive that are not 

also listed with USFWS. There are also 27 birds, 7 amphibians, 1 reptile, and 9 mammals. 

There are also 14 terrestrial invertebrates, 7 birds, and 2 mammals that are listed as Strategic. 

Table H-6 in Appendix H lists the BLM special status species that have been identified to occur 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-114

or suspected to occur within BLM districts crossed by the proposed Pacific Connector pipeline 

and includes a description of habitat occurrence. Federal and state endangered or threatened 

species (also considered special status species by the BLM) are discussed in the previous 

sections. 

USFS Special Status Species 

Several species were identified as sensitive species by the three National Forests that are crossed 

by the Pacific Connector pipeline. This list includes 17 mammals, 34 birds, 2 reptiles, 10 

amphibians and 6 invertebrates. Table H-6 in Appendix H lists the USFS sensitive species 

potentially present within the National Forests crossed by the proposed Project. 

Table 4.6.4-2 is a summary of terrestrial wildlife species that are provided a special status by the 

BLM or USFS and are documented or suspected to occur within the districts and forests crossed 

by the proposed Pacific Connector pipeline; however, all species documented or suspected may 

not occur within the proposed Project area. This summary table includes BLM Sensitive and 

Strategic species and USFS sensitive species, but does not include federal and/or state threatened 

and endangered species that are discussed above in section 4.6 although they are considered on 

the BLM and USFS special status species lists. 

TABLE 4.6.4-2 

Numbers of BLM and USFS Special Status Species within the Seven BLM Districts and National Forests Crossed 

by the Proposed Pacific Connector Pipeline a/

Number in BLM Districts Number in National Forests 

Taxonomic Group Coos Bay Roseburg Medford Lakeview Umpqua 

Rogue RiverSiskiyou 

FremontWinema 

Mammals 6 5 4 6 14 17 3 

Birds 24 8 8 17 27 29 8 

Reptiles 1 1 1 1 2 2 1 

Amphibians 2 1 4 3 8 6 2 

Terrestrial Invertebrates b/ 17 10 16 7 5 7 3 

a/ Numbers do not include federal and/or state threatened or endangered wildlife species. 

b/ Note that aquatic invertebrates are discussed in Section 4.5. 

Special Status Species Presence 

Based on several available data sources including the BLM GeoBOB database (BLM 2006), 

ORNHIC species request (ORNHIC 2006a), and USFS database (USFS 2006d), 45 special status 

wildlife species have been previously documented within 3 miles of the proposed Pacific 

Connector pipeline, including the red tree vole and mollusks that have been documented along 

and within 500 feet of the proposed pipeline. See Appendix H for locations of species 

documented within the vicinity of the proposed pipeline. 

Pacific Connector conducted surveys during 2007 and 2008 for red tree voles (tree-climbing 

surveys), great gray owls, and terrestrial or aquatic mollusks; species with survey and manage 

status that require surveys prior to ground-disturbing activities. Red tree voles are arboreal and 

endemic to dense, moist, mixed, usually old-growth coniferous forests in western Oregon. Their 

diet consists almost exclusively of Douglas-fir needles. Red tree voles, in turn, are a major food 

item for the NSO. Similar to the NSO, a major threat to red tree voles is habitat loss and 

fragmentation. During 2007 and 2008 surveys, 16 active nests were identified in the right-of-
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-115

way, two in TEWAs, and two in UCSAs. Seventeen more nests were found within 150 feet of 

the project area but not within it, and 31 nests identified as inactive were also found. For more 

details on the red tree vole, including locations potential habitat along the pipeline route and 

impacts, see the BE. 

Three mollusks with special status – Oregon shoulderband, Chace sideband, and Siskiyou 

Hesperian – were found at four different locations within the proposed construction right-of-way. 

The first year of great gray owl surveys documented two pairs (one with fledgling) and one 

resident single. Surveys completed in 2008 found three pairs with young and one resident single. 

The great gray owl is a widespread raptor, found in boreal forests up to 9,000 feet elevation 

throughout the northern hemisphere. The project may impact individuals or habitat, by 

disturbance, habitat alteration or fragmentation, and possibly cumulatively by increasing human 

traffic through the cleared right-of-way. These are unlikely to have negative effects on overall 

great gray owl population viability due to the secure global status of the great gray owl, the 

mobility of the owls, and the relatively small area of their range that would be impacted. For 

more details, see the BE (Appendix H-11). 

Pacific Connector has also conducted surveys in 2007 within habitats that may support special 

status plant species, including federal and state candidate species, BLM special status species, 

USFS sensitive species, and BLM and USFS survey and manage species. In addition to plants, 

special status wildlife species (vertebrates and invertebrates) were documented if observed 

during the survey activities. The results of those surveys were submitted by Pacific Connector to 

the FERC, BLM, and USFS as part of the FERC’s application process. 

4.6.4.1 Mammals 

There are 29 additional special status terrestrial mammals that may be present and potentially 

affected by construction of the proposed LNG terminal or pipeline. These include 15 species 

listed as federal species of concern, one of which is a federal candidate for listing (Pacific fisher). 

Thirteen of the listed species are also sensitive under state, BLM, or USFS designation. The 

remaining 14 special status species are designated as sensitive by the state, BLM, or USFS. 

Descriptions of expected habitat, documented or suspected occurrences, and a description of 

potential Project impacts to these special status species within the proposed Project area are 

presented in table H-6 in Appendix H. 

An analysis of the Pacific fisher is provided in a BE, prepared for the USFS and BLM in support 

of the final EIS. The BE discusses fisher habitat loss or modification that might be caused by 

pipeline construction. The following has been prepared to supplement that analysis and 

discussion, per a request from USFS. In 2004, FWS determined that the West Coast DPS of the 

Pacific fisher was warranted for listing but precluded by higher priority actions to amend the 

Lists of Endangered and Threatened Wildlife and Plants (USFWS 2004a). More recently, FWS 

completed a species assessment for West Coast fisher DPS and concluded that the overall 

magnitude of threats to the DPS was high but non-imminent; the greatest risk to the DPS is 

isolation of a few small populations that have persisted under those conditions for some time. 

The assessment concluded that emergency listing under ESA was not warranted (USFWS 

2007p). 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-116

Fishers were apparently extirpated from Oregon and the west coast primarily due to overtrapping 

and habitat loss (Aubry and Lewis 2003) but were reintroduced in Oregon from British Columbia 

into the southeastern Cascades near Klamath Falls in 1961. From 1977 through 1981, fishers 

from British Columbia and Minnesota were reintroduced to the southwestern Cascades in the 

vicinity of Crater Lake, though details of the translocations are limited (Aubry and Lewis 2003). 

Recent detections of fishers indicate that a population exists in the northern Siskiyou Mountains 

near the California-Oregon border (near Oregon Caves National Monument in Josephine 

County), and another population persists in the southern Cascade Range in the vicinity of the 

translocation releases done between 1977 and 1981 (Aubry and Lewis 2003). 

Of particular concern with respect to risk of the species’ recovery (USFWS 2007p) is the 

apparent lack of genetic interchange – genetic isolation – between the two focal population 

centers (Aubry and Lewis 2003; Wisely et al. 2004; Aubry and Raley 2006). Fishers in the 

northern Siskiyou Mountains appear related to indigenous populations from northern California. 

Fishers in the southern Cascades are descended from those introduced from British Columbia 

and Minnesota, though animals from those two geographically separated sources have interbred 

and are more genetically diverse than indigenous populations (Wisely et al. 2004). Even though 

fishers are considered to be vagile, their current distribution does not facilitate genetic 

interchange (Wisely et al. 2004). 

In their comments on the JCE & PCGP draft EIS, USFS expressed concern that the proposed 

pipeline is routed between the two extant fisher populations in Oregon. They suggested that the 

project could impact potential dispersal between the two populations given that I-5 and Highway 

140 may already present barriers to interchange. As discussed above, there currently appears to 

be no genetic interchange between the two populations. Whether that is due to the existence of 

highways, including I-5 and Highway 140, and/or widely interspersed unsuitable habitat has not 

been determined. Fishers, especially dispersing juveniles, are known to cross similar potential 

barriers in the area including the Rogue River mainstem and Highway 62; smaller rivers, creeks, 

and paved county roads “did not appear to substantially influence where fishers established their 

home ranges” (Aubry and Raley 2004). Likewise, unpaved logging roads do not appear to limit 

fisher movements although wide paved roads do (Lewis and Stinson 1998). 

The proposed action could limit fisher movements, such as crossing from one side of the rightof-way to the other, during construction when humans and machinery are present with maximum 

noise and activities. However, such effect, if it occurred, would probably be limited to the actual 

period of construction and possibly some limited time afterward. Fishers tend to avoid areas of 

low canopy cover, clearcuts and large forest openings (Lewis and Stinson 1998), though the 

pipeline right-of-way would be a less extensive clearing than logging clear cuts or large forest 

openings. All areas disturbed by construction, including the construction right-of-way, TEWAs, 

UCSAs, and contractor yards as necessary, would be restored and revegetated in accordance with 

Pacific Connector’s ECRP. Replanting conifers within each affected forested area would leave 

an estimated 30-foot-wide maintenance corridor of non-forested vegetation within former forests 

over the long-term or permanently. A 30-foot-wide corridor within forested habitat is not 

expected to impede fisher movements in the vicinity of the proposed action. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-117

Marine Mammals 

Four additional marine mammal species could potentially occur in the proposed Project area 

(along the waterway for LNG marine traffic or near the LNG terminal). These species are 

protected under the MMPA, which prohibits killing, harming, or harassing any marine mammal. 

Descriptions of expected habitat, documented or suspected occurrences, and a description of 

potential Project impacts to these special status species within the Project area are presented in 

table H-6 in Appendix H. Other marine mammals that may occur in the zones of the LNG 

carrier transit route include whales and the Steller sea lion, which are described in section 4.6.1 

of this EIS. 

4.6.4.2 Birds 

There are 67 additional special status birds that may be present and potentially affected by 

construction of the proposed LNG terminal or Pacific Connector pipeline. These include 20 

species listed as federal species of concern, two of which are candidates for listing (yellow-billed 

cuckoo and streaked horned lark). Nineteen of those 20 species are also sensitive under state, 

BLM, or USFS designation. The remaining 46 species are designated as sensitive by the state, 

BLM, or USFS. Descriptions of expected habitat, documented or suspected occurrences, and a 

description of potential Project impacts to these special status species within the Project area are 

presented in table H-6 in Appendix H. 

4.6.4.3 Fish 

There are 24 additional special status fish species that may be present along the LNG carrier 

transit route, or in the waters of Coos Bay potentially affected by construction of the proposed 

LNG terminal or Pacific Connector pipeline, or in waters crossed by the proposed pipeline. Of 

these species, 12 are anadromous and 12 are non-anadromous . These include 15 species listed 

by the FWS (2006a and 2006b) and NMFS (2006) as federal species of concern. There are 13 

state special status fish species known or suspected to occur within the Project area based on 

species distributions (ORNHIC 2006c and 2006a), of which eight are also considered federal 

species of concern. Within the four BLM districts crossed by the proposed Pacific Connector 

pipeline, there are 18 BLM special status fish species that could occur within the Project area, of 

which 15 are also considered FWS species of concern or state special status. Finally, the USFS 

identified additional sensitive fish species which are known or suspected to occur within their 

districts and which may occur within the Project area, of which seven are also considered federal 

species of concern or state special status. Descriptions of life histories, expected habitat, and 

potential occurrences of these special status fish species within the Project area are presented in 

table H-7 in Appendix H. 

4.6.4.4 Amphibians and Reptiles 

There are 21 additional special status amphibians and reptiles that may be present and potentially 

affected by construction of the proposed LNG terminal or Pacific Connector pipeline.. These 

include 12 species listed as federal species of concern, and one species that is a candidate for 

listing (Oregon spotted frog). All of these species are also sensitive under state, BLM, or USFS 

designation. The remaining eight species are designated as sensitive by the state, BLM, or 

USFS. Descriptions of expected habitat, documented or suspected occurrences, and a 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-118

description of potential Project impacts to these special status species within the Project area are 

presented in table H-6 in Appendix H. 

4.6.4.5 Invertebrates 

Aquatic 

There are 26 species of special status aquatic invertebrates that may be present and potentially 

affected by construction of the proposed LNG terminal or Pacific Connector pipeline, of which 

12 are federal species of concern; four species (Olympia oyster, Oregon floater, western 

ridgemussle, and western pearlshell) are designated by the BLM as BT species, which are not 

considered special status species for management purposes. The NMFS (2008) has proposed to 

list the black abalone endangered under the ESA. With the exception of the Olympia oyster and 

the black abalone, which occur in marine and estuarine environments, all of the species are 

associated with freshwater environments. Table H-7 in Appendix H provides summarizes the 

life history, habitat associations, and occurrence of these invertebrates. 

Terrestrial 

There are 28 additional special status terrestrial invertebrates that may be present and potentially 

affected by the construction of the proposed LNG terminal or Pacific Connector pipeline. Of 

these species, four are listed as federal species of concern, and one is a federal candidate for 

listing (Mardon skipper). An additional 23 are listed as sensitive under the state, BLM, and/or 

USFS designation. Descriptions of expected habitat, documented or suspected occurrences, and 

a description of potential Project impacts to these special status species within the Project area 

are presented in table H-6 in Appendix H. 

4.6.4.6 Plants 

There are 383 special status plant species that may be present in the proposed Project area. 

Descriptions of expected habitat, documented or suspected occurrences, and a description of 

potential Project impacts to these special status species within the Project area are presented in 

table H-8 in Appendix H. During 2007-2008, Siskiyou BioSurvey, LLC (SBS) surveyed for 

special status vascular and non-vascular plant species in suitable habitat within 200 feet of the 

proposed right-of-way, TEWAs, UCSAs, and access roads. Survey results, including 

methodology, are provided in the 2007 Draft and 2008 Biological Survey Report. During these 

surveys, 34 special status plant species were documented: 23 vascular plants, 7 lichens, 3 

mosses, and 1 liverwort. 

Bryophytes 

There are 34 species of special status bryophyte that may be present in the proposed Project area. 

Thirty-three of these species have special status under the state, BLM, and/or USFS designation. 

One of these species, Limbella fryei, is listed as a federal species of concern and is a state 

candidate for listing. Species found during the 2007-2008 biological surveys were one liverwort 

(Metzgeria violacea) and three mosses. Information on Metzgeria violacea, the new BLM 

sensitive liverwort species, is provided in those reports and, per a request from BLM, 

summarized below. Potential Project effects to bryophytes include trampling or killing of 

individual plants. This possible effect would be mitigated by fencing off and marking known 

occurrences of sensitive bryophyte species along the right-of-way and not disturbing them. 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-119

Metzgeria violacea, a coastal liverwort species, is an ORNHIC List 2 species and, as of January 

2008, a BLM sensitive species. During surveys conducted in 2007 for the Pacific Connector 

pipeline, this species was not included on the BLM special status list or USFS Region 6 list. On 

May 2, 2007, SBS located Metzgeria violacea in the BLM Coos Bay District approximately 180 

feet from the proposed pipeline centerline (northeast of MP 17.45) and 100 feet from TEWA 

17.43-N. Plants were located on salmonberry (Rubus spectabilis) branches within a riparian 

forest wetland and were scattered within an area of approximately 0.14 acre. Prior to the 

discovery of this site there were no documented occurrences of this liverwort on BLM lands, but 

it was suspected on Coos Bay BLM District because of similar habitat and proximity to known 

sites (South Slough National Estuarine Research Reserve, Charleston). It is not expected that the 

plants at this site would be negatively impacted by the pipeline because the overstory riparian 

habitat and substrate shrubs at this site would be maintained. Therefore, no avoidance or 

mitigation plan has been prepared. 

Fungi and Lichens 

There are 115 species of fungi and lichen with special status under the state, BLM, and/or USFS 

that may be present in the proposed Project area. During surveys, seven species of BLM and/or 

USFS special status lichen were found; no special status fungi were documented. A potential 

project effect to special status lichens is destruction of individual lichens or their substrate (e.g., 

felling of trees on which lichens are growing). This possible effect would be mitigated by 

fencing off and marking known occurrences of sensitive bryophyte species along the right-ofway and not disturbing them. 

Vascular Plants 

There are 234 additional special status vascular plants that may be present within the Project area 

and could be potentially affected by construction and operation of the proposed LNG terminal or 

pipeline. Of these species, 34 are federal species of concern; 19 of which are also state 

candidates for listing. One species, the Siskiyou mariposa lily, is a federal candidate for listing. 

An additional nine species are described only as state candidates for listing. One hundred and 

ninety other species of vascular plants are protected as special status under state, BLM, and/or 

USFS designation. Of the special status vascular plant species likely to be found in the proposed 

Project area, 23 were found during the 2007-2008 surveys. Potential Project effects to these 

plants could include trampling of individuals, fragmentation of populations, disruption of 

pollinator species populations, alteration of habitat, and introduction and facilitation of spread of 

noxious and invasive weeds. These possible effects would be mitigated by fencing off, marking, 

and not disturbing sensitive plants found along the right-of-way; restoring disturbed areas to their 

preexisting condition; and following recommendations outlined in Oregon Aquatic Species 

Management Plan and the Oregon Noxious Weed Strategic Plan. Before construction, Pacific 

Connector would also develop a Noxious Weed Control Plan that would incorporate the 

recommendations of various federal and state agencies. See section 4.4.1.3 for more information 

on noxious weeds control and mitigation. 

4.6.5 Conclusions and Recommendations for Threatened, Endangered, and Other 

Special Status Species 

Based on informal consultations with the FWS and NMFS, 35 federally listed species were 

identified as potentially occurring in the general vicinity of the proposed JCE & PCGP Project. 
4.6 – Threatened, Endangered, and 

Other Special Status Species 4.6-120

A variety of measures have been proposed by Jordan Cove and Pacific Connector that would 

avoid or minimize environmental impacts on threatened, endangered, and other special status 

species. These measures include, but are not limited to: 

• reducing the size of the LNG terminal footprint to avoid or minimize impacts on wetlands 

and Henderson Marsh; 

• routing the Pacific Connector pipeline to avoid or minimize impacts to sensitive 

environmental features, habitats, and/or species; 

• use of the HDD or bore technique during construction of the Pacific Connector pipeline 

to avoid or minimize disturbance of waterbodies containing sensitive aquatic species or 

habitats; 

• minimizing potential water quality impacts by using erosion control measures; 

• restoring temporary construction work areas by implementing appropriate restoration and 

revegetation techniques; 

• controlling the spread of noxious and/or invasive plants; 

• providing screened water intakes at the LNG terminal to provide cooling and ballast 

water to the LNG carriers while unloading to minimize entrainment and impingement of 

juvenile fish; and 

• development of a plan to minimize potential ship strikes to marine species by LNG 

carriers. 

Additionally, Jordan Cove and Pacific Connector have proposed a Mitigation Plan to address 

impacts and effects that cannot be otherwise mitigated. The goal of the plan is to compensate for 

unavoidable impacts to listed species and their habitats through substitute habitat and/or habitat 

stewardship. Unmitigated impacts have been identified in accordance with ODFW and FWS 

criteria and include impacts that cannot be mitigated in-proximity and/or in-kind, and impacts to 

high value habitat that is unique and irreplaceable. 

After further consultations with the FWS and NMFS, completion of field surveys, and review of 

Jordan Cove and Pacific Connector’s proposed measures to avoid, minimize, or mitigate impacts 

on listed species, we have determined that the proposed Project would likely adversely affect 

eight federally listed species: MAMUs, NSOs, coho salmon (in both the Southern 

Oregon/Northern California Coast and Oregon Coast ESUs), Lost River suckers, shortnose 

suckers, Applegate’s milk-vetch, Gentner’s fritillary, and Kincaid’s lupine. In compliance with 

section 7 of the ESA, the FERC staff is currently preparing a BA and EFH Assessment for the 

proposed projects which will be submitted to the FWS and NMFS with a request to initiate 

formal consultation. The FWS and NMFS would prepare BOs as to whether or not the federal 

actions associated with the Project would likely jeopardize the continued existence of a listed 

species, or result in the destruction or adverse modification of designated critical habitat. The 

FERC would only authorize the Project to proceed if the FWS’ and NMFS’ BOs find the Project 

would not jeopardize the continued existence of listed species or result in the destruction or 

adverse modification of designated critical habitat (assuming reasonable or prudent alternatives 

are not available). Further, to ensure compliance with the ESA, we recommend that: 

• Jordan Cove and Pacific Connector should not construct or use any of their 

proposed facilities, including related ancillary areas for staging, storage, temporary 

work areas, and new or to-be-improved access roads until: 
4.6 – Threatened, Endangered, and 

Other Special Status Species

4.6-121

a. the Commission staff completes formal consultations with the NMFS and FWS; 

and 

b. Jordan Cove and Pacific Connector have received written notification from the 

Director of OEP that construction and/or implementation of conservation 

measures may begin.