4.3 – Water Resources and Wetlands 4.3-1

4.3 WATER RESOURCES AND WETLANDS 

4.3.1 Groundwater 

Groundwater is a critical natural resource providing domestic, industrial, and agricultural water 

supply; base flow for rivers, lakes, streams, wetlands; and other beneficial uses. Groundwater 

levels in a few areas have declined as a result of withdrawals by wells. State governments have 

taken steps to alleviate declines in some areas by enacting programs that either limit the number 

of additional wells that can be completed in a particular aquifer or prevent further groundwater 

development. 

In areas where groundwater monitoring shows groundwater contamination at sufficiently high 

levels and the contamination is potentially related to non-point source activities on the land 

surface, the ODEQ can declare a Groundwater Management Area (GMA) under state law (ORS 

468B.180). ODEQ then designates a lead agency responsible for developing an action plan to 

reduce existing contamination and prevent further groundwater contamination. The ODA is 

responsible for developing the portion of the action plan to address farming practices. 

Oregon currently has three GMAs: the Northern Malheur County GMA and the Lower Umatilla 

Basin GMA, declared over a decade ago; and the Southern Willamette Valley GMA declared in 

May 2004 (ODEQ 2006a). The proposed LNG terminal, and Pacific Connector pipeline and 

associated aboveground facilities would not overlie any GMAs. The Southern Willamette 

Valley GMA, which is the GMA nearest the Project area, is located more than 50 miles northeast 

of Coos Bay. 

The LNG terminal, pipeline, and associated aboveground facilities would not overlie any EPAdesignated sole-source aquifers. The nearest EPA-designated sole-source aquifer, and the only 

one in Oregon, is the North Florence Dunal Aquifer (EPA 2007; 2008), which is in Lane County, 

more than 40 miles to the north of the proposed facilities. 

There are four general aquifer types (unconsolidated-deposit, pre-Miocene rock, volcanic and 

sedimentary rock, and Pliocene and younger basaltic rock) defined by their geologic and 

hydrologic characteristics within the Project area, which are described in detail below. The 

following aquifer descriptions are taken from the USGS Groundwater Atlas (USGS 1994). 

Surface geology is discussed in section 4.1. 

Unconsolidated-deposit Aquifers – Groundwater is commonly available to shallow wells that 

are completed in unconsolidated-deposit aquifers that consist primarily of sand and gravel but 

contain variable quantities of clay and silt. The proposed pipeline would cross unconsolidateddeposit aquifers for approximately 7.6 miles in and around Coos Bay (between MPs 0.0 and 

23.4), 3.1 miles between MPs 55.28 and 69.70, and 23 miles in the Klamath Falls area between 

MPs 191.85 and 214.91. Many of the large lower-gradient streams in the area flow through 

unconsolidated deposits. These aquifers consist primarily of sand and gravel and are the most 

productive and widespread aquifers in Idaho, Oregon, and Washington. These unconsolidateddeposit aquifers typically provide freshwater for most public-supply, domestic, commercial, and 

industrial purposes (USGS 1994). 
 4.3 – Water Resources and Wetlands 4.3-2

Pre-Miocene Rock Aquifers – The majority of the proposed pipeline route from just south of 

Coos Bay between MPs 23.53 and 155.76 crosses aquifers in pre-Miocene rocks (a total of about 

132.4 miles). These aquifers consist of undifferentiated volcanic rocks, undifferentiated 

consolidated sedimentary rocks, and undifferentiated igneous and metamorphic rocks principally 

in the mountainous areas crossed by the pipeline. Within the Cascade Range and west of it, the 

consolidated sedimentary rocks are of marine origin and commonly yield salt water. At depth, 

the salt water can contaminate overlying freshwater aquifers. Permeability of the aquifers varies 

greatly. Water from wells completed in these aquifers is used mostly for domestic and 

agricultural (livestock watering) supplies (USGS 1994). 

Volcanic and Sedimentary Rock Aquifers – Due west of Medford, between MPs 134.24 and 

156.88, the proposed pipeline route enters a groundwater area of volcanic and sedimentary rock 

aquifers for about 8.2 miles. These aquifers consist of a variety of volcanic and sedimentary 

rocks and are not as productive as the unconsolidated-deposit, Pliocene and younger basalticrock or Miocene basaltic-rock aquifers. Volcanic- and sedimentary-rock aquifers generally yield 

fresh water but locally yield salt water. About 30 percent of the fresh groundwater withdrawals 

are used for public-supply, about 20 percent are used for domestic and commercial, and about 50 

percent are used for agricultural (primarily irrigation) purposes (USGS 1994). 

Pliocene and Younger Basaltic-rock Aquifers – Northeast of Medford between MPs 191.85 

and 230.91, the proposed pipeline route passes south of Brown Mountain through Pliocene and 

younger basaltic-rock aquifers and crosses these for about 51.0 miles while passing in and out of 

unconsolidated deposit aquifers. Pliocene and younger basaltic-rock aquifers consist primarily 

of thin, basaltic lava flows and beds of basaltic ash, cinders, and sand and yield fresh water that 

is used mostly for agricultural (primarily irrigation) purposes (USGS 1994). 

Groundwater resources and potential impacts from construction and operation of the proposed 

Project components are described below. 

4.3.1.1 Waterway for LNG Traffic 

LNG carriers would not use groundwater and the LNG marine traffic would not have an impact 

on groundwater resources along the waterway. There are groundwater wells within the 1.0 mile 

zone of the LNG carrier transit route that are used to supplement the sources of water provided 

by the CBNBWB. Because of the operational and safety requirements that would be in place for 

the LNG terminal and LNG carriers, including measures recommended by the Coast Guard, the 

likelihood of a substantial LNG spill, and fire resulting from such a spill, would be extremely 

remote. It is unlikely that groundwater wells within the Zones of Concern would be adversely 

affected by LNG marine traffic in the waterway to the terminal. 

4.3.1.2 LNG Terminal 

The proposed LNG terminal site is located on the southern edge of the Coos Dune Sheet on the 

bay side of the North Spit of Coos Bay. The North Spit is composed of vast expanses of sand 

dunes that are easily penetrated by water. The site is underlain by an unconsolidated-deposit 

aquifer. Unconsolidated-deposit aquifers consist of sand and gravel, but may contain variable 

quantities of silt and clay (USGS 1994). Recent borings indicate that the depth of 

unconsolidated sands to the dense sandstone below is over 100 feet. Depth to groundwater in 
 4.3 – Water Resources and Wetlands 4.3-3

Coos County typically ranges from approximately 10 to 110 feet below ground surface (USGS 

1994). Groundwater at the LNG terminal site has been reached at approximately 8 to 10 feet. 

Groundwater supply in the Coos Dune Sheet aquifer is readily available. Although none are in 

use at this time, the CBNBWB maintains 18 freshwater production wells on the North Spit, north 

of the Trans-Pacific Parkway. In all, approximately 20 wells are located north of the LNG 

terminal site in the Oregon Dunes National Recreation Area; however, there are no drinking 

water wells located within 150 feet of the terminal and the nearest registered well is located 

approximately 0.5 mile from the site. 

Groundwater resources underlying and near the LNG terminal site would not be used for either 

construction or operation of the proposed terminal. All water would be supplied by the 

CBNBWB. 

Impacts and Mitigation 

One comment was received during scoping that expressed concern about groundwater 

withdrawals from the North Spit, including impacts to wetlands. All the water to be used during 

construction and operation of the LNG terminal would come from the existing CBNBWB water 

line. The water provided by the CBNBWB is obtained from groundwater wells located on the 

North Spit, as well as two reservoirs (Upper Pony Creek Reservoir and the Joe Ney Reservoir). 

The CBNBWB is responsible for operating its wells and surface water sources in accordance 

with its existing authorizations to prevent adverse impacts. The North Spit wells are capable of 

supplying up to 4 million gallons per day of untreated water. The North Spit treatment plant can 

provide up to 1 million gallons per day of potable water (CBNBWB, no date). During operations 

excess water is produced as part of the vaporization process and would be used to maintain the 

fire water pond, thus reducing the water needed from the CBNBWB line. Adverse impacts due 

to use of CBNBWB supplied water is not expected. 

No adverse impacts are expected to occur to groundwater resources from construction and 

operation of the LNG terminal. No groundwater withdrawals would be required for the 

construction, operation, or maintenance of the LNG terminal, and therefore, there would be no 

lowering of the groundwater table in the immediate vicinity of the proposed LNG terminal. 

No adverse effects on groundwater resources are anticipated from the placement of foundations 

for the terminal facilities. With the exception of the piles for the LNG carrier unloading 

facilities, all other foundation excavations would be shallow in depth. 

No blasting activities are anticipated during construction of the slip, access channel, or LNG 

facility, therefore no adverse effects due to blasting on water wells, springs, and wetlands are 

expected. No wells occur within 150 feet of the proposed LNG terminal and slip sites. Any 

localized hydraulic impacts from the construction of the access channel and slip to the 

CBNBWB wells would be negligible (Groundwater Solutions, Inc. 2006). 

Spills or leaks of hazardous liquids have the potential for long-term impacts on groundwater 

resources, especially in areas where there is a high susceptibility to surface contamination. 

Factors in determining groundwater susceptibility to contamination are the type of underlying 

bedrock, depth to bedrock, depth to the water table, and characteristics of soils and surficial 

deposits. Of these, soil and surficial deposit characteristics are considered the most important 
 4.3 – Water Resources and Wetlands 4.3-4

factors in determining how susceptible an area is to groundwater contamination. Areas with 

sand and gravel are considered more susceptible to groundwater contamination than those areas 

consisting of silt and clay, mainly due to the permeability of the material. 

Spill-related impacts from the construction of the proposed LNG terminal and slip would mainly 

be associated with fuel storage, equipment refueling, and equipment maintenance. These 

potential impacts would be avoided or greatly reduced by regulating storage and refueling 

activities, and by requiring immediate cleanup should a spill or leak occur. Jordan Cove would 

be required to prepare an SPCCP that would describe in detail the preventative measures that 

would be implemented to avoid spills and leaks, as well as the mitigative measures utilized to 

minimize potential effects should a spill or leak occur. The plan would be consistent with all 

federal, state, and local regulations and permit conditions, as well as with Jordan Cove’s Plan 

and Procedures. Upon finalization, the SPCCP would designate refueling areas and procedures; 

spill response procedures, spill response materials, and training; mitigative measures/response; 

and hazardous liquids quantities, storage, and disposal. By following the SPCCP, the potential 

impacts on groundwater due to spills or leaks would be minimized. Furthermore, the 

downgradient location of the proposed site from the nearest wells would prevent contamination 

from accidental spills from entering a production well (Groundwater Solutions, Inc. 2006). 

The only need for driving piles would be for the Port’s construction activities at the slip. It is not 

anticipated that pile driving operations would have any detrimental effect on the groundwater or 

aquifers supporting water wells in the slip area as the nearest registered water supply well is 

approximately 0.6 mile from the proposed slip construction site. Borings drilled at the site reveal 

the sub-soils to consist of sand and weathered sandstone. 

Neither construction nor operation of the proposed LNG terminal and slip would have a 

measurable effect on groundwater quality or quantity. Groundwater resources underlying and 

near the LNG terminal site would not be used for either construction or operation of the proposed 

LNG terminal. There are no construction or operation activities that would likely have a 

significant adverse effect on groundwater use for drinking water supplies; therefore, drinking 

water supplies would be unaffected by construction or operation of the proposed LNG terminal 

and slip facilities. An analysis performed by Groundwater Solutions, Inc. (2006) concluded that 

the excavation of the slip would have negligible effects on water quantity and quality at the 

CBNBWB wells located north of the proposed site, and that the freshwater table would be 

maintained at approximately +10 feet above sea level at the northern site boundary. 

Following construction, the approximately 159-acre site would contain approximately 15.8 acres 

of impervious surfaces. This 10 percent reduction in area that could serve as recharge may cause 

a decrease in the local recharge of groundwater to the shallow water-bearing zone underlying the 

LNG terminal site (by converting infiltration to runoff). However, this decrease would not likely 

result in an adverse effect on groundwater resources used as a water supply source or on the level 

of groundwater in wetlands. 

4.3.1.3 Pacific Connector Pipeline 

Public Water Supply Wells 

Groundwater is a substantial source of drinking water in the areas crossed by the proposed 

pipeline. Groundwater supplies 90 percent of rural residential drinking water in Oregon (ODEQ 
 4.3 – Water Resources and Wetlands 4.3-5

2003). Records for groundwater supply wells in Oregon are maintained in separate databases by 

various agencies depending on the type and use of the well, as described below. The type of well 

and the use of the water dictates the level of regulation for the well. 

The 1996 Federal Safe Drinking Water Act requires Source Water Assessments for all public 

water systems that have at least 15 hookups, or serve more than 25 people year-round. The 

Oregon Department of Human Services Drinking Water Program and the ODEQ Drinking Water 

Protection Program teamed jointly manage the assessment requirements of the Safe Drinking 

Water Act. In Oregon, public water systems with greater than 3 hookups, or serving more than 

10 people, year-round are regulated (ODEQ 2007b). ODEQ maintains the Drinking Water 

Protection database, which includes public drinking water source areas for both groundwater and 

surface water as well as the locations of public water system intakes and public groundwater 

wells. An inventory of the potential contamination sources for the source areas has been 

developed as well. 

The FERC requires identification of public groundwater supply wells within 400 feet of the 

pipeline construction right-of-way and any other areas disturbed during construction. Pacific 

Connector reviewed the ODEQ (2007c) Public Drinking Water database, and according to the 

database there are no groundwater wells that supply public drinking water systems within 400 

feet of the proposed construction right-of-way or work space. 

Even though there are no groundwater wells that supply public drinking water systems within 

400 feet of the construction right-of-way or work space, there are wellhead protection areas, or 

drinking water protection areas as defined in OAR Chapter 333, that would be crossed by the 

proposed pipeline. The ODEQ and Department of Human Services prepared a Source Water 

Assessment of public water systems in the state, and some communities or operators of those 

systems have followed up by designating groundwater protection source areas. Table 4.3.1.4-1 

lists the wellhead protection source areas that would be crossed by the construction right-of-way 

(ODEQ 2007d). None of the proposed rock source and disposal sites, yards, access roads, or 

aboveground facilities would be located within a groundwater protection source area. 

TABLE 4.3.1.4-1 

Wellhead Protection Areas That Would Be Crossed by the Pacific Connector Pipeline

Starting Milepost Ending Milepost County 

Ownership/ 

Jurisdiction Public Groundwater Source Area 

195.09 196.14 Klamath Private Production Metal Forming, Inc 

197.35 197.77 Klamath Private Timber Resource Services LLC 

198.45 199.23 Klamath Private Collins Products LLC 

199.23 199.62 Klamath Private, State Collins Products LLC 

199.26 199.66 Klamath Private, State Columbia Plywood Corp 

200.54 201.12 Klamath Private Crossroads Mobile Home Park 

Groundwater Wells with Water Rights 

Pacific Connector identified private groundwater wells within 200 feet of the construction rightof-way and associated construction facilities. The ODWR Groundwater Rights database was 

reviewed to determine where water rights have been obtained for groundwater wells (ODWR 

2007). Review of the database showed that there were five private wells within 200 feet of the 
 4.3 – Water Resources and Wetlands 4.3-6

proposed right-of-way and associated construction facilities as shown in table 4.3.1.4-2. None of 

the wells is used as a source of drinking water. 

TABLE 4.3.1.4-2 

List of Private Wells Within 200 Feet of the Proposed Pipeline 

Milepost Owner Permit Number Use County 

0.20 Roseburg Lumber Company G-6116 Industrial Manufacturing Coos 

0.29 Roseburg Lumber Company G-4783 Industrial Manufacturing Coos 

217.34 J. R. Pope G-3957 Irrigation Klamath 

224.04 C. Unruh G-12433 Irrigation Klamath 

224.04 J. Madden G-365 Irrigation Klamath 

Other Groundwater Wells 

There are several types of groundwater wells in Oregon that are exempt from obtaining any kind 

of permit, and are therefore not registered or identified in a state database. These include wells 

for single or group domestic purposes not exceeding 15,000 gallons per day. Pacific Connector 

would attempt to identify any unregistered wells in the vicinity of its proposed pipeline through 

field investigations and contacts with landowners within and adjacent to the proposed pipeline 

right-of-way prior to construction. Pacific Connector would supply landowners with 

documentation that explains the proposed pipeline construction project and outlines the field 

investigation for identification of groundwater supplies. During the field investigation, 

landowners would be requested to identify groundwater supply wells, springs, and seeps located 

on their property. Landowners would also be asked to identify the use of the water. 

Groundwater Quality 

Pacific Connector reviewed the ODEQ’s Potential Contaminated Sites (ODEQ 2007d) and ECSI 

(http://www.deq.state.or.us/lq/ecsi/ecsi.htm) to identify areas if contamination that may be 

encountered during pipeline construction. Six potentially contaminated sites were identified 

along the proposed pipeline route and associated facilities and are described below. 

On December 4, 2008, Pacific Connector filed with the FERC a new proposed route (WC-1A2A) between MPs 0.0 and 11.4, based on our recommendation in the draft EIS that it should 

adopt Route Variation WC-1A to avoid an extensive crossing of Coos Bay (see section 3.4.2.1). 

The draft EIS indicated that the route proposed in Pacific Connector’s September 2007 

application to the FERC would have been 0.5 mile from the Weyerhaeuser North Spit Landfill 

near MP 1.2 and near an abandoned fish hatchery, also on Weyerhaeuser property, near MP 1.36. 

Now, the new proposed route would place the pipeline about 265 feet south of the Weyerhaeuser 

Landfill at MP 1.1, and north of the site of the former fish hatchery. Both the landfill and fish 

hatchery are within a parcel that was part of the Menasha paper mill acquired by Weyerhaeuser 

in 1981 and closed in 2003. The potential for contaminated soils at the Weyerhaeuser mill 

location was discussed in section 4.2.2.2. 

Starting in 1995, Weyerhaeuser utilized the landfill to dispose of non-hazardous materials 

generated by the operation of its mill. Weyerhaeuser reported a spill of approximately 5 gallons 

of transformer oil during an annual oil screening test in August of 1995. The spill was cleaned 

up by a certified technician. ODEQ records indicate that the permitted landfill cells and settling 

basins have leaked over time, contributing to a localized area of groundwater contamination. 
 4.3 – Water Resources and Wetlands 4.3-7

The fish hatchery operated between 1980 and 1992 on property leased from Weyerhaeuser. It 

has a separate entry in the ECSI database, identified as a level II area of concern, from a release 

of diesel fuel. In 2006, Weyerhaeuser conducted Phase II testing of its old mill property that led 

to a finding of “No Further Action” by the ODEQ in 2008. ODEQ and Weyerhaeuser believe 

this land can be commercially developed in the future. The Port has an option to acquire this 

tract, and Jordan Cove proposes to use part of the Weyerhaeuser linerboard land to deposit 

materials excavated and dredged from the creation of the access channel and slip for the LNG 

terminal. 

Because of Weyerhaeuser’s cleanup program after closure and dismantling of the mill, it is not 

expected that contaminated groundwater would be encountered during pipeline construction 

activities. The pipeline construction right-of-way and TEWAs would not affect the landfill cells, 

or directly overlap the abandoned fish hatchery. On January 21, 2009, Pacific Connector filed 

with the FERC a draft Contaminated Substances Discovery Plan that outlines practices to protect 

human health and worker safety and prevent impacts in the event of an unanticipated discovery 

of contaminated soil, water, or groundwater during pipeline construction. If trench dewatering 

activities were required while crossing the former Weyerhaeuser mill property, Pacific 

Connector would coordinate with the ODEQ about dewatering procedures that comply with state 

permit requirements. Pacific Connector would coordinate with the landowner about crossing this 

area, so that the pipeline would not affect the landfill. 

The Roseburg Forest Products site located in Douglas County is adjacent to two proposed 

construction yards (i.e., the 8.9-acre Hult Chip Yard and the 2.65-acre Hult Chip Yard Parking 

Area). According to ODEQ records, Roseburg Forest Products has been landfilling hazardous 

substances in its own solid waste landfill. In 1985, it was also reported that a diesel tank 

ruptured resulting in the release of 8,000 gallons of fuel at the site with subsequent cleanup. As 

of 1996, the ODEQ required no further action in the cleanup program at this facility, but 

indicated that further work would be conducted to assess potential hazardous substance releases 

from the landfill of solid waste. In 2006, solvents could still be detected in the downgradient 

wells. Roseburg Forest Products is working with the ODEQ Solid Waste Program to create a 

lined ash monofill to better manage the waste they currently generate. Although this site would 

be located within 0.07 mile of the proposed 8.9-acre Hult Chip Yard, the yard would only be 

used as a rail port to offload pipe. No excavation would be required to utilize this yard; 

therefore, potential contact with contaminated sediments or groundwater is not likely to occur. 

A 660-acre Weyerhaeuser facility located south of MP 198.0 in Klamath County was originally a 

sawmill constructed in 1929. Operation of the mill was discontinued in 1992, and several 

buildings at the site have been demolished. ODEQ records indicate that at this facility an old 

landfill was present where wood waste and painted hardboard was burned and at least one paint 

drum was identified. High concentrations of total petroleum hydrocarbons were observed at the 

sawmill and powerhouse facilities, and a stormwater outfall to the Klamath River was observed 

to have an oily sheen. In addition, sediment contamination was confirmed by high levels of 

arsenic, chromium, copper, mercury, polycyclic aromatic hydrocarbons, and droplets of 

petroleum in most sediment samples. The ODEQ is concerned with groundwater contamination 

at the site and has scored the facility as a high priority for further action. The proposed pipeline 

has been routed to the north and around this site, which is currently occupied by Collins Forest 

Products; therefore, disturbance to contaminated materials is unlikely. Trenching activities 
 4.3 – Water Resources and Wetlands 4.3-8

would occur upgradient of the site, so any groundwater that might be encountered in the trench 

in this area should not be contaminated. If trench dewatering is required in this area, Pacific 

Connector would coordinate with ODEQ to ensure compliance. 

Mac’s Store is located in Klamath County east of MP 206.0. The site is listed in the ODEQ 

hazardous waste site database due to a suspected underground fuel spill. It was recommended 

for site screening in 2001. A site priority evaluation to determine further action began in March 

2006. At this time, no information is available on the level or extent of the contamination. The 

Mac’s Store site is located approximately 0.4 mile east of the proposed pipeline near MP 206.0. 

It is unlikely that trenching activities would encounter any contaminated sediments or 

groundwater potentially associated with this site. Pacific Connector’s proposed Klamath Falls 

North Cross Roads East Construction Yard is located immediately adjacent to the Pacific 

Connector route at MP 206.0 and would be within 0.25 mile of this site. However, because no 

trenching or other excavation activities would occur at this proposed yard, potential contact with 

contaminated groundwater is unlikely. 

The DG Shelter Products site is located in Klamath County and is also the same location as the 

Pacific Connector pipeline’s proposed Klamath Falls Memorial Drive Contractor Yard. This 

site, located near a portion of the Klamath River, was added to the ODEQ’s hazardous site 

database for tracking purposes because it is on ODEQ’s 303d-list for toxics and an Oregon 

Department of Human Services (ODH) health advisory is in effect. Site screening was 

recommended and completed in 2001. Currently, there are no additional actions listed for the 

site. The Pacific Connector pipeline’s proposed Klamath Falls Memorial Drive Contractor Yard 

is located at the DG Shelter Products site. The use of this potential yard would not require any 

excavation activities or ground disturbance; therefore, contact with any potential site 

contamination is unlikely. Prior to utilizing this site as a contractor yard, Pacific Connector 

would further investigate the status of this site with the ODEQ. 

Impacts and Mitigation 

Approximately a dozen comments were received during scoping expressing concern that 

construction and operation of the pipeline would interfere with shallow groundwater flow and 

interrupt or contaminate domestic and irrigation water supplies. Some of these comments were 

general while others expressed concerns at specific locations. One comment expressed concern 

over impacts to the source of water for Glasgow; however, the pipeline has since been rerouted 

in that area and would have no impact on Glasgow’s water supply. Many of the comments 

questioned who would supply water in the event that Wellhead Protection Areas and known 

private wells within 200 feet of the proposed pipeline, as listed above; however, none of these 

are used for domestic supply. Other wells in the vicinity of the proposed pipeline would be 

identified through field investigations and contacts with landowners within and adjacent to the 

proposed pipeline right-of-way prior to construction. Potential impacts to groundwater resources 

and mitigation measure to reduce or eliminate impacts are discussed below. 

The primary pipeline construction activities that could affect groundwater are clearing of 

vegetation, trench excavation and dewatering, soil mixing and compaction, and accidental spills 

of hazardous materials. Although pipeline construction activities could affect groundwater 

resources, potential impact would be avoided or minimized by the use of standard construction 

techniques and adherence to Pacific Connector’s ECRP. 
 4.3 – Water Resources and Wetlands 4.3-9

Clearing and grading can remove vegetation that acts as a filter or affects the groundwater 

recharge rate. Vegetation would only be cleared where necessary, and vegetation would be 

allowed to revert to pre-construction conditions (with certain limitations) upon completion of 

construction. Shallow aquifers could experience minor impacts from changes in overland water 

flow and recharge caused by clearing and grading. 

Trench excavation would be too shallow and too narrow to alter groundwater flow or have a 

significant effect on the major aquifer systems underlying the proposed Pacific Connector 

project. Dewatering of the pipeline trench consists of pumping of groundwater or surface water 

that collects in the trench and would be necessary in areas where there is a high water table (such 

as in alluvium). The potential effect of groundwater withdrawal on aquifer users would depend 

on the rate and duration of pumping. Pipeline construction activities within a particular location 

are typically completed within several days, and any lowering of the groundwater table is 

expected to be temporary and localized. Pacific Connector would minimize the amount of time 

the trench remains open to allow the water table to return to original elevations as soon as 

possible. 

In order to recharge the aquifer and prevent silt-laden waters from flowing into waterbodies and 

wetlands, Pacific Connector would discharge all water from dewatering activities into upland 

areas using straw bale dewatering structures or silt bags. Implementation of these procedures is 

expected to minimize the impact on groundwater during dewatering operations. 

Trenching and dewatering could result in adverse impacts to wells, springs, and wetlands from 

disruption of water supply. Generally these impacts are temporary and water tables should be 

quickly re-established when backfilling is complete. 

Alteration of the natural soil strata or creation of trenches within bedrock could potentially result 

in new migration pathways for groundwater away from waterbodies including springs and seeps. 

Trench plugs would be installed adjacent to streams and wetlands and on slopes to minimize 

water flow into and along the trenchline to prevent potential subsurface erosion, minimizing 

potential stability issues. Trench plugs are installed after the pipeline is installed in the trench 

and prior to trench backfilling. 

To avoid long-term changes in water table elevation and subsurface hydrology, excavated topsoil 

and subsoils would be segregated, where appropriate, and returned as nearly as possible to their 

original soil horizon. With the use of these measures, impacts to groundwater pathways, 

including springs and seeps, are not likely. 

Because pipeline construction activity is generally limited to surface disturbance and shallow 

trenching, is temporary, and is contained within the approved construction work areas, 

groundwater wells (both public and private) beyond 200 feet of the construction work areas are 

not expected to be affected by the pipeline. Pacific Connector would conduct pre-construction 

surveys to confirm the presence and locations of groundwater wells (both public and private). 
 4.3 – Water Resources and Wetlands 4.3-10

Pacific Connector developed a Groundwater Supply Monitoring and Mitigation Plan1 in order to 

identify monitoring and mitigation measures to prevent and/or minimize impacts to groundwater. 

There are three phases to the plan: 

1. Identification of groundwater supplies through records review, field surveys, and 

landowners; 

2. Determination of Susceptibility – Public groundwater supplies may be susceptible to 

adverse impacts; however, none have been identified within 400 feet of the proposed 

construction disturbance. Other groundwater wells, springs, and seeps within 200 feet of 

the proposed construction disturbance that could be susceptible to possible adverse 

effects would be identified prior to construction. Pre-construction monitoring would be 

conducted with landowner permission to establish baseline conditions; and 

3. Monitoring – At the landowner’s request, pre- and post-construction monitoring would be 

conducted for affected wells and seeps. 

Should it be determined after construction that there has been an impact on groundwater supply 

(either yield or quality), Pacific Connector would work with the landowner to ensure a temporary 

supply of water, and if determined necessary, Pacific Connector would replace a permanent 

water supply. Mitigation measures would be coordinated with the individual landowner in order 

to meet the landowner’s specific needs. Mitigation measures for groundwater wells, springs, and 

seeps would be specific to each property and would be determined during landowner 

negotiations. 

Soil Mixing and Compaction

To avoid long-term changes in water table elevation and subsurface hydrology, excavated topsoil 

and subsoils would be segregated within wetlands and agricultural areas, and returned as nearly 

as possible to their original soil horizon. Compaction of soils from the passage of heavy 

machinery could reduce the ability of the soil to absorb or retain water. However, this impact 

would be localized and would not significantly affect groundwater resources and groundwater 

quality. 

Following construction, restoration of most compacted surfaces within the pipeline right-of-way 

would include regrading, recontouring, scarifying (or ripping), and final cleanup activities. 

Decompacting soils would restore infiltration, reduce surface water runoff, minimize erosion, 

and support revegetation efforts. Pacific Connector incorporated USFS and BLM comments 

related to measures and mitigation for soil compaction into the ECRP. The operational 

descriptions meet agency guidelines and contract standards for treating soil compaction. Both 

mechanical and biological mitigation are described. The BOR may accept these measures or 

may require additional measures in their POD. Further discussion of soil compaction is provided 

in section 4.2. 

Pacific Connector would test for soil compaction in agricultural (e.g., active croplands, hayfields, 

and pastures), residential areas, and on USFS, BLM, and BOR lands. On federal lands, the 

maximum extend of detrimental compaction may vary by land management agency or specific 

 

1

 Pacific Connector’s Groundwater Supply Monitoring and Mitigation Plan was filed with the FERC as part of its application on 

September 4, 2007. 
 4.3 – Water Resources and Wetlands 4.3-11

land management plan. Pacific Connector would finalize restoration objectives and methods 

with the federal land management agencies prior to construction in the POD prepared in 

consultation with the agencies. 

Blasting

Pacific Connector identified a number of locations along the proposed pipeline route where 

blasting may be required for pipeline installation (see section 4.1.3.5). As a result of blasting, 

temporary changes in water level and turbidity may affect groundwater quality near the 

construction right-of-way. 

In areas where hard shallow bedrock is encountered, Pacific Connector would first attempt to 

utilize specialized excavation methods to reach the required pipeline design burial depth. These 

excavation methods may include ripping, using hydraulic hammers or rock saws. However, if 

these methods prove to be ineffective or inefficient, blasting may be necessary to achieve the 

required trench depth. Where blasting is necessary, mitigation measures would be incorporated 

into the blasting program to minimize potential adverse impacts to the environment, nearby 

water sources, structures, or utilities. If blasting is required, all applicable federal, state, and 

local regulations would be observed and all necessary permits would be obtained. All blasting 

activities would be conducted by licensed blasting contractors in accordance with all applicable 

regulatory requirements. 

Pacific Connector’s blasting contractor would prepare blasting plans specific to the area to avoid 

potential impacts. The blasting contractor would conduct appropriate pre-construction 

investigations, as needed, and develop specific blasting operation and monitoring plans to 

address site variables (soil and rock types, etc.), which would incorporate locations of existing 

groundwater wells or springs and seeps. Limits would be set for blast peak particle velocity to a 

level that would protect water wells, springs and other nearby structures from any structural 

damage. Should it be determined after construction that there has been an impact on 

groundwater supply (either yield or quality), Pacific Connector would ensure a temporary supply 

of water, and if determined necessary, would replace a permanent water supply. Mitigation 

measures would be coordinated with the individual landowner in order to meet the landowner’s 

specific needs. Pacific Connector has committed to these measures in their Groundwater Supply 

Monitoring and Mitigation Plan. Potential blasting locations, impacts, and control measures are 

also discussed in section 4.1.3.5 and impacts to aquatic species from blasting are discussed in 

section 4.5.2.3. 

Accidental Spills of Hazardous Materials

Groundwater contamination could occur from an inadvertent spill of fuels, lubricants, and other 

materials used during construction. Implementation of proper storage, containment, and 

handling procedures would minimize the chance of such releases. Prompt cleanup responses 

would prevent migration of contaminants to the groundwater. Pacific Connector has developed a 

SPCCP that describes measures that would be implemented to prevent and control inadvertent 

spills of hazardous materials. These measures include, but are not limited to: 

• prohibiting fueling, lubricating, and hazardous material storage in or adjacent to sensitive 

areas; 

• requiring secondary containment for fuels, oils, hazardous materials, and equipment; 
 4.3 – Water Resources and Wetlands 4.3-12

• implementing trench dewatering procedures to prevent contamination (such as using 

pump containment structures and equipment inspection); 

• specifying collection and disposal procedures for wastes generated during equipment 

maintenance; 

• utilizing emergency response procedures; and 

• developing standard procedures for excavation and off-site disposal of any soils 

contaminated by spillage. 

Prior to construction, Pacific Connector would include in the SPCCP the types and quantities of 

hazardous materials that would be stored or used during construction. 

Equipment fueling and storage of fuel, oil, and other fluids during construction could create a 

potential long-term contamination hazard to aquifers. Hazardous liquid spills or leaks could 

contaminate groundwater and affect aquifer users. Soil contamination could continue to add 

pollutants to the groundwater long after a spill has occurred. This type of impact would be 

avoided or minimized by providing secondary containment for fuel, oil, and other hazardous 

chemicals, restricting the location of fueling and hazardous material storage and by requiring 

immediate cleanup in the event of a spill or leak. Pacific Connector would prohibit fueling 

activities and storage of hazardous materials within 200 feet of all private water supply wells and 

within 400 feet of all public supply wells unless done in compliance with the SPCCP. 

Potentially Contaminated Groundwater Sites

While several potentially contaminated groundwater sites have been identified near the proposed 

pipeline, it is not anticipated that contaminated groundwater would be encountered. We 

recommended in the draft EIS that Pacific Connector prepare a plan to address the unanticipated 

discovery of contaminated soils or groundwater during construction. Pacific Connector prepared 

and submitted a draft plan that outlines practices to protect human health and worker safety and 

to prevent further contamination in the event of an unanticipated discovery of contaminated soil, 

water, or groundwater during construction. Measures in the plan include: 

• halting all work in the immediate vicinity where hazardous or unknown wastes are found; 

• notification and response based on site-specific conditions and implementation of 

measures from Pacific Connector’s SPPC Plan, as appropriate; 

• removal and proper disposal of contaminated material in accordance with applicable 

regulations and Pacific Connector’s SPPC Plan; and 

• replacing the contaminated material with clean, uncontaminated soil. A barrier would be 

placed between the clean fill and any remaining contaminated soils if they cannot be 

completely removed. 

4.3.2 Surface Water 

The proposed LNG import terminal would be located on the bay side of the North Spit of Coos 

Bay, Oregon. LNG carriers servicing the terminal would proceed up the waterway about 7.5 

miles within the existing Coos Bay navigation channel. Coos Bay is an inland estuary that drains 

the Coos and Millicoma Rivers and their tributaries, Catching, Isthmus, Pony, South, North and 

Kentuck Sloughs, and Haynes Inlet. 
 4.3 – Water Resources and Wetlands 4.3-13

The Pacific Connector pipeline would cross 218 waterbodies, including the Coos Bay estuary. 

The following section provides additional information on applicable regulations, affected 

waterbodies, and on the potential impacts associated with the construction and operation of the 

Project. 

4.3.2.1 Federal Regulations 

Construction of project facilities that affect waters of the United States would be regulated by the 

COE under section 10 of the RHA and section 404 of the CWA. Section 10 of the RHA 

prohibits the creation of any obstruction to the navigable capacity of any waters of the United 

States without specific approval of the COE. Section 404 of the CWA regulates the discharge of 

dredged or fill material into waters of the United States. 

Construction activities including clearing, grading, excavation, and stockpiling that would 

disturb one or more acres and may discharge to surface waters or conveyance systems leading to 

surface waters of the state would be regulated by the ODEQ under ORS 468B.050 and Section 

402 of the CWA. 

In addition to the COE permitting requirements, the proposed pipeline installation, LNG terminal 

development, and dredging activities would need to comply with section 401 of the CWA. The 

applicant would be required to obtain a section 401 water quality certificate demonstrating that 

the discharges associated with the project comply with federal and state water quality standards. 

The ODEQ is the state agency responsible for section 401 water quality. 

4.3.2.2 Oregon Water Quality Regulations and Standards 

Section 303(c) of the CWA requires states to establish, review, and revise water quality 

standards for all surface waters. To comply with these standards, the ODEQ has developed its 

own unique classification system to describe the highest beneficial use(s) and associated 

minimum water quality standards of identified surface waterbodies within the state. The Oregon 

Water Quality Standards include beneficial use(s), fish use designations, narrative and numeric 

criteria to support the beneficial use(s), and antidegradation policies. The purpose of the 

Antidegradation Policy is to guide decisions that affect water quality such that unnecessary 

further degradation from new or increased point and nonpoint sources of pollution is prevented, 

and to protect, maintain, and enhance existing surface water quality to ensure the full protection 

of all existing beneficial uses (OAR 340-041-0001). 

The state-designated beneficial use classifications for the basins that would be affected by the 

proposed Pacific Connector pipeline are shown in table 4.3.2.2-1. 
 4.3 – Water Resources and Wetlands 4.3-14

TABLE 4.3.2.2-1 

Designated Beneficial Uses for Basins Crossed by the Proposed Pacific Connector Pipeline

South Coast Umpqua Rogue Klamath 

Beneficial Use 

Estuaries and Adjacent Maine Waters All Streams and Tributaries Thereto South Umpqua River Main Stem All Other Tributaries to Umpqua, North and South Umpqua Rivers Rogue River Main Stem From Estuary to Lost Creek Dam Rogue River Main Stem above Lost Dam and Tributaries All Other Tributaries to Rogue River and Bear Creek Klamath River from Klamath Lake to Keno Dam Lost River and Lost River Diversion Channel 

Public Domestic Water Supply X X X X X X X X 

Private Domestic Water Supply X X X X X X X X 

Industrial Water Supply X X X X X X X X X 

Irrigation X X X X X X X X 

Livestock Watering X X X X X X X X 

Wildlife and Hunting X X X X X X X X X 

Fishing X X X X X X X X X 

Boating X X X X X X X X X 

Water Contact Recreation X X X X X X X X X 

Aesthetic Quality X X X X X X X X X 

Hydro Power X X X X X X 

Commercial Navigation and Transportation X X X 

Fish and Aquatic Life a/ X X X X X X X X X 

Source: ODEQ 2006a 

a/ See additional discussion in section 4.5.2 of this EIS. 

Water Quality Limited Waters 

Each state is required, under Section 305(b) of the CWA, to submit a report to the EPA 

describing the status of surface waters in the state biennially. Waterbodies are assessed to 

determine if their use is “fully supported,” “fully supported but threatened,” “partially 

supported,” or “not supported” in accordance with the water quality standards. A use is said to 

be “impaired” when it is not supported or only partially supported. A list of waters that are 

impaired is required by Section 303(b) of the CWA and included in the 305(b) report. To restore 

a waterbody to its use classification, a state may elect to impose restrictions more stringent than 

those normally required by the NPDES or other permitting programs, or even deny a permit for 

activities that adversely affect an “impaired” waterbody. 

States are also required to develop Total Maximum Daily Loads (TMDL) for the impaired 

waterbodies. TMDLs describe the amount of each pollutant a waterbody can receive and not 

violate water quality standards (ODEQ 2006b). To comply with EPA requirements, the State of 

Oregon recently produced a combined report entitled Oregon’s 2004/2006 Integrated Report on 

Water Quality (Integrated Report). The report includes an assessment database containing 
 4.3 – Water Resources and Wetlands 4.3-15

information on the water quality status of waters in Oregon, the assessment methodology used to 

evaluate data, the 2004/2006 303d list, and a schedule for developing TMDLs for waters on the 

Section 303(d) list (ODEQ 2006c). EPA approved the report on February 26, 2007. 

The Integrated Report designates waterbodies according to five Water Quality Assessment 

Categories, which are: 

1. All standards are met (this category is not used). 

2. Attaining - some of the pollutant standards are met. 

3. Insufficient data to determine whether a standard is met. 

− 3a. Potential concern - some data indicate non-attainment of a criterion, but data are 

insufficient to assign another category. 

4. Water quality is limited but a TMDL is not needed. This includes: 

− 4a. TMDL approved - TMDLs needed to attain applicable water quality standards 

have been approved. 

− 4b. Other pollution control requirements are expected to address all pollutants and 

will attain water quality standards. 

− 4c. Impairment is not caused by a pollutant (e.g., flow or lack of flow is not 

considered a pollutant). 

5. Water quality is limited (303d list) and a TMDL is required. 

Section 303(d) List 

The Integrated Report was reviewed to determine the locations of the Category 5 (303d list) 

water quality limited waters to determine if they are in the vicinity of Project components. The 

Port’s slip and access channel would involve dredging in Coos Bay. This waterbody was added 

to the Oregon 303(d) list in 2004 for fecal coliform contamination. 

Based on the ODEQ Integrated Report, Category 5 waterbodies that would be crossed by the 

pipeline are shown in table 4.3.2.2-2. TMDLs for the South Umpqua subbasin were completed 

in October 2006. TMDLs for the Upper Rogue subbasin were completed in December 2008. 

TMDLs for the Coos, Coquille, Upper Klamath River, and Lost River subbasins are in progress. 

Pacific Connector proposes to cross 25 of these waterbodies using dry open-cut crossing 

techniques. Conventional boring or HDD methods would be used to cross 4 of the impaired 

waterbodies. Only the Coos Bay estuary would be crossed using wet open-cut trenching. 

TABLE 4.3.2.2-2 

303(D) Category 5 Listed Waterbodies Crossed by the Proposed Pacific Connector Pipeline

Waterbody Crossing Method 

FERC 

Classification a/ Stream Type 303(d) Category 5 Listing 

Coos Bay Wet Open-Cut Major Estuary Fecal Coliform/Year-Round 

Kentuck Slough Conventional Bore Intermediate Perennial Fecal Coliform/Year-Round 

Willanch Slough Dry Open-Cut Intermediate Perennial Fecal Coliform/Year-Round 

Coos River HDD Major Perennial Fecal Coliform/Year-Round 

Stock Slough Dry Open-Cut Intermediate Perennial Fecal Coliform/Year-Round 

Catching Slough Conventional Bore Major Perennial Fecal Coliform/Year-Round 
 4.3 – Water Resources and Wetlands 4.3-16

TABLE 4.3.2.2-2 

303(D) Category 5 Listed Waterbodies Crossed by the Proposed Pacific Connector Pipeline

Waterbody Crossing Method 

FERC 

Classification a/ Stream Type 303(d) Category 5 Listing 

Ross Slough Dry Open-Cut Minor Perennial Fecal Coliform/Year-Round 

Catching Creek Dry Open-Cut Minor Perennial Fecal Coliform/Year-Round 

Cunningham Creek Dry Open-Cut Intermediate Perennial Fecal Coliform/Year Round; 

Dissolved Oxygen/Year Round 

North Fork Coquille 

River 

Dry Open-Cut Intermediate Perennial Dissolved Oxygen/Year-Round (nonspawning) Temperature/Year-Round 

Middle Creek Dry Open-Cut Intermediate Perennial Temperature/Year-Round (nonspawning) 

East Fork Coquille River Dry Open-Cut Major Perennial Temperature/Summer 

Elk Creek Dry Open-Cut Minor Perennial Temperature/Year-Round (nonspawning) 

Upper Rock Creek Dry Open-Cut Intermediate Perennial Temperature/Summer (non-spawning) 

Middle Fork Coquille 

River 

Dry Open-Cut Intermediate Perennial Temperature/Summer (non-spawning) 

Olalla Creek Dry Open-Cut Intermediate Perennial Biological Criteria; Temperature/YearRound; Iron/Year-Round 

Rice Creek Dry Open-Cut Major Perennial Temperature/Summer (non-spawning) 

South Umpqua River Diverted Open-Cut Major Perennial Fecal Coliform/Summer; Biological 

Criteria; Aquatic Weeds or 

Algar/Summer; Dissolved Oxygen/Year 

Round (non-spawning); 

Temperature/Year-Round (non 

spawning); Chlorophyll a/Summer; E 

Coli/Summer; pH/Summer 

North Myrtle Creek Dry Open-Cut Intermediate Perennial Temperature/Year-Round (nonspawning; E Coli/Summer 

South Myrtle Creek Dry Open-Cut Intermediate Perennial Temperature/Year-Round (nonspawning) 

Fate Creek Dry Open-Cut Intermediate Perennial Temperature/Year-Round (nonspawning) 

Days Creek Dry Open-Cut Intermediate Perennial Temperature/Year-Round (nonspawning) 

South Umpqua River Diverted Open-Cut Major Perennial Fecal Coliform/Summer; Biological 

Criteria ; Aquatic Weeds or 

Algar/Summer; Dissolved Oxygen/Year 

Round; (non-spawning); 

Temperature/Year-Round (non 

spawning); Chlorophyll a/Summer; E 

Coli/Summer; pH/Summer 

West Fork Trail Creek Dry Open-Cut Intermediate Perennial Dissolved Oxygen/Summer 

Lick Creek Dry Open-Cut Intermediate Intermittent Dissolved Oxygen/Summer; E 

Coli/Summer 

Salt Creek Dry Open-Cut Intermediate Perennial E Coli/Year-Round 

North Fork Little Butte 

Creek 

Dry Open-Cut Intermediate Perennial Temperature/Summer; E Coli/Fall, 

Winter, Spring; pH/Summer 

South Fork Little Butte 

Creek 

Dry Open-Cut Intermediate Perennial Temperature/Summer b/; E 

Coli/Summe b/; Sedimentation b/

Spencer Creek Dry Open-Cut Minor Perennial Biological Criteria; Sedimentation; 

Temperature/Year-Round 

Clover Creek Dry Open-Cut Minor Intermittent Sedimentation 

Klamath River HDD Major Perennial Dissolved Oxygen/Year-Round (nonspawning); Ammonia/Year-Round; 

Chlorophyll a/Summer; pH/Summer 
 4.3 – Water Resources and Wetlands 4.3-17

TABLE 4.3.2.2-2 

303(D) Category 5 Listed Waterbodies Crossed by the Proposed Pacific Connector Pipeline

Waterbody Crossing Method 

FERC 

Classification a/ Stream Type 303(d) Category 5 Listing 

Lost River Dry Open-Cut Major Perennial Dissolved Oxygen/Year-Round (nonspawning); Ammonia/Year-Round; 

Chlorophyll a/Summer 

a/ Minor waterbody includes all waterbodies less than or equal to 10 feet wide at the water's edge at the time of construction; intermediate 

waterbody includes all waterbodies greater than 10 feet wide but less than or equal to 100 feet wide at the water's edge at the time of 

construction; and major waterbody includes all waterbodies greater than 100 feet wide at the water's edge at the time of construction. 

b/ Water quality limited within one mile of crossing, not at point of crossing. 

4.3.2.3 Waterway for LNG Marine Traffic 

Coos Bay, and the tributaries that flow into Coos Bay lie within the USGS-designated watershed, 

Coos Bay (USGS Cataloging Unit: 17100304). The watershed covers an area of approximately 

739 square miles of Oregon’s southern coastal range, and is included in the larger South Coast 

Watershed Basin. 

LNG carrier activity, including prop wash, at the unloading facilities may result in minor 

resuspension of bottom sediments into the water column resulting in a temporary increase in 

turbidity within the slip. Resuspension of bottom sediments and resulting increases in turbidity 

are considered temporary short-term impacts. Use of shallow draft tugs to assist LNG carriers 

throughout the mooring and departure operations may result in some resuspension of bottom 

sediments and increase turbidity over the short term until the bottom sediments become 

stabilized. 

LNG carriers that would deliver LNG to the proposed facilities would transit offshore waters 

before entering Coos Bay to off-load cargo at the proposed LNG terminal. Accidental spills or 

releases of hazardous materials could occur along the transit route from the open ocean into Coos 

Bay. However, the primary carrier-related impacts to water resources in Coos Bay would be 

associated with operational intakes and discharges, particularly of cooling water, while berthed at 

the proposed slip. The cooling water requirements, however, are similar to those of all dieseland steam-powered commercial vessels currently transiting Coos Bay. While in transit offshore 

in the open ocean and within Coos Bay, LNG carrier operations and any resulting impacts to 

water resources would be comparable to typical shipping traffic, and would need to comply with 

international and U.S. shipping regulations. 

The municipal waste treatment plant for the cities of North Bend and Coos Bay is within 1.0 mile 

of the LNG carrier transit route, overlapped by Zone of Concern 3. It is possible that a 

flammable vapor cloud from an LNG cargo spill, if ignited, could affect the municipal water 

treatment plant. Zone of Concern 3 would have the lowest level of impacts in the unlikely 

incident where LNG is spilled from a carrier and vapor ignited. However, if the 

recommendations of the Coast Guard outlined in the WSR would be implemented, the possibility 

of such an incident would be remote, so there should be no adverse impacts on existing water 

facility infrastructure as a result of LNG marine traffic in the waterway. 
 4.3 – Water Resources and Wetlands 4.3-18

Ballast Water and Ship Engine Cooling 

Because the LNG carriers would be fully loaded when arriving at the proposed terminal, it is 

unlikely that any ballast water would be discharged into Coos Bay. However, as the LNG cargo 

is unloaded, a carrier would take on water to maintain trim and stability and for cooling engines 

while docked at the terminal. Potential impacts on water quality and aquatic resources due to 

ballast water intake and engine cooling water appropriations and discharges are discussed in 

sections 4.3.2.4 and 4.5.2. 

Release of LNG or Fuel 

Spills, leaks, or other releases of hazardous materials during the LNG carrier transit could 

adversely impact water quality of the bay or the ocean. The addition of 80 LNG carriers to the 

existing ship traffic would increase the probability of potential spills. Jordan Cove has prepared 

a draft Emergency Response Plan for the operational phase of the terminal to minimize the 

potential for accidental releases of hazardous materials and to establish proper protocol 

concerning minimization, containment, remediation, and reporting of any releases that might 

occur. 

In the unlikely event that LNG is spilled into the water from an accidental or intentional breach 

of an LNG carrier during transit, the cryogenic liquid would vaporize rapidly upon contact with 

the warm air and water. Being less dense than water, LNG would float on the surface before 

vaporizing. Because LNG is not soluble in water and would completely vaporize shortly after 

being spilled, the LNG could not mix with or contaminate the water. 

If the LNG vapor cloud were to burn, shoreline vegetation along the Coos Bay navigation 

channel could be damaged; however, the area of effect resulting from an LNG release and any 

resulting fire would be fairly limited and short-lived. Affected areas would likely revegetate 

naturally except possibly in the immediate vicinity of the breach. With implementation of the 

mitigation measures recommended by the Coast Guard (see Appendix B), a release would be 

highly unlikely; therefore, it is unlikely that there would be an increase in shoreline erosion, and 

resultant impacts to water quality, due to the loss of shoreline vegetation as a result of a 

catastrophic LNG spill being ignited. 

A catastrophic loss of an LNG carrier could result in other petroleum products (lubricating oil 

and fuel, if the vessel uses diesel or Bunker C oil) being released to the water column. This type 

of release would adversely affect water quality. Fuel (e.g., diesel) used for vessel propulsion or 

auxiliary/emergency generators on an LNG carrier could potentially spill or leak. However, fuel 

on each carrier is protected by the vessel’s double hull. Furthermore, each LNG carrier would 

maintain a Shipboard Oil Pollution Emergency Plan (SOPEP) as required by international 

convention. The SOPEP would comply with MARPOL [marine pollution] 73/78 Consolidated 

Edition 2002 Annex 1 Regulation 26, which requires every oil tanker of 150 tons gross and 

above, and every vessel of 400 tons gross and above to carry an approved SOPEP. All LNG 

carriers would also be required to comply with state spill prevention and contingency plans. 

The impacts associated with routine vessel activity, such as sediment resuspension and increased 

turbidity, would be minor and short term. With the implementation of the Emergency Response 

Plan and each vessel’s SOPEP, impacts resulting from the spill of oil or other hazardous 

chemicals are unlikely. The primary potential carrier-related impact to water resources would be 
 4.3 – Water Resources and Wetlands 4.3-19

associated with operational intakes and discharges while at the slip (discussed further below 

under operational impacts and mitigation for the LNG terminal). 

4.3.2.4 LNG Terminal 

The primary surface waterbody associated with the proposed Jordan Cove LNG terminal is Coos 

Bay. The Coos Bay navigation channel forms the southern boundary of the Port’s proposed slip 

site, which, in turn, forms the southern border of the proposed LNG terminal site. Jordan Lake is 

located approximately 0.4 miles to the east of the proposed LNG terminal site and Henderson 

Marsh borders the western side of the site. Other than Coos Bay, there are no other on-site 

surface waterbodies that would be affected by the construction of the LNG terminal. 

Construction Impacts and Mitigation 

Dredging of Slip and Access Channel

Construction of the slip and access to the channel would require the excavation and dredging of 

approximately 4.3 million cy (2.3 million cy excavated and 2.0 million cy dredged) and an 

additional 1.3 million cy to be dredged from the access channel, for a total of 5.6 million cy. The 

Port would use hydraulic cutterhead dredging to excavate the access channel. Studies by the 

COE indicate that cutterhead dredging generally results in lower sediment resuspension than 

other forms of dredging (e.g., clamshell or hopper barge) (COE 1986; COE 1988). Dredging 

operations to create the access channel would suspend sediments and affect water quality in Coos 

Bay. In general, dredging-related water quality impacts would include both the physical effects 

of suspended sediment and alterations of water chemistry due to the release of various chemical 

constituents associated with the sediment. 

Approximately 41 acres of the 72 acres to be dredged for the slip and access channel would be 

conducted in isolation from the waters of Coos Bay. While this area is being excavated and 

dredged, a berm would remain intact to provide complete separation of the excavation and 

dredging activities from the bay, resulting in no turbidity being released to the waters of Coos 

Bay. 

The remaining area to be dredged, including removal of the berm, would result in temporary 

siltation and sedimentation impacts similar to those that currently occur during maintenance 

dredging activities. On the average, the COE removes approximately 550,000 cy from the sand 

bar near the mouth of Coos Bay, 200,000 cy from CM 2-12 and 150,000 cy from CM 12-15 each 

year. In comparison, approximately 500,000 cy would be removed in the water during the 

removal of the berm separating the slip, and during creation of the access channel. Because the 

duration of the dredging in the bay would be 4 to 6 months, the turbidity created would be 

relatively short term and localized. Long-term turbidity effects, lasting more than 3 to 5 years, 

would not result from the construction dredging. Maintenance dredging is discussed further 

below. 

Dredging activities would temporarily stir up sediment and degrade the water quality in the area 

of the dredging, which in turn, may extend out into the Coos Bay. It is anticipated that the 

pumps used to convey the material from the cutter heads, in a hydraulic dredging operation, 

would serve to contain most of the siltation caused by the dredging as the siltation would be 

conveyed with the material removed to the confined disposal area (CDF) where it would be 
 4.3 – Water Resources and Wetlands 4.3-20

decanted within the CDF, allowing the suspended solids to settle out, effectively resulting in 

clear water to be returned to the slip. The suspended solids and turbidity levels in Coos Bay 

would decline to ambient levels following completion of dredging activities. Turbidity resulting 

from dredging could cause a temporary decline in water quality in the area of the slip and access 

channel. The suspension of organic materials and sediments could cause an increase in the total 

suspended solids (TSS) in the area of the slip and access channel. Lower dissolved oxygen 

concentrations could cause a decrease in available dissolved oxygen within the affected area. 

Jordan Cove submitted its Report on Turbidity Due to Dredging2

 that included a modeling 

analysis of the turbidity that would be generated by the proposed dredging operation at the slip 

and access channel, which showed that the proposed dredging for the slip would be unlikely to 

have significant adverse effects on Coos Bay. The model was developed on the basis of a 

sediment analysis conducted at the site of the dredging and took into consideration wind, tidal 

currents, and seasonal flows. The ambient turbidity levels in the water (generated by flows, 

waves and ship traffic) create a background level of turbidity, ranging by season from 3.7 to 18.1 

nephelometric turbidity units (NTUs), thereby reducing the relative impact of dredging-related 

turbidity. The model indicated that for the hydraulic cutterhead dredge the TSS levels would be 

a maximum of 500 mg/l in the vicinity of the dredge and would rapidly reduce to a maximum of 

14 mg/l by a distance of 60 meters (200 feet). More information is provided in section 4.5.4.2. 

Specifications and guidelines for dredging would comply with those established by the COE for 

dredging in the area, including but not limited to the following: 

• evaluation of dredge material to test for contaminated sediments; 

• Endangered Species Act coordination; and 

• disposal site assessment in accordance with the MPRSA. 

Resuspension of sediments during dredging operations can be a significant source of turbidity; 

however, through proper operational controls and the potential use of physical barriers, this 

source can be controlled. 

Dredged Material Placement

The estimated 5.6 million cy of excavated and dredged material resulting from construction of 

the slip and access channel would be placed at three upland sites: 1) property owned by Jordan 

Cove; 2) placement facilities constructed at the site of the former Weyerhaeuser Linerboard Mill 

site (Linerboard East and West sites); and 3) property owned by the Port. Ultimately, the Port 

would be responsible for coordinating with COE regarding all necessary permits and dredged 

material disposal. 

While the material is being placed and then again following final placement of material and final 

stabilization of the Port site, the area would be contoured and stabilized with native grasses. At 

completion a minimum of two rows of silt fence would be installed at the toe of the berms 

surrounding the placement sites to contain the movement of the sand by wind or water forces. 

The exterior of the berms would be covered in erosion control matting and seeded with native 

 

2

 Jordan Cove filed its Report on Turbidity Due to Dredging in Appendix B.2 to Resource Report 2 as part of its application to 

the FERC. 
 4.3 – Water Resources and Wetlands 4.3-21

grasses. The material from the construction of the slip placed on the Port site would be stored 

temporarily until it is sold for commercial uses and removed by barge from the site. 

During the dredging of the slip, the water used to hydraulically convey the material dredged to 

the storage sites (slurry water) would settle at the dredged material disposal areas before being 

transported back to the slip area either by gravity flow or via mechanical pumping. While the 

slip dredging is isolated from Coos Bay by the berm, there would be no turbidity released to 

Coos Bay. 

Facility Water Supply and Discharges

No on-site surface waters would be used in the construction of the proposed LNG terminal. All 

the water to be used would come from the existing CBNBWB line. The water provided by the 

CBNBWB would be obtained from groundwater wells located on the North Spit, as well as two 

reservoirs (Upper Pony Creek Reservoir and the Joe Ney Reservoir). Hydrants from taps to the 

water line would be placed in construction areas to provide water for the concrete batch plant, 

compaction during site grading (if required), dust suppression during construction, hydrostatic 

testing and any other construction activity requiring water. Hydrostatic testing water and 

stormwater discharges are discussed below. 

Hydrostatic Testing

Water used for hydrostatic testing of the LNG storage tanks would be potable water obtained 

from the existing CBNBWB line. Testing would require approximately 28.25 million gallons. 

The 28 million gallons used to test the first tank would be transferred to the second tank, 

effectively using that quantity of water twice, reducing the total volume of water required for 

testing. An additional 0.25 million gallons would be required as make-up water for the second 

test. No biocides or chemicals would be added to the hydrostatic test water since it is potable 

water that has already been treated by the CBNBWB. The test water would be discharged into 

the industrial wastewater pipeline via the firewater pond, ultimately connecting to a previously 

existing permitted ocean discharge point. Ten million of the 28.25 million gallons used to 

hydrotest the LNG storage tanks would be retained in the firewater pond, further reducing the 

amount of water required from the CBNBWB. 

The rate of discharge is expected to be approximately 1.8 million gallons per 24 hours for the 

bulk pumping operation, with substantially lower rates being achieved when removing the final 

amounts of water from the tank bottom. Test water discharge would be subject to ODEQ 

authorization and would be sampled and tested for suitability prior to discharge. If treatment is 

found to be required, treatment procedures would be developed in consultation with ODEQ prior 

to discharge. 

Stormwater Runoff

During construction of the LNG storage tanks and other LNG terminal facilities, disturbed soils 

would be exposed to potential erosion. To minimize the impacts of erosion and sedimentation on 

surface waters, land-disturbing and construction activities would be conducted in compliance 

with the NPDES permit (1200-C) for stormwater discharges during construction activities. 

Stormwater runoff from the disturbed portions of the site would be managed in accordance with 

a site-specific ECRP, which incorporates stormwater pollution prevention. Jordan Cove and the 

Port would install all necessary erosion and sedimentation control structures in compliance with 
 4.3 – Water Resources and Wetlands 4.3-22

the ECRP. Following appropriate treatment, all construction stormwater from the proposed LNG 

terminal site would be directed towards the slip. 

Accidental Spills or Leaks of Hazardous Materials

Spills, leaks, or other releases of hazardous materials during construction of the proposed LNG 

terminal could also adversely affect water quality. Hazardous materials entering Coos Bay resulting 

from material spills being flushed into waterbodies with stormwater runoff or entering Coos Bay 

directly from leaks or spills at the LNG unloading berth could have an adverse impact on water 

quality and aquatic organisms. Jordan Cove has prepared a draft SPCCP for both construction and 

operational phases to minimize the potential for accidental releases of hazardous materials and to 

establish proper protocol concerning minimization of, containment of, remediation of, and reporting 

of any releases that might occur. Measures to reduce the risk of hazardous material spills and 

minimize impacts should a spill occur include, but are not limited to: 

• All employees handling fuels and other hazardous substances would be properly trained; 

• Hazardous substances, including chemicals, oils, and fuels, would not be stored within 

100 feet of a waterbody or wetland boundary; 

• All equipment would be parked overnight and fueled at least 100 feet from a waterbody 

or in an upland area at least 100 feet from a wetland boundary. 

• Secondary containment or diversionary devices would be required for all containers 55 

gallons or larger. Discharge prevention measures include dikes, retaining walls, curbing, 

weirs, booms, diversion ponds, retention ponds, and absorbent materials. The secondary 

containment systems would be adequate to contain the content of the largest container 

plus sufficient freeboard for precipitation (i.e., 110 percent). 

• All drainage of accumulated stormwater from containment systems would be inspected to 

ensure no visible sheen is present and the condition documented prior to discharge. 

Should a spill occur, Jordan Cove would implement containment actions identified in the SPCCP 

and notify the appropriate agencies based on the type, volume, and location of the spill. While a 

hazardous material spill has the potential for significant adverse environmental impacts, 

adherence to the SPCCP would greatly reduce the likelihood of such impacts, as well minimize 

the resulting impacts should a spill occur. As such, significant adverse impacts to surface water 

due to contamination from hazardous material spills or releases are unlikely. 

Operation Impacts and Mitigation 

Stormwater Runoff

Following construction of the LNG terminal facilities, approximately 15.8 acres of the 159-acre 

site would consist of impervious surface area. The stormwater management system is designed 

and constructed to accommodate this increase in runoff volume and to direct any flow that does 

not come into contact with any equipment containing potential contaminants to the slip. During 

operations stormwater flows that could come into contact with equipment containing potential 

contaminants would be directed to a holding area in the firewater pond where they would be 

tested before being released to the firewater pond and ultimately discharged through the NPDES 

permitted discharge. 
 4.3 – Water Resources and Wetlands 4.3-23

Maintenance Dredging of the Slip and Access Channel

The volume of maintenance dredged material from the slip and access channel is estimated to be 

approximately 350,000 cy every 2 years, which is about the same total amount that the COE 

removes from CM 2-12 over the same duration. Future maintenance dredging of the slip and 

access channel would likely be conducted using a mechanical clamshell dredge, which consists 

of a close-lipped bucket operated from a floating barge. A close-lipped bucket is specifically 

designed to reduce sediment resuspension into the overlying water column by forming a seal 

when the bucket is retrieved to the surface in the closed position. The material removed by 

clamshell dredging would be placed on either a flat-deck barge with watertight sideboards, or a 

bin-barge with one or multiple cells. The material would be transported to the EPA designated 

offshore Site F for disposal. 

Coos Bay Site F is located in the Pacific Ocean, about 1.75 miles north-northwest of the north 

jetty at the mouth of Coos Bay. The site is owned by the State of Oregon out to the 3 mile 

territorial limit, and the remainder by the COE. This is an existing EPA-approved offshore 

placement site, used by the COE since 1986 to dispose of materials dredged during maintenance 

of the Coos Bay navigation channel, in accordance with section 103 of the Marine Protection, 

Research, and Sanctuary Act (MPRSA). The site was expanded in 1989, 1995, and 2006, so that 

it now encompasses about 3,075 acres, with water depths ranging from 20 to 160 feet. The 

maintenance dredging plan, including disposal, would need to be approved by the COE. While 

the COE has indicated to the Port that this site has the capacity to take in the operational 

maintenance dredging of the LNG terminal access channel and slip, which over 20 years would 

be a total of about 3.5 mcy of material, the EPA has stated that the applicant would still be 

required to demonstrate that the site could accommodate this dredge material without adverse 

effects on short- to medium-term site capacity. If subsequent redistribution of material did not 

occur at a fast enough rate, and mounding to a depth of less than -50 feet MLLW were to take 

place, the COE and EPA could take immediate action to avoid wave attenuation at the ocean 

surface, and to avoid compromising navigation safety; possibly including reducing or avoiding 

disposals in certain parts of the site, or if necessary, closing site F to use. To ensure that Site F 

could be used for the proposed maintenance dredging while considering the needs and 

characteristics defined by the COE and EPA for this site, we recommend that:

• Prior to commissioning of the LNG terminal, Jordan Cove should file with the 

Secretary a Maintenance Dredging Plan, developed in consultation with the COE 

and EPA, that outlines procedures for the disposal of materials resulting from 

maintenance dredging of the LNG terminal access channel and slip at Site F, to 

ensure that the site capacity is not significantly inhibited. The plan should be 

specific, consider the needs and characteristics of Site F defined by the COE and 

EPA, address the types and volumes of materials to be deposited, methods of 

disposal, frequency, and location, and include any necessary monitoring provisions. 

Maintenance dredging of the slip and dumping of the Jordan Cove LNG terminal maintenance 

dredge material would occur during in-water work windows established by the ODFW. A more 

detailed description of the proposed use of offshore disposal Site F is provided in Moffatt and 

Nichol (2007). 
 4.3 – Water Resources and Wetlands 4.3-24

No dewatering of dredge material would occur in Coos Bay. Based on the turbidity modeling 

conducted for this maintenance dredging, the effects are predicted to be localized and relatively 

short term. During maintenance dredging activities, the proposed dredged material is assumed to 

be primarily fine particles (mud, clay, silt). Soil concentrations predicted with the DREDGE 

model for the open “clamshell” dredge were lower than during the construction stage with the 

maximum of 830 mg/l in the vicinity of the dredge and decreasing to 125 mg/l at approximately 

660 feet. 

Distribution of the generated turbidity plume depends on location of the dredge machine in the 

channel and basin area. For dredging with an open “clamshell” dredge in the channel the 

generated sediment plume (concentration higher than 150 mg/l) can move up to 1.2 to 1.9 miles 

from the dredging location at highest ebb or flood currents; however, the duration of such 

entrainment is limited by not more than a 2-hour period and the time average concentrations do not 

exceed natural ambient concentrations (10 to 30 mg/l) outside the dredging area. During 

maintenance dredging with an open “clamshell” dredge, the maximum concentrations in the 

generated plume do not exceed 50 mg/l. Therefore, the distribution of the generated turbidity 

plume is assumed to be greater in the channel as opposed to the basin area. Resuspension of 

sediments during dredging operations can be a significant source of turbidity; however, through 

proper operational controls and the potential use of physical barriers, this source can be controlled. 

Water Supply and Discharge

No on-site surface waters would be used for operation of the proposed LNG terminal. All the 

water to be used would come from the existing CBNBWB line. The water provided by the 

CBNBWB would be obtained from groundwater wells located on the North Spit, as well as two 

reservoirs (Upper Pony Creek Reservoir and the Joe Ney Reservoir). 

During operation of the proposed LNG terminal, water from the CBNBWB line would provide 

the potable water requirements for the various buildings, the initial filling of the fire water pond, 

and any water needed to supplement the water from the fire water pond in the event of an 

emergency. No intakes would be placed in the bay or any other surface waterbodies for 

emergency fire water requirements. No surface water from the bay or any other surface 

waterbodies would be required for the vaporization of LNG or any other related processes. 

Water is produced as part of the vaporization process and would be used to maintain the fire 

water pond with excess water discharged through the existing industrial wastewater pipeline. 

Because water supply would come from the existing CBNBWB system, or from the vaporization 

process (discussed below), there would be no impacts to site surface waters resulting from water 

uses. No municipal water supplies or watershed protection areas would be disturbed by the 

construction of the proposed LNG terminal. Coos Bay, the primary surface waterbody, is not a 

suitable source for potable water; thus there are no potable water intake sources that would be 

affected by the proposed LNG terminal. 

During the operation of the LNG terminal, each SCV would produce approximately 20 gpm of 

water from the combustion process. With five SCVs operating, approximately 100 gpm, or 

144,000 gallons per day (gpd) would be generated. This water would be slightly acidic and 

would be neutralized before being conveyed to the fire water pond where it would be used to 

recharge the pond and the overflow discharged to the industrial wastewater pipeline, which 
 4.3 – Water Resources and Wetlands 4.3-25

ultimately discharges to the ocean. Jordan Cove would apply for a new NPDES permit for this 

discharge. The industrial wastewater pipeline has a design capacity of 30 mgd. At its peak use 

the pipeline handled approximately 2.5 to 3.5 mgd from the paper mill. The only flow currently 

through the industrial wastewater pipeline is 500,000 gpd purchased by Weyerhaeuser from the 

Coos Bay North Bend CBNBWB that is passed through the pipeline to keep the ocean diffusers 

operational. The Port has committed one mgd to another user, which would still allow sufficient 

capacity for the 144,000 gpd overflow from the fire water when the pond is filled to its capacity 

of 10 million gallons. 

Accidental Spills or Leaks of Hazardous Materials

As discussed above for construction, spills, leaks, or other accidental releases of hazardous 

materials during operation could adversely affect water quality. Hazardous materials entering 

Coos Bay resulting from material spills being flushed into waterbodies with stormwater runoff or 

entering Coos Bay directly from leaks or spills at the LNG unloading berth could have an 

adverse impact on water quality and aquatic organisms. Jordan Cove’s draft SPCCP includes the 

operational phase of its proposed project and is intended to minimize the potential for accidental 

releases of hazardous materials and to establish proper protocol concerning minimization of, 

containment of, remediation of, and reporting of any releases that might occur. 

While a hazardous material spill has the potential for significant adverse environmental impacts, 

adherence to the SPCCP would greatly reduce the likelihood of such impacts, as well minimize 

the resulting impacts should a spill occur. As such, significant adverse impacts to surface water 

due to contamination from hazardous material spills or releases are not anticipated. In the 

unlikely event of a spill or leak of hazardous material to Coos Bay, Jordan Cove would work 

with the appropriate agencies to identify appropriate cleanup and remediation measures 

appropriate to the material released and the timing and location of release. 

Ballast and Cooling Water Intake

During operation of the proposed LNG import terminal, two sources of water intake would occur 

for carriers arriving at the terminal: ballast water for vessel stability and cooling water needed 

for carrier power plant operations. Carriers delivering LNG to the terminal would take in ballast 

water as they unload. Additional water would be added once they have left the facility. The 

quantity of water used for these two items depends primarily on size and type of vessel, duration 

of unloading, time at the dock, and power source used while at the dock. Generally, there are 

two size carriers that are currently in use for LNG transport, those of about 145,000 m3, and 

those about 220,000 m3. As proposed, the Jordan Cove facility could only accept the smallersized carriers. These carriers are either diesel engine, or steam-turbine engine driven. The 

majority of smaller class boats are steam-turbine engines (CH2MHill 2007). Steam-turbine 

vessels use much more water for cooling than the diesel engine vessels. Generally, the whole 

operation from arrival to departure at the dock would last about 24 hours, but actual off loading 

of the LNG would occur in about half that time. Another factor is the potential for the carrier to 

use land-based power to augment power needs of the vessel while at dock. This is referred to as 

“cold ironing.” Jordan Cove has proposed the option of doing partial “cold ironing” while 

carriers are at the dock; however, they acknowledged that due to the various vessels that may be 

used, it may not be feasible. They are continuing to pursue this option to minimize water use and 

vessel engine emissions. 
 4.3 – Water Resources and Wetlands 4.3-26

Jordan Cove supplied estimates for both ballast water use and cooling water needs based on 

assumptions of the factors noted above. We have augmented these estimates with information 

from two other sources. One is a document supplied to FERC for Oregon LNG that provides 

estimates for potential vessel and offloading scenarios (CH2MHill 2007). The other is a FERC 

EIS prepared for the proposed Broadwater LNG project (FERC 2008). For this analysis, we 

have selected some values that may differ from those used by Jordan Cove. 

Jordan Cove estimated a range of cooling water intake rates, with a low of 1,250 m3/hr (330,215 

gallons per hour) based on diesel engine vessels using some shore power. CH2MHill (2007) 

estimated about 6,300 m3/hr (1,664,284 gallons per hour) for cooling water use, while for the 

Broadwater EIS (FERC 2008) we used the highest value of about 9,800 m3/hr (2,588,886 gallons 

per hour). The range of potential cooling water and ballast water requirements are shown in 

table 4.3.2.4-1. Based on the current vessel characteristics available in the fleet and the unknown 

likelihood of using shore-based power, the higher estimate of water use is most likely to be 

representative of this Project. 

TABLE 4.3.2.4-1 

Estimates of LNG Carrier Water Use and Use Rate While at Dock

Range 

Time to 

Offload (hr) a/

Total 

Dock Time 

(hr) 

Ballast Intake 

Rate (M3/hr) b/

Ballast Volume 

(M3) c/

Cooling Intake 

Rate (M3/hr) d/

Cooling 

Volume (M3) 

Total Intake 

Volume (M3) 

Low 13 24 2,600 34,000 1,250 30,000 64,000 

High 13 24 3,900 50,000 9,800 235,000 285,000 

a/ Jordan Cove response to FERC data request from January 23, 2009, Attachment 9-1 

b/ All ballast intake occurs during offloading. 

c/ Low value from Jordan Cove, high value from FERC 2008, 

d/ Low value assumes some power supplied from land and vessel has diesel engine, high from FERC 2008 with no land power 

and vessel has steam turbine engine. 

These LNG carriers would take in about 34 to 50 thousand m3 (about 9 to 13 million gallons) of 

water for ballast. Combined with the cooling water intake, the total water intake could range 

from about 64 to 285 thousand m3 (about 17 to 75 million gallons). This would range from 

about 2 to 8 percent of the slip volume, which is about 3.7 million m3 (977 million gallons) in 

volume. Considering that the slip volume is a very small portion of the total bay volume, and 

that Bay water is replaced frequently from the tides and river inflow, water use would be a very 

small portion of the bay water with either water use scenario. 

Current regulations require that ballast water be exchanged at least 200 nautical miles offshore 

where the water depth is at least 660 feet prior to entering U.S. ports in order to minimize the 

likelihood of introducing invasive species from foreign waters. As part of the International 

Convention for the Control and Management of Ships’ Ballast Water and Sediments, the 

International Maritime Organization may institute more stringent requirements for the control of 

invasive organisms in ballast water, provided the convention is ratified by at least 30 member 

states (only 8 have currently ratified it). Under the 2004 convention, all ships with ballast water 

capacity more than 5,000 m3 (which would include all LNG carriers) would be required to follow 

Ballast Water Exchange and/or Performance Standards, which include testing to demonstrate that 

potentially harmful organisms either are not present or are present in very small quantities. In 

September 2006, a federal district court ruled that by September 30, 2008, EPA needs to take 
 4.3 – Water Resources and Wetlands 4.3-27

specific action to ensure that shipping companies comply with the intent of the CWA and restrict 

the discharge of ballast water into U.S waters (Buck 2006). While EPA has not developed 

specific actions, LNG carriers calling on the proposed Jordan Cove LNG terminal would be 

required to comply with any future EPA discharge requirements. 

One other minor water use during offloading is side-shell water curtain water. It is discharged 

from ballast water storage into the hull area near the offload site to maintain hull integrity and 

may be at about 30 m3/hr, less than 1 percent of the total water intake of other sources (cooling 

and ballast water intake), and would be insignificant relative to overall water usage. 

Currently, due to variability of sea chest openings, and effects externally applied screens may 

have on water intakes, no screening system are being developed for the water intakes on the 

LNG carriers beyond those already in place. This is discussed further in section 4.5. 

Vessel Discharge

LNG carriers would discharge water throughout the transit route from the territorial sea to the 

proposed terminal. As discussed above, at the terminal berth, the LNG carriers would discharge 

engine cooling water into the slip. As is standard in the shipping industry, the cooling water for 

the LNG carriers may be injected with a low dose of biocide (expected to be sodium 

hypochlorite for LNG carriers) to prevent the growth of marine organisms. This residual 

chlorine concentration is not expected to significantly affect water quality. 

As discussed above, LNG carriers would not be allowed to discharge ballast water while at berth. 

In addition, LNG carriers would not discharge on-board wastewater during off-loading 

operations at the slip. 

Discharges from the LNG carriers would increase water temperature slightly while at dock. Two 

sources affecting overall temperature are the cooling water discharges and the LNG present on 

the ship. The discharged cooling water, based on the range of values presented above, could 

range from about 30 to 235 thousand m3 while at the dock. The estimated temperature of the 

discharge water is about 3 °C (5.4 °F) warmer within 75 feet of the discharge point (FERC 2008) 

after passing through the ship’s cooling system during an approximate 13-hour period. Due to 

the extreme differential of the temperature of the cargo in the LNG carrier (-260 °F) and that of 

the surrounding air and water (nominally 45 °F), there is a constant uptake of heat by the LNG 

carrier from its surroundings. This heat uptake is manifested by the amount of LNG cargo that 

changes state from liquid to vapor on a daily basis. Not considering the actual effect of LNG 

cooling, based on an estimated volume of the slip area of 4.8 million cubic yards (3.7 million 

m3), temperature would increase an estimated 0.04 to 0.35 °F. Considering the volume of Coos 

Bay, virtually no change in Bay temperature would occur from heated water discharge. Coos 

Bay temperatures historically remain less than 20°C (68 °F) (McAlister and Blanton 1963). 

We do not think that this warmer engine cooling water would have significant adverse impact on 

the water in Coos Bay because of mixing and other factors. First, tides would be continually 

exchanging the water, about 25 percent each tidal cycle. Also, because the cooling water would be 

discharged in the same localized area (the northeast corner of the slip) as the location where intake 

water would be filtered for use as both ballast and cooling water make-up, a portion of the cooling 

water discharge would be recycled as ballast water, thereby reducing the thermal load that is 
 4.3 – Water Resources and Wetlands 4.3-28

transferred to the slip mass and the total volume of water taken on by the vessel. There may be 

some local areas near the cooling water discharge that would be warmer than this average. 

4.3.2.5 Pacific Connector Pipeline 

Construction of the Pacific Connector pipeline would involve 218 waterbody crossings (this 

includes several waterbodies that would be crossed multiple times, so the actual number of 

waterbodies crossed is slightly less) and run adjacent to another 32 waterbodies within the rightof-way or TEWAs. Of the 218 waterbody crossings, 102 are perennial, 114 are intermittent, 1 is 

a stock pond, and 1 is an estuary (within Coos Bay). The following section provides additional 

information on applicable regulations, affected waterbodies, and on the potential impacts 

associated with the construction and operation of the Project. 

The proposed Pacific Connector pipeline would cross six subbasins including the Coos, Coquille, 

South Umpqua, Upper Rogue, Upper Klamath, and Lost River subbasins. Within the six 

subbasins, 19 fifth-field watersheds3

 would be crossed (table 4.3.2.5-1). 

TABLE 4.3.2.5-1 

Fifth-Field Watershed Crossed by Proposed Pacific Connector Pipeline

Fifth Field Watershed 

Subbasin Name HUC Miles Crossed 

Coos Coos Bay Frontal 1710030403 21.4 

Coquille 

Lower Coquille River 

North Fork Coquille River 

East Fork Coquille River 

Middle Fork Coquille River 

1710030505 

1710030504 

1710030503 

1710030501 

2.0 

8.3 

9.8 

15.5 

South Umpqua 

Olalla Creek-Lookingglass Creek 

Middle South Umpqua River 

Myrtle Creek 

South Umpqua River 

Elk Creek-South Umpqua 

Upper Cow Creek 

1710030212 

1710030210 

1710030211 

1710030205 

1710030204 

1710030206 

8.7 

13.2 

8.4 

19.4 

3.1 

5.6 

Upper Rogue 

Trail Creek 

Rogue River-Shady Cove 

Big Butte Creek 

Little Butte Creek

1710030706 

1710030707 

1710030704 

1710030708 

10.6 

7.5 

5.3 

32.9 

Upper Klamath Spencer Creek

Klamath R.-John C. Boyle Res. 

1801020601 

1801020602 a/ 

15.1 

5.2 

Lost River Lake Ewauna-Upper Klamath River 

Lower Lost River 

1801020412 

1801020409 

16.5 

25.1 

Total 233.6 

a/ There are no waterbodies crossed in the Klamath River-John C. Boyle Reservoir Fifth Field Watershed. 

Drinking Water Source Areas

The proposed pipeline route would cross or be adjacent to 11 public drinking water source areas 

(ODEQ 2007f). Table 4.3.2.5-2 lists the locations where the proposed pipeline route would cross 

source areas. In some locations, the pipeline route is within a particular source area for several 

 

3

 The fifth-field scale was selected in the 1995 Federal Guide for Watershed Analysis as the consistent size for analysis. It is the 

first subdivision of a subbasin and considered the most appropriate to “provide the context for management through description 

and understanding of specific ecosystem conditions and capabilities” (p. 7) and “satisf[y] many needs and offers a consistent 

format for reporting results of an analysis” (p. 8). (USFS and BLM 2003) 
 4.3 – Water Resources and Wetlands 4.3-29

miles, but in other locations the route travels along ridgelines meandering in and out of source 

areas. Where the proposed route meanders in and out of source areas, two source areas are 

shown in table 4.3.2.5-2 for that length of the proposed route. 

TABLE 4.3.2.5-2 

Public Drinking Water Surface Water Source Areas that would be Crossed by the Proposed Pacific Connector Pipeline 

Starting 

Milepost 

Ending 

Milepost County 

Drinking Water Source 

Area a/

Public Drinking 

Water System 

ID 

Land Ownership/ 

Jurisdiction Source Water 

19.86 35.81 Coos City of Myrtle Point 4100551 Private, BLM N. F. Coquille River 

35.81 38.42 Coos City of Coquille 4100213 Private, BLM Coquille River 

38.42 42.48 Coos City of Myrtle Point 

City of Coquille 

4100551 

4100213 

Private, BLM N.F. Coquille River 

Coquille River 

42.48 52.90 Coos City of Coquille 4100213 Private, BLM Coquille River 

52.90 64.71 Douglas Winston-Dillard Water 

District 

4100957 Private, BLM S. Umpqua River 

64.71 70.67 Douglas Roseburg Forest ProdDillard 4194300 Private S. Umpqua River 

70.67 74.86 Douglas Clarks Branch Water 

Association 

Roseburg Forest ProdDillard 

4100548 

4194300 

Private S. Umpqua River 

74.86 82.75 Douglas Clarks Branch Water 

Association 

4100548 BLM, Private S. Umpqua River 

82.75 82.95 Douglas Tri-City Water District 

Clarks Branch Water 

Association 

4100549 

4100548 

BLM S. Umpqua River 

82.95 95.36 Douglas Tri-City Water District 4100549 BLM, Private S. Umpqua River 

95.36 101.83 Douglas Milo Academy 

Tri-City Water District 

4100250 

4100549 

BLM, Private, 

USFS 

S. Umpqua River 

101.83 102.81 Douglas Tiller Elementary SD #15 

Tri-City Water Distract 

4192139 

4100549 

USFS, BLM S. Umpqua River 

102.81 110.76 Douglas City of Glendale 

Tiller Elementary SD #15 

4100323 

4192139 

USFS, Private Cow Creek 

S. Umpqua River 

110.76 111.12 Jackson 

Douglas 

Country View Mountain 

Home Estates 

City of Glendale 

4100808 

4100323 

USFS Rogue River 

Cow Creek 

111.12 124.61 Jackson Country View Mountain 

Home Estates 

4100808 USFS, Private, 

BLM 

Rogue River 

124.61 135.04 Jackson Medford Water Commission 

Country View Mountain 

Home Estates 

4100513 

4100808 

BLM, Private Rogue River 

135.04 167.90 Jackson Medford Water Commission 4100513 Private, BLM, 

USFS 

Rogue River 

a/ The proposed route meanders in and out of Drinking Water Surface Water Source Areas for the length of the proposed route 

where there are two Drinking Water Surface Water Source Areas listed. 

Public Drinking Water Intakes

Table 4.3.2.5-3 lists the public water systems that have surface water intakes within 3 miles 

downstream of waterbodies that would be crossed by the proposed pipeline (ODEQ 2006a). The 

downstream distance from the waterbody crossing to the intake is also provided in table 4.3.2.5-3 

in addition to the source water. The surface water intake for Roseburg Forest Products in Dillard 
 4.3 – Water Resources and Wetlands 4.3-30

on the South Umpqua River is 0.81 mile downstream of the crossing of Rice Creek at MP 65.76 

and 1.82 miles downstream of the crossing of Willis Creek at MP 66.95. Pacific Connector 

would provide written notification to the authorities of the surface water supply intakes in table 

4.3.2.5-3 at least one week before beginning in-water work or as otherwise specified by the 

TABLE 4.3.2.5-3 

Public Drinking Water Surface Water Intakes within 3 Miles 

Downstream of Proposed Waterbody Crossings for the Pacific Connector Pipeline 

Intake Public Water System 

Source Water for 

Intake Waterbody Crossing 

Distance 

Downstream County 

4194300 Roseburg Forest 

Products –Dillard S. Umpqua River Rice Creek – MP 65.76 

Tributary to S. Umpqua River 0.81 mile Douglas 

4194300 Roseburg Forest 

Products –Dillard S. Umpqua River Willis Creek MP 66.95 

Tributary to S. Umpqua River 1.82 miles Douglas 

4100808 Country View Mountain 

Home Estates Rogue River Rogue River MP 122.65 1.44 miles Jackson 

4101483 Anglers Cove 

Subdivision Rogue River Rogue River 122.65 Approx. 3 miles Jackson 

appropriate authorities. In the event of an inadvertent spill, or a disruption of flow and sediments 

are introduced into these waters, Pacific Connector would notify potable water intake users of 

the conditions so that necessary precautions could be implemented. 

Pacific Connector indicated it would notify the public drinking water operators within 3 miles 

downstream of stream crossing locations listed in table 4.3.2.5-3. However, it has not developed 

a process for coordinating construction with other potential surface water intake operators within 

3 miles downstream of stream crossing locations. Therefore, we recommend that:

• Pacific Connector should consult with all surface water intake operators with active 

intakes located within 3 miles downstream from a stream crossing location and 

establish a process for advanced notification of instream work. A summary of the 

consultations should be filed with the Secretary prior to construction of the pipeline. 

Nationwide Rivers Inventory

The Nationwide Rivers Inventory is a listing of more than 3,400 free-flowing river segments in 

the United States that are believed to possess one or more "outstandingly remarkable" natural or 

cultural values judged to be of more than local or regional significance. Under a 1979 

Presidential directive, and related Council on Environmental Quality procedures, all federal 

agencies must seek to avoid or mitigate actions that would adversely affect one or more 

Nationwide Rivers Inventory segments. 

Two rivers crossed by the proposed pipeline are listed on the Nationwide Rivers Inventory (NPS 

2006): 

• The North Fork of the Coquille from its headwaters in Section 16, T26S,R10W to the 

confluence with the South Fork Coquille River in Section 5, T29S,R12W. It was listed in 

1993 for outstanding remarkable fish, wildlife, and cultural (prehistoric Indian sites) 

values. The Pacific Connector pipeline would cross this section of river at MP 23.06 

using a dry open-cut method. Dry open-cut methods include dam and pump or fluming 
 4.3 – Water Resources and Wetlands 4.3-31

and are designed to limit impacts to flowing waterbodies by creating a “dry” stream 

segment to work in and contain disturbed sediments. 

• The South Umpqua River from Tiller (Section 33, T30S,R2W) to the confluence with the 

North Umpqua River at River Forks (Sections 31 and 32, T26S,R6W). It was listed in 

1993 for outstanding and remarkable fish and historical values. It supports outstanding 

fishery-related recreation. The pipeline would cross this section of river twice at MP 

69.02 and MP 94.73 using diverted open-cut at each crossing. Similarly, this method is 

designed to limit impacts to flowing waterbodies by creating a “dry” working area. It is 

discussed further below. 

Depending on the overall construction schedule, pipeline construction at waterbody crossings 

would be conducted during low-flow periods whenever possible and within ODFW 

recommended in-water construction windows. Construction during low flows would minimize 

sedimentation and turbidity, minimize streambank and bed disturbances, and limit the time it 

takes to complete instream construction. 

Considering the crossing methods proposed, the timing (during seasonal low flows) and the 

measures contained in their SPCCP and ECRP, impacts to these waterbodies should be 

temporary and of small magnitude. 

General Construction Impacts and Mitigation 

Construction of the pipeline could result in minor, short-term impacts to waterbodies. These 

impacts could occur because of instream construction activities, use of access roads, or 

construction on slopes and riparian areas adjacent to stream channels. Clearing and grading of 

streambanks, removal of riparian vegetation, instream trenching, trench dewatering, and 

backfilling could result in streambank modification; increased sedimentation; turbidity; increase 

in temperature, decreased dissolved oxygen concentrations; releases of chemical and nutrient 

pollutants from sediments; and introduction of chemical contaminants, such as fuel and 

lubricants. An increase in soil compaction and vegetation clearing could potentially increase 

runoff and subsequent streamflow or peak flows. Surface waters could be impacted due to 

alteration of groundwater flow where the pipeline intersects waterbodies. To minimize potential 

adverse impacts along the construction right-of-way and at waterbody crossings, Pacific 

Connector would implement its ECRP during construction, restoration, and operation of its 

proposed facilities. Pacific Connector’s ECRP is mostly compatible with the FERC staff’s Plan 

and Procedures. Alternative measures requested by Pacific Connector are identified and 

reviewed in Appendix I. 

Construction activities at waterbody crossings would be conducted in accordance with all federal 

and state regulations and permit requirements. Depending on the overall construction schedule, 

pipeline construction at waterbody crossings would be conducted during low-flow periods 

whenever possible and within ODFW recommended in-water construction windows. 

Construction during low flows would minimize sedimentation and turbidity, minimize 

streambank and bed disturbances, and limit the time it takes to complete instream construction. 

Specific impacts and proposed mitigation measures are discussed further below. Permits 

required for instream work may contain mitigation measures in addition to those discussed here. 
 4.3 – Water Resources and Wetlands 4.3-32

Pacific Connector proposes to use several different waterbody crossing methods, dependant on 

site- and waterbody-specific conditions (see section 2.4.2.2). Many of the proposed waterbody 

crossings are intermittent streams or ditches that are expected to be dry or non-flowing at the 

time of construction. For all intermittent waterbodies without flow at the time of construction, 

Pacific Connector would utilize standard upland, cross-country construction methods. At these 

crossings, the depth of cover would be at least 5 feet (from the top of pipe to the bottom of 

streambed). Where subsurface water is encountered in intermittent streams and ditches, the 

methods described above for trench excavation and dewatering would be employed. 

To minimize increases in turbidity and suspended sediment at waterbody crossings, Pacific 

Connector would utilize the dry crossing methods (i.e., flume and dam-and-pump) for most of 

the flowing waterbodies crossed by the proposed pipeline (94 of the 102 perennial waterbodies). 

The remainder would be crossed by conventional bore, diverted open-cut, HDD, and one 

instance of wet-open cut in the Coos Bay estuary. Turbidity and sedimentation impacts 

associated with dry open cut methods are generally minor and are associated with 1) installation 

and removal of the upstream and downstream dams used to isolate the construction area; 2) 

water leaking through the upstream dam and collecting sediments as it flows across the work 

area and continues through the downstream dam; 3) movement of in-stream rocks and boulders 

to allow proper alignment and installation of the flume and dams; and 4) when streamflow is 

returned to the construction work area after the crossing is complete and the dams and flume are 

removed. Both “dry” techniques produce much less sediment in the water than alternative “wet” 

open cut methods (Reid and Anderson 1999; Reid et al. 2002; Reid et al. 2004). Dry methods 

have been reported to produce at least seven times less suspended sediment in streams than 

“wet” methods (Reid et al. 2002). According to Pacific Connector, during construction of 

Williams’ Northwest Pipeline Corporation’s Capacity Replacement Project in Washington State 

(completed in 2006), a total of 67 waterbodies were crossed using dry open cut crossing methods 

(fluming and/or dam and pump). During these crossings there was only one event where state 

water quality turbidity limits were exceeded. The exceedance occurred through a failure of the 

pumps during the night when a monitor was not on site to restart the pump. 

There would also be short-term turbidity increases during portions of the installation and 

removal of the diversion structure(s) for the proposed diverted open cut crossings of the South 

Umpqua River (MPs 69.02 and 94.73). Trenching within Coos Bay and Cooston Channel would 

result in elevated levels of fine-grained mineral and organic particles, or turbidity plumes for 

short-term periods during the dredging operations. Section 4.5 contains more discussion on 

turbidity and suspended sediment at waterbody crossings and the potential for impacts to aquatic 

resources. 

To prevent impacts due to alteration of groundwater flow, or the creation of new groundwater 

pathways, Pacific Connector’s ECRP requires the use of trench breakers or installation of trench 

plugs at the edges of waterbodies to prevent movement of silt-laden water through the pipeline 

trench. The following sections describe the general impacts expected from pipeline construction 

and outline the mitigation measures that would be followed to minimize these impacts. 

The FWS has requested additional site-specific information for waterbody crossing along the 

Pacific Connector pipeline for their assessment of adequacy of design, construction, restoration, 

and monitoring of the pipeline’s waterbody crossings. The FWS would continue to work with 
 4.3 – Water Resources and Wetlands 4.3-33

Pacific Connector and other agencies to identify additional site specific data and analyses, design 

plan needs, and restoration plan needs the FWS believes may be required prior to construction. 

For this EIS, individual stream data was gathered for each crossing consistent with the 

information FERC staff needs to assess impacts. Additional data were collected based on the 

pre-survey input of other agencies. Stream crossings would be conducted consistent with the 

FERC staff’s Procedures, which were developed with input from regulatory agencies and the 

industry, and have been in use on FERC-regulated projects for over 15 years. If a project is built 

following the FERC staff's Procedures, it allows the FERC to evaluate and describe impacts on 

waterbodies and reach a conclusion on impacts even without individual stream crossing plans for 

each waterbody. Additional site-specific data could be gathered and site-specific crossing plans 

could be prepared at a later date if required by the other agencies, such as ODEQ as part of the 

401 permitting process, but these plans are not necessary to assess the potential impacts, as 

described in this EIS. 

Streambank Protection

During pipeline construction, clearing and grading of vegetative cover could increase erosion 

adjacent to streambanks. Alteration of the natural drainage or compaction of soils by heavy 

equipment near streambanks during construction may accelerate erosion of the banks and the 

transportation of sediment carried by runoff water into the waterbodies. The extent of the impact 

would depend on sediment loads, stream velocity, turbulence, streambank composition, 

streambank vegetation, stream type, scour depth, and sediment particle size. To minimize these 

impacts, equipment bridges and mats would be used, as necessary, to provide stable work areas 

and isolate equipment from direct impact on waterbodies. TEWAs for spoil storage and pipe 

staging would be set back from the bank as discussed in the following paragraph, and temporary 

sediment barriers would be installed around disturbed areas, where necessary, in accordance with 

Pacific Connector’s ECRP. 

Sedimentation Control

Pacific Connector would install temporary equipment bridges across perennial or intermittent 

waterbodies flowing at the time of construction to prevent sedimentation caused by construction 

and vehicular traffic. These temporary bridges would be removed when construction and 

restoration are completed. 

Trench spoil excavated from within the waterbody would be placed at least 10 feet from the 

water’s edge or in a TEWA. In some waterbodies, native washed streambed boulders, cobbles, 

and gravels removed from the surface of the trench may be stored within the construction rightof-way in the streambed in areas isolated from streamflow (i.e., within the dammed area for 

flumes or dam-and-pump crossing). Storing this material in the streambed would minimize 

handling and help to ensure the material would be available for backfill and streambed 

restoration. Staging areas and additional spoil storage areas would be located at least 50 feet 

away from waterbody boundaries, where topographic conditions and other site-specific 

conditions allow. Where topographic conditions do not allow a 50-foot setback, spoil storage 

areas would be located at least 10 feet from the water’s edge. Sediment control devices, such as 

silt fences and straw bales, would be placed around the spoil piles to prevent spoil flow back into 

the waterbody. 
 4.3 – Water Resources and Wetlands 4.3-34

Trench Dewatering

During construction, the open trench may accumulate water either from groundwater intrusion or 

precipitation. Intermittent streams and ditches that are dry on the surface may contain water 

below the surface. As such, the trench may require dewatering to allow for proper and safe 

construction. However, the construction schedule would generally coincide with the period 

when the soils in these areas are dry, thereby minimizing the amount of trench dewatering. 

During trench dewatering, water would be pumped from the trench into stable, vegetated areas 

through a straw bale structure or filter bag. No vegetation clearing outside of the approved work 

spaces would be required. Trench dewatering structure locations would be selected in the field 

in response to actual conditions encountered. The rate of flow from dewatering pumps would be 

regulated to prevent erosion from runoff, and dewatering would be conducted in a manner 

designed to ensure that water is allowed to infiltrate into the ground rather than flow over the 

surface whenever possible. If trench dewatering does result in surface runoff, it would be 

conducted to ensure that turbid water does not reach a surface water of the state, and does not 

result in the deposition of sand, silt, and/or sediment. All materials used to filter water from the 

trench would be cleaned up and the site restored after dewatering is complete. 

Pacific Connector proposes a winter construction schedule for the Klamath Basin area between 

approximately MPs 188 and 230 to minimize impacts to agricultural activities and to minimize 

construction across areas of high groundwater due to irrigation activities that would increase the 

instances of trench dewatering. Potential sedimentation impacts would be reduced due to the dry 

climate of the area and the colder winter climate of the area would reduce runoff potential during 

frozen periods. Additionally, Pacific Connector would utilize BMPs as necessary as discussed in 

the ECRP to prevent sedimentation into waterbodies or wetlands. Mulch would also be used to 

apply effective ground cover to minimize erosion potential. Effective ground cover is considered 

to be the amount of cover necessary for maintaining a disturbed site in a low hazard category for 

erosion. 

Blasting

Blasting may be required for pipeline construction in areas where hard, non-rippable bedrock 

occurs within the trench profile (see section 4.1.3.2). In these areas, Pacific Connector would 

attempt to use other mechanical or hydraulic techniques such as hammering to excavate the 

trench to design depths. Where blasting is required in streambeds, Pacific Connector proposes to 

utilize the dam-and-pump crossing method so that blasting activities can be completed in the dry 

to avoid or minimize potential impacts to aquatic species during in-water blasting. Blasting 

could alter the in-channel characteristics and hydrology of the stream, potentially decreasing 

flows due to increased infiltration where bedrock would be fractured. To reduce impacts, a site 

blasting plan would be developed by the blasting contractor prior to work. Blasting-related 

operations including obtaining, transporting, storing, handling, loading, detonating, and 

disposing of blasting material, drilling, and ground-motion monitoring would comply with 

applicable federal, state, and local regulations and permits. A permit from the ODFW would be 

required for any blasting in waters of the state. Additional discussion of potential blasting 

impacts and Pacific Connector’s proposed measures to minimize impacts is included in section 

4.1.3.5 and 4.3.1.3, as well as section 4.5.2.3, where the effects of in-stream blasting on fish are 

discussed. 
 4.3 – Water Resources and Wetlands 4.3-35

Spills/Hazardous Materials

Equipment fueling and storage of oil, fuel, or other materials near waterbodies could create a 

potential water quality impact if a spill were to occur. Leaks from equipment and vehicles could 

also cause potential impacts to surface waters. Degraded water quality could affect downstream 

water users and aquatic resources. Hazardous materials, chemicals, fuels, and lubricating oils 

would be stored in accordance with Pacific Connector’s ECRP and SPCCP. Pacific Connector 

has developed a general SPCCP that describes measures to be implemented by Pacific 

Connector’s personnel and contractors to prevent and, if necessary, control any inadvertent spill 

of hazardous materials such as fuels, lubricants, and solvents that could affect water quality. 

This general SPCCP would be updated with site-specific information before construction. All 

Project employees would receive SPCCP training. 

The SPCCP includes a measure to prohibit the storage of hazardous substances, chemicals, fuels, 

and lubricating oils within 150 feet of waterbody banks or wetlands. Restricted areas for storage 

of these materials would be clearly marked in the field. These activities would only occur closer 

if the Environmental Inspector finds, in advance, no reasonable alternative and the contractors 

have taken appropriate steps (including secondary containment structures) to prevent spills and 

provide for prompt cleanup in the event of a spill and the procedures outlined in Pacific 

Connector’s SPCCP are followed. Pacific Connector has proposed containment structures for 

pumps to prevent fuel spills from entering waterbodies. All hazardous materials would be 

handled in accordance with the SPCCP. 

All surplus material and equipment would be removed when instream construction and 

restoration are complete, and all trash, litter, and debris would be collected for disposal in an 

approved solid waste disposal facility. Under no circumstances would refuse be discarded in 

waterbodies, in trenches, or along the construction right-of-way and associated work areas. 

Contaminant Suspension and Migration

No known contaminated sites would be directly crossed by the pipeline, so contact with 

contaminated soil from pipeline construction is not anticipated; however, the chance for 

unanticipated discover of contaminated sediments remains. In rural areas, potential sources for 

contamination of sediments in waterbodies are agricultural fields containing fertilizers and 

pesticides, and leachate from feed lots and sanitary fields. In urban areas, contaminated 

stormwater runoff, wastewater discharges, erosion or leachate from industrial sites such as 

mineral processing or mining, petroleum refining, treatment plants, or landfills may contribute to 

the sediment contamination in waterbodies. 

A records search has not indicated any known hazardous waste sites in Coos Bay that would be 

crossed by the pipeline, so toxic effects from resuspended sediment should not occur. However 

much development, including boat painting with toxic compounds (e.g. lead, tributyltin), has 

occurred in Coos Bay in the past. There are records of elevated levels of tributyltin in the 

sediment of Catching Slough (Elgethun et al. 2000), which the pipeline would cross under using 

a bore at about MP 11.1. 

Pipeline construction in areas with existing sediment contamination, if encountered, could 

disturb and suspend sediments in the waterbody, temporarily degrading water quality and 

redistributing contaminants downstream. Because pipeline construction would be a temporary 
 4.3 – Water Resources and Wetlands 4.3-36

disturbance, would be confined to a limited area of streambed, and would be designed to 

minimize streambed disturbance, these impacts would be localized and temporary. To minimize 

resuspension of any potentially contaminated sediments, Pacific Connector would cross 

waterbodies during low flow to the extent possible, minimize handling of sediments, limit the 

duration of instream disturbance for trench excavation and backfilling, and incorporate special 

federal or state requirements regarding handling of potentially contaminated sediments into 

permit applications and construction plans. 

To minimize contaminant suspension, Pacific Connector would prevent water flow between the 

excavated trench on the adjacent right-of-way and the waterbody by leaving hard or soft soil plugs in 

place until construction across the waterbody begins. Trench breakers would be installed at the base 

of slopes adjacent to waterbody crossings after pipeline installation to restrict subsurface water flow 

between the trench and the waterbody. Depending on the contours, erosion control devices such as 

straw bales or silt fences would be installed to prevent sediment from entering the waterbody from 

the disturbed right-of-way. In the draft EIS we recommended that Pacific Connector prepare a plan 

to address the unanticipated discovery of contaminated soils or groundwater during construction. 

See discussion of this plan in section 4.3.1.3. 

Channel Migration and Scour

Fluvial erosion represents a potential hazard to the proposed pipeline where streams are capable 

of exposing the pipe as a result of channel migration, avulsion, widening, and/or streambed 

scour. The principal hazard resulting from channel migration and streambed scour is complete 

or partial exposure of the pipeline within the channel from streambed and bank erosion or within 

the floodplain from channel migration and/or avulsion. Minimizing the effects of migration and 

scour hazards to the pipeline can be accomplished with the following approaches (GeoEngineers 

2007b): 

1. At each channel crossing, bury the pipe below the estimated depth of streambed scour. 

Where bedrock is encountered at shallower depths than the estimated scour depth, the 

elevation of competent bedrock represents the limit of scour. 

2. Where feasible, place the pipe into bedrock. 

3. Within floodplains adjacent to migrating channels, bury the pipe below the projected 

depth of the channel thalwag within the 50-year channel migration zone. 

The Pacific Connector pipeline would be designed to protect the integrity of the pipeline, which 

may include increasing the depth of cover to more than the 5-foot minimum to accommodate the 

potential for long-term scour and bank stabilization. At a minimum, Pacific Connector would 

design all waterbody crossings to meet DOT CFR 49 Part 192 standards. Additional depth 

would be evaluated and considered based on a channel migration and scour analysis 

(GeoEngineers 2007b) developed for the Pacific Connector pipeline or other site-specific 

investigations based on the final route alignment. Based on the results of the Phase II Channel 

Migration and Scour Analysis, Pacific Connector would design all pipeline crossings for the 50-

year condition. 

Because Pacific Connector has modified its proposed pipeline route since the initial migration 

and scour analysis (GeoEngineers 2007b), it completed an assessment for all 114 of the new or 

shifted stream crossings along the re-routed portions of the proposed pipeline alignment, 
 4.3 – Water Resources and Wetlands 4.3-37

including GIS analysis and review of field notes from the previous assessment (GeoEngineers 

2009). As a result, two crossings were identified that require additional field reconnaissance; 

West Fork Trail Creek and North Fork Little Butte Creek. Further, the assessment recommended 

burial of the pipeline at least 5 feet below the surface at Indian Creek (MP 128.6) due to channel 

migration concerns (GeoEngineers 2009). 

Scour risks associated with pipeline routing through Coos Bay has been reduced greatly by 

incorporation of the upland alignment around most of Coos Bay. Scour and migration hazards 

were eliminated in Spencer Creek (MP 171.1) by relocating the proposed crossing several miles 

upstream (GeoEngineers 2009). 

Drain Tiles

The BLM has identified that French drains were installed to stabilize Elk Creek Road near the 

proposed pipeline route at MPs 33.8 and 35.9. The pipeline would also cross agricultural fields 

along about 20 miles of the proposed route in Klamath County, which are underlain by drain 

tiles. Pacific Connector has not identified the exact locations of drain tiles that would be crossed 

by the proposed alignment but would identify the presence of drain tiles on individual properties 

during right-of-way easement acquisition, expected to begin early 2009. 

Pacific Connector would ensure that any drain tiles cut or damaged by the pipeline would be 

repaired before backfilling. All drain tiles crossed by the Pacific Connector pipeline would be 

probed prior to right-of-way restoration to check for damage, and a qualified specialist would 

test tiles for damage and conduct any necessary repairs. Filter-covered drain tiles would not be 

used during repairs unless appropriate authorities and the landowner approve its use. Pacific 

Connector would restore any damaged drain tiles to the same condition that existed prior to 

construction. 

Dust Control

While it is not possible to know how much water would be needed for dust suppression on the 

pipeline construction right-of-way, during dry seasons, Pacific Connector estimates that there 

would be approximately five 3,000-gallon water trucks per construction spread on a given day. 

Pacific Connector anticipates using five construction spreads, which would total 75,000 gallons 

for 25 water trucks. Watering trucks would spray only enough water to control the dust or to 

reach the optimum soil moisture content to create a surface crust. Runoff should not be 

generated during this operation. Water may be obtained through municipal sources or withdrawn 

from surface water or groundwater sources. All appropriate permits/approvals would be 

obtained prior to withdrawal. Table 4.3.2.5-4 lists potential dust control water sources that have 

been identified by Pacific Connector. 

TABLE 4.3.2.5-4

Potential Dust Control Water Sources for the Pacific Connector Pipeline

County Approximate MP Source 

Coos 16.5 Aqueduct Lake 

Douglas 32.0 Brewster Lake (Wl-602) 

Douglas 50.2 Lang Creek Reservoir 

Douglas 79.0 Big Lick Reservoir 

Jackson 128.0 Indian Lake Reservoir 
 4.3 – Water Resources and Wetlands 4.3-38

TABLE 4.3.2.5-4

Potential Dust Control Water Sources for the Pacific Connector Pipeline

County Approximate MP Source 

Jackson 133.4 Eagle Point Irrigation Canal Crossing 

Jackson 141.0 Star Ranch Lake 

Jackson 144.0 Unnamed Reservoir 

Jackson 145.0 Gardener Reservoir 

Klamath 228.5 High Line Canal 

Klamath 228.7 Capek Reservoir 

Klamath 229.4 Low Line Canal 

Additionally, Pacific Connector has indicated it may utilize a synthetic product such as 

Dustlock®, in addition to water, for dust control. Dustlock® is a naturally occurring by-product 

of the vegetable oil refining process. Dustlock® penetrates into the bed of the material and 

bonds to make a barrier that is naturally biodegradable, ensuring that the surrounding ground and 

water are not contaminated, and minimizing any potential effects to fish and wildlife. While 

there are no known health risks by the use of Dustlock® to fish and wildlife resources, Pacific 

Connector would not use Dustlock® within riparian areas. 

Hydrostatic Testing

After backfilling, the pipeline would be hydrostatically tested in accordance with DOT 

regulations to ensure that the system is capable of operating at the maximum operating pressure. 

Pacific Connector estimates that approximately 59 million gallons of water would be required to 

test the pipeline. 

Water for hydrostatic testing would be obtained from commercial or municipal sources, private 

supply wells, or from surface water right owners. Potential sources of hydrostatic test water are 

listed in table 2.4.2.1-2. If water for hydrostatic testing would be acquired from surface water 

sources, Pacific Connector would obtain all necessary appropriations and withdrawal permits, 

including from the ODWR, prior to use. As part of this process, ODWR would have the 

applications reviewed by ODEQ and ODFW to determine if there are concerns about the impact 

water withdrawals may have on water resources, including concerns relating to the timing, 

seasonality, and method of withdrawal. ODWR would provide public notice and opportunity to 

comment on the applications. Pacific Connector does not anticipate that chemicals would be 

added to the hydrostatic test water. If chlorinated municipal water is used, the discharge of this 

water would be treated, if necessary, to minimize potential impacts to sensitive areas. 

Hydrostatic test water for the compressor station would be obtained from nearby municipalities. 

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, discharges would be minimized and water would be conserved as much 

as practical by cascading water between test sections when feasible (pumping from one segment 

to the next). When discharged, the test water would be released adjacent to the construction 

right-of-way through an energy dissipating device and a straw bale filter or sediment bag. Test 

water would not be discharged directly into surface waters. Pacific Connector would ensure that 

discharge into state-designated exceptional value waters, waterbodies that provide habitat for 

federally listed threatened or endangered species, or waterbodies designated as public water 
 4.3 – Water Resources and Wetlands 4.3-39

supplies would not occur unless appropriate federal, state, and local permitting agencies grant 

written permission. 

In addition to the 75 test header section breaks located within the construction right-of-way or 

TEWAs (identified in table E-3 in Appendix E), Pacific Connector identified seven potential 

hydrostatic discharge locations outside of the construction right-of-way and TEWAs (see table 

2.4.2.1-3). In these seven locations, small brush or trees may be cleared by a rubber-tired rotary 

or flail motor (brush hog) or by hand with machetes/chainsaws. A rubber-tired or track hoe 

would be utilized to lay the discharge line and to remove the saturated hay bales or filter bags 

upon completion of hydrostatic discharge. 

Where possible, test water would be released within the same basin from which it was 

withdrawn. However, cascading water from one test section to another to minimize water 

withdrawal requirements may make it impractical to release water within the same basin where 

the water was withdrawn in all cases. 

Pacific Connector would apply for permission to discharge the hydrostatic test water 

concurrently with its request for coverage under the ODEQ General Stormwater Discharge 

Permit and permitted through a separate letter of approval. State withdrawal permits require 

review by the ODWR, ODEQ, and ODFW to ensure potential impacts from the withdrawal do 

not occur. The review includes volume, timing and duration of the withdrawal. The withdrawal 

permit ensures that the proposed withdrawal does not impact existing water rights or beneficial 

uses of the waterbody. All hydrostatic test water would be discharged to upland areas at a rate to 

prevent scour, erosion, and sediment migration to sensitive resources such as wetlands and 

waterbodies as detailed in Pacific Connector’s ECRP and all permit conditions would be 

implemented. The ECRP also specifies that the test water would be released into a dewatering 

device such as a straw bale structure to dissipate energy of the test water flow, filter the test 

water, and to allow release of the test water as sheet flow back into the ground. Flow rates to the 

discharge structure would be controlled by controlling the discharge valve to ensure the 

discharged flows do not flow above the carrying capacity of the structure(s). Pacific Connector 

is proposing methods for hydrostatic test water withdrawal and discharge that we believe are 

consistent with industry practices, and that have been shown through use on many similar 

pipeline projects to adequately minimize impacts on waterbodies. 

Additionally, Pacific Connector submitted a Draft Hydrostatic Testing Plan in its comment filed 

with the FERC on December 4, 2008 in response to a recommendation in the draft EIS to ensure 

that impacts to surface water resources would be minimized (see section 4.3.4 below). This plan 

was developed in consultation with the USFS and includes measures to prevent the transfer of 

aquatic invasive species and disease. While consultation is ongoing, final hydrostatic test 

designs and drawings would be developed prior to testing. Pipeline contractors would develop 

the final hydrostatic test plan and drawings that would include anticipated flow rates, and intake 

and discharge volumes and water discharge locations and procedures. Ramping rates would be 

submitted to ODFW for review prior to hydrostatic testing. 

In the event that a section is identified that requires repair and retesting, depending on sitespecific conditions, it may be possible for Pacific Connector to cascade the test water to another 

section and reuse the test water; however, if this is not possible, Pacific Connector would have to 

discharge the test water prior to repairs and replace the water for retesting. The measures 
 4.3 – Water Resources and Wetlands 4.3-40

described in this and other sections to reduce impacts associated with test water withdrawals and 

discharges would still be implemented and Pacific Connector would still have to follow all 

permitting requirements. Adherence to the authorizations and plans described above would limit 

or prevent impacts to waterbodies as a result of water withdrawals or discharges, soil erosion, 

and stream channel and flow effects. 

Restoration

After the pipe has been installed, the trench would be backfilled with the native material that was 

excavated from the trench. The FERC staff’s Procedures call for the upper 1 foot of the trench to 

be backfilled with clean gravel or native cobbles in all waterbodies that contain cold water 

fisheries. However, Pacific Connector has modified this requirement in its ECRP for instances 

where the existing substrate is not gravel or cobbles and site access is limited. Backfill material 

would match the natural streambed material size, gradation, and composition as closely as 

possible. We find this modification acceptable. The streambed profile would be restored to preexisting contours and grade conditions. To restore the streambanks, Pacific Connector would 

explore options such as tree revetments, stream barbs/flow deflectors, toe-rock, and vegetation 

riprap before using hard bank protection. Streambanks would be returned to their 

preconstruction contours or shaped to a stable angle. Erosion control fiber fabric or matting 

would be installed on slopes adjacent to streams. On some banks, depending on site-specific 

conditions, fiber rolls may also be installed to stabilize bank toes. The streambanks would be 

seeded and woody riparian vegetation planted for stabilization according to Pacific Connector’s 

ECRP (see section 4.4). Pacific Connector does not anticipate that riprap would be required for 

streambank stabilization, but if used would be limited to the areas where flow conditions 

preclude effective vegetation stabilization techniques. Riprap would be a last resort intended to 

limit damage. 

All areas where grading would be required for pipeline construction would be regraded and 

contoured to blend into the surrounding landscape and to re-establish natural drainage patterns. 

The emphasis during recontouring would be to return the entire right-of-way to its approximate 

original contours, to stabilize slopes, control surface drainage, and to aesthetically blend into the 

adjacent contours. Ruts and other scars would be regraded and all drainage ditches would be 

returned to their preconstruction condition. 

Pacific Connector would revegetate TEWAs with weed-free native plant species, and seed 

mixtures would be certified as weed-free. On a site-specific basis, and in consultation with 

individual landowners, riparian areas (of both perennial and intermittent waterbodies) within 

Pacific Connector’s permanent easement would be restored and enhanced using plantings of 

native shrubs and trees to within 25 feet of the streambanks, depending on existing land use and 

vegetation conditions. On federal lands, Pacific Connector has committed to extending the 

riparian strip plantings along all streams (perennial or intermittent) within federally designated 

Riparian Reserves to up to 100 feet from the OHWM (subject to the same 5-foot (shrubs) and 

15-foot (trees) restrictions on either side of the centerline). The extended riparian planting area 

within Riparian Reserves would occur to 100 feet or to the limit of the existing riparian 

vegetation where it does not extend to 100 feet. 

All revegetated areas would be monitored for the first 2 to 3 years following construction to 

verify successful revegetation and implement corrective action, should it be required. 
 4.3 – Water Resources and Wetlands 4.3-41

Throughout operation of the pipeline, Pacific Connector would continue to monitor and maintain 

the right-of-way. The USFS and BLM, in consultation with Pacific Connector, have prepared a 

list of mitigation actions (Appendix L) to address unavoidable impacts on NFS and BLM lands. 

This is discussed in section 4.3.4, below, as well as in section 4.5. 

Peak Flows

Vegetation management or clearing activities that create sizable canopy openings can increase 

water yields (USFS 2000). Sizeable canopy openings can result in decreased evapotranspiration 

(due to decreased leaf area), decreased interception by the canopy, increased snow accumulation 

and melt rates, greater snow accumulation and more rapid snowmelt compared to locations 

lacking large canopy openings, resulting in increased peak flows (USFS 2008 and Grant et al 

2008). Clearing can also reduce cloud water interception, having the opposite effect (Grant et al 

2008). Due to the linear nature of the pipeline (resulting in low harvest intensity as opposed to 

the clearing created by timber harvests), the proportionally small affected acres within the 

watersheds, and the measures discussed below, the effect that construction and operation of the 

Pacific Connector pipeline would have on peak flows and rain-on-snow events is expected to 

cause no measurable or consequential effect to peak flows. The pipeline would cross 16 Fifth 

Field Watersheds within the transient snow zone (2,000- to 5,000-foot elevation range), affecting 

a total of 2,618 acres within the transient snow zone. This represents about 0.18 percent of the 

total acreage of these 16 watersheds. Increase in peak flows generally diminish with decreasing 

intensity of percentage of watershed harvested and the magnitude of any effect diminishes with 

increasing basin size (Grant et al. 2008). Only clearing that permanently alters canopy cover 

could affect long-term peak flows; disturbance in existing agricultural and rangeland areas, 

grasslands, and shrubs (where the restored vegetation would provide similar cover) would have 

no long-term effects. When only considering forest clearing within these 16 watersheds, pipeline 

disturbance to forested vegetation types would represent only 0.10 percent of the total area of 

these watersheds. 

The greatest disturbance within the transient snow zone on a percentage basis would occur 

within the Trail Creek Watershed. The pipeline would disturb a total of 191.32 acres within the 

transient snow zone in this 28,867-acre watershed, which represents 0.66 percent of the total 

watershed area. When considering forest vegetation disturbance within the transient snow zone, 

the pipeline would also have the highest percentage of forested disturbance within the Trail 

Creek Watershed, disturbing 171.81 acres of forested vegetation types within the Trail Creek 

Watershed, which represents 0.60 percent of the total watershed acreage. 

The Little Butte Creek Fifth Field Watershed would have the largest area of disturbance within 

the transient snow zone with 514.8 acres, including 153.5 acres of forested vegetation, 166.1 

acres of grass-shrub-sapling or regenerating young forest, 76.6 acres of Oregon white oak forest, 

and 83.6 acres of grasslands or shrublands. Thirty-five acres of disturbance would occur within 

three minor land use types including developed areas and roads. 

The Lower Lost River and the Lake Ewauna-Upper Klamath River watersheds would have the 

second and third highest acres of disturbance from the pipeline within the Fifth Field Watershed 

transient snow zones, disturbing 492.9 acres and 375.1 acres, respectively within the transient 

snow zones. However, most of the disturbance within these watersheds would occur to 
 4.3 – Water Resources and Wetlands 4.3-42

agricultural, rangeland, and grasslands land use types, which would not affect potential increased 

peak flows from rain-on-snow events. 

The South Umpqua watershed would have the fourth highest acres of disturbance within the 

transient snow zone with a total of 272.3, including 129.4 acres of Douglas-fir dominated mixed 

conifer forest and 125.0 acres of grass-shrub-sapling or regenerating young forest types. The 

Trail Creek watershed would have the fifth highest acres of disturbance within the transient snow 

zone with 191.3 acres. This includes 129.5 acres of forested vegetation and 42.3 acres of grassshrub-sapling or regenerating young forest. 

Because of the pipeline’s linear nature, disturbance within the transient snow zone would occur 

across a broad number of watersheds and various vegetation types and affect a relatively small 

percentage of the watersheds. Although permanent canopy removal in forested areas along the 

right-of-way would increase the potential for snow accumulation, it is not expected that forest 

clearing within any of the watersheds would have a measurable influence on peak flows. In 

addition, Pacific Connector’s proposed design measures are intended to ensure that impacts 

would have an immeasurable effect on forest hydrology. These measures include: 

1. Where feasible, the pipeline route has been primarily aligned along ridgelines and 

watershed boundaries where it would traverse the Coast and Cascade Mountain Ranges. 

This alignment would minimize clearing effects within any single watershed. 

2. The size of construction work areas have been minimize to the extent practical to 

minimize clearing. 

3. After construction, disturbed areas would be returned to a stable approximate original 

contour configuration to restore preconstruction drainage patterns. 

4. BMPs would be used to minimize runoff and erosion and to promote infiltration. These 

BMPs include: 

• surface roughening and use of waterbars on slopes to promote onsite infiltration and 

to minimize runoff; 

• Appling slash or mulch on disturbed areas to ensure effective ground cover 

requirements are achieved; and 

• replanting cleared forested areas. 

Stream Temperature 

Because of the pipeline’s linear nature, it is not possible to avoid crossing waterbodies and 

riparian areas. However, the number of stream crossings required for the pipeline was 

minimized by Pacific Connector’s identification of a pipeline route that follows ridgelines and 

watershed boundaries to ensure the long-term safety, stability and integrity of the proposed 

pipeline as it crosses the Coast and Cascade mountain ranges. 

Removal of riparian vegetation during silvicultural practices can increase the temperature of 

streams; however, available information on the effects of linear pipeline crossings of streams on 

water temperature indicates there is little to no change. Construction across two coldwater, fishbearing streams in Alberta required removing forested riparian vegetation. Water temperatures 

at pipeline crossing sites and downstream did not increase above water temperatures at 

undisturbed sites upstream from the crossings (Brown et al. 2002). Similarly, studies at four 
 4.3 – Water Resources and Wetlands 4.3-43

coldwater streams in New York before and during pipeline construction and for three years 

following construction showed that the pipeline crossings had no short-term or long-term effect 

on water quality parameters, including water temperature, even though such effects were 

expected because streambank vegetation had to be cleared with reduced shading (Blais and 

Simpson 1997). While these studies were not in the same watersheds that would be affected by 

the proposed pipeline, they evaluated impacts specific to linear pipeline rights-of-way and 

therefore are relevant to the proposed pipeline. 

In response to requests from the USFS, Pacific Connector submitted the results of a water 

temperature impacts assessment for this project (North State Resources 2009). The assessment 

looked at 6 waterbody crossings that would occur on USFS managed lands. Five of the locations 

modeled occur in the Upper Umpqua River sub-basin; two on East Fork Cow Creek and three 

small tributaries to East Fork Cow Creek. The sixth modeled location was on the South Fork 

Little Butte Creek in the Upper Rogue River sub-basin. The analysis used two models to 

estimate instream temperature effects that would occur as a result of vegetation clearing for 

pipeline construction immediately after construction and after 5, 10, and 20 years based on 

conditions that could be expected on the hottest summer days. The conceptual model for the 

analysis assumed that for a given stream temperature at base flow, the main source of heat load is 

direct and indirect solar radiation and that effective shade from topographic features and 

vegetation is a dominant influence of stream temperatures regimes. The analysis is conservative 

in that it assumed a maximum amount of anticipated disturbance at each crossing based on 95-

foot construction right-of-way, while Pacific Connector would actually reduce the construction 

right-of-way to 75 feet at stream crossings. 

Most of the streams that were modeled were small streams; three were tributaries to East Fork 

Cow Creek that are 3 feet wide or less with baseflows estimated at 0.9 cfs to practically zero. 

Two streams were between 5 and 6 feet wide with baseflows estimated between 0.18 and 0.48 

cfs. The sixth stream, South Fork Little Butte Creek, is about 22 feet wide and has an estimated 

baseflow of 4.2 cfs. The results of the analysis indicated that the greatest effect would occur in 

the smallest and slowest waterbodies immediately following disturbance. For the three smallest 

streams, the model predicted initial average temperature changes of 1.0° to 8.6° C (1.8° to 15.4° 

F). The highest predicted increase (8.6° C) was in a very small drainage that is frequently dry in 

the summer, but occasionally has water present from phreatic groundwater and any water present 

infiltrates back into the ground shortly downstream of the proposed crossing location. Just as 

these very small waterbodies are modeled to warm quickly in response to clearing, they would 

likely also have rapid temperature reductions downstream of the affected reach; thus there would 

be no measurable effect on stream temperatures in East Fork Cow Creek. At the two modeled 

crossing locations on East Fork Cow Creek, the creek would be about 5 to 6 feet wide. Average 

Temperature changes in East Fork Cow Creek as a result of pipeline construction and 

maintenance were predicted to be up to 0.5° C (0.8°F) immediately following disturbance. The 

predicted temperature increase in the largest stream, 22 feet wide, was 0.1° C (0.1° F). All 

temperature impacts were predicted to decrease with time as vegetation returns to provide shade; 

with significant recovery occurring between 5 and 10 years following disturbance. Most of the 

values presented here are well below the uncertainty of the model (1 to 2°C). For comparison to 

the modeled crossings, about 62 percent of the perennial and intermittent dry open-cut stream 

crossings would occur on streams 10 feet wide or less. 
 4.3 – Water Resources and Wetlands 4.3-44

Pacific Connector proposes mitigation measures to help ensure that the Core Cold-Water Habitat 

temperature criteria is not exceeded at the maximum point of impact. These measures are 

designed to speed up the rate of riparian area recovery and provide more effective shade 

immediately following construction. Pacific Connector would increase the post project effective 

shade within the construction right-of-way by planting conifer and hardwood tree saplings and 

small pole sized trees of sufficient size (i.e. 15-20 feet tall with full crowns) to increase riparian 

area canopy closure and placing large woody debris and boulders to create micro-topography 

within the wetted stream channel. Shading from transplanted vegetation and micro-topographic 

features incorporated into the final grading plan are likely to reduce the heat load enough to 

reduce the likelihood of measurable water temperature increases. 

Pacific Connector modeled the potential benefit of post project effective shade created by these 

mitigation measures. The results of the 10-year post project modeling time step was used to 

predict the benefits of the mitigation measures because the trees that would be transplanted 

provide at least the same shade values as predicted for this time step. The predicted water 

temperature changes are small, with less than a 0.3 °C (0.5 °F) change at the point of maximum 

impact, with no increase at the stream network scale (North State Resources 2009). Inclusion of 

the measures improves the certainty that riparian area clearance and stream channel disturbance 

activities within the construction right-of-way would not cause measurable water temperature 

increases at the maximum point of impact or at the stream network scale. 

To address water quality concerns in the Umpqua and Rogue River Basins, the ODEQ issued 

TMDLs in 2006 and 2008, respectively. For nonpoint sources (which includes near stream 

vegetation disturbance), heat allocations are translated into effective shade surrogate measures 

(stream side vegetation objectives) to provide site-specific targets for land managers. Attainment 

of these measures ensures compliance with the nonpoint source allocations (ODEQ 2006d and 

2008). Compliance with Oregon water quality standards and applicable TMDLs would be 

addressed during the 401 certification processes prior to construction. 

Construction of the pipeline would remove riparian vegetation, reduce shade, and increase the 

exposure of surface water to radiant energy, including those within Riparian Reserves. However, 

the recovery of the riparian areas would occur over the long term and the magnitude of the rightof-way’s effects on stream temperature would be minimal because of the narrow disturbance 

corridor (i.e., 75- to 95-foot width). The water temperatures have the potential to increase, 

though most likely very little to immeasurably in all but the smallest of streams. Any changes 

that may occur would gradually recover over time as vegetation returns. Additional information 

on the effects of the proposed pipeline on stream temperature and fish is provided in Section 

4.5.2. 

To minimize the potential effects of the Pacific Connector pipeline on stream temperature by the 

removal of riparian vegetation, Pacific Connector has incorporated the following mitigation 

measures into its project design: 

1. narrowing the construction right-of-way at waterbody crossings to 75 feet where feasible 

based on site-specific topographic conditions; 

2. locating TEWAs 50 feet back from waterbody crossings to minimize impacts to riparian 

vegetation, where feasible; and 
 4.3 – Water Resources and Wetlands 4.3-45

3. replanting the streambanks after construction to stabilize banks and to re-establish a 

riparian strip across the right-of-way for a minimum width of 25 feet back from the 

streambanks. 

On NFS lands, the USFS has requested that the riparian vegetation strip be extended up to 100 

feet on either side of waterbodies in Riparian Reserves. Pacific Connector has agreed to 

implement this measure on both NFS lands and BLM lands. The riparian strip would generally 

be replanted with willow cuttings to provide a quick cover for shading and streambank stability 

as described in the ECRP. Quick cover plantings may be shorter in height than vegetation 

removed during constructions, thus providing less shade. Other appropriate species would also 

be installed such as dogwood and other similar species. In upland areas, other adaptable species 

would be substituted for willows based on the moisture regime at each site. 

The riparian strip would be maintained to allow an herbaceous cover 10 feet in width centered 

over the pipeline to facilitate corrosion and leak surveys. Trees that are within 15 feet of the 

pipeline and are greater than 15 feet in height would be selectively removed from the corridor. 

The remaining area of the construction right-of-way within the riparian strip would be replanted 

with trees that would provide greater height and stream shading over time. Plantings/seeding 

would be done with native vegetation of a local source. 

Stream crossings and associated vegetation clearing would be conducted consistent with the 

FERC staff’s Procedures, which were developed with input from regulatory agencies and the 

industry, and have been in use on FERC-regulated projects for over 15 years. If a project is built 

following the FERC staff's Procedures, it allows the FERC to describe impacts on waterbodies 

and conclude impacts would be reasonable. 

Existing Access Roads

Most access to the pipeline construction right-of-way would be along existing roadways, and 

impacts on waterbodies as a result of use of these roads would be minimal, and consistent with 

existing road use. However, Pacific Connector has estimated that modifications to 62 existing 

access roads may be required outside of the existing road bed (e.g. widening corners to allow for 

the longer turning radius of larger vehicles), resulting in about 17 acres of disturbance. In 

general, roadway improvements would require a minimal amount of site disturbance and 

earthwork necessary to make the roads useable for access to the construction right-of-way. 

However, the USFS has stated that a number of additional roads that Pacific Connector has 

identified as construction access roads would require improvements prior to use, in some cases 

requiring clearing, grading, widening, and drainage improvements. Pacific Connector has begun 

to identify these impacts, but much of the specific road improvement requirements would not be 

identified until closer to construction. These areas would be identified and addressed prior to 

construction in the POD prepared in consultation with the USFS and BLM. 

Where road improvements would be required, Pacific Connector would use BMPs according to 

the ECRP to minimize potential impacts on waterbodies. BMPs may include silt fence/straw 

bale sediment barriers or prefabricated construction mats to prevent rutting/compaction impacts. 
 4.3 – Water Resources and Wetlands 4.3-46

New Temporary and Permanent Access Roads

Pacific Connector has identified 18 locations where it would be necessary to construct new 

TARs, and 16 locations where it would be necessary to construct new PARs (see table 2.3.3.1-1). 

Six of the 18 proposed new TARs would be located within 100 feet of a stream or ditch (table 

4.3.2.5-5); three are adjacent to or within 50 feet of fish-bearing waterbodies, and two are 

adjacent to or within 50 feet of non-fish-bearing ditches. One proposed new TAR (TAR-93.00) 

is located within the South Umpqua River Key Watershed on BLM land. None of the PARs are 

located within Key Watersheds on USFS or BLM lands. 

TABLE 4.3.2.5-5 

New Temporary and Permanent Access Roads Located within 100 feet of Waterbodies 

TAR/PAR Waterbody Name Waterbody ID Direction 

TAR-8.28 Ditch BDX-113 Parallel to field road 

TAR-81.34 Tributary to Myrtle Creek BSP-259 Crossed 

TAR-88.63 Days Creek BSP-233 Crossed 

TAR-128.69 Tributary to Indian Creek ASP-310 Crossed 

TAR-212.50 Ditch NDX-28 Crossed 

PAR-230.90 Ditch NDX-36 Crossed 

Most of the 16 PARs would be located within Pacific Connector’s permanent easement. 

Construction of the new PARs would permanently impact 2.8 acres, converting land from 

existing vegetation to roads (see table 4.4.2.3-4 for vegetation types). One PAR would cross a 

non-fish-bearing ditch. 

To minimize impact on waterbodies from construction of new temporary or PARs, Pacific 

Connector would install BMPs according to the ECRP. BMPs may include silt fence/straw bale 

sediment barriers or prefabricated construction mats to prevent rutting/compaction impacts. 

Construction of the TARs would temporarily impact 6.1 acres. All TARs would be restored to 

preconstruction conditions following completion of construction. 

Contractor Yards and Pipe Storage Yards

Construction activities associated with the contractor and pipe storage yards and off-site rock 

source and disposal sites would have no adverse impact to waterbodies. Thirty-nine yards are 

proposed for use during construction. Of the 39 yards, 32 have been surveyed for wetlands and 

surface water features. No wetlands or surface water features were found on 20 of the surveyed 

yards. Twelve yards contain wetland features or drainage ditches. Where wetlands or drainage 

ditches occur at any of the proposed yard sites, Pacific Connector would avoid wetland impacts 

by utilizing appropriate BMPs and working around them (see section 4.3.3). 

Operation and Maintenance of the Pipeline

The operation of the new pipeline would not result in any adverse impacts to surface water use or 

quality. Vegetation maintenance would be limited adjacent to waterbodies to allow a riparian 

strip at least 25 feet wide, as measured from the waterbody’s MHWM, to permanently revegetate 

with native plant species across the entire right-of-way. On NFS lands where Riparian Reserves 

are affected, up to a 100-foot riparian strip would be planted. However, to facilitate periodic 

pipeline corrosion/leak surveys, a corridor centered on the pipeline and up to 10 feet wide would 
 4.3 – Water Resources and Wetlands 4.3-47

be maintained in an herbaceous state. In addition, trees that are located within 15 feet of the 

pipeline and that are greater than 15 feet in height would be cut and removed from the right-ofway. 

Site-Specific Construction Impacts 

Coos Bay

The wet open cut method would be used for construction of the pipeline within Coos Bay which 

would be crossed between about MPs 1.7 and 4.1. The wet open cut method involves trench 

excavation, pipeline installation, and backfilling through a waterbody without controlling or 

creating a dry zone to work in. 

During construction of the Coos Bay water route, Pacific Connector would comply with 

applicable permit conditions as well as the measures set forth in its ECRP. The following is a 

summary of preliminary work procedures, BMPs, and protective measures that would be 

implemented during construction to minimize short-term and long-term impacts to water 

resources. 

1. The contractor would develop a turbidity monitoring and management plan (TMMP) that 

describes measures to reduce turbidity impacts resulting from dredging and backfill 

operations to ensure compliance with federal and state water quality standards. 

2. Where water depths allow, the dredge bucket would be kept below the water surface 

while placing excavated spoil along the trench in order to minimize turbidity. 

3. The pipeline trench would be backfilled as quickly as possible after the pipeline is 

installed to minimize the distribution of excavated spoil from tidal influence. 

4. Turbidity would be monitored in accordance with the 401 Water Quality Certification 

(WQC) requirements during dredging and backfilling operations by the EI. If turbidity 

levels exceed established tolerances, then the procedures outlined in the WQC would be 

followed. 

5. Turbidity curtains may be deployed, as practicable, in certain areas to protect sensitive 

resources such as oyster and eel grass beds. Implementation of turbidity curtains is 

limited by local site conditions including flow velocities. Use and location of turbidity 

curtains would be determined during final design or as approved by the EI. 

6. Construction would be scheduled to reduce impacts to sensitive resources and would be 

in accordance with the recommended in water work window established by ODFW. 

7. Work below MHHW would be conducted during the recommended in-water work 

window established by ODFW and approved by the FWS and NMFS. The recommended 

in-water work period for Coos Bay is October 1 through February 15. 

Construction of the pipeline across the Coos Bay and Haynes Inlet would span about 2.4 miles. 

Turbidity impacts would be similar to those related to the dredging of the Jordan Cove LNG 

terminal slip. 
 4.3 – Water Resources and Wetlands 4.3-48

South Umpqua River

Pacific Connector proposes to use a diverted open cut crossing for the first crossing of the South 

Umpqua River (MP 69.0) because the river is too wide to utilize other dry crossing methods 

(flume or dam-and-pump), and other crossing methods (conventional boring or HDD) are not 

feasible due to topographic and subsurface constraints. The proposed crossing location is 

conducive to a diverted open cut method because of an existing gravel bar that braids the river 

into two separate channels (a larger main channel on the east side of the river and a smaller 

overflow channel on the west side). The gravel bar and stream channel configuration at the 

proposed crossing location would provide for minimal instream and channel reconfiguration to 

divert the river’s flow temporarily between the channels and away from the work area in order to 

minimize contact between streamflow and the excavation and backfill activities. 

The location of the existing gravel bar would allow the flow of the river to be diverted to the 

overflow channel while allowing work (trench excavation, pipe installation, and backfilling) to 

proceed across the main river channel in the “dry.” Once the pipe segment has been installed 

across the main channel and the channel restored, the river flow would then be diverted back into 

the main channel. Trench excavation, pipe installation, and backfilling would commence across 

the overflow channel in the dry. The pipe sections that have been installed across both of the 

channels would then be joined together on the gravel bar. 

This crossing method would require TEWAs to be located in the river and would require 

equipment to work in the river to place the diversion structures or dams to divert the river flow 

from one channel to the other. These diversion structures would consist of one, or a combination 

of, the following: imported riprap, concrete jersey barriers, water bladder portadams, and/or sand 

bags. Pacific Connector estimates the crossing would take a minimum of 14 days to complete, 

including 3 to 4 days of instream work required to install, rearrange, and remove the diversion 

structures. Some turbidity would result during instream activities and as the water is diverted to 

the backfilled areas. 

Pacific Connector is also proposing a diverted open cut at the second crossing of the South 

Umpqua River (MP 94.7). Although the South Umpqua River channel is not braided into two 

channels at this location like the first South Umpqua River crossing, it is sufficiently flat, wide, 

and shallow to divert all of the river flow to one side or bank of the river while work is 

proceeding in the dry on the opposite bank. 

Like the first crossing, the second crossing of the South Umpqua River would require TEWAs to 

be located in the river and would require equipment to work in the river to place the diversion 

structures or dams to divert the river flow from one side of the river and then to the other. The 

diversion could be constructed using imported riprap, concrete jersey barriers, water bladder 

portadams, and/or sand bags to divert the river’s flow temporarily away from the work area in 

order to minimize contact between streamflow and the excavation and backfill activities. This 

would require Pacific Connector to place equipment within the stream to install, maintain, and 

ultimately remove the diversion structures. Pacific Connector estimates the crossing would take 

a minimum of 14 days to complete including 3 to 4 days of instream work to install, rearrange, 

and remove the diversion structures. Some turbidity would result during instream activities and 

when the water is diverted to the backfilled areas. 
 4.3 – Water Resources and Wetlands 4.3-49

Once the construction right-of-way has been isolated by the diversions and/or sediment control 

devices, trenching would proceed to approximately the middle of the river. Trench spoil would 

be stored within the stream channel behind the diversion or sediment control structures to ensure 

that sedimentation from saturated materials does not flow back into the river. After the trench 

has been completed, a section of pipe would be placed in the trench. Trench boxes or another 

marker form would be placed at the end of the pipe section in the middle of the riverbed for the 

tie-in. The trench would be backfilled and the streambed restored to the original contour 

configuration, except for the immediate area around the tie-in. 

The diversion structure would then be removed and rearranged to divert the flow temporarily to 

the other side or dry side of the river in order to minimize contact between streamflow and the 

excavation and backfill activities. This would again require Pacific Connector to place 

equipment within the stream in order to rearrange the diversion structures. Once the diversion 

structures have been properly reconfigured and extended beyond the tie-in location and the river 

flow diverted to the opposite side of the river, excavation for the other section of pipe would 

begin. Trenching would proceed across the river bed to the tie-in point in the middle of the river 

where it would be uncovered. Once the excavation is complete, the second pipe section would 

be carried in and tied-into the first section. After the tie-in has been made, the streambed would 

be restored to its original contours and configuration and the diversions structures would be 

removed. Streambanks would be re-established and stabilized. 

During the diverted open cut at the second crossing of the South Umpqua River, multiple 

discharge pumps would be required to keep the tie-in area dry while the welds are being made 

and to control any flow seepage in the work areas. The discharge from this activity would occur 

to a straw bale discharge structure located in an upland area as far away from the river as 

possible to prevent any silt-laden water from flowing into the river. 

We received comments regarding the crossing of Fate Creek in Douglas County. Fate Creek is a 

tributary to Days Creek, which is a tributary to the South Umpqua River. Commenters were 

concerned that pipeline construction activities would have a negative impact on past and ongoing 

restoration activities on private lands, such a those that have occurred on Fate Creek at or near 

the proposed crossing location. Impacts to Fate Creek, as with all crossings, would be limited by 

the implementation of Pacific Connector’s ECRP. The ECRP requires that native shrubs and 

trees be planted in areas where these species existed prior to construction, using a local 

restoration contractor. Further, the waterbody crossing would occur during the ODFW-specified 

work window. A recently replaced culvert on Fate Creek would not be impacted by the pipeline. 

Kentuck Slough, Catching Slough, and the Medford Aqueduct 

Pacific Connector proposes to use conventional bores to cross underneath the Kentuck Slough 

(MP 6.2), Catching Slough (MP 11.1) and the Medford Aqueduct (MP 133.4). A bore would 

involve excavation of pits on either side of the waterbody and boring horizontally underneath the 

waterbody. A successful bore would result in no direct impact to the waterbody. The specific 

type of bore (i.e., jack and bore, slick bore, hammer, etc.) that would be utilized would be 

determined during final design and would depend on construction characteristics and the type of 

soils present. Because bore pits on either side of the crossing would be required, there is some 

risk that high water tables may cause groundwater to infiltrate the bore pit walls, or create 
 4.3 – Water Resources and Wetlands 4.3-50

pressure from the exterior of the pit walls and cave in the bore pits. Shoring would be used as 

required to prevent bore pit cave in, and pit dewatering would be conducted as required. Water 

pumped from the pit would be discharged to an upland location designed to prevent turbid waters 

from reaching a waterbody. Erosion control measures would be implemented to prevent surface 

erosion at the pump discharge point. 

Coos River, Rogue River, and Klamath River 

Pacific Connector proposes to use the HDD method (see section 2.4.2.2) for the crossing of the 

Coos River (MP 8.2), the Rogue River (MP 122.6), and the Klamath River (199.4). 

GeoEngineers Inc. (2007a, 2007b, 2007c) evaluated the feasibility of the HDD crossings of the 

Coos River, Rogue River, and Klamath River crossings. GeoEngineers, Inc. determined that 

HDD crossings at the Coos, Rogue, and Klamath Rivers are feasible assuming proper HDD 

construction best management practices and specifications are adhered to during construction. 

Pacific Connector has prepared an HDD Contingency Plan and Failure Procedure4 that describes 

the procedures that would be followed if an inadvertent release of drilling mud occurred during 

the HDD process and the methods that would be used to contain the drilling fluid. 

If an inadvertent return occurs, the HDD operation would be stopped temporarily to determine an 

appropriate response plan. Pacific Connector would attempt to determine the cause of the 

hydraulic fracture and inadvertent return and would implement procedures, which may reduce 

the chance of recurrence. One possible corrective measure would be increasing the drilling fluid 

viscosity in an attempt at sealing the release point. The drilling operation may be suspended for 

a short period (i.e. overnight) to allow the fractured zone to become sealed with the higher 

viscosity drilling fluid. 

If seepage occurs in the river, there may be a visible plume. Minor seepage may be difficult to 

detect due to the turbidity of the river water and the high specific gravity of bentonite clay 

drilling fluid. There would be very little drilling fluid pressure to disturb sediments due to the 

distance that the drilling fluid must travel to reach the surface. The composition of the drilling 

fluid is primarily water and bentonite clay. If a small amount is released into the river, the 

rivers’ currents would quickly dissipate it. In the event an inadvertent return is detected in a 

river, agencies would be notified. If corrective measures can be feasibly implemented, an 

assessment would be made to determine the most appropriate containment structure to be erected 

to minimize the volume of drilling fluid released into the river. The area downstream of the 

project site would be monitored to identify areas that may have substantial accumulations of 

drilling fluid. Where possible, drilling fluid volumes that represent significant adverse impacts 

to aquatic habitat would be removed from the substrate, pending agency review and approval of 

the removal plan. 

Pacific Connector has evaluated contingency locations for each proposed HDD crossing, so that 

an alternative crossing location could be used in the event of an HDD failure (GeoEnginers 

2007f, 2007g, 2007h). In the event of an unsuccessful HDD at the proposed Coos River crossing 

location, the HDD method would be reattempted at a crossing location approximately 1,000 feet 

southwest of the proposed crossing location. Preliminary analysis by GeoEngineers 

 

4

 Pacific Connector’s HDD Contingency Plan and Failure Procedure, was filed with the FERC as part of its application on 

September 4, 2007. 
 4.3 – Water Resources and Wetlands 4.3-51

(GeoEngneers 2007f) indicates that HDD could be successfully implemented at these 

contingency sites. 

In the event that the proposed HDD crossing fails at the proposed Klamath or Rogue Rivers, 

Pacific Connector’s contingency crossing plans would be wet open-cut crossings at approximately 

the same location as the proposed HDD crossings. Wet open-cut methods produce more 

suspended sediments and turbidity that dry open-cut methods, as it would be completed in the 

flowing waterbody. Should either of these HDD crossings fail, Pacific Connector would be 

required to obtain all necessary permits and authorizations for in-water construction from the 

appropriate agencies prior to commencing an open cut crossing. Pacific Connector’s proposed 

schedule for HDD crossings would allow adequate time to apply for necessary permits within the 

overall construction schedule in the event that an HDD crossing is unsuccessful. 

As an alternative, or in the event of a failure of these HDD crossings, Pacific Connector could 

evaluate an aerial crossing. This contingency has not been proposed by Pacific Connector and 

would require numerous approvals. There are some clear benefits of aerial crossings (such as 

decreased impacts to water quality and aquatic species compared to the wet open-cut method). 

However, there are trade offs with impacts to other resources increasing (e.g., visual impacts, 

recreation, and pipeline safety and security). An overhead crossing alternative for the Rogue 

River is discussed further in section 3.1.4.2. 

4.3.3 Wetlands 

Wetlands are defined jointly by the EPA and the COE as areas that are inundated or saturated by 

surface or groundwater at a frequency or duration sufficient to support a prevalence of vegetation 

adapted for life in saturated soil conditions (Environmental Laboratory 1987). Wetlands are 

considered to be ecologically important and can provide substantial biodiversity. They serve a 

variety of physical, biological, and chemical functions such as wildlife and fish habitat, flood 

flow moderation, groundwater recharge and discharge, water quality protection, and recreational 

opportunities. 

Wetlands in the proposed Project area are regulated at the federal, state, and local level. At the 

federal level, wetlands have been deemed Waters of the United States (33 CFR 328.3) and are 

subject to regulation through the CWA. Sections 401 and 404 of the CWA were created 

specifically with the intent “to restore and maintain the chemical, physical, and biological 

integrity of our Nation’s waters.” The COE has authority under section 404 of the CWA to 

review and issue permits for activities that would result in the discharge of dredged or fill 

material into wetlands. Section 401 of the CWA requires that proposed dredge and fill activities 

under section 404 be reviewed and certified by the designated state agency, in this case the 

ODEQ, that the proposed Project would meet state water quality standards. 

In Oregon, wetlands are also regulated at the state level by the ODSL and at the local level by 

some city and county land-use ordinances. Most activities that affect more than 50 cy of 

material in wetlands are required to have a permit from ODSL, which administers Oregon’s 

Removal-Fill Law (ORS 196.800) enacted in 1967 and 1971 to protect waterways and wetlands. 

On federally managed land, EO 11990 amended in 42 USC 4321 et. seq., requires the federal 

agencies “to avoid adverse impacts associated with the destruction or modification of wetlands 
 4.3 – Water Resources and Wetlands 4.3-52

wherever there is a practicable alternative” and to “include all practicable measures to minimize 

harm to wetlands.” Further, the agencies are required to preserve and enhance the natural and 

beneficial values of wetlands in carrying out their responsibilities. 

The COE Wetlands Delineation Manual (Environmental Laboratory 1987) provides the 

standards for determining areas of wetlands and deepwater habitats. Land areas are defined as 

wetlands when soil, hydrology, and vegetation all meet the technical criteria for establishing 

wetlands. Wetland delineations for the proposed Project were conducted in accordance with 

these federal regulations and methodologies. 

4.3.3.1 Waterway for LNG Marine Traffic 

Existing Wetland Resources 

Wetlands occurring along the LNG carrier transit route within the Zones of Concern as mapped 

by the FWS NWI are shown in figure 4.3-1. Wetland systems along the waterway for LNG 

marine traffic fall into four categories: marine, estuarine, lacustrine, and palustrine, as 

summarized below. 

The marine system consists of the open-ocean and subtidal and intertidal shorelines. The 

estuarine system consists of deepwater tidal habitats and adjacent tidally influenced flats and 

wetlands. Vegetated estuarine wetlands along the waterway consist of submerged aquatic beds 

and intertidal salt marsh. The lacustrine system consists of permanently or intermittently flooded 

lakes and reservoirs, which includes the industrial waste pond located on the west side of the 

Trans-Pacific Parkway. 

Palustrine wetlands are nontidally influenced freshwater wetlands. Palustrine wetlands along the 

waterway for LNG marine traffic include ponds, emergent wetlands, scrub-shrub wetlands, and 

forested wetlands. The emergent wetland type is dominated by herbaceous hydrophytes and may 

include scattered shrubs, which include peat bogs and marshes. Palustrine scrub-shrub wetlands 

in this area are dominated by shrubs, including willows and Douglas spiraea (Spiraea douglasii), 

with an understory of herbaceous hydrophytes. Dominant tree species in forested wetlands in the 

Coos Bay area include red alder (Alnus rubra), black cottonwood (Populus balsmifera), and 

willows (Salix spp.). Typical species within the vegetated wetlands along the waterway are 

described in more detail below under LNG Terminal Facilities. 

Impacts and Mitigation 

The wetlands located nearer to the navigation channel have some potential to be affected by 

increased wave action from LNG carriers. Ship wakes breaking along the shoreline could cause 

increased erosion, resulting in damage or loss to shoreline vegetation. To estimate the effects of 

prop wash and waves from LNG vessels in Coos Bay, Jordan Cove developed a model to simulate 

the effects of waves from a vessel traveling a maximum of 6 knots (6.9 miles/hour). The model 

considered waves generated at seven locations between the mouth and docking location of an LNG 

vessel (Moffatt and Nichol 2008). They found that the maximum wave height generated would be 

about 1.1 foot. This wave size, while still uncommon, currently occurs within Coos Bay, based on 

wind-generated waves. Waves of this size occur within the bay during about 2 percent of the year. 

The predicted waves would equal from 0.0 to 3.1 percent of the annual wave energy at the seven 

locations modeled. The model assumed about 200 vessel transits per year (combined inbound and 
 4.3 – Water Resources and Wetlands 4.3-53

Figure 4.3-1. Wetlands Along the Waterway 
 4.3 – Water Resources and Wetlands 4.3-54

outbound; about 160 combined vessel transits are proposed) of a 934-foot-long vessel traveling at 

about 6 knots. Some additional shore sediment movement may occur from these waves, but 

overall effects would be small because they would infrequently occur, they contribute a very small 

portion of total annual wave energy, and they are within the normal magnitude of waves that 

naturally occur within the bay. The outer mile of the entrance where the vessels would be traveling 

8 to 10 knots may have higher vessel-generated waves due to the greater speeds, but this but this 

area is already less protected from naturally occurring ocean generated waves and likely has higher 

background naturally generated waves than the regions farther into the bay. Also, the wave 

analysis did not include effects of ocean-generated waves, which would be more substantial near 

the bay entrance (Moffatt and Nichol 2008), so relative change from background near the entrance, 

even with the higher speeds, may not be substantial. (See sections 4.2 and 4.5 for more discussion 

of soil erosion and wave modeling.).

During transit to the LNG terminal, the potential exists for an accidental or intentional breach of 

an LNG carrier resulting in a release of LNG; however, LNG is less dense than freshwater or 

saltwater so it would float on the water’s surface. Immediately upon contact with any warmer 

substance such as water or air, it would begin to evaporate. Because LNG is not soluble in water 

and the LNG would completely vaporize shortly after being spilled, there would be no liquid left 

that could mix with and/or contaminate the water or sediments. As the LNG vaporizes, a vapor 

cloud may form that is initially heavier than air and may be dispersed by wind. An LNG vapor 

cloud cannot explode in the open atmosphere, but can burn. If the LNG vapor cloud were to 

burn, wetland vegetation along the Coos Bay navigation channel could be damaged; however, 

the area of effect resulting from an LNG release and any resulting fire would be fairly limited 

and short-lived. As discussed in section 4.12, the risk of an accidental or intentional release of 

LNG during transit of the LNG carriers is extremely low and can be managed by implementing 

the Coast Guard’s recommendations (Appendix B); therefore potential impacts on wetlands due 

to LNG marine traffic in the waterway would be less than significant. 

4.3.3.2 Jordan Cove LNG Import Terminal 

Existing Wetland Resources 

Jordan Cove conducted wetland delineations for the proposed LNG terminal site in 2005 and 2006. 

FWS NWI maps were also consulted to identify the potential occurrence of wetlands (SHN 2006). 

Approximately 21.4 acres of wetland were delineated at the proposed LNG terminal site. 

Palustrine emergent, palustrine scrub-shrub, and palustrine forested wetlands were found in the 

northern and northeastern portion of the proposed LNG terminal site. There are also palustrine 

scrub-shrub wetlands in a small area near Jordan Lake, where an existing access road is located. 

The palustrine forested wetlands in the northeast portion of the LNG terminal site would remain as 

part of a conservation area on the site. 

Wetlands found at the Port Commercial Sand Stockpile area have the potential to be impacted 

during construction of the Jordan Cove import terminal; therefore, wetland delineations were 

conducted at this location as well. The Port site would be used to store dredged material created 

during the construction of the slip. Habitat at this location has been disturbed both recently and 

historically. Recent disturbance includes construction of the adjacent Southport industrial 

facility and recreational use, particularly by OHVs. Much of the Port site has substantial 

amounts of clamshell and wood chip deposits, which suggest that portions of the site have been 

historically filled. 
 4.3 – Water Resources and Wetlands 4.3-55

A wetland delination was conducted of the Port site, using wetland classifications based on 

Cowardin et al. (1979). The wetland delineation report was reviewed and accepted by the 

ODSL, and its results are described below. Figure 4.3-2 depicts the wetlands found at the Port 

site. Approximately 11.5 acres of wetlands were delineated near the proposed Port site. Wetland 

vegetation in the area varies from palustrine emergent and palustrine scrub-shrub wetlands, to 

open water areas virtually devoid of vegetation. The most substantial area of wetland vegetation 

in the area is located in the northwestern portion of this site, along the Trans-Pacific Parkway. 

Approximately 0.1 acre of palustrine scrub-shrub with semi-permanently flooded wetlands are 

located within the area of impact at the Port site. 

Palustrine emergent wetlands are nontidally influenced freshwater wetlands dominated by erect, 

rooted, herbaceous wetland plants that generally persist for most of the growing season. Plant 

species found in the emergent wetland on the proposed site include slough sedge (Carex 

obnupta), Hooker’s willow (Salix hookeriana), toad rush (Juncus bufonius), dagger-leaved rush 

(Juncus ensifolius), tinker’s penny (Hypericum anagalloides), devil’s beggartick (Bidens 

frondosa), knotgrass (Paspalum distichum), Yorkshire fog (Holcus lanatus), creeping bent-grass 

(Agrostis stolonifera), yellow pond lily (Nuphar lutea ssp. polysepala), and floating-leaved 

pondweed (Potamogeton natans). 

Palustrine scrub-shrub wetlands are nontidally influenced freshwater wetlands that include areas 

dominated by woody vegetation less than 20 feet tall and are vegetated with true shrubs, young 

trees, and trees or shrubs that are small or stunted because of environmental conditions. Shrub 

species found within the scrub-shrub wetlands on the Project site include Hooker’s willow, Sitka 

willow (S. sitchensis), Douglas spiraea, and twinberry (Lonicera involucrata). Herbaceous species 

in the scrub-shrub wetlands include slough sedge, spreading rush (Juncus effuses), dagger-leaved 

rush, toad rush, western bent-grass (Agrostis exarata), creeping bent-grass, reed canary grass 

(Phalaris arundinacea), northern willowherb (Epilobium ciliatum), tall mannagrass (Glyceria 

elata), and lowland cudweed (Gnaphalium palustre). 

Palustrine forested wetlands are nontidally influenced freshwater wetlands that contain woody 

vegetation that is 20 feet or taller. The trees found on the proposed site are coniferous and 

include shore pine (Pinus contorta), Douglas-fir (Pseudotsuga menziesii), Sitka spruce (Picea 

sitchensis), western hemlock (Tsuga heterophylla), and scattered Port-Orford-cedar 

(Chamaecyparis lawsoniana). Shrubs within the forested wetland areas include scotch broom 

(Cytisus scoparius), coyote brush (Baccharis pilularis), hairy manzanita (Arctostaphylos 

columbiana), evergreen huckleberry (Vaccinium ovatum), salal (Gaultheria shallon), wax myrtle 

(Myrica californica), and scattered rhododendron (Rhododendron macrophyllum). Herbaceous 

species include European beachgrass (Ammophyla arenaria), silver hairgrass (Aira 

caryophyllea), little hairgrass (A. praecox), hairy cat’s ear (Hypochaeris radicata), braken fern 

(Pteridium aquilinum), sheep sorrel (Rumex acetosella), candy-stick (Allotropa virgata), and 

rattlesnake plantain (Goodyera oblongifolia). 
 4.3 – Water Resources and Wetlands 4.3-56

Figure 4.3-2. Vegetation and Wetlands at the Port Commercial Sand Stockpile Site 
 4.3 – Water Resources and Wetlands 4.3-57

Impacts and Mitigation 

During scoping we received comments about the potential for the LNG terminal to impact 

Henderson Marsh. Jordan Cove would maintain a buffer between its LNG terminal facilities and 

Henderson Marsh; and no filing of this marsh would be done as a result of this Project. In 

addition, construction activities are unlikely to affect the water table at the LNG site or within 

adjacent wetlands (see section 4.3.1.2). Jordan Cove identified other wetlands within the tract 

they would acquire from the Port; but again, no terminal facilities would be built in those 

wetlands. 

Wetlands that would be impacted are those within the intertidal portion of the access channel and 

slip for the terminal. Also, some wetlands at the Port Commercial Sand Stockpile area may be 

impacted due to the storage of dredged material. Sand generated during dredging activities 

would be stored at the Port site for 7 years, resulting in a long-term adverse impact to 0.1 acre of 

palustrine scrub-shrub wetlands. The Port is prepared to undergo revegetation efforts at this 

location following closure; however, the implementation of these revegetation efforts would be 

dependent on the land use proposed for the Port Commercial Sand Stockpile after the sand has 

been removed (after 7 years). 

Wetland communities are susceptible to invasion by noxious weeds. These noxious weeds can 

degrade the function and values of the affected wetland by altering hydrologic flow and species 

composition. Jordan Cove would implement the measures prescribed in the 2008 Noxious Weed 

Policy and Classification System and in the Oregon Aquatic Nuisance Species Management Plan 

during construction, to prevent the introduction or spread of invasive plant species that could 

occur within the Project area. Surveys would be conducted within construction areas to 

determine the presence of invasive species. In the event that invasive species are identified, 

equipment would be cleaned to prevent the export and spread of weed species and seeds. 

Appropriate native seed mixes would also be used to limit germination of weeds during the 

stabilization and restoration of the site following construction. The noxious weeds present 

within the entire project area and the measures which would be taken to prevent their spread 

and/or establishment within vegetated communities, including wetlands, are addressed in more 

detail within section 4.4. 

Slip and Access Channel 

Estuarine intertidal wetlands occur along the shoreline of Coos Bay where the slip would be 

constructed. These wetlands are unvegetated sand-mud flats and submerged aquatic vegetation, 

including algal flat and eelgrass. Estuarine intertidal wetlands have water flows dominated by 

tidal influences and water depths controlled by tidal cycles. Intertidal wetlands can be either 

vegetated or not, and provide food and habitat for many aquatic and amphibious species. 

Benthic organisms in tidal flats are specially adapted to sediment sizes and the temperatures and 

exposure of a particular intertidal environment. This is an important part of the ecosystem that 

provides habitat and food for a variety of terrestrial, avian, and aquatic species. 

Construction and operation of the slip and access channel would result in the permanent loss of 

approximately 3.85 acres of intertidal habitat, 4.45 acres of shallow subtidal habitat, and 39.5 

acres of deep subtidal habitat. Included among the subtidal habitat affected would be 

approximately 6.8 acres of submerged aquatic vegetation (5.7 acres of algal flat and 1.1 acres of 

eelgrass). The permanent loss of these wetlands would be a long-term adverse effect. 
 4.3 – Water Resources and Wetlands 4.3-58

When unavoidable wetland impacts are proposed, the COE, and the ODSL require that all 

practicable actions be taken to avoid, minimize, and then compensate for those impacts. The 

specific type and amount of compensatory mitigation that would be required to offset the loss of 

wetland acreage and functions would be determined by the COE as part of the section 404 permit 

process, and by the ODSL as part of the state Removal-Fill permit process. 

Jordan Cove has proposed mitigation to offset the permanent impact to wetlands that would 

result from construction and operation of the slip and access channel, as outlined in their 

Estuarine Resource Mitigation Plan. To mitigate for loss of intertidal unvegetated sand-mud 

flats and algal flat, Jordan Cove originally proposed to restore and enhance approximately 30.7 

acres of low and/or high marsh along a tidal flood bench adjacent to the Isthmus Slough, near 

channel mile 6.0. Enhancement/restoration at this site would have been accomplished by 

removing a damaged dike and reestablishing tidal flow. Due to concerns from NMFS regarding 

the distance of this proposed mitigation site from the area of impact, Jordan Cove has moved the 

mitigation site to the Kentuck Slough site. The Kentuck mitigation site is located on a golf 

course adjacent to the south bank of the Kentuck Slough, between river mile 0.0 and 0.9. 

Approximately 35 acres of land, disturbed by the construction and operation of the golf course, 

would be restored to a mud-flat condition by re-establishing tidal connections between the 35-

acre site and Kentuck Inlet. This would be accomplished through the removal of tidegates and 

dikes. 

Restoration effort at the Kentuck Slough mitigation site would result in some impacts; however, 

they would be limited in scope and would only exist during the actual restoration process. 

Potential impacts include a temporary reduction in water quality due to an increase in 

sedimentation during dike/tidegate removal, temporary disturbances to adjacent wildlife, and a 

temporary impact to vegetation removed during restoration activities. As the site is currently 

utilized as a golf course, these impacts would not be significant and would be part of an overall 

enhancement of the habitat. 

To mitigate for the impact to eelgrass, Jordan Cove proposes to create new eelgrass habitat at a 

shallow unvegetated island approximately 900 feet southwest of the Coos-Bay North Bend 

Airport runway. This site is adjacent to a successful eelgrass restoration site owned by the State 

of Oregon and managed by the ODSL. The 2-acre eelgrass mitigation site would be 

dredged/excavated to the appropriate elevation and then revegetated with eelgrass during 

summer months (the optimal time for eelgrass transplantation). The proposed success criteria for 

this eelgrass mitigation site would be the successful establishment of 1.1 acres of new eelgrass 

habitat. The COE, NMFS, and EPA have expressed concern regarding the mitigation ratio 

proposed for eelgrass restoration, and have suggested that the mitigation area be larger than 

proposed. Therefore, we recommend that: 

• Jordan Cove should continue to consult with COE, NMFS, ODSL, and ODFW, and 

other appropriate resource agencies to develop a final compensatory mitigation plan 

for permanent impacts on eelgrass. Jordan Cove should file the final plan, including 

documentation of agency consultations, with the Secretary prior to construction of 

the LNG terminal, for the review and approval of the Director of OEP. 

The dredged/excavated and eelgrass revegetation effort could result in temporary short-term 

impacts, as they would be limited in scope and temporary in duration. Potential impacts include 
 4.3 – Water Resources and Wetlands 4.3-59

a temporary reduction in water quality due to an increase in sedimentation during dredging 

activities and a temporary loss of benthic organisms. Benthic organisms would re-establish 

within the area once eelgrass revegetation was complete (see section 4.5.2). 

Jordan Cove would prepare a mitigation plan for the wetland permits to address compensation 

for wetlands permanently impacted by the slip. Specifically, the 404/401 permit requires a 

mitigation plan prior to the initiation of construction. 

4.3.3.3 Pacific Connector Pipeline 

Existing Wetland Resources 

Pacific Connector conducted wetland delineations during 2006 and 2007 for the proposed 

pipeline right-of-way, staging areas, temporary extra work areas, and aboveground facilities. 

On-site delineation was not possible in some areas because access was denied by the landowners, 

and in these areas Pacific Connector used USGS topographic maps, NRCS soil surveys, FWS 

NWI maps, and aerial photography to identify the approximate wetland type and boundaries. 

A total of 689 wetlands and other waters were identified within the Pacific Connector pipeline 

area. The primary wetland types identified during the delineations were palustrine emergent, 

palustrine scrub-shrub, palustrine forested, riverine, and open water wetlands. These 

classifications are based on Cowardin et al. (1979) and summarized below. 

Palustrine Emergent Wetlands – Most of the emergent wetlands identified are disturbed by 

agricultural activities, primarily grazing or haying. The disturbed wetlands are dominated by 

pasture grasses such as meadow foxtail (Alopecurus pratensis), rough bluegrass (Poa trivialis), 

and various bentgrasses (Agrostis spp.). Native emergent wetlands are uncommon, and generally 

contain cattail (Typha latifolia), small-fruited bulrush (Scirpus microcarpus), hardstem bulrush 

(S. acutus), manna grass, American sloughgrass (Beckmannia syzigachne), and various sedges 

(Carex spp.). 

Palustrine Scrub-Shrub Wetlands – The delineation identified disturbed scrub-shrub wetlands 

associated with grazing or development activities dominated by invasive species such as 

Himalayan blackberry (Rubus armeniacus) and sweetbriar rose (Rosa eglanteria) around wetland 

fringes. The less-disturbed, native scrub-shrub wetlands generally contain a mixture of native 

species such as Douglas’ spirea, Pacific willow (Salix lasiandra), salmonberry (Rubus 

spectabilis), and Pacific ninebark (Physocarpus capitatus). 

Palustrine Forested Wetlands – The majority of delineated forested wetlands contain Oregon ash 

(Fraxinus latifolia). Red alder and black cottonwood are more common along the western part 

of the pipeline route in Coos and Douglas Counties. Western redcedar (Thuja plicata) and Sitka 

spruce are common in the coast range forested wetlands. Skunk cabbage (Lysichiton 

americanum), salmonberry (Rubus spectabilis), lady fern (Athyrium filix-femina), and horsetails 

(Equisetum spp) are often present in the understory. Forested wetlands are uncommon along the 

southeastern portions of the pipeline route, but are generally in swales or depressions. They are 

dominated by Oregon ash with an understory of Himalayan blackberry, slough sedge, and 

spreading rush. 
 4.3 – Water Resources and Wetlands 4.3-60

Riverine Wetlands – Riverine wetlands are freshwater wetland habitats contained within a 

channel. The riverine wetlands in the Project area include species similar to those found in the 

palustrine emergent, scrub-shrub, and forested wetlands. 

Open Water Wetlands - Open water wetlands are areas of open water, often within a palustrine 

vegetated wetland. 

Impacts and Mitigation 

The Pacific Connector pipeline would cross approximately 11.5 miles of wetlands. The 

construction right-of-way and TEWAs would impact approximately 123.2 acres of palustrine 

emergent wetlands, 77.6 acres of estuary wetlands, , 48.2 acres of riverine wetlands, 4.2 acres of 

palustrine forested wetlands, 2.1 acres of palustrine aquatic bed intermittently exposed/excavated 

wetlands, 1.4 acres of palustrine unconsolidated bottom wetlands, and 0.4 acre of palustrine 

scrub-shrub wetlands. Table G-1 in Appendix G contains a copy of Table 2A-10 from the 

November 2, 2008 data response to the FERC, which summarizes wetlands crossed by the 

Pacific Connector pipeline by ecoregion and sub-basin, fifth field watershed, and wetland type. 

The construction of a pipeline within wetlands could have several effects. Removal of 

vegetation can alter various wetland functions including providing fish and wildlife habitats, 

sediment and nutrient trapping, and other water quality functions. Soil disturbance and removal 

of vegetation could temporarily affect a wetland’s capacity to moderate flood flow, control 

sediment, or facilitate surface water flow. Removal of vegetation could increase water and soil 

temperatures and alter species composition within forested and shrub wetlands to a more shade 

intolerant composition. Digging a trench through an impervious layer of soil in a wetland could 

alter hydrology of a perched water table leading to drier conditions and affect the reestablishment of wetland functions. Failure to segregate topsoil from the trench could result in 

altered biological and chemical functions in the wetland soil and affect the vegetation reestablishment, recruitment of native vegetation, or success of plantings. Improper operation of 

equipment or transport of pipe in wetlands could inadvertently rut or compact the soil and affect 

natural hydrologic patterns of the wetlands and may lead to inhibited seed germination or 

increase the potential for siltation. Improper sediment controls could lead to sediment deposition 

in the wetlands that could lead to the release of chemical and nutrient pollutants from sediments. 

Soil disturbance and hydrology changes would generally be minimized by the procedures used 

during construction (see sections 4.2 and 4.3.2). The primary effects of the proposed pipeline 

construction and operation activities on wetlands would be the temporary short-term or 

permanent long-term alteration of wetland vegetation. 

In herbaceous wetlands (palustrine, emergent, and riverine), the effects of pipeline construction 

would be considered temporary because the topsoil would be preserved, the hydrology would not 

be altered, and herbaceous vegetation would regenerate quickly. Generally, the wetland 

vegetation community would eventually transition back into a community with functionality 

similar to that of the wetland prior to construction. In emergent wetlands, the herbaceous 

vegetation would regenerate quickly (typically within one to three years). The effects would be 

greatest during and immediately following construction. After construction, Pacific Connector 

would re-establish pre-existing wetland elevations, restore surface hydrology, and allow 

herbaceous vegetation to return to pre-construction conditions. 
 4.3 – Water Resources and Wetlands 4.3-61

In scrub-shrub and forested wetlands, the recovery would be long-term because it would take 

more than three years for forested and most scrub-shrub vegetation to recover to pre-construction 

conditions. Scrub-shrub wetlands could take several years to reach functionality similar to 

preconstruction conditions, depending on the age and complexity of the system. Removing trees 

would result in a short-term loss in hydrologic and biogeochemical function that would begin to 

return as soon as the area was revegetated. The habitat functions provided by forested wetlands 

would require more time to return. Measures to mitigate for any permanent effects to wetlands 

would be determined during final permitting with the COE in addition to the mitigation measures 

addressed later in the section. Construction activities would also temporarily displace wildlife 

from the pipeline right-of-way, and reduce the recreation and aesthetic functions of wetlands. 

Indirect effects to wetlands outside the construction right-of-way are expected to be negligible 

because Pacific Connector would implement measures during construction to avoid changes to 

wetland hydrology and to contain sediment within the construction right-of-way. 

The majority of wetland impacts would occur in Coos County, where approximately 5.2 miles of 

wetlands would be crossed resulting in 117.7 acres of impacts. The miles of wetland crossings 

within Coos County represent 45 percent of the total miles along the pipeline, while the acres of 

impact represent approximately 46 percent of the total acres of wetlands affected by the pipeline. 

Furthermore, installing the pipe in the Coos Bay Estuary between about MPs 1.7 and 4.1 would 

impact approximately 75 acres of estuarine and open water habitats. Various eelgrass surveys 

have been conducted with the Coos Bay Estuary (ODLCD 1998; Clinton 2007); however, the 

most resent eelgrass survey indicates that approximately 1 acre of eelgrass would be impacted 

during the pipe installation within the Coos Bay Estuary (Ellis Ecological Services 2009). 

Eelgrass densities within Coos Bay vary, and are defined as low-density (10 to 39 percent cover), 

medium-density (40 to 79 percent cover), and high-density (≥ 80 percent cover). The majority of 

eelgrass impacted within Coos Bay would consist of low-density, while no high-density eelgrass 

would be impacted. The remaining impacts within the bay would occur to sand/mud flats and 

shallow subtidal areas (Ellis Ecological Services 2008). 

The crossing of the Lake Ewauna Upper Klamath River fifth field watershed in Klamath County 

would cover approximately 3.3 miles of wetlands, resulting in 66.2 acres of impacts to wetlands. 

The miles of wetland crossings within Lake Ewauna represents 29 percent of the total crossings 

along the pipeline, and the acres of wetland impact represent 25 percent of the total acreage of 

impacts. The impacts would almost entirely affect previously disturbed emergent agricultural 

pasture and hayfield wetlands, ditches, and canals, and would be temporary impacts. The Pacific 

Connector pipeline would cross approximately 1.2 miles of wetlands in Big Butte Creek and 

Little Butte Creek fifth field watersheds, resulting in 15.4 acres of wetland impacts, while the 

pipeline’s 0.2-mile crossing of the Middle South Umpqua hydrologic unit code (HUC), in 

Douglas County would have 32.0 acres of wetland impacts. The impacts from these areas 

described above represent approximately 90 percent of the wetland impacts from the Pacific 

Connector pipeline. The impacts outside of these areas would occur primarily to small palustrine 

emergent wetlands and intermittent drainages where impacts would be temporary and short-term. 

Table G-2 in Appendix G contains a list of the permanent and temporary impacts to wetlands 

within the fifth field watershed and the Cowardin classification of impacted wetlands. 

At MP 68.68, within the site of the Clarks Branch Meter Station, 0.1 acre of emergent wetland 

would be permanently filled. This wetland is located at the intersection of the Pacific Connector 
 4.3 – Water Resources and Wetlands 4.3-62

pipeline with Williams' Northwest Pipeline Grants Pass lateral, where a gas delivery interconnect 

has been proposed. Because of the location of the existing pipeline, cultural resources issues in 

the immediate area, and landowner requirements, the Clarks Branch Meter Station could not be 

relocated to avoid the wetland. 

Following construction, vegetation maintenance within the permanent operational right-of-way 

would convert forested or scrub-shrub wetlands to a different wetland type resulting in a 

different wetland function. Figure 2.7-1 depicts the plan for permanent maintenance of 

vegetation within forest and shrub-wetlands, while figure 2.7-2 depicts the plan for maintenance 

of vegetation within riparian areas. Permanent wetland vegetation conversion would occur in 

approximately 1.1 acres of palustrine forested wetlands and 0.1 acre of palustrine scrub-shrub 

wetlands. The total permanent wetland vegetation type conversion would be approximately 1.2 

acres; therefore, the total permanent impacts to wetlands resulting from permanent fill (0.1 acre) 

and permanent type conversion (1.2 acres) would be 1.3 acres, or 0.5 percent of the total wetland 

disturbances. 

The function and values of wetlands were accessed in order to determine which affected 

wetlands were high value wetlands. The criteria used to access wetlands were their water quality 

and quantity, the value of their fish and wildlife habitat, their native plant communities and 

species diversity, and their value for recreation and educational purposes. Table G-3 in 

Appendix G contains a copy of Table 2A-11 from the FERC data request dated June 2, 2008, 

which lists the permanent and temporary impacts to high-value wetlands and the justification for 

their classification as high value wetlands. Long-term impacts to high-value wetlands could 

include permanent filling of wetlands resulting in loss of function or a type conversion from 

forest-shrub wetlands to herbaceous wetlands, which would result in a change in wetland 

function. Project construction would result in 0.63 acre of permanent impacts to high-value 

wetlands. (This value of 0.63 acres of permanent impact to high-value wetlands is included in 

the 1.3 acres of total permanent impacts to wetlands reported above.) In Coos Bay fifth field 

watershed, 0.28 acre of permanent impacts would occur to a large forested wetland on the edge 

of Coos River floodplain (Wetland ID BW110). In North Fork Coquille River fifth field 

watershed, 0.12 acre of permanent impacts would occur to a forested slope wetland (Wetland ID 

CW010). In East Fork Coquille River fifth field watershed, 0.02 acre of permanent impacts 

would occur to a riparian scrub-shrub wetland adjacent to the East Fork Coquille River (Wetland 

ID BW250). In Olalla Creek-Lookingglass Creek fifth field watershed, 0.12 acre of permanent 

impacts would occur, 0.05 acre to an ash-dominated wetland (Wetland ID BW161) and 0.07 acre 

to a forested wetland (BW162). In Rogue River-Shady Cove fifth field watershed, 0.01 acre of 

permanent impacts would occur to a forested stream (Wetland ID AW309). In Big Butte Creek 

fifth field watershed, 0.03 acre of permanent impacts would occur to a wetland with a perennial 

stream running through (Wetland ID AW264). In Spencer Creek fifth field watershed, 0.05 acre 

of permanent impacts would occur to a scrub-shrub seep wetland associated with Clover Creek 

(Wetland ID EW103). 

Pacific Connector has identified 39 privately owned storage yards that may be used during the 

construction of the proposed Pacific Connector pipeline. Of these sites, Pacific Connector 

surveyed 32 for wetlands, but was unable to survey the remaining 7 sites because access was 

denied. Most of the proposed sites consist of graded, compacted gravel, pavement, vacant lots, 

or agricultural fields. Based on completed wetland surveys, wetland features are absent from 20 
 4.3 – Water Resources and Wetlands 4.3-63

sites and present on 12 of the sites. Pacific Connector would avoid impacting wetlands on 

storage yards by utilizing appropriate agency BMPs and working around any wetlands that are 

present at these sites. 

Impacts resulting from improvements required to existing access roads (including 

blading/grading, filling, clearing, widening, or turnouts), have not been fully evaluated. Existing 

access roads that are located at least 100 feet from a waterbody within Key Watersheds are listed 

in Table 2A-7 within Appendix 2A of Resource Report 2, filled with Pacific Connector’s 

application to the FERC. Acreage of impacts resulting from road improvements would be 

provided within the Final POD. Impacts resulting from road improvements would be minimized 

due to the implementation of Pacific Connector’s ECRP and the mitigation measures described 

below. The construction of new TARs would temporarily impact approximately 0.3 acre of 

wetlands. 

Pacific Connector would implement the wetland construction and restoration measures contained 

in its ECRP. In general, within areas where the wetlands can not be avoided, the width of the 

construction right-of-way would be limited to 75 feet wide or less and TEWAs would be located 

at least 50 feet away from wetland boundaries. However, it is expected that there would be some 

stream and wetland crossings where a construction right-of-way wider than the 75-foot width 

would be necessary due to factors such as topographic conditions, stockpile area requirements 

for topsoil segregation, crossing of adjacent waterbodies, or other construction and safety issues. 

In addition, there would be areas where the TEWAs would be located less than 50 feet away 

from wetlands due to site-specific conditions such as avoiding sensitive areas or resources. The 

specific variance request and our review and disposition of those requests are located in table I-1 

in Appendix I. 

In addition, Pacific Connector would implement the follow measures to mitigate for wetland 

impacts and speed restoration of affected areas. 

• The top one foot of topsoil would be segregated from the subsoil in the area disturbed by 

trenching, except where standing water is present or soils are saturated or frozen. 

Immediately after backfilling, the segregated soil would be restored to its original 

location. 

• Vegetation would be cut just above ground level to leave the existing root system in 

place. Tree stump removal and grading would occur directly over the trenchline. They 

would not be removed from the rest of the right-of-way unless required for safety 

reasons. 

• Construction equipment operating in the wetland would be limited to that needed to clear 

vegetation, dig trenches, install the pipe, backfill, and restore the right-of-way. Other 

equipment would use upland access roads to the maximum extent possible. 

• Low ground-weight equipment would be used in saturated wetlands or the normal 

equipment would be operated on prefabricated equipment mats. 

• Permanent slope breakers and sediment controls would be installed in the case of slopes 

greater than 5 percent that are less than 50 feet from a waterbody. They would be 

properly maintained or re-installed, as needed. 
 4.3 – Water Resources and Wetlands 4.3-64

• Temporary erosion control methods would be used as necessary to minimize potential 

runoff from entering wetlands. 

− Ineffective temporary erosion control methods would be replaced within 24 hours of 

their discovery. 

• Trench breakers would be installed, or the bottom of the trench would be sealed as 

necessary to maintain the original wetland hydrology. 

• Hazardous materials, fuels, and oils would not be stored in a wetland or within 100 feet 

of a wetland. 

• The restoration plans would include measures for re-establishing herbaceous or woody 

vegetation, controlling the establishment or spread of exotic species, weed control, and 

site monitoring (discussed in more detail below). 

• Wetlands would be monitored after revegetation for 3 years after construction or until the 

revegetation is successful. Revegetation would be considered successful when 80 percent 

of the type, density, and distribution of species are similar to that of adjacent unaltered 

wetlands (discussed in more detail below). 

− Appropriate seed mixtures for each county would be used on private lands (based on 

NRCS recommendations). No fertilizers would be used during the revegetation of 

wetlands. 

− Riparian areas would be restored with appropriate native trees and shrubs. 

• Vegetation maintenance would not be conducted over the full width of the right-of-way 

within wetlands. A corridor 10 feet wide could be maintained in herbaceous vegetation 

to facilitate periodic surveys. Additionally, trees may be selectively removed if they are 

15 feet tall or greater and within 15 feet of the pipeline. 

• Construction efforts would be scheduled to take advantage of dryer seasons in order to 

minimize potential effects to wetlands. 

• All travel across retopsoiled areas would be restricted and retopsoiling efforts would not 

occur during wet periods in order to minimize soil compaction within wetlands. 

In order to prevent or limit the spread of invasive aquatic organisms and noxious weeds into 

wetlands and other vegetation locations, all construction equipment would be inspected to ensure 

that it is clean and free of potential weed seed or sources, prior to transporting equipment to the 

construction right-of-way. Construction equipment would be power washed, if necessary, as 

determined by the EI. Initial inspections of all project inspector vehicles and construction 

contractor vehicles would also be performed prior to being allowed on the construction 

right-of-way. The EI or Pacific Connector’s authorized representative would be responsible for 

performing inspections and registering or tagging the equipment prior to being transported or 

moved to the right-of-way. Any equipment used for clearing of areas with noxious weeds 

present that are classified as priority A and T as well as selected B listed weeds would be cleaned 

by hand, blown down with air, or pressure washed prior to leaving the site. Equipment cleaning 

on the right-of-way would occur in cleaning stations, approved by the EI. Infested areas and 

cleaning stations would be mapped to ensure that these areas are monitored during construction 

and to ensure that these weeds are controlled and not spread (impacts from and mitigation 

measures used to control invasive species are discussed further in section 4.4). 
 4.3 – Water Resources and Wetlands 4.3-65

Pacific Connector would use weed-free seed during seeding operations. In addition, certified 

weed-free straw would be used for mulch and sediment barriers, dewatering structures, or other 

uses along the right-of-way. The EI or Pacific Connector’s authorized representative would be 

responsible for ensuring that all straw hauled to the construction yards would be certified 

weed-free. 

After construction, Pacific Connector would monitor the right-of-way for infestations of noxious 

weeds. Monitoring would occur in the areas where noxious weeds were identified prior to 

construction and were previously mapped to ensure that potential infestations do not reestablish 

and/or spread. Monitoring would also occur in areas along the right-of-way where equipment 

cleaning stations and hydrostatic dewatering sites were located to ensure that infestation at these 

locations do not occur. Pacific Connector’s operational staff or their contractors would be 

responsible for these monitoring efforts. 

Pacific Connector would conduct follow-up inspections of all disturbed areas after the first and 

second growing season to determine the success of revegetation. In wetland areas, revegetation 

would be considered successful if the cover of herbaceous and/or woody species is at least 80 

percent of the type, density, and distribution of the vegetation within adjacent wetlands that were 

not disturbed by construction. If revegetation is not successful at the end of 3 years, Pacific 

Connector would develop and implement a remedial revegetation plan to actively revegetate the 

wetland and would continue revegetation efforts until wetland revegetation is successful. 

An as-built report documenting the final design of the restoration in wetlands and riparian areas 

would be prepared when site construction and planting are completed. The report would include 

the following: 

• site vicinity map; 

• drawings that identify the boundaries of the restoration areas; 

• the installed planting scheme providing quantities, densities, sizes, and approximate 

locations of plants, as well as plant sources and the time of planting; and 

• general notes indicating site conditions, concerns, or other issues that might affect site 

planning success. 

A copy of the as-built report would be provided to the COE and ODSL by December 31 or other 

specified date as required by these agencies. Additional reports would be prepared after each 

monitoring period to document collected data. 

Pacific Connector would comply with conditions in the section 404 permit obtained from the 

COE, in the Removal/Fill permit from ODSL, and in the section 401 Permit obtained from the 

ODEQ. As part of the permitting process, the agencies would evaluate whether wetlands have 

been avoided to the maximum extent practicable, and whether the effects have been minimized 

or rectified to the extent practicable. The agencies also would specify additional requirements as 

necessary to comply with regulations. Pacific Connector would comply with additional 

procedures as specified in the permits. 

We received comments from the Coos Watershed Association regarding the proposed crossing of 

the Brunschmid Wetland Reserve project in Coos County, between about MPs 10.5 and 10.8 

along the portion of revised proposed route around Coos Bay. The Brunschmid Wetland 
 4.3 – Water Resources and Wetlands 4.3-66

Reserve project’s goal is to restore wetland function to 17 acres of pastureland near Lilienthal 

Creek. Commenters were concerned that pipeline construction activities would have a negative 

impact on past and ongoing restoration activities. As with all proposed wetland crossings, 

impacts from construction and operation of the pipeline would be limited through the 

implementation of Pacific Connector’s ECRP as described above. However, we believe Pacific 

Connector should coordinate with the Coos Watershed Association to ensure the crossing of this 

wetland restoration project is done in such a way to minimize impacts on restoration measures 

within the wetland. Therefore, we recommend that:

• Pacific Connector should coordinate with the Coos Watershed Association 

regarding the crossing of the Brunschmid Wetland Reserve project in Coos County, 

between MPs 10.5 and 10.8. Prior to pipeline construction, Pacific Connector 

should file with the Secretary documentation of this consultation, and a description 

of any site-specific measures that would be implemented to reduce impacts on the 

Brunschmid Wetland Reserve. 

Compensatory mitigation would be required for the effects to wetland functions or loss in 

acreage and is part of the permitting process. Compensatory mitigation could include creating, 

restoring, or enhancing wetlands to replace the wetland functions and area/connectivity lost due 

to proposed Project activities, or purchasing credits from a mitigation bank. ODSL 

administrative rules (OAR 141-085-136) include minimum ratios for acres required for 

compensation that varies by type of mitigation proposed (e.g., restoration is 1 acre for each acre 

lost, creation is 1.5 for 1, and enhancement is 3 for 1). The ratios account for the likelihood of 

success of a type of restoration; however, the specific type and amount of compensatory 

mitigation would be determined by the COE as part of the section 404 permit process and by the 

ODSL as part of the Removal-Fill permit process. 

In its September 2007 JPA, Pacific Connector identified proposed compensatory mitigation for 

the 0.1 acre of permanent wetland impacts associated with fill at two wetlands (MPs 68.68 and 

108.97). Pacific Connector proposes to provide compensatory mitigation by acquiring credits in 

a mitigation bank (i.e., Cow Hollow) or by applying other COE- and ODSL-approved 

compensatory mitigation methodologies. Pacific Connector also proposes to acquire credits in 

the Cow Hollow Mitigation Bank to compensate for permanent conversion of 1.2 acres of 

forested and scrub-shrub wetland to emergent wetland. Alternatively, Pacific Connector would 

apply other COE-and ODSL-approved compensatory mitigation methodologies to mitigate for 

the project's permanent wetland vegetation type conversion impacts. 

To mitigate for the Pacific Connector pipeline's temporary estuary impacts in Coos Bay (i.e., 

eelgrass, mud/sandflat, and shallow subtidal habitats), Pacific Connector has developed an 

Estuarine Wetland Mitigation Plan (EWMP). We have reviewed the plan and find it sufficient 

for our NEPA review. The goal of the proposed EWMP is to establish a one-to-one on-site 

restoration of all wetlands impacted along the estuarine crossing of Coos Bay (Ellis Ecological 

Services 2009). The applicable standard of success is a return of each habitat to pre-construction 

conditions, or better, in order to ensure that the original functions and values of wetlands 

impacted during the crossing are preserved. The methods proposed for use to restore the 

disturbed areas, including the sources of donor plants, monitoring plans, and any contingency 

plans, are detailed within the EWMP (Ellis Ecological Services 2009). 
 4.3 – Water Resources and Wetlands 4.3-67

4.3.4 Environmental Consequences on Federal Lands 

4.3.4.1 USFS 

The 1994 NWFP set forth detailed requirements that describe how land managers should treat the 

forest lands within the range of the northern spotted owl (through implementation of the Standards 

and Guidelines – Attachment A to the 1994 NWFP ROD [USFS and BLM 1994a]). Some 

standards and guidelines apply to all lands and others to a specific land allocation. The 1994 

NWFP ROD described the ACS, which was developed to restore and maintain the ecological 

health of watersheds and aquatic ecosystems contained within them on public lands. The strategy 

would protect salmon and steelhead habitat on federal lands managed by the USFS within the 

range of the NSO. 

To achieve ACS objectives in the 1994 NWFP ROD, the ACS included areas defined as Riparian 

Reserves and Key Watersheds, specified analytical procedures for evaluating watersheds, and 

defined a program for watershed restoration. While the ACS focus was primarily on the 

conservation of anadromous salmon and steelhead, the nine objectives listed for the ACS include 

maintaining and restoring aquatic systems, floodplains, wetlands, upslope habitats, and riparian 

zones in general to support invertebrate and vertebrate species dependent on those habitats. 

The existing conditions of the fifth-field watershed(s) that would be crossed by the Pacific 

Connector pipeline are provided in the watershed analyses documents that were prepared by the 

various federal land management agencies having jurisdiction over the federal lands within the 

watersheds. These watershed analyses also provide a description of the range of natural 

variability of the important physical and biological components of the watershed. Table 4.3.4.1-

1 lists the fifth-field watersheds that would be crossed by the proposed pipeline. The table lists 

the federal land management agency jurisdiction, the date of completion of the watershed 

analysis, if available, and the total miles that would be crossed by the pipeline within each fifthfield watershed. 

TABLE 4.3.4.1-1 

Fifth-Field Watersheds Crossed by the Pacific Connector Pipeline on Federal Lands

Jurisdiction Watershed (Name) 

Approximate 

Miles Crossed 

Watershed Analysis 

Completed 

BLM – Coos Bay District 

Coos Bay Frontal 

Lower Coquille River 

North Fork Coquille River 

East Fork Coquille River 

Middle Fork Coquille River 

0.29 

0.06 

2.84 

2.72 

4.84 

Not Completed 

Not Completed 

2001 

1999 

1994 

BLM – Roseburg District 

Middle Fork Coquille River 

Olalla Creek-Lookingglass Creek 

Middle South Umpqua River 

Myrtle Creek 

South Umpqua River 

Elk Creek South Umpqua 

2.49 

1.08 

0.73 

3.41 

6.23 

0.24 

1994 

1998 

1999 

2002 

2001 

2004 

BLM – Medford District 

Trail Creek 

Rogue River-Shady Cove 

Big Butte Creek a/ 

Little Butte Creek 

3.88 

4.42 

0.67 

5.99 

1999 

Not Completed 

1999 

1997 
 4.3 – Water Resources and Wetlands 4.3-68

TABLE 4.3.4.1-1 

Fifth-Field Watersheds Crossed by the Pacific Connector Pipeline on Federal Lands

Jurisdiction Watershed (Name) 

Approximate 

Miles Crossed 

Watershed Analysis 

Completed 

BLM – Lakeview District Spencer Creek 

Lower Lost River 

1.04 

0.26 

1995 

N/A b/ 

FS – Umpqua NF 

South Umpqua River c/ 

Elk Creek South Umpqua c/ 

Upper Cow Creek c/ 

Trail Creek c/ 

.59 

2.40 

4.78 

2.09 

1996 c/ 

1995 c/ 

FS – Rogue River-Siskiyou NF Little Butte Creek 13.66 1997 

FS – Fremont-Winema NF Little Butte Creek 

Spencer Creek 

0.01 

6.04 

1997 

1995 

Bureau of Reclamation Lake Ewauna-Upper Klamath River 0.65 N/A b/ 

Total Watersheds Crossed on Federal Lands 72.43

Source: BLM 2006; USFS 2006a 

a/ The Lower Big Butte Creek Watershed Analysis encompasses the BLM lands within the Big Butte Creek Watershed that are 

crossed by the pipeline. 

b/ Outside the range of the northern spotted owl. 

c/ The Elk Creek Watershed Analysis (1996) and the Cow Creek Watershed Analysis (1995) encompass the Umpqua National 

Forest lands crossed by the pipeline. 

Riparian Reserves 

Riparian Reserves are lands along streams, wetlands, ponds, lakes, reservoirs and unstable and 

potentially unstable areas where special standards and guidelines direct land use. Standards and 

guidelines prohibit and regulate activities in Riparian Reserves that retard or prevent attainment 

of the ACS objectives. Riparian Reserves include those portions of a watershed directly coupled 

to streams and rivers, that is, the portions of a watershed required for maintaining hydrologic, 

geomorphic, and ecological processes that directly affect standing and flowing waterbodies such 

as lakes and ponds, wetlands, streams, stream processes, and fish habitats. Riparian Reserves 

generally parallel the stream network but also include other areas necessary for maintaining 

hydrologic, geomorphic, and ecological processes, such as wetlands. 

Under the ACS, Riparian Reserves are used to maintain and restore riparian structures and 

functions of intermittent streams, confer benefits to riparian-dependent and associated species 

other than fish, enhance habitat conservation for organisms that are dependent on the transition 

zone between upslope and riparian areas, improve travel and dispersal corridors for many 

terrestrial animals and plants, and provide for greater connectivity of the watershed. Attachment 

A to the NWFP ROD (C-31 through C-38) includes standards and guidelines for the 

management of timber, roads, grazing, recreation, minerals, fire and fuels, lands, general riparian 

areas, watershed and habitat restoration, wildlife, and research within Riparian Reserves. 

Within the 25.03 acres of riparian areas (25.1 acres of Riparian Reserves) that would be affected 

by the Pacific Connector pipeline, construction of the pipeline would affect an estimated 13.21 

acres of forested habitat (coniferous, deciduous, mixed), 8.66 acres of regenerating forest 

(coniferous, deciduous, mixed), 0.46 acre of wetland (forested and nonforested classes), 0.22 

acre of unaltered nonforested habitat (grasslands, sagebrush, shrublands), and 2.48 acres of 

altered habitats (urban, industrial, residential, roads, utility corridors). Permanent disturbance to 
 4.3 – Water Resources and Wetlands 4.3-69

Riparian Reserves would be about 5.5 acres. (Also see the discussion in section 4.5.2.4 and table 

4.5.2.4-3) 

Consistency Within Riparian Reserves

Some of the Riparian Reserve standards and guidelines may be applicable to pipeline 

construction; however, the overall applicability of any standard or guideline is ultimately related 

to maintaining or restoring riparian functions that are implied or specified in the nine ACS 

objectives. Riparian functions include fluvial processes, sediment dynamics; and 

biogeochemical interactions. 

The temporary and permanent loss of 22.1 and 5.5 acres of Riparian Reserves, respectively, and 

associated habitats would be a long-term impact to those habitats. To compensate for these 

unavoidable impacts, the USFS and Pacific Connector have identified specific mitigation actions 

(Appendix L3). 

Measures in Pacific Connector’s ECRP and site-specific BMPs would apply to maintaining and 

restoring riparian functions and to consistency with the ACS. In summary, these measures 

include: 

• Construction impacts to Riparian Reserves have been minimized to the extent possible 

through routing efforts to ensure a safe, stable alignment for long-term integrity. 

Through these efforts, the proposed route follows ridgelines and watershed boundaries in 

many areas significantly minimizing waterbody and riparian crossings. 

• No new temporary or permanent access roads would be located in Riparian Reserves. 

• Maintenance of existing roads would be conducted according to BMPs to minimize or 

prevent sediment delivery to streams and impacts to riparian areas. 

• Construction work area limits have been minimized and work area setbacks provided 

where feasible based on topographic and engineering constraints. 

• Construction schedules across waterbodies have been planned to coincide with ODFW 

recommended instream work windows and the low-flow periods. 

• Streambeds would be restored to their preconstruction contours elevations and grade and 

streambanks would be restored to their approximate original contour or to a stable 

configuration to ensure stability and to restore floodplains. These measure would ensure 

streamflow characteristics and floodplain functions are restored. 

• Streambeds would be restored with suitable spawning substrate. 

• After construction is complete, large woody debris would be placed in streams or banks. 

• Riparian areas would be replanted with appropriate native trees and shrubs. 

• Exotic and weedy vegetation currently within Riparian Reserves at sites where the 

pipeline would cross would be removed and replaced with native riparian species. 

• Coniferous and shrub vegetation would be re-established within affected Riparian 

Reserves for a distance of up to 100 feet on each side of intermittent and perennial 

waterbodies. 

• The pipeline maintenance corridor would be narrowed to the minimum necessary and to 

comply with DOT maintenance requirements. 

• Erosion control would be applied as described in the ECRP through implementation of 

extensive BMPs as required by federal, state, and local permits. 
 4.3 – Water Resources and Wetlands 4.3-70

• USFS or BLM personnel would provide oversight and assist Pacific Connector and 

FERC inspectors in interpreting and implementing compliance with NWFP Standards 

and Guidelines on federal lands. 

Key Watersheds 

The ACS includes two designations for Key Watersheds. Tier 1 (Aquatic Conservation 

Emphasis) Key Watersheds contribute directly to conservation of at-risk anadromous salmonids, 

bull trout, and resident fish species. They also have a high potential of being restored as part of a 

watershed restoration program. While Tier 2 (other) Key Watersheds may not contain at-risk 

fish stocks, they are important sources of high-quality water. 

The Standards and Guidelines for Key Watersheds include: 

• Inside Roadless Areas - no new roads will be built in remaining unroaded portions of 

inventoried roadless areas. 

• Outside Roadless Areas - reduce existing system and nonsystem road mileage. If funding 

is insufficient to implement reductions, there will be no net increase in the amount of 

roads in Key Watersheds. 

• Key Watersheds are highest priority for watershed restoration. 

• Watershed analysis is required prior to management activities, except minor activities 

such as those Categorically Excluded under NEPA (and not including timber harvest). 

• Watershed analysis is required prior to timber harvest. 

Four watersheds that would be crossed by the Pacific Connector pipeline are designated as Key 

Watersheds: 1) South Umpqua River (Tier 1); 2) North and South Forks Little Butte Creek (Tier 

1); 3) Spencer Creek (Tier 1); and Clover Creek (Tier 2). North and South Forks Little Butte 

Creek is a Key Watershed within the Little Butte Creek Fifth-Field Watershed. Key watersheds 

that would be crossed by the proposed Pacific Connector pipeline are listed in table 4.3.4.1-2. 

Although the Key Watershed designation no longer applies to BLM lands because of the 

December 2008 RMPs, they are still included in table 4.3.4.1-2 to show the ownership and 

management of the Key Watershed. 

TABLE 4.3.4.1-2 

Key Watersheds Crossed by the Proposed Pacific Connector Pipeline

Key Watershed Jurisdiction 

Approximate 

Miles Crossed 

Approximate 

Construction 

Disturbance (acres) a/ 

Approximate 

Operational Easement 

(acres) b/ 

BLM Roseburg 

District 

6.23 183.4 38.0 

Umpqua National 

Forest 

1.59 56.3 9.7 

South Umpqua River 

(Tier 1) 

MP 82.8-102.7 Private 11.58 383.3 70.6 

BLM Medford 

District 

5.99 113.8 36.5 

Rogue RiverSiskiyou National 

Forest 

13.66 280.6 82.8 

Fremont-Winema 

National Forest 

0.01 0.24 0.08 

North and South Forks Little 

Butte Creek 

(Tier 1) 

MP 135.0-168.0 

Private 13.20 220.2 80.1 
 4.3 – Water Resources and Wetlands 4.3-71

TABLE 4.3.4.1-2 

Key Watersheds Crossed by the Proposed Pacific Connector Pipeline

Key Watershed Jurisdiction 

Approximate 

Miles Crossed 

Approximate 

Construction 

Disturbance (acres) a/ 

Approximate 

Operational Easement 

(acres) b/ 

Fremont-Winema 

National Forest 

6.04 90.0 36.7 

BLM Lakeview 

District 

1.04 13.7 6.3 

Spencer Creek 

(Tier 1) 

MP 168.0-177.1 

MP 180.5-183.0 

Private 7.98 113.8 48.5 

Fremont-Winema 

National Forest 

0.00 0.00 0.00 

BLM Lakeview 

District 

0.21 3.1 0.8 

Clover Creek 

(Tier 2) 

MP 177.1-180.5 Private 2.82 37.0 10.2 

Private Total 35.58 754.3 209.4 

Federal Total 34.77 744.1 210.1 

Total 70.35 1495.4 420.3 

a/ Includes uncleared storage areas. 

b/ Assumes 50-foot wide permanent easement. 

The Standards and Guidelines for Key Watersheds include: 

• Reduce existing system and nonsystem road mileage. If funding is insufficient to 

implement reductions, there would be no net increase in the amount of roads in Key 

Watersheds. 

• Key Watersheds are the highest priority for watershed restoration. 

• Watershed analysis is required prior to management activities, except minor activities 

such as those Categorically Excluded under NEPA (and not including timber harvest). 

• Watershed analysis is required prior to timber harvest. 

• Inside Roadless Areas - No new roads would be built in remaining unroaded portions of 

inventoried (RARE II) roadless areas. 

• Outside Roadless Areas - Reduce existing system and nonsystem road mileage. If 

funding is insufficient to implement reductions, there would be no net increase in the 

amount of roads in Key Watersheds. 

Table 4.3.4-2 lists the Tier 1 and 2 Key Watersheds that would be crossed by the pipeline on 

federal land and private land. All other fifth-field watersheds that would be crossed by the 

pipeline are non-key watersheds. The Tier 1 Key Watersheds that would be crossed include the 

South Umpqua River, South Fork/North Fork Little Butte Creek, and Spencer Creek. The only 

Tier 2 Watershed crossed by the pipeline would be Clover Creek. The pipeline would cross the 

South Umpqua River Watershed in which a total of 623 acres (0.14 percent of the Key 

Watershed) would be disturbed by pipeline construction. The total acres of disturbance within 

this watershed that would be disturbed by the pipeline include a total of 232.4 acres of federal 

lands (183.4 acres of BLM and 56.3 acres of NFS lands) and 383.3 acres of private lands. The 

pipeline would cross the South Fork/North Fork Little Butte Creek Key Watershed within the 

Little Butte Creek Fifth-Field Watershed with a total of 614.8 acres of disturbance (0.48 percent 

of the Key Watershed). The total acres of disturbance within this watershed include a total of 

394.6 acres of federal lands (113.8 acres of BLM and 280.8 acres NFS lands) and 220.2 acres of 
 4.3 – Water Resources and Wetlands 4.3-72

private lands. The pipeline would also cross the Spencer Creek Tier 1 Key Watershed with 

217.5 acres of total disturbance (0.53 percent of the watershed), including 103.7 acres of federal 

land (13.7 acres of BLM and 90.0 acres of NFS lands) and 113.8 acres of private land. Within 

the Clover Creek Tier 2 Watershed, the total disturbance would be 40.1 acres (0.29 percent); 

however, there are only 3.1 acres of disturbance on federal land (all BLM) and 37.0 acres of 

disturbance on private land. The disturbance on federal land represents 0.02 percent of the 

watershed. 

Consistency Within Tier 1 Key Watersheds

The pipeline would not cross any roadless areas and would not require any new roads to be 

constructed within Tier 1 Watersheds. Although the pipeline would cause temporary disturbance 

within Tier 1 watersheds, all disturbed areas associated with the pipeline would be restored after 

construction. No adverse, long-term effects are anticipated to the water resources. The 30-foot 

operational maintenance corridor along the pipeline centerline would create a permanent 

vegetation type conversion impact within forested vegetation types, but the vegetation 

conversion is not expected to alter hydrologic functions. The total acres of disturbance in the 

Umpqua River, South Fork/North Fork Little Butte Creek, Spencer Creek, and Clover Creek 

Watersheds would be 0.14 percent, 0.48 percent, 0.53 percent, and 0.29 percent, respectively. 

Restoration of all areas disturbed by the Pacific Connector pipeline would include shaping to the 

approximate original contour to restore drainage patterns, scarification to relieve compaction, 

and revegetation for stabilization and to restore habitats and land use functions. The 

compensatory mitigation measures outlined for LSRs and Riparian Reserves would benefit Key 

Watersheds if the mitigation projects such as road decommissioning occur within these 

watersheds. 

4.3.4.2 BLM 

In December 2008 the BLM issued six RODs for the RMPs that were developed under the 

WOPR. With this action, the BLM completed its revision of the land use plans that will guide 

the management of its lands within western Oregon, including the BLM's Roseburg, Medford, 

and Coos Bay Districts, and the Klamath Falls Resource Area of the Lakeview District. Under 

the December 2008 RMPs, RMAs are managed to maintain or promote development of mature 

or structurally complex forests and provide for the riparian and aquatic conditions that supply 

streams with shade, sediment filtering, leaf litter, and large wood and root masses that stabilize 

stream banks. The reserves are one site-potential tree height on each side of a stream channel as 

measured from the ordinary high water line on perennial and intermittent fish-bearing streams 

and perennial non-fish-bearing streams, and one-half of one site-potential tree height on each 

side of a stream channel for intermittent non-fish-bearing streams. The RMAs contain a 

restriction on thinning and silvicultural activities as described in table 4.3.4.2-1. 

RMA management objectives include maintaining and restoring water quality and RMA 

directions restrict development and harvest within RMAs; however, BLM-administered land is 

generally available for needed rights-of-way where consistent with local comprehensive plans, 

Oregon statewide planning goals and rules, and the exclusion and avoidance areas identified in 

RMPs (BLM 2008). The BLM has identified utility corridors that are the preferred location for 
 4.3 – Water Resources and Wetlands 4.3-73

Table 4.3.4.2-1. 

Criteria Established For The Riparian Management Area Land Use Allocation

Riparian Management Areas Distance a/, b/

Perennial and intermittent fish-bearing streams and 

perennial non-fish-bearing streams 

One site-potential tree height on each side of a stream channel as 

measured from the ordinary high water line. 

Intermittent non-fish-bearing streams Half of one site-potential tree height on each side of a stream channel 

as measured from the ordinary high water line. 

Natural lakes and ponds greater than 0.25 acre One site-potential tree height extending from the edge of the water 

body as measured from the ordinary high water line. 

Natural wetlands, springs, seeps, constructed reservoirs, 

ditches, canals, and ponds smaller than 0.25 acre 

The edge of a body of water or wetland to the outer edge of its 

riparian vegetation, or to the extent of seasonally saturated soil, 

whichever is greatest. 

Eastside non-forest areas of the Klamath Falls Resource 

Area 

The extent of the water influence zone as indicated by hydrophilic 

vegetation. 

a/ Riparian Management Areas are measured by slope (not horizontal) distance from the ordinary high water line. 

b/ The site-potential tree height for the purposes of determining riparian management areas would be based on district averages 

measured at a scale no finer than the fifth-field watershed. 

Source: BLM 2008. 

energy transmission or distribution facilities, including the proposed Pacific Connector pipeline 

route. Corridors are generally 1,000 feet on each side of the centerline. BLM direction indicates 

that the rights-of-way granted will be the minimum necessary to accommodate a specific request. 

Construction of the proposed pipeline would cross a total of 1.4 miles of RMAs, temporarily 

impacting 29.9 acres and permanently affecting 6.8 acres of RMAs. To compensate for these 

unavoidable impacts, the USFS and Pacific Connector have identified specific mitigation actions 

(Appendix L). Also see the discussion in section 4.5.2.4 and table 4.5.2.4-3. The measures 

described above to reduce impacts to USFS Riparian Reserves would also be implemented on 

BLM RMAs, unless the BLM indicates otherwise. Further mitigation measures, discussed 

below, would also be implemented. With these measures in place, impacts within RMAs would 

be minimized. 

4.3.4.3 Mitigation Measures 

While these procedures have been designed to reduce long-term impacts to Riparian Reserves 

and RMAs and be consistent with the ACS, unavoidable impacts to Riparian Reserves and 

RMAs would occur from the removal of riparian vegetation, streambanks, and substrates as a 

result of pipeline construction. To mitigate for unavoidable short-term effects, the USFS and 

BLM, in consultation with Pacific Connector, have prepared a list of mitigation actions 

(Appendix L) to address unavoidable impacts on NFS and BLM lands. 

The mitigation measures include habitat and vegetation improvements riparian plantings, placing 

large woody debris and providing large wood pieces for restoration projects; road 

decommissioning, paving, and maintenance to reduce sedimentation; protecting springs and 

seeps; cattle exclusions; culvert replacements; and other beneficial projects. See section 4.5 for 

addition discussion of the CMP. 
 4.3 – Water Resources and Wetlands 4.3-74

Site-Specific Impact and Mitigation 

Hydrostatic Testing

Prior to the release of the draft EIS, the USFS had expressed concern that details for hydrostatic 

test water withdrawal and discharge were not adequately defined to ensure erosion is prevented, 

stream flows and aquatic organisms would not be affected, and that inter-basin transfer of 

undesirable organism would not occur. As a result, we recommended that Pacific Connector 

continue to consult with the USFS and BLM regarding specific plans for hydrostatic test water 

withdrawal and discharge on NFS and BLM lands. In response, Pacific Connector submitted a 

revised draft Hydrostatic Testing Plan in December 2008, proposing methods for hydrostatic test 

water withdrawal and discharge that we believe are consistent with industry practices, adequately 

minimize impacts on waterbodies, and address the concerns of the USFS and BLM. 

East Fork Cow Creek Crossing

Since publication of the draft EIS, Pacific Connector has revised its proposed route between MPs 

108.5 and 110.9, which includes a revised crossing location of the East Fork Cow Creek. The 

revised crossing location avoids areas with known mercury contamination near the creek. This is 

discussed further, below. 

The USFS raised a number of concerns regarding the crossing of the East Fork Cow Creek as 

proposed in the draft EIS. In response to concerns regarding underground mine hazards and 

potential mercury contamination near the proposed creek crossing along the route analyzed in the 

draft EIS, Pacific Connector conducted a mine hazard and geochemical analysis of former mine 

sites identified near the construction right-of-way at East Fork Cow Creek (GeoEngineers 

2007e). Soil samples were taken in general accordance with the request from the Umpqua 

National Forest. Results from soil samples analyzed for mercury ranged from 0.03 to 0.072 

mg/kg mercury, compared to upstream (presumed background) results of 0.28 to 0.30 mg/kg 

mercury. The analysis compared the results to accepted human health and ecological risk 

screening criteria, taking into account mitigation measures to be include in the crossing design, 

and concluded that the relatively low concentrations of mercury in sediment in the East Fork 

Cow Creek channel at the proposed pipeline crossing, along with the limited disturbance area 

(less than 95 linear feet), would not pose a significant risk to downstream human and ecological 

receptors. 

Further, the draft EIS included design measures that Pacific Connector had committed to, in 

addition to their project-wide plans and procedures. These specialized measures would reduce 

impacts to Riparian Reserves as well as stabilize the previously disturbed site. The draft EIS 

found that these site-specific measures and adherence to Pacific Connector’s ECRP and SPCCP 

would minimize the impact of construction and operation on the East Fork Cow Creek Crossing, 

although we recommended that Pacific Connector continue consultations with the USFS 

regarding additional details for the specific BMPs it would employ when crossing East Fork Cow 

Creek. 

Pacific Connector continued to consult with the USFS on this and other resource concerns. As a 

result of these consultations, Pacific Connector has adopted a new route between approximately 

MP 109 and 111 to avoid the potential area of the USFS Peavine quarry expansion, as well as 

avoid important wildlife habitat, a recreation site, and the mine workings of concern at the East 
 4.3 – Water Resources and Wetlands 4.3-75

Fork Cow Creek Crossing. The new route would cross East Fork Cow Creek twice at 3,075 feet 

and 4,775 feet upstream of the previous crossing. 

According to GeoEngineers’ Addendum to Geologic Hazards Evaluation (2009), two inactive 

mercury mines occur along the newly proposed pipeline route in this area. This is discussed 

further in section 4.1.3.2, where we recommend that Pacific Connector file a plan to evaluate, 

mitigate, and/or store naturally occurring hazardous substances discovered during excavation for 

pipeline installation. 

South Fork Little Butte Creek

The USFS has expressed concern that the crossing of South Fork Little Butte Creek would go 

through basalt and andesite bedrock, this area may have lava cap type material present with 

unique groundwater flow. Pacific Connector’s ECRP requires the use of trench breakers or 

installation of trench plugs at the edges of waterbodies; this would prevent movement of water 

through the pipeline trench and the interception and/or diversion of groundwater flow away from 

surface streams. 

Additional Mitigation Measures For Federal Lands

For any temporary equipment crossings on any stream channel (whether intermittent or 

perennial, wet or dry) on NFS lands, the USFS has stated that it is the their policy that equipment 

crossings must be accomplished using 1) a bridge 2) a temporary culvert with temporary road fill 

to be removed after work is completed or 3) a low water ford with a rock mat. While the use of a 

low water ford with a rock mat for wet crossing is consistent with USFS policy, it would be 

inconsistent with FERC staff’s Procedures for wet waterbody crossings or the ECRP. Low water 

fords would not be allowed for any wet crossing unless Pacific Connector requests a site-specific 

variance and received approval from FERC. For temporary equipment crossing of dry 

waterbodies, any of the measures requested by the USFS would be acceptable to FERC. These 

measures are more restrictive than those required by FERC and may be required by the USFS 

during development of the POD for NFS lands. 

In response to a USFS request, Pacific Connector would stabilize intermittent stream crossings 

(whether flowing or not) on NFS lands with temporary sediment barriers and reseed as described 

for other waterbodies. 

As discussed in section 4.3.2.4, Pacific Connector has requested a modification to the FERC 

staff’s Procedures requirement that the upper 1 foot of the trench to be backfilled with clean 

gravel or native cobbles in all waterbodies that contain cold water fisheries. Pacific Connector 

has requested that for instances where the existing substrate is not gravel or cobbles, and site 

access is limited and would require unreasonable efforts to transport clean gravel to the 

waterbody, that only native materials removed from the stream be used for backfill. The USFS 

has requested that site-specific approval, by the authorized USFS officer, shall be obtained on 

NFS lands when requesting to not fill the upper 1 foot of trench backfill in coldwater fisheries 

with clean gravel or native cobbles. We believe that site specific approval by the authorized 

USFS officer on NFS lands, and similar authorizations by other land managers, would be 

coordinated through the development of the POD to support the Right-of-Way Grant. However, 

we have also recommended that Pacific Connector provide site-specific justification for where 

this standard measure from the FERC staff’s Procedures could not be met (see section 4.6.1.3). 
 4.3 – Water Resources and Wetlands 4.3-76

Pacific Connector has agreed to the measure that on NFS lands, the USFS Authorized Officer, or 

his or her representative, would be informed of the EI’s determination to store hazardous 

substances, chemicals, fuels, or lubricating oils within 150 feet of waterbody banks or wetlands. 

Representatives from the BLM have expressed similar concerns. Because Pacific Connector has 

agreed to the measure on NFS lands, we believe it is reasonable to expect that the same measure 

could be implemented on BLM-administered lands, and that the requirement would be 

coordinated with the BLM during development of the POD for BLM lands. 

On BLM and NFS lands where Riparian Reserves are affected, a 100-foot riparian strip (or less 

if the preconstruction riparian vegetation did not extend to 100 feet) would be planted 

perpendicular to the waterbody on both sides of the waterbody. If currently forested, impacted 

areas beyond the riparian strip would be reforested as detailed in the ECRP. However, to 

facilitate periodic pipeline corrosion/leak surveys, a corridor centered on the pipeline and up to 

10 feet wide would be maintained in an herbaceous state with no vegetation greater than 6 feet in 

height. Trees that are located within 15 feet of the pipeline and that are greater than 15 feet in 

height would be cut and removed from the right-of-way. Pacific Connector would only maintain 

30 feet of the permanent pipeline easement (15 feet either side of the pipeline centerline) within 

Riparian Zones on federal lands, significantly minimizing the impacts to forested riparian areas. 

No waterbodies or riparian reserves on federal lands would be affected by temporary or 

permanent access roads. 

Water withdrawals on federal lands for dust suppression on the pipeline construction right-ofway would require site-specific approval from the land manager. We believe that site-specific 

approval by the authorized USFS officer on NFS lands, and similar authorizations by other land 

managers, would be coordinated through the development of the POD to support the Right-ofWay Grant. 

Wetlands

On federally managed land, the Pacific Connector pipeline would cross approximately 0.2 mile 

of wetlands, affecting a total of approximately 3 acres within 69 wetland systems. Permanent 

wetland vegetation conversion within federally managed lands would occur in approximately 0.1 

acre of palustrine forested wetlands as a result of vegetation management on the operational 

right-of-way. This 0.1 acre of permanent type conversions would occur to two wetlands: 

wetland CW010 located on lands managed by the BLM Coos Bay District, and wetland AW309 

located on lands managed by the BLM Medford District. Mitigation measures for this and other 

long-term impacts on federal lands would be as described above for the entire pipeline. 

There would be no permanent wetland loss or wetland impacts on federally managed land due to 

the construction of aboveground facilities. Impacts resulting from use of existing roads would be 

minimized through the implementation of Pacific Connector’s ECRP and the mitigation 

measures described above for the pipeline on all lands. 

In order to prevent or limit the spread of invasive species and noxious weeds into wetlands, 

Pacific Connector would inspect all construction equipment prior to transporting equipment to 

the construction right-of-way to ensure that it is clean and free of potential weed seed. Because 

of the contiguous pattern of NFS lands crossed by the pipeline, equipment would be inspected 

and cleaned at cleaning stations located at the borders of each National Forest, prior to clearing 
 4.3 – Water Resources and Wetlands 4.3-77

and grading activities, in addition to being cleaned at cleaning stations associated with any 

mapped infestation of noxious weed of priority A and T and selected B listed weeds within each 

National Forest. Because the BLM-managed lands crossed by the pipeline are not contiguous 

but are instead spread out in a checkerboard pattern, it is not practical to set up inspection and 

cleaning stations at each entry point. Instead, where BLM lands are contiguous to NFS lands, 

the cleaning stations would be located to include the adjacent BLM lands. The location of any 

additional cleaning stations required in areas where BLM lands are not contiguous with NFS 

lands would be coordinated with the BLM. Additional measures to prevent the spread of 

invasive weed and wildlife species into wetlands and waterbodies are addressed within sections 

4.4 and 4.5. 

Mitigation measures to avoid or minimize impacts on wetlands that would be implemented on 

federal lands, in addition to those described above for the entire pipeline, include the following: 

• Where straw is to be used on federal lands during seeding operations, the BLM’s or 

USFS’ authorized officer may inspect and approve straw material to verify that the straw 

is weed-free. Any gravel or rock used on NFS lands would be from weed-free sources as 

well, and approved by the USFS’ authorized representative. 

• Hazardous materials, fuels, and oils would not be stored in a wetland or within 150 feet 

of a wetland. Storage of hazardous materials on NFS lands would be in accordance with 

SPCCP -AGAR Regulations at USFS-approved sites. 

• During revegetation efforts, specific mixtures specified by the BLM and USFS would be 

used on federal lands. No fertilizers would be used during the revegetation of wetlands.