5-1 5.0 – Conclusions and Recommendations 

5.0 CONCLUSIONS AND RECOMENDATIONS 

5.1 SUMMARY OF THE STAFF’S ENVIRONMENTAL ANALYSIS 

The conclusions presented in this final EIS are those of the environmental staff of the FERC 

working in cooperation with the Coast Guard, EPA, COE, BLM, BOR, FWS, USFS, DOT, and 

Douglas County. The Coast Guard LOR will address the suitability of the Coos Bay navigation 

channel for LNG marine traffic, and the Coast Guard’s LNG Operations Plan will address issues 

related to the public impact of safety and security zones for LNG vessels. The COE will present 

its conclusions and recommendations in the permits it may issue pursuant to section 10 of the 

RHA and section 404 of the CWA regulating dredging, dredged material placement, and the 

crossing of wetlands. The EPA has the authority to review and veto the COE decisions on the 

section 404 permit. The FWS will review the Project for compliance with the MBTA and will 

consult on species and habitats protected by the ESA. The BLM, BOR, and USFS are federal 

agencies that administer lands that would be crossed by portions of the Pacific Connector 

pipeline, and the BLM has authority under the MLA to grant the right-of-way across all federal 

lands with the concurrence of the surface managing agencies. All actions on the federal lands, 

including those proposed under the application for a Right-of-Way Grant, must comply with the 

respective BLM RMPs and USFS LRMPs. In implementing the NEPA process to assess the 

proposed action on federal lands, this EIS is tiered by reference to these management plans, as 

amended by the NWFP and the BLM’s December 2008 WOPR. 

We (the Commission’s staff) conclude that construction and operation of the JCE & PCGP Project 

would result in some adverse environmental impacts. However, most of these impacts would be 

reduced to less-than-significant levels with the implementation of the applicants’ proposed mitigation 

measures and the additional measures we recommend in the final EIS. We developed measures that 

would appropriately and reasonably avoid, minimize, or mitigate environmental impacts 

resulting from construction and operation of the proposed Project. If the proposed Project is 

found to be in the public interest and is constructed and operated in accordance with the 

recommended mitigation measures, it would be an environmentally acceptable action. Our 

conclusions are based on information provided by Jordan Cove and Pacific Connector; analyses 

and field investigations by Commission staff; review of comments from federal, state, and local 

agencies; and input from public groups and individual citizens. We recommend that specific 

additional mitigation measures be attached as conditions to any authorization issued by the 

Commission. 

If the Coast Guard issues an LOR finding the waterway suitable for LNG marine traffic, the 

arrival, transit, cargo transfer, and departure of LNG carriers would be required to adhere to the 

procedures of an TMP recommended by the Coast Guard Sector Portland. In addition, Jordan 

Cove would develop Operations and Emergency Manuals in consultation with the Coast Guard, 

to ensure the safety and security of all operations associated with LNG marine transits and 

unloading. With implementation of the risk mitigation measures recommended in the Coast 

Guard’s WSR, an LNG release would be highly unlikely and the potential impact on resources 

would be less-than-significant. 
5-2 5.0 – Conclusions and Recommendations

5.1.1 Geology 

The geology of the Pacific Northwest is dominated by the CSZ. The Jordan Cove LNG facilities 

would be located at the eastern edge of the CSZ, on a site mantled by thick (over 100 feet) dune 

sheets. The Pacific Connector pipeline would cross the Coast Range, Klamath Mountains, 

Western and High Cascades, and Basin and Range physiographic regions and would pass 

through varying soil and lithologic units ranging from soft sediments to hard granite. 

No faults are reported at the LNG terminal site, and the Coos Bay area is located in a region with 

historically (last 170 years) moderate seismic activity within the active CSZ. However, 

geological evidence suggests that large megathrust earthquakes have occurred along the CSZ 

prior to the written historical record. Intense ground shaking, lateral spreading, and subsidence 

pose design issues for the site. A further series of geotechnical studies would be performed 

during detailed design, and ground improvement would be used to mitigate the liquefaction 

hazard. We are recommending that detailed designs be submitted for review and approval by the 

Director of OEP prior to construction, and that Jordan Cove retain a Board of Consultants to 

review the final LNG terminal design and perform construction and quality inspections to ensure 

that the final design satisfies both the FERC Seismic Guidelines and the 2007 Oregon Structural 

Safety Specialty Code. 

A tsunami generated by a megathrust earthquake on the CSZ would present the greatest 

inundation risk at the site. Jordan Cove sponsored a site-specific tsunami study by the OHSU 

which predicted that the maximum calculated tsunami inundation at the LNG terminal would be 

about 21 feet above MSL, with a maximum flow velocity of less than 2m/s. Jordan Cove has 

designed the LNG terminal so that foundations for facilities in the process area would be above 

the runup height of the worst-case tsunami wave, and the LNG storage tanks would be 

surrounded by a storm surge barrier with a peak crest elevation of + 55 feet. 

Pacific Connector selected the proposed pipeline route through an iterative process to avoid areas 

with high risk of geological hazards. During construction, Pacific Connector would implement 

site-specific construction techniques and BMPs to mitigate local geological hazards that could 

not be completely avoided. The pipeline would cross a Holocene age fault near MP 213, that 

would require site-specific design to account for potential displacement. 

The pipeline would cross two moderate-risk rapidly moving landslide site (at MPs 18.14 to 18.20 

on private land, and MP 36.92 on BLM land). Implementation of Pacific Connector’s ECRP 

would minimize or avoid the potential for construction to adversely affect slope stability. We are 

recommending that Pacific Connector characterize potential landslide hazards through other 

means in areas where remote sensing data coverage (LiDAR and aerial photography) is not 

available. 

The crossing of Coos Bay between MPs 1.7 and 4.1 has the greatest potential for liquefaction 

and lateral spreading. For this crossing, Pacific Connector would use thicker-walled pipe coated 

with concrete. The crossing of Haynes Inlet also may be susceptible to scour from tides. Pacific 

Connector would install the pipeline with 5 feet of cover in Coos Bay to protect it from scour. 

Moderate potential for liquefaction and/or lateral spread were also identified at Hayes Inlet, 

Kentuck Slough, Willanch Slough, Coosion Channel, Willis Creek, Klamath Valley, and the 

alluvial valleys between MPs 221.80 and 224.40 and MPs 229.0 and 230.9. Therefore, we are 
5-3 5.0 – Conclusions and Recommendations 

recommending that Pacific Connector file the results of numerical modeling for those pipeline 

crossings, and any site-specific measures that would need to be implemented to mitigate impacts 

from liquefaction or lateral spreading. 

Fluvial erosion may represent a hazard to the proposed pipeline where streams have the potential 

to expose the pipe as a result of significant channel migration or scour of the streambed. Pacific 

Connector relocated most of the pipeline in high scour potential areas to avoid these hazards and 

has proposed design changes to mitigate remaining crossings. We are recommending additional 

studies at three stream crossings (Indian Creek, West Fork Trail Creek, and North Fork Butte 

Creek) with high scour potential, and the formulation of site-specific mitigation measures as 

necessary to protect the pipeline. Locations where the pipeline would cross streams could also 

provide a new path for water to follow. Implementation of the ECRP and use of trench breakers 

and trench plugs would mitigate potential impacts. 

The pipeline would be near mines at 23 locations, including 13 sand, gravel, or aggregate open 

pit quarries. Two mercury mines occur along the proposed pipeline route (MP 109.3 and MP 

109.4). These are unlikely to pose any mine hazard risk. However, if contaminated soils are 

encountered during pipeline construction, Pacific Connector would follow the procedures 

outlined in its Contaminated Substances Discovery Plan. 

Effects on Federal Lands 

A low-risk rapidly moving landslide site could not be avoided at MP 36.92 on BLM Coos 

District land. Pacific Connector would conduct regular monitoring of the pipeline right-of-way 

across rugged terrain within BLM and NFS lands, including in this area, for previously 

unidentified landslides or new landslides. 

The pipeline would cross Middle Creek, which has a moderate risk for scour, at MP 27.04 on 

BLM lands. Pacific Connector would design this crossing to withstand estimated potential scour 

that could occur during 50-year maximum scour events, which would adequately protect the 

pipeline at this crossing location. 

The proposed route for the pipeline has been realigned between MPs 104 and 112 on the 

Umpqua National Forest to avoid habitat for NSO, cultural resources, and the Peavine Quarry. 

At about MP 150.4 the pipeline would be near the Heppsie Mountain Quarry on BLM land. 

Because the BLM is concerned that the pipeline may preclude future mining at this quarry, we 

are recommending that Pacific Connector develop a plan, in consultation with the BLM, to 

minimize the impact of blasting and outline mitigation measures as necessary. 

5.1.2 Soils and Sediments 

The proposed LNG marine traffic is not expected to have a significant impact on soils along the 

waterway or sediments within the waterway. LNG carriers would transit through the navigation 

channel at slow speeds and would not produce wakes that could erode the banks of the 

waterway. 

Jordan Cove identified existing areas of contaminated upland soils resulting from past use of the 

property by a paper mill. With implementation of Jordan Cove’s SPCCP and its Hazardous 

Waste Discovery Plan, construction of the LNG terminal is not anticipated to spread existing 

contamination or cause additional soil contamination. 
5-4 5.0 – Conclusions and Recommendations

Construction of the LNG terminal would require the dredging of about 5.6 mcy of material for 

the slip and access channel. Based on modeling results it is anticipated that turbidity generation 

at the dredging site would not present a significant environmental concern to the aquatic species 

located in the vicinity of the proposed dredge prism. Sediments that would be dredged from 

Coos Bay during the creation of the access channel were found not to be contaminated. Dredged 

material from the slip and access channel would be stockpiled in the Jordan Cove Placement site, 

two locations on the former Weyerhaeuser Linerboard site, and at the Port site. To minimize the 

impacts of erosion and sedimentation at the proposed LNG terminal, Jordan Cove would install 

erosion and sedimentation control structures in compliance with its project-specific Plan and 

Procedures, which incorporates many of the measures outlined in the FERC staff’s Plan and 

Procedures. 

During operation of the LNG terminal, Jordan Cove and the Port would have to conduct regular 

maintenance dredging of the access channel and slip every 2 to 4 years. Because of concerns 

raised by agencies about potential impacts on resources at dredge disposal Site F, we are 

recommending that Jordan Cove develop a plan, in consultation with the EPA and COE, 

providing details of its maintenance dredging spoil disposal activities and monitoring to ensure 

that the capacity and use of Site F are not inhibited. 

Long-term impacts on soils would occur at aboveground facilities associated with the Pacific 

Connector Project where soils would be graded and graveled or where permanent facilities 

would be constructed. Three co-located meter stations and four mainline valve sites would be 

located on prime farmland soils and would permanently remove about 7 acres from agricultural 

use. New permanent access roads would also have long-term impacts on soils. 

Potential impacts on soils would be minimized through measures specified in Pacific 

Connector’s ECRP. The ECRP was based on the FERC staff’s Plan and Procedures, and reflects 

recommendations from federal land managing agencies, the NRCS, and local County Soil and 

Water Conservation Districts. Pacific Connector’s Hydrostatic Test Plan would mitigate 

potential erosion during hydrostatic testing discharge. 

Effects on Federal Lands 

The USFS and BLM have requested topsoil segregation where the Pacific Connector pipeline 

would cross forested lands under their management. Pacific Connector states that where the 

pipeline would traverse steep forested landscapes, it would be impractical to salvage topsoil 

based on topographic and vegetation conditions. To mitigate for the potential reduction in soil 

productivity, to ensure that these areas properly revegetate, and to prevent long-term erosion 

impacts, Pacific Connector proposes to fertilize the right-of-way as described in its ECRP, and 

use slash to cover 65 to 85 percent of the ground in areas with a high to very high erosion 

potential. However, if the USFS finds that Pacific Connector does not meet its standards and 

guideline thresholds for soil disturbance, it may have to amend individual National Forest 

LRMPs. 

5.1.3 Water Resources and Wetlands 

It is highly unlikely that LNG marine traffic in the waterway would have significant adverse 

impacts on water resources or wetlands. No surface or groundwater resources underlying and in 

the vicinity of the LNG terminal site would be used for either construction or operation of the 

slip or LNG terminal. All water would be supplied to the LNG terminal by the CBNBWB. The 
5-5 5.0 – Conclusions and Recommendations 

nearest registered well maintained by the CBNBWB is located approximately 0.5 mile from the 

terminal site. 

Approximately 28.25 million gallons of water would be used for hydrostatic testing of the LNG 

storage tanks. Ultimately, 10 million gallons would be retained in the fire water pond. The 

remaining 18.25 million gallons would be discharged into an existing industrial wastewater 

pipeline that connects to a previously existing permitted ocean discharge point. Prior to 

discharge, Jordan Cove would test the water in the firewater pond, and develop treatment 

measures if it does not meet the standards of the discharge permit. 

Dredging the slip and access channel would have limited temporary impacts on water quality in 

Coos Bay. Approximately 41 acres of the 72 acres required for construction of the slip and 

access channel would be excavated or dredged in isolation from the waters of Coos Bay resulting 

in no turbidity being released to the waters of Coos Bay. The remaining area to be dredged 

would result in temporary siltation and sedimentation impacts similar to those that currently 

occur during channel maintenance dredging activities. 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. 

No ballast water from LNG carriers would be discharged into Coos Bay during their transit to the 

terminal. However, once at dock each LNG carrier would take in between 64 to 285 thousand 

m3 (about 17 to 75 million gallons) for ballast and engine cooling. The discharge of engine 

cooling water from LNG carriers at the terminal berth, ranging from 30 to 235 thousand m3 per 

ship, would only have a minor impact on water temperature within the slip, with an increase of 

about 3 degrees C within 75 feet of the point of discharge. 

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

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

144,000 gpd would be generated. This water would be neutralized before being conveyed to the 

fire water pond, with the overflow discharged to the industrial wastewater pipeline. 

Shallow trenching during installation of the Pacific Connector pipeline is not likely to have 

significant long term adverse impacts on groundwater resources. While there are no 

groundwater wells that supply public drinking water systems within 400 feet of the proposed 

Pacific Connector pipeline construction right-of-way, there are six wellhead protection areas that 

would be crossed by the proposed pipeline. Pacific Connector identified five private wells 

within 200 feet of the proposed pipeline, but none of these are used for drinking water. Because 

not all wells are registered in the state database, Pacific Connector would attempt to identify any 

unregistered wells in the vicinity of its proposed pipeline through field investigations and 

contacts with landowners prior to construction. Pacific Connector would follow the measures 

outlined in its ECRP and SPCCP to avoid or minimize impacts on groundwater resources. 

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

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

wells, including from blasting. In addition, we are recommending that Pacific Connector 

develop a plan to further reduce impacts on domestic water supplies. 

The Pacific Connector pipeline would cross 218 waterbodies, including perennial rivers and 

streams, intermittent flowing streams, irrigation canals and ditches, stock ponds, and the Coos 

Bay estuary. The proposed pipeline route would be located within six hydrological subbasins 
5-6 5.0 – Conclusions and Recommendations

including the Coos, Coquille, South Umpqua, Upper Rogue, Upper Klamath, and Lost River 

subbasins. 

Pacific Connector would minimize impacts on waterbodies by following the measures of its 

ECRP and SPCCP. Construction activities at waterbody crossings would be conducted in 

accordance with all federal and state regulations and permit requirements. Waterbodies would 

be crossed during low-flow periods whenever possible and within ODFW recommended inwater construction windows. 

The pipeline would cross 16 Fifth Field Watersheds, affecting about 2,618 acres within the 

transient snow zone (between 2,000 and 5,000 feet in elevation). Only clearing that permanently 

alters canopy cover could affect long-term peak flows. 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; which we do not consider to be a 

significant adverse impact. Pacific Connector’s proposed design measures are intended to ensure 

that impacts have a negligible effect on forest hydrology. 

The pipeline would cross 34 waterbodies that have been determined to be water quality limited 

according to the ODEQ Integrated Report. Pacific Connector proposes to cross 25 of these 

waterbodies using dry open-cut crossing techniques. To minimize the potential effects on stream 

temperature due to the removal of riparian vegetation, Pacific Connector has incorporated 

mitigation measures including narrowing the construction right-of-way to 75 feet wide, locating 

TEWA more than 50 feet back from waterbodies, and reestablishing riparian vegetation by 

replanting after construction for a minimum width of 25 feet back from the streambanks. 

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. While a wet opencut crossing would create more turbidity and sedimentation than a dry crossing, the effects would 

be short-term during construction, and impacts would be mitigated by following measures in 

Pacific Connector’s ECRP and the applicable permit conditions. 

The proposed pipeline would cross two rivers listed on the Nationwide Rivers Inventory; the 

North Fork of the Coquille and the South Umpqua Rivers. The Pacific Connector pipeline would 

cross the North Fork of the Coquille River (at about MP 23) using a dry open-cut method. 

Pacific Connector proposes to use diverted open cuts at the two crossings of the South Umpqua 

River (at about MPs 69 and 95) because the river is too wide to utilize other dry crossing 

methods, and use of a bore or HDD are not feasible due to topographic and subsurface 

constraints. Except for the wet crossing of Coos Bay, and the use of bores or HDD under six 

waterbodies, Pacific Connector would use standard dry open-cut crossing methods at the 

remaining crossings, including dam-and-pump and fluming. Dry open-cut methods, are designed 

to limit impacts to flowing waterbodies by creating a dry stream segment to work in and contain 

disturbed sediments. 

At six waterbody crossings Pacific Connector would use bore or HDD to eliminate the need for 

in-water construction activities that could result in sedimentation and turbidity as well as impacts 

on waterbody banks and beds. Pacific Connector would use conventional bores to cross 

underneath Kentuck Slough (MP 6.3), Catching Slough (MP 11.1), and the Medford Aqueduct 

(MP 133.4). The Coos River (MP 8.2), Rogue River (MP 122.7), and Klamath River (MP 199.4) 

would be crossed with HDDs. Pacific Connector has prepared an HDD Contingency Plan and 
5-7 5.0 – Conclusions and Recommendations 

Failure Procedure 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. 

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 or from surface water right owners. If water for hydrostatic testing would be acquired 

from surface water sources, Pacific Connector would obtain all necessary appropriations and 

withdrawal permits prior to use. 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. 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. 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. 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. 

Pacific Connector’s draft Hydrostatic Testing Plan includes measures to prevent the transfer of 

aquatic invasive species and disease. We expect this plan to be refined and finalized after further 

consultations between Pacific Connector and federal land managing agencies. 

Four public water systems that have surface water intakes within 3 miles downstream of 

waterbodies would be crossed by the proposed pipeline. Pacific Connector would provide 

written notification to the authorities of the surface water supply intakes at least one week before 

beginning in-water work or as otherwise specified by the appropriate authorities. We are 

recommending that Pacific Connector continue its coordination regarding the surface water 

intakes within 3 miles downstream of pipeline crossings. 

Construction and operation of the LNG terminal 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). Also, some wetlands at the Port Commercial Sand Stockpile site may be 

impacted due to the temporary storage of dredged. We are recommending that Jordan Cove 

continue to consult with COE, NMFS, ODSL, ODFW, and other appropriate resource agencies 

to develop a final plan to mitigate for permanent impacts on wetlands and aquatic vegetation 

resulting from the construction and operation of the LNG terminal facilities. 
5-8 5.0 – Conclusions and Recommendations

The Pacific Connector pipeline would cross approximately 11.5 miles of wetlands affecting a 

total of 257.1 acres including TEWAs. A total of 0.1 acre of wetlands would be lost because of 

construction of the Clarks Branch Meter Station. Following pipeline construction, vegetation 

maintenance within the permanent operational right-of-way would convert forested or scrubshrub wetlands to a different wetland type resulting in a different wetland function. Use of 

measures from Pacific Connector’s ECRP would minimize impacts on. In addition, we are 

recommending that Pacific Connector coordinate with the Coos Watershed Association to ensure 

that impacts on the Brunschmid Wetland Reserve project, crossed between about MPs 10.5 and 

10.8, are minimized. 

Effects on Federal Lands 

The Pacific Connector pipeline would cross a total of about 35 miles of Tier 1 and 2 Key 

Watersheds on federal lands. The Tier 1 Key Watersheds, which provide habitat for salmonids, 

include the South Umpqua River, North and South Fork Little Butte Creek, and Spencer Creek. 

Within the South Umpqua River watershed, the pipeline would affect about 139 acres of federal 

lands, which represents about 0.03 percent of all the federal lands within this watershed. Within 

the Little Butte Creek fifth-field watershed the pipeline would disturb about 309 acres of federal 

lands, representing 0.25 percent of the total amount of federal land within that watershed. 

Within the Spencer Creek watershed, the pipeline would affect about 92 acres of federal land, 

representing about 0.17 percent of all the federal land in the watershed. 

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 according to 

its ECRP. The FERC approved of Pacific Connector’s proposed modifications to the staff’s Plan 

and Procedures to adhere to USFS requirements for waterbody crossings on NFS lands. It is 

USFS 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. The USFS also wants Pacific Connector to obtain site-specific approval from 

the authorized USFS officer when requesting to not fill the upper 1 foot of trench backfill in 

coldwater fisheries with clean gravel or native cobbles for waterbody crossings on NFS lands. 

On federally managed land, the Pacific Connector pipeline would cross approximately 0.2 mile 

of wetlands, affecting a total of approximately 3 acres. 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. Pacific Connector would reduce impact on wetlands by following 

its ECRP, and has drafted a Mitigation Plan to make up for any wetland losses. We are 

recommending that the applicants finalize their Federal Land Mitigation Plan in consultation 

with appropriate resource agencies. 

5.1.4 Vegetation and Timber 

It is highly unlikely that LNG marine traffic in the waterway would have any significant adverse 

impacts on vegetation. Construction of the proposed LNG terminal would impact approximately 

117.2 acres of vegetation. Operation of this facility would permanently affect approximately 

61.5 acres of dune forest and 16.7 acres of herbaceous vegetation. In addition, dredged material 
5-9 5.0 – Conclusions and Recommendations 

disposal at the Port Commercial Sand Stockpile site would impact an additional 7.2 acres of dune 

forest and 60.7 acres of herbaceous vegetation. Jordan Cove would follow its Plan and 

Procedures to minimize impacts on vegetation. Mitigation for the permanent loss of vegetation 

habitat at the LNG terminal site would be accomplished through out-of-kind, off proximity 

habitat enhancement or protection to achieve the habitat replacement ratios acceptable to ODFW 

and FWS in terms of quantity and quality. 

Four invasive plant species listed by the ODA were encountered during the field surveys of the 

proposed LNG terminal site. These were gorse, scotch broom, smooth cordgrass, and parrotfeather milfoil. To avoid introducing or spreading invasive species, Jordan Cove would follow 

the recommendations outlined in the Oregon Aquatic Species Management Plan, and the Oregon 

Noxious Weed Strategic Plan. 

Construction of the Pacific Connector pipeline would affect about 3,035 acres of forest and 

woodland, 623 acres of agricultural lands, 488 acres of grasslands-shrubland, and 131 acres of 

non- riparian vegetation. Construction of the pipeline would have medium-term impacts on 

approximately 266.7 acres of grass-shrub-sapling areas, and long-term impacts on approximately 

2,044.7 acres of forest vegetation. Long-term impacts would occur on approximately 683.8 

acres of late-successional old-growth forests, 642.5 acres of mid-seral forests, 711.7 acres of 

regenerating young forests, and 4.9 acres of riparian (palustrine) forest. During operation, the 

proposed pipeline would have a permanent easement (right-of-way corridor), permanent access 

roads, and aboveground facilities that would impact approximately 851.7 acres of various 

vegetation types. 

The proposed pipeline would create approximately 120.2 miles of new edge within forest habitat, 

most of which (76 percent) would be through forest and woodland vegetation types. The 

restoration and revegetation of the temporary construction right-of-way, following Pacific 

Connector’s ECRP, would reduce edge effects. Pacific Connector would minimize the potential 

for the spread of wildfires by following the fuel load recommendations of land managing 

agencies, and coordinating with landowners and local fire districts to ensure that pipeline 

construction is done in accordance with fire prevention and suppression practices. 

Out of the total construction impact of 4,903.8 acres, about 4,125.3 acres would be revegetated. 

Some of these areas would fall within the permanent easement and would, therefore, only be 

revegetated with herbaceous cover to reduce erosion, but would not be allowed to regenerate to 

their original state if they were formerly forested. About 3,276.4 acres outside of the permanent 

maintenance corridor and UCSAs would be revegetated and allowed to regenerate to their 

original state. About 778.5 acres would consist of UCSAs that do not require revegetation, since 

Pacific Connector proposes to not clear these areas during pipeline construction. We are 

recommending that Pacific Connector file a plan at least 120 days prior to construction that 

details how it would accomplish its goal to protect live trees within UCSAs from damage. The 

permanent easement for the proposed pipeline would encumber approximately 848.9 acres. 

Pacific Connector has proposed a number of mitigation measures and a monitoring program to 

reduce the likelihood of the proposed pipeline increasing the rate of spread by noxious weeds. 

We are recommending that Pacific Connector add vehicle and equipment wash stations, and 

provide additional information about use of these stations in a revised Noxious Weeds, Soil 
5-10 5.0 – Conclusions and Recommendations

Pests, and Forest Pathogens Control Plan to be filed at least 120 days prior to the start of 

construction. 

Within the region around the proposed pipeline, the western pine beetle and fir engraver are the 

most prevalent insect or disease pathogens. In order to prevent the spread or establishment of 

these insects and/or diseases, Pacific Connector would implement the mitigation measures 

described in section 4.4.2. 

Approximately 545.7 acres of forest land would be removed from the timber base (the area 

within the permanently cleared right-of-way on private forest land, state forest land, NFS lands, 

and BLM-administered land). Future timber production would be lost on these acres for at least 

the life of the Pacific Connector pipeline. Pacific Connector would compensate affected 

landowners for the lost timber production. 

Pacific Connector has filed a draft timber extraction plan that contains information on estimated 

acres of forests to be cleared, net volume of clearing, and available harvesting methods. 

However, as timber cruises have not been conducted yet, the draft timber extraction plan does 

not contain information on dollar value of timber, logging system(s) to be used for each harvest 

segment, yarding locations, or the location of landings and decks. We are recommending that 

Pacific Connector file a final timber extraction plan with additional information at least 120 days 

prior to construction. 

Effects on Federal Lands 

Land allocations as defined by the NWFP on NFS lands include both Riparian Reserves and 

LSRs. On BLM-administered lands the land allocations defined by the December 2008 WOPR 

include RMAs and LSMAs. Construction of the Pacific Connector pipeline would disturb about 

25.03 acres within USFS Riparian Reserves, of which an estimated 13.64 acres would be 

forested habitat, 8.23 acres regenerating forest, 0.46 acre wetland, 0.22 acre unaltered 

nonforested habitat, and 2.48 acres altered habitats. Long-term impacts from the pipeline’s 

permanent easement would affect about 5.5 acres of USFS Riparian Reserves. On BLM lands, 

construction of the proposed pipeline would cross a total of 1.36 miles of RMAs, temporarily 

impacting 23.65 acres, with the permanent 30-feet of maintained right-of-way affecting 4.95 

acres. Approximately 5.0 acres of the disturbed acreage on BLM RMAs would consist of longterm impacts resulting from the pipeline’s permanent right-of-way. 

About 169.3 acres that would be disturbed by pipeline construction within NFS lands would be 

forests over 80 years in age. The pipeline would affect about 376.8 acres within USFS 

designated LSRs, most of which would occur within the Rogue River-Siskiyou National Forest 

(280.3 acres). Pipeline construction would affect about 542 acres of forests over 80 years in age 

on BLM lands. A total of 45.3 acres would be disturbed by the Project within BLM designated 

LSMAs. 

In consultations with the USFS and BLM, Pacific Connector developed a draft Mitigation Plan 

to compensate for unavoidable effects on USFS LSRs, and compensate for impacts on species 

resulting from clearing of mid- and late-serial forested habitats (including USFS Riparian 

Reserves). This Mitigation Plan incorporates three key mechanisms for achieving its goals: 1) 
5-11 5.0 – Conclusions and Recommendations 

transfers of federal land from the Matrix to the LSR administrative allocations; 2) funding for 

restoration and enhancement projects on public lands to mitigate for the direct and indirect 

effects of the Project on listed species and their habitats; and 3) acquisition of non-federal lands 

and the long-term management of those acquired lands to provide for substitute habitats as 

compensation that would not be mitigated by implementing the restoration and enhancement 

projects on public lands. Pacific Connector and the USFS have an Agreement in Principle to 

execute the proposed Mitigation Plan that includes committed funding. Because the draft plan 

has not yet been accepted by the federal land managing agencies, we are recommending that 

Pacific Connector continue to consult with the agencies, and file an approved final plan prior to 

pipeline construction. 

Approximately 8,540 million board feet (MBF) of timber would be harvested on NFS lands and 

8,839 MBF on BLM-administered lands. Pacific Connector would submit a reforestation plan to 

the BLM and the USFS for approval during right-of-way acquisition. Following construction, 

previously forested areas within the temporary construction right-of-way and TEWAs would be 

replanted in accordance with Oregon reforestation rules, BLM Management Directions, and 

USFS Standards and Guidelines. Areas within the permanent right-of-way would remain cleared 

and maintained in an herbaceous state in order to facilitate periodic checks of the pipeline. This 

would result in a permanent loss of timber production on land allocated for timber production on 

approximately 88 acres within BLM-administered lands and on approximately 35 acres of NFS 

lands. The government would be compensated for this loss in productivity by Pacific Connector. 

5.1.5 Wildlife and Aquatic Resources 

The potential for LNG carrier strikes on marine mammals and sea turtles in the waterway during 

transit to and from the proposed LNG terminal is low, given the speed of the LNG carriers and 

historic records indicating that vessel strikes of marine animals rarely occur. Additionally, 

Jordan Cove would implement measures to minimize potential ship strikes to marine mammals 

and sea turtles. 

We identified EFH for groundfish, coastal pelagic species, Pacific Coast salmon, and highly 

migratory species that could be affected by the Project. In order to comply with the MSA, we 

will include our EFH assessment with the BA we will be producing concurrent with this final 

EIS. 

Chances of fish stranding or excessive shoreline erosion that would affect fish resources are 

unlikely considering that waves and propeller wash generated by the LNG carriers in the bay 

would be similar to those that naturally occur. This determination was made from modeling the 

projected waves of a typical LNG carrier and velocity from the propeller in the bay based on 

expected ship velocity and morphology. 

Dredging for the LNG access channel and slip would remove the current benthic population of 

organisms within the sediments, including clams, ghost shrimp, polychaete worms in the 

estuarine regions. Rates of recovery for these species may range from several months to as much 

as 2 to 3 years depending on substrate type and currents in the affected area. Hydrodynamic and 

sediment transport modeling for the dredging of the LNG facility showed that the combined 

background and Project-related suspended sediment concentrations would be well below the 

lethal level for fish, but would be at levels likely to cause some short-term harm to aquatic 

resources near the active dredge areas. 
5-12 5.0 – Conclusions and Recommendations

Piles would be installed as part of the marine berth at the proposed LNG terminal. Impacts would 

be reduced by conducting some pile driving within the excavated basin behind the earthen berm 

during slip excavation. To further minimize impacts on aquatic, Jordan Cove would observe the 

in-water work window for the Coos Bay and would use vibratory pile driving as conditions 

allow, and pile caps. In addition, Jordan Cove would use bubble curtains around each pile, and 

only operate the pile driving with flows around piles remain low enough for the bubble curtain to 

remain effective. 

Jordan Cove proposed a system capable of delivering filtered bay water to the LNG carriers for 

engine cooling water and ballast through high-pressure pre-screen water jets. Use of a prescreened water intake to transfer water to land-based storage containers, and then transfer back, 

through high-pressure jets to the ship at berth would limit the entrainment and impingement of 

juvenile fish and other organisms. However, intakes on LNG carriers would not be directly 

screened and this proposed system has not been demonstrated to be effective at preventing 

entrainment of aquatic organisms. Jordan Cove has stated it would conduct pre-and post 

construction monitoring to determine the number and effects of this system on Coos Bay aquatic 

biota. We are recommending that Jordan Cove continue to consult with NMFS, ODFW, FWS, 

and the Coast Guard on the details of its sampling plan, interpretation of results, and water 

supply design to protect aquatic resources and, if required, to develop a compensatory mitigation 

plan for affected resources. 

The primary impact on wildlife from construction and operation of the LNG terminal would be 

habitat loss. The upland habitat most heavily affected during construction of the Jordan Cove 

LNG terminal facilities would be dune forest. Using the ODFW habitat categories, terminal 

construction would convert a total of about 53 acres of Category 4 (important) habitat to lesser 

functioning habitat categories. ODFW policy would require mitigation for this conversion of 

Category 4 habitat. 

The proposed pipeline would cross 123 waterbodies that may be fish bearing. Most effects from 

pipeline construction across streams would result in short-term impacts on water temperature, 

pH, dissolved oxygen, benthic invertebrate populations, and aquatic species. To improve stream 

habitat, and mitigate for impacts, Pacific Connector is proposing to install LWD at selected 

locations. In addition, to protect fish habitat in waterbodies crossed by the pipeline, we are 

recommending that Pacific Connector file prior to pipeline construction site-specific requests for 

streams where gravel or cobbles would not be used for backfill. We are also recommending that 

Pacific Connector develop a stream habitat mitigation plan, in consultations with the appropriate 

agencies, that provides site-specific details about placement of LWD and other stream 

improvements. 

The installation of the pipeline in Hayes Inlet could affect commercial oyster operations. 

Therefore, we are recommending that Pacific Connector consult with the commercial oyster 

growers about how to minimize impacts. 

We determined that the Project could result in a minor impact due to the introduction of invasive 

aquatic species from pipeline construction equipment or through hydrostatic testing bringing 

water from one basin to another. However, because concerns remain we are recommending that 

Pacific Connector develop a project-specific Aquatic Species Nuisance Prevention Plan to ensure 

these impacts are minimized. 
5-13 5.0 – Conclusions and Recommendations 

There would be long term impacts on species that use forested habitats that would be cleared and 

maintained in a herbaceous state within the permanent easement. Pacific Connector would 

minimize habitat loss through its ECRP and its Mitigation Plan. To compensate for the loss of 

cavities and snags within the construction right-of-way, Pacific Connector would top or girdle 

trees at the edge. Pacific Connector would also put up nesting boxes within riparian areas. 

However, we are concerned that these boxes could be used by non-native birds, so we are 

recommending that the entrance holes to the boxes be limited in size for use by native cavitynesting birds. 

A bald eagle nest was recently identified near the first pipeline crossing of the South Umpqua 

River. While the bald eagle was recently removed from the federal list of threatened and 

endangered species under the ESA, it is a state listed species, a USFS sensitive species and MIS 

for the Umpqua National Forest, and is offered protection under the MBTA and the Bald and 

Golden Eagle Protection Act. Therefore, we are recommending that Pacific Connector should 

monitor the bald eagle nest near MP 69 prior to any construction activity in that area, and no 

construction would be allowed during the breeding season between January 1 and August 31. 

Effects on Federal Lands 

The Pacific Connector pipeline would cross or affect riparian vegetation at 47 waterbody 

crossings on lands administered by the BLM and USFS, of which 18 are known or suspected to 

contain fish, and initially remove about 49 acres of federally defined riparian areas. Most of this 

(about 70 to 80 percent) would be recovered in the long term through replanting of native trees in 

the riparian area. 

Pacific Connector has prepared a study of MIS for the USFS, to comply with the National Forest 

Management Act. That study discussed MIS within NFS lands crossed by the pipeline, including 

NSO, pileated woodpecker, three-toed woodpecker, pine marten, bald eagle, peregrine falcon, 

northern goshawk, Roosevelt elk, Columbian black-tail deer, mule deer, and steelhead and 

resident trout. In addition, this EIS includes a BE that discusses other sensitive species identified 

by the USFS. 

Pacific Connector would mitigate for impacts on habitat where the pipeline crosses federal lands, 

using a plan drafted after consultations with the USFS and BLM. To compensate for the loss of 

old growth forest habitat, some NFS lands may be reassigned from a Matrix allocation to a LSR 

allocation amending Forest Plans. Pacific Connector would fund a series of projects through the 

USFS and BLM that would restore and enhance substitute habitat on federal lands. 

5.1.6 Federally Listed Threatened and Endangered Species 

Based on informal consultations with the FWS and NMFS, 29 federally listed species were 

identified as potentially occurring in the general vicinity of the Project. Within the EEZ and the 

waterway for LNG marine traffic, there are six species of federally listed whales, one marine 

mammal, one bird, four species of marine turtles, and three fish species. The main threat to 

those aquatic species would be from vessel strikes, or leaks. Leaks are unlikely, and Jordan 

Cove has proposed measures to reduce the potential for vessel strikes. Three federally listed fish 

species are known to utilize Coos Bay. 

Jordan Cove and Pacific Connector conducted biological surveys to assess the presence of 

individuals or habitats. No federally listed plants or animals were found during surveys of the 
5-14 5.0 – Conclusions and Recommendations

Jordan Cove terminal facilities. However, the North Spit of Coos Bay, where the LNG terminal 

would be located, contains habitat for three federally listed bird species. 

In addition to the federally listed fish species in Coos Bay, there are two other fish species that 

could reside in waterbodies along the Pacific Connector pipeline route. One federally listed 

invertebrate may occupy habitat near proposed pipe yards and staging areas. Because of 

concerns about the adequacy of surveys for this invertebrate, we are recommending that Pacific 

Connector should confirm the presence or absence of vernal pool fairy shrimp at all yards with 

habitat, before use of the yards would be allowed. Besides the birds that are known from the 

North Spit, there is another federally listed bird that inhabits old growth forest habitat along the 

pipeline route. While seven federally listed plant species were identified from the literature for 

the pipeline area, Pacific Connector’s botanical surveys located populations of three of those 

plant species. Because there are areas of suitable habitat for federally listed plants along the 

pipeline route that have not yet been surveyed, we are recommending that Pacific Connector 

consult with the FWS to develop a Plant Contingency Plan. 

The FERC prepared a BA to be submitted to the NMFS and FWS concurrent with this final EIS. 

That BA provides supporting documentation for our findings, summarized below. 

We conclude that the Project should have No Effect on: 

• the endangered Rough popcorn flower 

The Project is Not Likely to Adversely Affect: 

• the threatened Steller sea lion; 

• the endangered Blue whale; 

• the endangered Fin whale; 

• the endangered Killer whale (Eastern North Pacific, Southern Resident stock); 

• the endangered Humpback whale; 

• the endangered Sei whale; 

• the endangered Sperm whale; 

• the endangered California brown pelican; 

• the threatened Western snowy plover; 

• the threatened Green sturgeon (Southern DPS); 

• the endangered Green turtle; 

• the endangered Leatherback turtle; 

• the endangered Olive Ridley turtle; 

• the threatened Loggerhead turtle; 

• the threatened Vernal pool fairy shrimp; 

• the endangered Short-tailed albatross; 

• the endangered Western lilly; 

• the endangered Large-flowered meadowfoam; 

• the endangered Applegate milk-vetch; 

• the endangered Genter’s frillary; and 

• the endangered Cook’s lomatium. 
5-15 5.0 – Conclusions and Recommendations 

The Project is Likely to Adversely Affect: 

• the threatened Marbled murrelet; 

• the threatened Northern spotted owl; 

• the threatened Coho salmon (SONCC); 

• the threatened Coho salmon (Oregon Coast ESU); 

• the endangered Lost River sucker; 

• the endangered Shortnose sucker; and 

• the threatened Kincaid’s lupine. 

Jordan Cove and Pacific Connector have proposed a Mitigation Plan to compensate for 

unavoidable impacts on listed species and their habitats through substitute habitat and/or habitat 

stewardship. Because some federally listed species and their habitats may be affected, we will 

request that the FWS and NMFS develop a BO indicating whether or not the proposed Project is 

likely to jeopardize the continued existence of a listed species or adversely modify designated 

critical habitat for those species. We are recommending that no construction can proceed until 

after we have completed formal consultations to comply with the ESA. 

Effects on Federal Lands 

Within the Coos Bay and Roseburg BLM Districts, the Pacific Connector pipeline would affect a 

total of about 57 acres of occupied or presumed occupied habitat for MAMU. The pipeline 

would affect about 279 acres of suitable habitat for NSO on federal lands. Pacific Connector’s 

mitigation plan would compensate for MAMU and NSO habitat loss on federal lands. 

The BOR is concerned about potential impacts to the Lost River sucker and shortnose sucker 

within irrigation facilities it manages as part of the Klamath Project that would be crossed by the 

pipeline. Therefore, we are recommending that Pacific Connector formulate a salvage plan, in 

consultation with the FWS and BOR, to outline procedures for capturing listed sucker species 

during stream crossings in the Klamath Basin. 

5.1.7 Land Use, Recreation, and Visual Resources 

There are a number of houses and commercial buildings within the communities along the 

waterway overlapped by the Zones of Concern for LNG marine traffic. In addition, the Zones of 

Concern overlap the entirety of the North Spit, including the Coos Bay Shorelands SRMA, 

portions of the Oregon Coast National Wildlife Refuge at Gregory Point, the Siuslaw National 

Forest, the Coos Head Air Naval Facility, and some state and local parks. With the 

implementation of the risk mitigation measures recommended by the Coast Guard in its WSR, 

LNG marine traffic in the waterway should not have any adverse significant impacts on land use, 

residences, commercial buildings and government offices, and parks and recreational areas. 

Recreational boaters using Coos Bay would merely have to temporarily move out of the way of 

an LNG carrier as it passes, like they currently do for other deep draft commercial ships in the 

navigation channel. 

The proposed LNG terminal would be located within a 159-acre tract of industrial zoned land. 

In 2008 Coos County issued three ACU permits for the Project, to cover the Port’s proposed 

construction of the slip and access channel, the use of Port land to store dredge materials, and 

Jordan Cove’s proposed LNG import terminal. Two of the permit approvals were challenged to 
5-16 5.0 – Conclusions and Recommendations

the LUBA, which remanded three conditions for the Jordan Cove permit back to the county to 

correct errors. Opponents then took their appeal to the Oregon Supreme Court, and the county 

cannot finalize its land use decision until after the court ruling. 

The LNG terminal and western portion of the pipeline would be within Oregon’s Designated 

Coastal Zone. Jordan Cove and Pacific Connector submitted preliminary applications to the 

ODLCD to determine if the Project would be consistent with the CZMA, but the ODLCD found 

the applications deficient and requested additional information. We are recommending that both 

applicants file with the Commission documentation of concurrence from the ODLCD that their 

respective projects would be consistent with the CZMA. 

There are no residences closer than 1 mile from the proposed LNG terminal. The most visible 

part of the LNG terminal would be the LNG storage tanks, which would be about 180 feet high. 

Visual impacts of the LNG facility would be minor because views would be screened by 

landscape, topography, and distance. 

The clearing of forest for the pipeline right-of-way would have long-term visual impacts. 

However, visual simulations at KOPs where the pipeline would cross well traveled roads show 

that with implementation of Pacific Connector’s Aesthetics Management Plan and its ECRP over 

time vegetation would grow up within the temporary right-of-way to reduce visual impacts. 

Pacific Connector has identified 15 residences within 100 feet of the construction right-of-way 

and work areas, and has proposed measures to minimize impacts on these residences during 

construction. However, because survey access has not been granted for the entire pipeline route, 

additional residences may be identified. We are recommending that Pacific Connector provide 

additional information including the results of a civil survey of the entire pipeline route that 

identifies all residences and commercial structures within 50 feet of the construction right-ofway, a plan outlining measures that would be implemented to mitigate pipeline construction 

impacts on domestic water supply systems and septic systems, and additional measures that 

would be implemented for any residence closer than 25 feet to the construction work area. 

The proposed pipeline installation across the Hynes Inlet portion of Coos Bay would be in close 

proximity to a boat ramp along North Bay Drive, and would cross the Haynes Inlet Water Trail, 

both near MP 3.9. We are recommending that Pacific Connector develop a plan to minimize 

impact on recreational and other boaters using Haynes Inlet during pipeline construction. 

Effects on Federal Lands 

The proposed pipeline would cross a portion of the BLM Coos Bay District Upper Rock Creek 

ACEC. Because Pacific Connector proposed no specific measures to mitigate or further reduce 

impacts to this area, we are recommending that Pacific Connector continue to consult with the 

BLM as necessary to ensure that appropriate site-specific mitigation measures for the crossing of 

this ACEC are included in the POD. 

The pipeline would cross the PCT on NFS land. To reduce visual impacts from the pipeline 

crossing of the trail cross, Pacific Connector adopted a route variation recommended by the 

USFS. 

Visually, the Pacific Connector pipeline would meet BLM-VRM Classes 4 objectives. On NFS 

lands, without visual resource mitigation, the Pacific Connector pipeline would meet the USFS-
5-17 5.0 – Conclusions and Recommendations 

VQO definition of Unacceptable Modification because of its straight edge clearing limits and 

excessive visual contrasts created by root wads, boulders, and cull logs scattered across the rightof-way. A visual mitigation plan has been developed by the USFS and adopted by Pacific 

Connector that would substantially reduce visual impacts on NFS lands. As mitigated the 

Project would meet a Modification or Partial Retention Standard on visually sensitive areas 

within National Forests. We are recommending that Pacific Connector continue to consult with 

the BLM and USFS as necessary to finalize visual resource protection design and mitigation 

measures that would be included in the POD. 

5.1.8 Socioeconomics 

With the risk management measures recommended by the Coast Guard in its WSR, LNG marine 

traffic is not likely to have significant adverse impacts on commercial fishermen or other 

commercial ships. Jordan Cove would develop a TMP to reduce conflicts with other users of 

Coos Bay. There would be temporary delays for other boats while an LNG carrier passes by. 

Construction of the LNG terminal is anticipated to last for 36 months. At its peak, construction 

of the terminal and slip would employ about 970 people. On average, there would be about 470 

people working at this job site each month. Approximately 41 percent of the construction 

workforce would be expected to commute daily from their homes in the area. Jordan Cove 

estimates that operation of the proposed LNG terminal would require a permanent staff of 56 

employees. 

The economic benefits of the Project include total wages during construction of the terminal and 

slip estimated at about $119 million, plus $74 million to be spent on local goods and services. 

One study estimated that Coos County could earn $2 million per year in taxes from the Jordan 

Cove facility during construction and its first three years of operation. In addition, the proposed 

power plant at the LNG terminal would supplement local availability of electricity. 

There is a adequate supply of housing available for non-local workers. It is estimated that there 

are 1,658 housing units available for rent, for sale, or otherwise vacant in Coos County. A total 

of 2,608 hotel and motel rooms were identified within 35 miles of Coos Bay, with vacancy rates 

ranging from 20 percent in August to almost 70 percent in January. In addition, there are about 

3,270 mobile home and RV spaces in Coos County, with annual vacancy rates averaging almost 

50 percent. 

Pacific Connector would construct its pipeline using five construction spreads and estimates the 

average workforce for each construction spread would be about 280 workers per month, with a 

peak of 369 workers mid-season. The greatest activity would occur during the second year of 

construction, with an estimated peak construction workforce of 1,844 people over five spreads. 

Pacific Connector estimates that approximately 50 percent of the construction jobs for its 

pipeline would be filled by local workers. Pacific Connector estimates that operation of the 

pipeline would require a permanent staff of five employees, stationed and residing at different 

locations along the pipeline, but reporting to a main office in Eugene, Oregon. 

Construction and operation of the Pacific Connector pipeline would only have temporary impacts 

on the local population and communities along the route. Non-local pipeline workers may 

compete with tourists for available hotel rooms during the peak summer vacation period. Pacific 

Connector estimated that for each construction spread about 184 housing units would be needed 
5-18 5.0 – Conclusions and Recommendations

for non-local workers. However, we estimate there are about 2,195 housing units available in the 

four counties crossed by the pipeline. 

It is possible that the location of a pipeline near a residence could affect property values. 

However, the pipeline crosses a mostly rural region, and is not near many houses. Several 

studies have shown that the location of a pipeline near a residence does not necessarily depress 

the sales price. Economic benefits from construction and operation of the pipeline include the 

availability of additional supplies of natural gas for local communities in southern Oregon 

serviced by the Williams Northwest Grants Pass Lateral and Avista, which will have 

interconnections with the Pacific Connector pipeline. Total construction payroll for the pipeline 

would be about $166 million, with another $320 million spent on materials and supplies. Pacific 

Connector also estimates it would pay about $14 million for local services, including logging and 

hauling. About $18 million in state taxes would be generated during pipeline construction, and 

local property taxes would generate a total of about $8.4 million for the four counties crossed by 

the pipeline in its first year of operation. 

Effects on Federal Lands 

Pacific Connector prepared a Financial Efficiency Analysis that assesses the net present value of 

costs and benefits that would accrue to the federal government as a result of construction and 

operation of the proposed project. Costs and benefits were projected over a 50 year time period, 

where appropriate, and discounted using a real discount rate of 4 percent. The analysis identifies 

two sources of direct government revenue: 1) Pacific Connector’s payment for timber that 

would need to be cut, and 2) Pacific Connector’s rental payments for construction access and the 

pipeline right-of-way. The analysis also identifies three sources of government costs: 1) the 

value of lost timber productivity along the new right-of-way, 2) the value of non-merchantable 

trees that would need to be cut prematurely (lost timber growth), and 3) the incremental cost of 

future maintenance for existing roads that Pacific Connector may upgrade above their existing 

federal maintenance level. The projected net present value of the Pacific Connector pipeline 

based on this analysis is $2.91 million in 2007 dollars. 

5.1.9 Transportation 

Based on a total of 80 LNG carriers visiting the proposed terminal each year, Jordan Cove 

estimates that operation of the terminal could affect recreational and other boating activity during 

about 1.3 percent of annual daylight hours and would have similar impacts to the on-going traffic 

of cargo vessels that call at Coos Bay to collect wood chips. Delays to other ship traffic related 

to LNG carrier traffic would occur on average once every 4.5 days. 

A traffic analysis was conducted for Jordan Cove to predict traffic impacts during construction of 

the LNG terminal, which concluded that construction-related traffic volumes would have 

operational impacts, specifically extended vehicular delays and queuing for some traffic 

movements. This analysis recommended that the following measures be employed to reduce 

construction-related traffic impacts: 1) temporary signalization at Highway 101 at the TransPacific Parkway, 2) manual flagging control at Trans-Pacific Parkway at Jordan Cove Road, 3) 

temporary speed reduction on Highway 101 in the vicinity of Trans-Pacific Parkway, and 4) 

staggered work shift start and end times. Jordan Cove has agreed to implement all the mitigation 

measures recommended in the above study, in accordance with the requirements of ODOT, Coos 

County, and the City of North Bend. However, because the traffic study was not reviewed by 
5-19 5.0 – Conclusions and Recommendations 

local authorities, we are recommending that Jordan Cove document that it provided the traffic 

study to ODOT, Coos County, and the City of North Bend, and file the comments the agencies 

have on the plan. 

The Southwest Oregon Regional Airport is located in the city of North Bend, directly across 

Coos Bay and less than 1 mile from the proposed LNG terminal site. Both the Coos County 

Airport District Board of Commissions, and the Coos Bay Pilots Association, are on the record 

stating that airport operations would not be shut down during the transit of an LNG carrier to 

Jordan Cove’s terminal. The FAA issued a limited aeronautical review for the proposed Jordan 

Cove LNG terminal in November 2008. The FAA review found that the LNG storage tank 

locations would exceed the Category C and D traffic patterns and VFR at the Southwest Oregon 

Regional Airport by 13 feet, and would exceed the VFR maneuvering areas for Category A and 

B aircraft (horizontal surface) by 66 feet. Therefore, the LNG storage tanks qualify as 

obstructions under Part 77 standards. When a structure exceeds the obstruction standards of Part 

77, it does not mean that the structure is a hazard to air navigation. Rather, it is an indication that 

further studies should be conducted to determine any adverse effects on operations in navigable 

airspace. We are recommending that before construction of the LNG terminal begins, Jordan 

Cove should file documentation of continuing consultations with the FAA and the results of any 

additional studies conducted by the FAA. 

About 710 roads would be used for access during construction of the Pacific Connector pipeline. 

Pacific Connector has estimated that modifications of 62 existing access roads may be required 

outside of the existing road bed resulting in about 17 acres of disturbance. In addition Pacific 

Connector would put in about 18 new access roads during construction, affecting about 6 acres, 

and would permanently maintain 16 new access roads during operation of the pipeline, impacting 

a total of about 3 acres. All new temporary roads would be decommissioned and the areas 

restored to preconstruction conditions following completion of construction. 

We received comments from residents on the east side of the proposed Rogue River crossing 

concerned about Pacific Connector’s proposed use of Old Ferry Road to access the right-of-way 

and river crossing HDD site during construction. Based on an analysis of alternative means of 

access at this location, we selected the use of Old Ferry Road as the preferred alternative with the 

least environmental impacts. 

It is projected that 80 percent of the workforce for each spread would be transported from the 

contractor yard to and from the right-of-way on crew buses, with the remaining 20 percent using 

their own vehicles (92 vehicles during peak construction) and moving from site-to-site along the 

right-of-way using local roads and highways. Pacific Connector would comply with all traffic 

control requirements under its road crossing permits, and has developed a draft Transportation 

Plan for Non-Federal Lands. We are recommending that prior to pipeline construction, Pacific 

Connector document that it provided its draft Transportation Plan to ODOT and the affected 

counties, and file the agency comments together with a revised plan. 

Effects on Federal Lands 

The Pacific Connector pipeline would use all or portions of 120 roads that would cross BLM 

lands for access to the pipeline right-of-way during construction, and 104 roads on NFS lands. 

Pacific Connector would need to construct two new TARs with a total length of approximately 

0.2 mile on BLM-administered lands, affecting approximately 0.4 acre, and would need to 
5-20 5.0 – Conclusions and Recommendations

construct two new PARs on BLM-administered lands, with a total length of less than 0.1 mile, 

affecting approximately 0.2 acre. Pacific Connector would modify 10 existing roads requiring 

about 6.1 acres would be on BLM-administered lands, and 10 roads resulting in disturbance to 

2.6 acres would be on NFS lands. The BLM is concerned about use and construction of roads on 

lands which are subject to reciprocal right-of-way agreements and permits where there may be 

multiple parties with rights to use and construct additional roads. Therefore, we are 

recommending that Pacific Connector identify and negotiate access agreements on all 

construction access roads across federal and non-federal lands, and where the United States and 

third parties hold rights. 

Pacific Connector has developed a draft Transportation Management Plan for Federal Lands. 

After review by the land managing agencies, the plan would be finalized and submitted with the 

POD. 

5.1.10 Cultural Resources 

A literature review and site file search indicated that there are 24 known previously recorded 

archaeological sites and 15 known previously recorded individual historic resources overlapped 

by the Zones of Concern. No significant impacts on cultural resources (archaeological sites or 

historic structures) within the Zones of Concern are expected from the proposed LNG marine 

traffic in the waterway to the Jordan Cove LNG terminal. 

Jordan Cove conducted a boat survey within the near shore tidal area of the proposed access 

channel to the LNG terminal, and did not identify any archaeological sites, such as prehistoric 

fishing weirs. We agree with the Oregon SHPO that the portion of Coos Bay to be affected by 

construction of the access channel has a low potential to contain any submerged cultural 

resources, such as shipwrecks. 

The literature review indicated that there are potentially unrecorded sites at the Jordan Cove 

LNG terminal facilities. This includes historic Indian villages in the vicinity of the 

Weyerhaeuser Linerboard dredge disposal areas and the Port Commercial Sand Stockpile site. 

Intensive pedestrian inventories of the proposed Jordan Cove LNG terminal identified one site 

(35CS221). Archaeological testing has been recommended to evaluate the NRHP eligibility of 

that site. Subsurface testing and monitoring was also recommended in other portions of the 

APE. We and the SHPO have agreed with these recommendations. 

As of August 2007, Pacific Connector had surveyed about 203 miles of the proposed pipeline 

route, in addition to potential access roads, TEWA outside of the 400-foot-wide corridor, and 

source and/or disposal yards. The surveys identified 111 new archaeological sites and 134 

isolated finds. Pacific Connector’s cultural resources contractors recommended that all of the 

isolated finds and 13 sites be considered not eligible for the NRHP, requiring no further 

investigation. It was also recommended that pipeline design modifications be made to facilitate 

avoidance for 10 sites. The remaining sites were unevaluated, or were considered potentially 

eligible for the NRHP, and testing was recommended to clarify their eligibility. The SHPO 

considers nine archaeological sites on private land along the pipeline route to be not eligible for 

the NRHP. In addition, the SHPO has found that the Project should have no adverse effects on 

the Columbia Forest Products complex, the Dora cemetery, and various historic trails, roads, and 

railroads crossed by the pipeline. We concur. 
5-21 5.0 – Conclusions and Recommendations 

The FERC staff and the applicants have consulted with Indian tribes that may attach religious or 

cultural importance to sites in the APE. The Coos Tribe indicated that the Jordan Cove terminal 

facilities may overlap with areas considered to be traditional cultural properties, including 

cemeteries and villages. To address these concerns, Jordan Cove has proposed an MOU with 

interested tribes to outline future archaeological investigations and consultations. At the request 

of the Cow Creek Tribe, Pacific Connector conducted an ethnographic study to identify potential 

traditional cultural properties along the pipeline route. Pacific Connector indicated it would file 

with the FERC the results of that study, together with the results from 2008 survey and testing, 

by June 2009. 

We have not yet completed the process of complying with the NHPA for this Project. Cultural 

resources inventories been not yet been completed for the entire route of the Pacific Connector 

pipeline, and related ancillary facilities and temporary construction use areas. In addition, 

Pacific Connector needs to provide the results of archaeological testing at unevaluated sites that 

cannot be avoided before we would be able to make determinations about site eligibility and 

potential Project effects. Jordan Cove also needs to complete archaeological testing and 

monitoring activities at its proposed facilities. We are recommending that Jordan Cove and 

Pacific Connector not construct or use any of their proposed facilities, including related ancillary 

areas for staging, storage, temporary work areas, and new or to-be-improved access roads, until 

we have completed all studies and consultations necessary to complete compliance with the 

NHPA. 

Effects on Federal Lands 

Pacific Connector’s surveys identified 21 archaeological sites within the APE on BLM or NFS 

lands. The SHPO indicated that it considers three of the sites on federal lands to be not eligible 

for the NRHP, requiring no further work. Additional data are needed for 18 sites on federal 

lands before we could make determinations of eligibility and effect, in consultations with the 

federal land managing agencies and the SHPO. 

The Pacific Connector pipeline would cross 27 irrigation features associated with the Klamath 

Project that are under the jurisdiction of the BOR, between MPs 200.5 and 214.2. The BOR 

considers the entire Klamath Project eligible for the NRHP, because of its age and importance to 

regional history and the agricultural development of the Klamath Basin. However, the SHPO 

believes the JCE & PCGP Project would have no adverse effects on the Klamath Canal System, 

because Pacific Connector proposes to cross irrigation ditches in the Klamath Basin during the 

low water period of the winter, and would restore all canals back to their previous condition after 

construction. 

5.1.11 Air Quality and Noise 

Air pollutants would be emitted as a result of both construction and operation of marine vessels 

on the waterway for LNG marine traffic, the proposed LNG terminal, the Pacific Connector 

pipeline, and the Butte Falls Compressor Station. Emissions from the marine vessel traffic 

would be periodic and transient, and they are not expected to result in significant long-term air 

quality impacts, although there could be short-term localized impacts. To minimize emissions 

while docked, Jordan Cove evaluated using only LNG carriers that are capable of “cold-ironing” 

(i.e., those that can use electrical power from land, rather than using their own engines to 

generate electricity), and provided emissions estimates base on this assumption. However, 
5-22 5.0 – Conclusions and Recommendations

because not all LNG carriers are capable of utilizing cold ironing, this estimate results in an 

underestimate of potential emissions. Jordan Cove has acknowledged this limitation and stated 

that it would provide revised emissions estimates. We are recommending that these revised 

emissions estimates be filed with the FERC prior to construction. 

Both the LNG terminal and the Butte Falls Compressor Station would require preconstruction 

permits from the ODEQ. Jordan Cove has to submit a revised air permit application that 

includes a worst case scenario for emissions if cold-ironing cannot be done. 

During construction of the pipeline there would be temporary emissions from pipeline 

construction equipment that have not yet been quantified. In the draft EIS we recommended that 

Pacific Connector provide an estimate of all criteria pollutants and GHG emissions from pipeline 

construction. Pacific Connector has not yet provided that estimate; therefore, we are 

recommending that this information be provided prior to construction. 

The NSA closest to the LNG terminal is a single-family home in the City of North Bend (NSA1) 

about 1.4 miles south of the center of the proposed LNG terminal site. Noise from heavy 

equipment operations would generally be reduced to 33 decibel on the A-weighted scale (dBA) 

or less at NSA1. Pile driving would be expected to generate peak noise levels of about 48 dBA 

at NSA1. LNG terminal construction noise would not have significant impact on NSAs. 

Predicted operational noise increments from the LNG terminal would be an Ldn (day-night 

equivalent noise level) of 45.4 dBA at NSA1. Noise levels during ship movements are estimated 

to be about 63 dBA at a distance of 300 feet during each passby event. The increased ship traffic 

would not be expected to create a significant change in overall noise levels along the Coos Bay 

navigation channel. 

During construction of the proposed Pacific Connector pipeline, neighbors in the vicinity of the 

construction right-of-way would hear construction noise. Only 0.64 percent of the land crossed 

by the proposed pipeline (1.48 miles of pipeline corridor) is categorized as having residential, 

commercial, or industrial use. Pipeline construction activities generally would be limited to 

daytime hours. Due to the assembly-line nature of pipeline construction, activities in any area 

could occur intermittently over a period lasting from several weeks to a few months. 

Some portions of HDD operations would occur as 12-hour work shifts, while other activities 

would normally occur as 24-hour per day operations. Pacific Connector has identified noise 

mitigation options for each HDD site. We have determined that with implementation of these 

measures, temporary noise impact on NSAs from pipeline construction would be acceptable. 

The closest occupied residences to the Butte Falls Compressor Station are about 2,000 feet away. 

Construction equipment noise levels would vary during the construction period, but typically 

would be less than 50 dBA at the nearest NSAs. Because construction activity would generally 

be limited to daytime hours, estimated construction activity noise levels would not represent a 

significant noise impact. 

The Butte Falls Compressor Station would include a variety of noise mitigation design features. 

The proposed noise mitigation features are predicted to keep Leq noise levels at nearby NSAs to 

less than 35 dBA, and thus comply with Oregon noise regulation requirements. The predicted 

Ldn levels at these NSAs are all less than 40 dBA, and thus comply with the FERC Ldn limit of 55 
5-23 5.0 – Conclusions and Recommendations 

dBA. Consequently, the proposed Butte Falls Compressor Station would not have a significant 

noise impact on surrounding NSAs. However, to ensure that actual operational noise is at or 

below the predicted noise, and that there would be no significant impact to noise quality at the 

nearest NSAs, we are recommending that Pacific Connector file the results of a noise survey no 

later than 60 days after the compressor station is placed in service to demonstrate that noise at 

nearby NSAs does not exceed 55 dBA Ldn. 

There would be limited noise generated by the proposed meter stations. However, some 

commenters have expressed concern about this potential impact, especially in rural areas. 

Therefore, we have recommended that Pacific Connector conduct noise surveys at each meter 

station and file the results no later than 60 days after the meter station is placed in service to 

demonstrate that noise at nearby NSAs does not exceed 55 dBA Ldn. 

Effects on Federal Lands 

The nearest federal Prevention of Significant Deterioration Class I areas to any of the proposed 

facilities are at least 110 km away, and impacts from Project air emissions at these locations 

would be minimal and well within compliance with federal standards. Air pollution regulations 

treat other (Class II) federal lands in the same manner as non-federal Class II lands. The nearest 

federal lands to the Jordan Cove LNG terminal include the Coos Bay Shorelands SRMA and the 

Oregon Dunes NRA. Air quality impacts at these locations would be less than the maximum 

Class II impacts identified above. 

Estimated noise from LNG terminal construction and operation at the southern boundary of the 

Oregon Dunes NRA would be well below an Ldn of 55 dBA, the noise level used by the EPA 

and FERC to protect the public from activity interference and annoyance outdoors in residential 

areas. During pile driving for installation of LNG terminal berth facilities, predicted noise levels 

at the BLM boat ramp would exceed 55 dBA, and would be noticeable to users of the BLM boat 

ramp. This impact would be a temporary annoyance during terminal construction. Predicted 

noise from operation of the LNG terminal would be below 55 dBA at the BLM boat ramp, which 

would be below a noise level that would interfere or be an annoyance for users of the boat ramp. 

During operation of the LNG terminal, BLM and COE lands near the Coos Bay navigation 

channel would receive limited noise impacts from LNG vessels arriving at and departing from 

the LNG terminal. Noise from LNG carriers would not be expected to create a noticeable 

change in overall noise levels at BLM and COE lands along the Coos Bay navigation channel. 

During construction of the Pacific Connector pipeline, there would be temporary noise impacts 

on federal lands crossed by the pipeline or crossed by construction access roads. Construction 

noise could have localized and temporary impact on recreational users and wildlife within 

federal lands. Assuming the operation of a piece of equipment results in typical noise levels of 

88 dBA at 50 feet, the noise impact of that equipment would be 82 dBA at 100 feet and 72 dBA 

at 300 feet from the equipment. If two items of equipment operate concurrently in the same area, 

typical construction noise levels would be about 91 dBA at 50 feet, 85 dBA at 100 feet, and 75 

dBA at 300 feet from the equipment. This noise impact would be a temporary annoyance to 

recreational users near the pipeline during active construction. Noise would diminish rapidly as 

the distance from the noise source increases, and the annoyance would be present only during 

active construction. 
5-24 5.0 – Conclusions and Recommendations

5.1.12 Reliability and Safety 

In order to analyze the safety, operability, and reliability of the proposed facilities, we performed 

a cryogenic design and technical review of the proposed terminal design and safety systems. Our 

evaluation of the front-end-engineering design of the proposed LNG storage facility included a 

review of the cryogenic safety, thermodynamics, heat transfer, instrumentation, cryogenic 

processes, and other relevant safety systems. As a result of this technical review, we identified a 

number of concerns and have made recommendations to address these issues. Compliance with 

these recommendations would need to be demonstrated by Jordan Cove prior to initial site 

preparation, prior to construction after final design, prior to commissioning, or prior to 

commencement of service. Therefore, we believe that appropriate features and modifications to 

enhance the safety and operability of the proposed LNG facility would be incorporated into the 

facility design. 

We also verified the exclusion zone modeling performed to ensure compliance with the federal 

siting standards. Although portions of the exclusion zones would extend beyond the property 

line of the terminal site, Jordan Cove has entered into an option-to-lease agreement with the 

owner of the adjacent property. This agreement would prohibit use of these areas in any manner 

that would conflict with the federal siting standards for LNG facilities. Therefore, the proposed 

facility would comply with the siting requirements of 49 CFR 193. 

In accordance with 18 CFR 157.21 and Navigation and Vessel Inspection Circular 05-05, Jordan 

Cove submitted a Follow-On WSA to the Coast Guard on March 1, 2007, that proposed 

mitigation measures to address identified navigation safety and maritime security risks posed by 

LNG marine traffic. The Coast Guard reviewed Jordan Cove’s assessment and also conducted 

its own independent risk assessment regarding accidental and intentional release scenarios 

involving LNG marine traffic. The COTP Sector Portland provided the FERC with a WSR 

which identified specific risk mitigation measures which must be in place to responsibly manage 

the maritime safety and security risks of the proposed LNG facility. The report indicated that the 

port community does not currently have these resources and that the Coos Bay navigational 

channel is not currently suitable for the type and frequency of LNG marine traffic associated 

with the proposed LNG facility. However, the Coast Guard has preliminarily determined that the 

waterway can be made suitable for LNG marine traffic if these additional measures are put into 

place. As a result, we are recommending that Jordan Cove ensure that the facility and any LNG 

vessel transiting to and from the facility comply with all requirements set forth by the Coast 

Guard COTP Sector Portland. 

In accordance with Section 3A of the EPAct05, we are recommending that Jordan Cove develop 

an ERP that includes a Cost-Sharing Plan. The Cost-Sharing Plan must contain a description of 

any direct cost reimbursements Jordan Cove agrees to provide to any state and local agencies 

with responsibility for security and safety at the LNG terminal and near vessels that serve the 

facility. This ERP, which would have to be approved prior to initial site preparation at the 

facility site, would address concerns of local communities about the costs related to 

security/emergency management of the proposed LNG facility and LNG marine traffic. 

Pacific Connector’s pipeline would be built and inspected according to DOT standards. These 

standards ensure pipeline safety. 
5-25 5.0 – Conclusions and Recommendations 

Effects on Federal Lands 

Locating the pipeline in non-populated areas minimizes the chance for unauthorized public 

access to the right-of-way. Pacific Connector has proposed mitigation measures to protect the 

public from construction activity. The BLM and USFS can require Pacific Connector to 

incorporate additional specific public safety measures into the POD as a condition of a Right-ofWay Grant for use of federal lands. Federal land management agencies may also issue 

temporary closure orders during periods of active construction when necessary to protect public 

health and safety. 
5-26 5.0 – Conclusions and Recommendations 

5.2 FERC STAFF’S RECOMMENDED MITIGATION 

If the Commission approves the proposed JCE & PCGP Project, we recommend that the 

Commission’s authorizations include the measures recommended below to further mitigate the 

environmental impacts associated with the construction and operation of the proposed Project. 

1. Jordan Cove and Pacific Connector shall follow the construction procedures and 

mitigation measures described in their respective applications, supplemental filings 

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

by the Order. Jordan Cove and Pacific Connector must: 

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

with the Secretary; 

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

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

protection than the original measure; and 

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

modification. 

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

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

and operation of the Project. This authority shall allow: 

a. the modification of conditions of the Commission’s Order; and 

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

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

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

environmental impact resulting from project construction and operation. 

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

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

construction and operation of the Project. This authority shall include: 

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

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

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

4. Before any construction for the LNG terminal and the pipeline, Jordan Cove and 

Pacific Connector shall each file an affirmative statement with the Secretary, certified by 

a senior company official, that all company personnel, EIs, and contractor personnel will 

be informed of the EI’s authority and have been or will be trained on the implementation 

of the environmental mitigation measures appropriate to their jobs before becoming 

involved with construction and restoration activities. 

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

alignment sheets, and shall include all of the staff's recommended facility locations. As 

soon as they are available, and before the start of construction for the LNG terminal 

and the pipeline, Jordan Cove and Pacific Connector shall each file with the Secretary 

any revised detailed maps or survey alignment sheets at a scale not smaller than 1:6,000 
5-27 5.0 – Conclusions and Recommendations 

with station positions for all facilities approved by the Order. All requests for 

modifications of environmental conditions of the Order or site-specific clearances must 

be written and must reference locations designated on these maps/alignment sheets. 

6. Jordan Cove and Pacific Connector shall each file with the Secretary detailed maps or 

alignment sheets and aerial photographs at a scale not smaller than 1:6,000 identifying all 

route realignments or facility relocations, and staging areas, pipe storage yards, new 

access roads, and other areas that would be used or disturbed and have not been 

previously identified in filings with the Secretary. Approval for each of these areas must 

be explicitly requested in writing. For each area, the request must include a description 

of the existing land use/cover type, and documentation of landowner approval, whether 

any cultural resources or federally listed threatened or endangered species would be 

affected, and whether any other environmentally sensitive areas are within or abutting the 

area must be approved in writing by the Director of OEP before construction in or near 

that area. 

This requirement does not apply to extra workspace allowed by Jordan Cove’s projectspecific Plan or Pacific Connector’s ECRP, minor field realignments per landowner 

needs, and requirements which do not affect other landowners or sensitive environmental 

areas such as wetlands. 

Examples of alterations requiring approval include all route realignments and facility 

location changes resulting from: 

a. implementation of cultural resources mitigation measures; 

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

measures; 

c. recommendations by state regulatory authorities; and 

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

sensitive environmental areas. 

7. Within 60 days of the acceptance of the Order and Certificate, and before 

construction of the LNG terminal and the pipeline begins, Jordan Cove and Pacific 

Connector shall each file an Implementation Plan (IP) with the Secretary for review and 

written approval by the Director of OEP. Jordan Cove and Pacific Connector must file 

revisions to their respective plan as schedules change. The plan shall identify: 

a. how Jordan Cove and Pacific Connector will implement the construction 

procedures and mitigation measures described in their applications and supplements 

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

the Order; 

b. how Jordan Cove and Pacific Connector would incorporate these requirements into 

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

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

site is clear to onsite construction and inspection personnel; 

c. the number of EIs assigned per spread, and how the company will ensure that 

sufficient personnel are available to implement the environmental mitigation; 
5-28 5.0 – Conclusions and Recommendations 

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

appropriate material; 

e. the location of the environmental compliance training Jordan Cove and Pacific 

Connector will give to all personnel involved with construction and restoration 

(initial and refresher training as the Project progresses and personnel change), with 

the opportunity for OEP staff to participate in the training session(s); 

f. the company personnel (if known) and specific portion of Jordan Cove and Pacific 

Connector’s organization having responsibility for compliance; 

g. the procedures (including use of contract penalties) Jordan Cove and Pacific 

Connector will follow if noncompliance occurs; and 

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

diagram), and dates for: 

(1) the completion of all required surveys and reports; 

(2) the environmental compliance training of onsite personnel; 

(3) the start of construction; and 

(4) the start and completion of restoration. 

8. Pacific Connector shall develop and implement an environmental compliance resolution 

procedure. The procedure shall provide landowners with clear and simple directions for 

identifying and resolving their environmental mitigation problems/concerns during 

construction of the Project and restoration of the right-of-way. Prior to construction of 

the pipeline, Pacific Connector shall mail the complaint procedures to each landowner 

whose property would be crossed or affected by the Project. 

a. In its letter to affected landowners, Pacific Connector shall: 

(1) provide a local contact that the landowners shall call first with their concerns; 

the letter shall indicate how soon a landowner shall expect a response; 

(2) instruct the landowners that, if they are not satisfied with the response, they 

shall call Pacific Connector’s Hotline; the letter shall indicate how soon to 

expect a response; and 

(3) instruct the landowners that, if they are still not satisfied with the response 

from Pacific Connector’s Hotline, they shall contact the Commission's 

Enforcement Hotline at (888) 889-8030. 

b. In addition, Pacific Connector shall include in its weekly status report a copy of a 

table that contains the following information for each problem/concern: 

(1) the date of the call; 

(2) the identification number from the certificated alignment sheets of the affected 

property; 

(3) the description of the problem/concern; and 
5-29 5.0 – Conclusions and Recommendations 

(4) an explanation of how and when the problem was resolved, will be resolved, 

or why it has not been resolved. 

9. Jordan Cove and Pacific Connector shall employ a team of EIs, including at least one EI 

at the LNG terminal and two or more per pipeline spread. The EIs shall be: 

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

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

documents; 

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

environmental mitigation measures required in the contract (see condition 7 above) 

and any other authorizing document; 

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

the Order, and any other authorizing document; 

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

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

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

other federal, state, or local agencies; and 

f. responsible for maintaining status reports. 

10. Beginning with the filing of its IP, Pacific Connector shall file updated status reports with 

the Secretary on a weekly basis until all construction and restoration activities are 

complete. On request, these status reports will also be provided to other federal and state 

agencies with permitting responsibilities. Status reports shall include: 

a. An update on Pacific Connector’s efforts to obtain the necessary federal 

authorizations. 

b. the construction status of the Project, work planned for the following reporting 

period, and any schedule changes for stream crossings or work in other 

environmentally sensitive areas; 

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

by the EI(s) during the reporting period (both for the conditions imposed by the 

Commission and any environmental conditions/permit requirements imposed by 

other federal, state, or local agencies); 

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

noncompliance, and their cost; 

e. the effectiveness of all corrective actions implemented; 

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

with the requirements of the Order, and the measures taken to satisfy their concerns; 

and 

g. copies of any correspondence received by Pacific Connector from other federal, 

state or local permitting agencies concerning instances of noncompliance, and 

Pacific Connector’s response. 
5-30 5.0 – Conclusions and Recommendations 

11. Jordan Cove and Pacific Connector must each receive written authorization from the 

Director of OEP before commencing service from the Project. Such authorization will 

only be granted following a determination that the LNG facility and the pipeline and 

associated facilities have been constructed in accordance with Commission approval and 

applicable standards, can be expected to operate safely as designed, and the rehabilitation 

and restoration of areas disturbed by construction are proceeding satisfactorily. 

12. Within 30 days of placing the authorized facilities in service, Jordan Cove and Pacific 

Connector shall each file an affirmative statement with the Secretary, certified by a senior 

company official: 

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

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

conditions; or 

b. identifying which of the conditions of the order Jordan Cove and Pacific Connector 

has complied with or will comply with. This statement shall also identify any areas 

affected by the Project where compliance measures were not properly implemented, 

if not previously identified in filed status reports, and the reason for noncompliance. 

13. Prior to pipeline construction, Pacific Connector shall file with the Secretary the 

following information on non-jurisdictional facilities that would be constructed as a result 

of its Project: 

a. final placement or routing and design information, including maps depicting the 

location of the facilities; 

b. documentation of consultations with the appropriate agencies and the status of 

federal, state, or local permits or approvals required for their construction and 

operation; and 

c. status and copies of agency clearances (or copies of any surveys and reports 

prepared) for wetlands, threatened and endangered species, and cultural resources. 

(EIS section 2.2) 

14. Jordan Cove and Pacific Connector shall be required to implement the following peer 

review process: 

a. Prior to construction of the LNG terminal and pipeline, Jordan Cove and Pacific 

Connector shall retain a “Board of Consultants” (Board) composed of three or more 

qualified independent engineering consultants experienced in the critical disciplines 

of geotechnical, civil, structural, and mechanical engineering, to review the final 

design and to perform construction quality inspections of the civil and structural 

aspects of the Project in accordance with the specifications contained in the FERC’s 

Draft Seismic Design Guidelines and Data Submittal Requirements for LNG 

Facilities (FERC Seismic Guidelines) and other measures agreed to by Jordan Cove 

and Pacific Connector. 

b. Jordan Cove and Pacific Connector shall file with the Secretary the names and 

qualifications of the Board members for approval by the Director of OEP. 

c. The Board shall certify that all civil and structural detailed design calculations, 

analyses, and construction documents are in compliance with all applicable codes 
5-31 5.0 – Conclusions and Recommendations 

and standards, Project-specific civil, structural, and mechanical design criteria, and 

other engineering requirements of the Order, including the FERC Seismic 

Guidelines. The Board shall further certify, based on construction inspections by 

the Board that all civil and structural construction of the terminal facilities is in 

conformance with the Project construction documents. The Board shall also certify 

that all procured equipment has been properly seismic qualified in conformance 

with the project-specific seismic qualification requirements, and the FERC Seismic 

Guidelines, that seismic detailing of structures has been properly implemented, and 

the pipeline has been designed to minimize the hazard of rupture due to ground 

instability. 

d. Among other things, the Board shall assess the adequacy of the following: 

• final geotechnical investigations necessary to support all final foundation 

designs in satisfying the FERC Seismic Guidelines, and final pipeline 

routing/mitigation measures through geologically hazardous areas; 

• field tests and associated results used to verify ground improvement, pile 

driving, and all civil and structural construction; 

• selection and implementation of the final seismic design categorization of all 

structures, systems, and components of the LNG terminal in satisfying the 

FERC Seismic Guidelines; 

• proposed seismic recording instrumentation and shutdown alarms in satisfying 

the FERC Seismic Guidelines; 

• construction procedures and progress; and 

• continuous and/or periodic inspections made by the Board to ensure that the 

construction quality of all Seismic Category I, II, and III structures, systems, 

and components is acceptable. 

e. The Board shall meet as necessary to allow the timely progress of the final design 

approvals and construction of the project in accordance with Jordan Cove and 

Pacific Connector's production of acceptable interim and final design data. 

f. Before each meeting, Jordan Cove and Pacific Connector shall file the following 

material with the Commission and furnish copies to members of the Board, and 

other appropriate federal and/or state agencies at the request of the Director of OEP: 

• a statement of the specific level of review the Board is expected to provide; 

• an agenda for the meeting; 

• a list of the items to be discussed; 

• a discussion of significant events in the design and construction that have 

occurred since the previous Board meeting; 

• drawings of the design and construction features; and 

• documentation of the details, calculations, and analyses of the design and 

construction features to be discussed. 
5-32 5.0 – Conclusions and Recommendations 

g. Jordan Cove and Pacific Connector shall ensure that the Commission and the Board 

has sufficient time to review all pertinent materials before each meeting. 

h. Within 30 days of each Board meeting, Jordan Cove and Pacific Connector shall 

file with the Commission copies of the Board's report and a statement of intent to 

comply with the Board's recommendations or a statement of a plan to resolve the 

issue(s). Jordan Cove and Pacific Connector must provide detailed reasons for any 

recommendation of the Board not implemented. 

i. The Board's review comments shall be submitted prior to or simultaneously with 

Jordan Cove and Pacific Connector’s request(s) for approval to proceed with any 

specific construction-related activities that may be required by the Order. The 

Director of OEP must approve in writing all requests to proceed with construction 

(EIS section 4.1). 

15. Prior to commissioning of the LNG terminal or commencing service through the 

pipeline, Jordan Cove and Pacific Connector shall file the Board's final report, which 

shall contain a statement indicating the Board's opinion with respect to the construction, 

safety, and adequacy of the LNG terminal structures and mitigation measures employed 

along the pipeline route in areas subject to ground instability (EIS section 4.1). 

16. Jordan Cove and Pacific Connector shall not construct or use any of their respective 

proposed facilities, including related ancillary areas for staging, storage, temporary work 

areas, and new or to-be-improved access roads until: 

a. the Commission staff completes formal consultations with the NMFS and FWS; and 

b. Jordan Cove and Pacific Connector have received written notification from the 

Director of OEP that construction and/or implementation of conservation measures 

may begin (EIS Section 4.6). 

17. Jordan Cove and Pacific Connector shall not construct or use any of their respective 

proposed facilities, including related ancillary areas for staging, storage, temporary work 

areas, and new or to-be-improved access roads, until: 

a. Jordan Cove and Pacific Connector each file with the Secretary the results of all 

additional cultural resource surveys, ethnographic studies, site evaluation 

investigations, a historic properties management plan, revised unanticipated 

discovery plan, and any necessary avoidance/treatment plans; 

b. Jordan Cove and Pacific Connector each file with the Secretary the comments of 

land managing agencies, the SHPO, and interested Indian tribes on all cultural 

resources reports or plans; 

c. The ACHP has been given an opportunity to comment if any historic properties 

would be adversely effected by the Project; and 

d. The Director of OEP reviews and approves all cultural resources reports and plans, 

and notifies Jordan Cove and Pacific Connector in writing that treatment 

plans/mitigation measures may be implemented or construction may proceed. 

 All materials filed with the Commission containing location, character, and 

ownership information about cultural resources must have the cover and any 
5-33 5.0 – Conclusions and Recommendations 

relevant pages therein clearly labeled in bold lettering: “CONTAINS PRIVILEGED 

INFORMATION – DO NOT RELEASE” (EIS section 4.10). 

18. Prior to construction of any Project facilities, Jordan Cove and Pacific Connector shall 

each file with the Secretary documentation of concurrence from the ODLCD that the 

proposed LNG terminal and associated sendout pipeline would be consistent with the 

CZMA (EIS section 4.7). 

19. Prior to commissioning of the LNG terminal, Jordan Cove shall 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 shall 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 (EIS section 4.3). 

20. Jordan Cove shall continue to consult with the COE, NMFS, ODSL, and ODFW, and 

other appropriate resource agencies to develop a final compensatory mitigation plan for 

permanent impacts on eelgrass. Jordan Cove shall 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 (EIS section 4.3). 

21. Jordan Cove shall finalize its pelagic sampling and entrainment estimating studies and 

develop alternative methods to reduce entrainment of juvenile salmonids as a result of 

LNG carrier water intakes while at the LNG terminal. Jordan Cove shall consult with 

NMFS, ODFW, FWS and the Coast Guard regarding the need for compensatory 

mitigation. These study results shall be filed with the Secretary for review and written 

approval of the Director of OEP prior to commissioning of the LNG terminal (EIS 

section 4.5). 

22. Prior to construction of the LNG terminal, Jordan Cove shall continue to consult with 

ODOT, Coos County, and City of North Bend regarding the DEA 2008 Transportation 

Impact Analysis, and file with the Secretary any comments these agencies have on the 

report (EIS section 4.9). 

23. Prior to construction of the LNG terminal, Jordan Cove shall file with the Secretary, 

documentation of continuing consultations with the FAA, and the results of any 

additional aeronautical studies conducted under FAR Part 77, together with copies of any 

official determination of findings made by the FAA with regards to the proposed LNG 

terminal (EIS section 4.9). 

24. Jordan Cove shall revise its worst-case emissions estimates (both hourly and annual) for 

criteria pollutants, hazardous air pollutants, and GHG in accordance with the FERC 

staff’s March 23, 2009 data request and file these calculations with the Secretary, for 

review and approval of the Director of OEP, prior to construction of the LNG 

terminal. The revised estimates shall incorporate the maximum worst case number of 

trips, to reflect the facility’s maximum sendout design capacity of 1.0 Bscfd of natural 

gas (EIS section 4.11). 
5-34 5.0 – Conclusions and Recommendations 

25. Jordan Cove shall revise its dispersion modeling based on revised estimates of worst-case 

emissions in accordance with the FERC staff’s March 23, 2009 data request, and identify 

mitigation necessary to comply with air quality standards. Jordan Cove shall file its 

revised modeling results with the Secretary, for review and approval of the Director of 

OEP, prior to construction of the LNG terminal (EIS section 4.11). 

26. Pacific Connector’s exercise of eminent domain authority granted under section 7(h) of 

the NGA in any condemnation proceeding related to the Order for the pipeline must be 

consistent with the authorized facilities and locations. Pacific Connector’s right of 

eminent domain granted under section 7(h) of the NGA does not authorize it to increase 

the size of its natural gas pipeline to accommodate future needs or to acquire a right-ofway for a pipeline to transport a commodity other than natural gas. In situations where 

Pacific Connector uses the power of eminent domain under section 7(h) of the NGA to 

acquire a permanent right-of-way, the width of that easement shall not exceed 50 feet 

(EIS section 2.3). 

27. Pacific Connector shall continue to consult with the Port and potentially affected oyster 

growers regarding measures that would be implemented during pipeline installation in 

Coos Bay to minimize impacts on Port activities and oyster raising. The results of this 

consultation shall be filed with the Secretary prior to pipeline construction (EIS section 

3). 

28. Prior to pipeline construction, Pacific Connector shall file with the Secretary, for the 

review and approval of the Director of OEP, results of numerical modeling for Haynes 

Inlet, Kentuck Slough, Willanch Slough, Cooston Channel, Willis Creek, Indian Creek, 

Klamath Valley, and the alluvial valleys between MPs 221.8 and 224.4 and between MPs 

229.0 and 230.9, as well as measures that would be implemented to mitigate impacts 

associated with liquefaction or lateral spreading at these pipeline crossings (EIS section 

4.1) . 

29. Pacific Connector shall characterize potential landslide hazards through other means in 

areas where LiDAR and aerial photograph coverage are not available. This information 

shall be filed with the Secretary prior to pipeline construction (EIS section 4.1). 

30. Prior to pipeline construction, Pacific Connector shall file with the Secretary, for 

review and approval of the Director of OEP, measures that would be implemented to 

mitigate impacts associated with stream scour or migration at the pipeline crossings of 

Indian Creek, West Fork Trail Creek, and North Fork Butte Creek (EIS section 4.1). 

31. Prior to pipeline construction, Pacific Connector shall file with the Secretary the blast 

plan and vibration and stress analysis for the Heppsie Mountain Quarry, and the 

comments of the BLM on the plan and analyses (EIS section 4.1). 

32. Pacific Connector shall 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 

shall be filed with the Secretary prior to construction of the pipeline (EIS section 4.3). 

33. Pacific Connector shall 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 shall file with the Secretary 
5-35 5.0 – Conclusions and Recommendations 

documentation of this consultation and a description of any site-specific measures that 

would be implemented to reduce impacts on the Brunschmid Wetland Reserve (EIS 

section 4.3). 

34. Prior to pipeline construction, Pacific Connector shall file its final Habitat Mitigation 

Plan with the Secretary, for review and approval of the Director of OEP (EIS section 4.4). 

35. Prior to pipeline construction, Pacific Connector shall file its Noxious Weeds, Soil 

Pests, and Forest Pathogens Control Plan with the Secretary. This plan shall include 

information regarding specific locations and number of wash stations, the source(s) of the 

wash water, how these stations would be operated, how effluent from the wash stations 

would be monitored/treated to prevent seed releases, and plans for station configuration 

and decommissioning. Pacific Connector shall place vehicle and equipment wash 

stations at various strategic locations such as prior to entering each county, and where 

equipment would be moved from an area that is known to contain noxious or invasive 

weeds. Washing stations shall be at least 0.25 mile from all perennial streams and 

monitored for weeds after construction (EIS section 4.4). 

36. Pacific Connector shall file a final timber extraction plan with the Secretary prior to 

pipeline construction (EIS section 4.4). 

37. Prior to pipeline construction, Pacific Connector shall file a plan with the Secretary, for 

the review and approval of the Director of OEP, that details how it would protect live 

trees within UCSAs (EIS section 4.4). 

38. All nest boxes installed to replace natural cavities removed during construction shall have 

entrance holes no larger than 1.25 inches in diameter and no external perches. To 

measure the effectiveness of the next boxes in attracting native cavity nesters, Pacific 

Connector shall monitor activity at the nest boxes for one year after pipeline 

construction, and file with the Secretary a report detailing the number, location, and 

species use of the nest boxes (EIS section 4.5). 

39. Pacific Connector, in consultation with appropriate resource agencies, shall develop a 

project-specific Aquatic Species Nuisance Prevention Plan, based on the Oregon Aquatic 

Nuisance Species Management Plan. This plan shall address movement of equipment 

and hydrostatic test water between U.S. Geological Survey hydrologic basins crossed by 

the proposed pipeline. The plan shall be specific on methods to be used to ensure species 

such as Quagga mussels, zebra mussels, New Zealand mud snails, Chytrid fungus, and 

other species would be prevented from both entering waterbodies in the pipeline project 

area and being transferred between waterbodies. The plan shall incorporate appropriate 

prevention methods from the BOR (2008) Draft Dreissenid Monitoring Plan. The plan 

shall be filed with the Secretary, together with any consulted agency comments on the 

plan, for review and approval by the Director of OEP, prior to pipeline construction

(EIS section 4.5). 

40. In consultation with appropriate resource agencies, Pacific Connector shall develop a 

stream habitat mitigation plan for placement of LWD or other stream improvements at 

each waterbody crossing where mitigation is proposed. The plan shall include details of 

when, where, and what structures (e.g., LWD) would be placed in streams, and/or 

describe the process for making those decisions in the field. The plan, together with any 

consulted agency comments on the plan, shall be filed with the Secretary prior to 
5-36 5.0 – Conclusions and Recommendations 

pipeline construction, for review and approval by the Directory of OEP (EIS section 

4.5). 

41. Prior to crossing any stream where gravel or cobbles would not be used to backfill, 

Pacific Connector shall file information on the stream sediment type at the crossing 

location, a characterization of sediments immediately downstream from the crossing, and 

the fill that would be used. The site-specific requests to not use gravel of cobbles for 

backfill at applicable stream crossings shall be filed with the Secretary, for review and 

approval by the Director of OEP (EIS section 4.6). 

42. Pacific Connector, in consultation with appropriate resource agencies, shall develop a 

salvage plan outlining procedures that would be followed to capture any federally-listed 

sucker species during stream crossings. The final salvage plan, including documentation 

of agency review, shall be filed with the Secretary prior to pipeline construction for 

review and approval by the Director of OEP (EIS section 4.6). 

43. Pacific Connector shall confirm the presence or absence of vernal pool fairy shrimp at all 

pipe storage yards containing potential habitat. For yards that contain the species, Pacific 

Connector shall file with the Secretary, for the review and approval of the Director of 

OEP, a plan to avoid both direct and indirect impacts on vernal pool fairy shrimp habitat, 

prior to use of the yards (EIS section 4.6). 

44. Prior to pipeline construction in any area that was not previously surveyed, Pacific 

Connector shall file with the Secretary, for review and approval by the Director of OEP, a 

Plant Conservation Plan, developed in consultation with the FWS and ODA, which 

outlines avoidance and minimization measures, propagation, restoration, and other 

compensatory mitigation measures for federally-listed plant species that may be affected 

(EIS section 4.6). 

45. Prior to any activity within 0.25 mile of the bald eagle nest at about MP 69, Pacific 

Connector shall conduct a survey to determine if the nest is occupied, and file a report of 

the survey results with the Secretary. If the nest is active, no construction activities shall 

take place during the breeding season, January 1 to August 31, within 0.25 mile of the 

nest (EIS section 4.6). 

46. Prior to pipeline construction, Pacific Connector shall file with the Secretary, for the 

review and written approval of the Director of OEP: 

a. the results of a civil survey of the entire pipeline route that identifies all residences 

and commercial structures within 50 feet of the construction right-of-way; 

b. a plan outlining measures that should be implemented to mitigate pipeline 

construction impacts on domestic water supply systems and septic systems; and 

c. for any residence closer than 25 feet to the construction work area, a site-specific 

plan that includes: 

(1). a description of construction techniques to be used (such as reduced pipeline 

separation, centerline adjustment, use of stove-pipe or drag-section 

techniques, working over existing pipelines, pipeline crossover, bore, etc.), 

and a dimensioned site plan that shows: 
5-37 5.0 – Conclusions and Recommendations 

i. the location of the residence in relation to the pipeline; 

ii. the edge of the construction work area; 

iii. the edge of the new permanent right-of-way; and 

iv. other nearby residences, structures, roads, or waterbodies. 

(2). a description of how Pacific Connector would ensure the trench is not 

excavated until the pipe is ready for installation and the trench is backfilled 

immediately after pipe installation; and 

(3). evidence of landowner concurrence if the construction work area and fencing 

would be located within 10 feet of a residence (EIS section 4.7). 

47. Pacific Connector shall develop a plan to minimize impacts on recreational and other 

boaters using Haynes Inlet during pipeline construction. The plan shall include specific 

measures to minimize impact on users of the boat ramp along North Bay Drive, and users 

of the Haynes Inlet Water Trail crossed by the proposed pipeline at MP 3.9. Pacific 

Connector shall file the plan with the Secretary, for the review and approval of the 

Director of OEP, prior to pipeline construction in Coos Bay (EIS section 4.7). 

48. Pacific Connector shall continue to consult with the BLM as necessary to ensure that 

appropriate site-specific mitigation measures are included in the POD, including 

revegetation, to reduce or mitigate impacts on the Upper Rock Creek ACEC. The results 

of these consultations shall be filed with the Secretary (EIS section 4.7). 

49. Pacific Connector shall continue to consult with the BLM and USFS as necessary to 

develop visual resource protection design and mitigation measures that would be 

included in the POD for construction and operation of the proposed facilities on federally 

managed lands. Pacific Connector shall file with the Secretary the Final Aesthetics 

Management Plan (EIS section 4.7). 

50. Prior to pipeline construction, Pacific Connector shall consult with ODOT and counties 

crossed by the pipeline regarding its December 2008 Transportation Plan for Non-Federal 

Lands, and file with the Secretary any comments from consulted agencies on its plan 

(EIS section 4.9).

51. Prior to submittal of the POD, Pacific Connector shall identify the construction access 

roads on, or leading to federal lands where federal and private parties hold existing costshare agreements, permits, and/or right-of-way grants, and provide a list of these parties, 

and the respective road and federal land management unit affected to the USFS, BLM, 

and BOR, and file these data with the Secretary (EIS section 4.9). 

52. Pacific Connector shall make all reasonable efforts to ensure its predicted noise levels 

from the Butte Falls Compressor Station are not exceeded at NSAs, and file noise surveys 

showing this with the Secretary no later than 60 days after placing the compressor 

station in service. If the noise attributable to the operation of the compressor station 

exceeds an Ldn of 55 dBA at any NSA, Pacific Connector shall file with the Secretary a 

report on what changes are needed and shall install additional noise controls 
5-38 5.0 – Conclusions and Recommendations 

within 1 year of the in-service date. Pacific Connector shall confirm compliance with 

these requirements by filing a second noise survey with the Secretary no later than 60 

days after it installs the additional noise controls (EIS section 4.11). 

53. Pacific Connector shall file the results of noise surveys at each meter station with the 

Secretary no later than 60 days after placing the metering stations/interconnects in 

service. If the noise attributable to the operation of any metering station/interconnect 

exceeds 55 dBA Ldn at an NSA, Pacific Connector shall file with the Secretary a report 

on what changes are needed and should install additional noise controls to meet the level 

within 1 year of the in-service date. Pacific Connector shall confirm compliance with 

these requirements by filing a second noise survey with the Secretary no later than 60 

days after it installs the additional noise controls (EIS section 4.11). 

Recommendation 54 shall apply to Jordan Cove’s terminal design and construction details. 

Information pertaining to this recommendation shall be filed with the Secretary for review 

and approval by the Director of OEP either: prior to initial site preparation; prior to 

commencing final design; prior to construction; or prior to commissioning as indicated by 

each specific subsection of the recommendation. All detailed design documents (drawings, 

calculations, specifications, etc.) and design submittals shall satisfy the requirements of 

Section 4, Part II of the FERC’s draft “Seismic Design Guidelines and Data Submittal 

Requirements for LNG Facilities,” January 2007 (FERC Seismic Guidelines). 

54. In consideration that the LNG terminal design is currently at the FEED stage, Jordan 

Cove shall implement the following prior to construction: 

a. Final seismic specifications to be used in conjunction with the procuring Category I, 

II, and III equipment as described in section 3.10 of Part II of the Commission’s 

Draft Seismic Design Guidelines and Data Submittal Requirements for LNG 

Facilities (FERC Seismic Guidelines) shall be submitted for review prior to 

commencing final design. The final seismic specifications shall satisfy Part I of 

the FERC Seismic Guidelines. 

b. Final Quality Control and Assurance procedures as described in section 3.11 of Part 

II of the FERC Seismic Guidelines that would be used for design and construction 

shall be submitted for review prior to commencing final design of the LNG 

terminal. The Final Quality Control and Assurance procedures shall satisfy Part I 

of the FERC Seismic Guidelines. 

c. A final list of Seismic Category assignments for all structures, systems and 

components shall be submitted for review prior to commencing final design as 

described in section 3.6 of Part II of the FERC Seismic Guidelines. The final 

classification definitions and assignments shall satisfy Part I of the FERC Seismic 

Guidelines. 

d. Final Seismic Design Criteria shall be provided for all Seismic Design Category I, 

II, and III structures, systems, and components as described in section 3.7 of Part II 

of the FERC Seismic Guidelines prior to commencing final design. The Final 

Seismic Design Criteria shall satisfy Part I of the FERC Seismic Guidelines. 
5-39 5.0 – Conclusions and Recommendations 

e. LNG Tank and Foundation Design shall comply with Part I of the FERC Seismic 

Guidelines. Submittals that demonstrate compliance shall be provided prior to 

commencing final design. 

f. The Seismic Isolation system for the LNG tanks shall comply with the design, 

analysis and testing requirements of Chapter 17 of ASCE 7-05 and the additional 

requirements below. Peer Review of the design shall be performed as required by 

Chapter 17. Submittals that demonstrate compliance shall be provided prior to 

commencing final design. 

(1) Non-linear response history analysis shall be performed of the LNG tank 

and isolation system. The analysis shall simultaneously include all three 

components of ground motion. The response spectra of the time history 

vertical component of motion shall envelope the site specific vertical 

design response spectra developed for the project. 

(2) The non-linear analyses will be performed for both maximum and 

minimum design liquid levels of the LNG tanks. 

(3) Separate non-linear analysis will be performed to account for variations of 

design stiffness, minimum values of friction and other properties as 

required by Sections 17.5 and 17.2.4.1 of ASCE 7-05. 

(4) The Lateral Displacement Capacity of the Seismic Isolation Bearings shall 

not be taken as less than 24 inches. 

g. Potential zones of liquefaction at the terminal site shall be mitigated. Details of the 

liquefaction mitigation method(s), procedures, plan extent, and verification methods 

proposed to verify mitigation of liquefaction potential shall be provided prior to 

commencing final design. 

h. Where necessary, detailed calculations of seismic slope stability and lateral 

movements anticipated after the liquefaction mitigation is implemented shall be 

provided prior to commencing final design to verify the stability of critical 

structures for the Project LNG terminal design earthquake motions. 

i. Final foundation design recommendations including foundation design and/or 

liquefaction mitigation measures for all other structures shall be submitted for 

review and approval prior to construction. Final foundation design 

recommendations shall satisfy Part I of the FERC Seismic Guidelines. 

j. The results of the hydrostatic load tests on the LNG storage tanks, including 

settlement data as described in section 7.4.1 shall be provided prior to 

commissioning (EIS section 4.12). 

The following measures shall apply to the Jordan Cove LNG terminal. Information 

pertaining to these specific recommendations shall be filed with the Secretary for review 

and written approval by the Director of OEP either prior to initial site preparation; prior 

to construction of final design; prior to commissioning; or prior to commencement of 

service, as indicated by each specific condition. Specific engineering, vulnerability, or 

detailed design information meeting the criteria specified in Order No. 683 (Docket No. 

RM06-24-000), including security information, shall be submitted as critical energy 

infrastructure information (CEII) pursuant to 18 CFR 388.112. See Critical Energy 
5-40 5.0 – Conclusions and Recommendations 

Infrastructure Information, Order No. 683, 71 Fed. Reg. 58,273 (October 3, 2006), FERC 

Stats. & Regs. ¶ 31,228 (2006). Information pertaining to items such as offsite emergency 

response; procedures for public notification and evacuation; and construction and 

operating reporting requirements will be subject to public disclosure. All information shall 

be filed a minimum of 30 days before approval to proceed is required. 

55. Prior to initial site preparation, Jordan Cove shall file finalized documentation of the 

easement agreement, which demonstrates that the thermal exclusion zones extending 

beyond the plant property line comply with 49 CFR 193.2007 and 193.2057 (EIS section 

4.12). 

56. Prior to initial site preparation, Jordan Cove shall file finalized documentation of the 

easement agreement, which demonstrates that the vapor dispersion exclusion zones 

extending beyond the plant property line comply with 49 CFR 193.2007 and 193.2059 or 

provide revised modeling which demonstrates the vapor dispersion exclusion zones stay 

within areas under the legal control of Jordan Cove (EIS section 4.12). 

57. Jordan Cove shall examine provisions to minimize any effects from flashing or jetting on 

the downwind dispersion distance of vapor from a release from pressurized piping. 

Measures to be considered may include, but are not limited to: vapor fencing; installation 

of spray shielding; or increasing the distance between leak sources and the plant property 

line. Jordan Cove should file final drawings and specifications for these measures with 

the Secretary prior to initial site preparation for review and written approval by the 

Director of OEP (EIS section 4.12). 

58. Prior to initial site preparation, Jordan Cove shall file with the Secretary, for review 

and approval by the Director of OEP, revised vapor production rate and vapor dispersion 

calculations based on the transient LNG release rate calculated for 10 minutes, including 

technical justification and calculations supporting the release rate curve. At a minimum, 

the technical justification should include the methodology and calculations for: 

a. the determination of depressurization effects; 

b. the determination of spill detection times and associated reliabilities; 

c. the determination of instrumentation response times and associated reliabilities; 

d. the determination of valve closure times and associated reliabilities; 

e. the determination of pump shutdown times and associated reliabilities; and 

f. quantification of the potential for manual overrides and other human factors and 

errors that may interfere with the timely closure of valves and shutdown of the 

pumps. 

Alternatively, Jordan Cove may submit revised vapor production rate and vapor 

dispersion calculations based on a steady-state LNG release rate equal to the initial 

release rate (at t=0) for the 6-inch-diameter LNG recirculation line during unloading for 

10 minutes which demonstrate the one-half LFL envelope stays onsite (EIS section 4.12). 

59. Prior to initial site preparation, Jordan Cove shall file with the Secretary, for review 

and approval by the Director of OEP, step-by-step calculations showing how the vapor 
5-41 5.0 – Conclusions and Recommendations 

production rate from a single trench elemental area over a 10-minute period was 

determined. These calculations shall include the following information: 

a. justification for the change in air temperature from the previous filing of 52°F to 

59°F, and clarification on the discrepancy between the trench wall and floor surface 

temperature of 52°F with the air temperature of 59°F; 

b. justification for the change in trench physical properties from the previous filing; 

c. justification for the longitudinal slope of the trench used to calculate the LNG 

velocity within the trench; 

d. an elevation drawing of the trench illustrating the slope along the entire trench path; 

e. the roughness coefficient used to calculate the LNG velocity within the trench (if 

the roughness coefficient is less than 0.012, provide justification for the selected 

value and include a sensitivity analysis using a roughness coefficient of 0.012; 

f. verification that both trench walls are included in calculating the wetted perimeter; 

and 

g. revised vapor production rate calculations based on an appropriate LNG velocity 

within the trench (EIS section 4.12). 

60. Prior to initial site preparation, Jordan Cove shall file with the Secretary, for review 

and approval by the Director of OEP, revised vapor dispersion simulations which 

include: 

a. Revised design spill and vapor production rates reflective of any changes resulting 

from the previous two recommendations; 

b. a lapse rate reflective of F atmospheric stability; 

c. a water vapor concentration at the inlet of the wind boundary reflective of the 

modeled relative humidity; 

d. properties reflective of the trench wall and floors and surrounding ground for all 

modeled surfaces and obstructions; 

e. a quantitative grid sensitivity analysis, including at least three grid resolutions with 

uniformly decreasing dimensions in all three dimensions (x, y, and z) that supports 

the selection of grid size and demonstrates the convergence of the downwind 

dispersion distances; 

f. simulations that allow the wind profile to reach a steady or quasi-steady state before 

injecting LNG vapor into the domain; 

g. a sensitivity analysis and technical justification that supports the slip factor value 

used to determine the downwind dispersion distances; 

h. technical justification and/or sensitivity analyses that support the selection of the 

lapse rate, ground surface material properties, temperature, humidity, and wind 

profile used to determine the downwind dispersion distances; and 

i. all pertinent input files (*.fds) and output files (*.out) used to determine the 

downwind dispersion distances (EIS section 4.12). 
5-42 5.0 – Conclusions and Recommendations 

61. Prior to initial site preparation, Jordan Cove shall file with the Secretary, for review 

and approval by the Director of OEP, models or drawings that would indicate a low level 

of confinement and congestion (i.e. volume blockage ratio) in the NGL extraction unit 

area or submit calculations indicating that a 1 psi overpressure would not extend offsite 

(EIS section 4.12) 

62. Complete plan drawings and a list of the hazard detection equipment shall be filed prior 

to initial site preparation. The list shall include the instrument tag number, type and 

location, alarm locations, and shutdown functions of the proposed hazard detection 

equipment. Plan drawings shall clearly show the location of all detection equipment (EIS 

section 4.12). 

63. Jordan Cove shall provide a technical review of its proposed facility that: 

a. identifies all combustion/ventilation air intake equipment and the distances to any 

possible hydrocarbon release (LNG, flammable refrigerants, flammable liquids and 

flammable gases); and 

b. demonstrates that these areas are adequately covered by hazard detection devices 

and indicates how these devices would isolate or shutdown any combustion 

equipment whose continued operation could add to or sustain an emergency. 

c. Jordan Cove shall file this review prior to initial site preparation (EIS section 4.12). 

64. Complete plan drawings and a list of the fixed and wheeled dry-chemical, fire 

extinguishing, and other hazard control equipment shall be filed prior to initial site 

preparation. The list shall include the equipment tag number, type, size, equipment 

covered, and automatic and manual remote signals initiating discharge of the units. Plan 

drawings shall clearly show the planned location of all fixed and wheeled extinguishers 

(EIS section 4.12). 

65. Facility plans showing the proposed location of, and area covered by, each monitor, 

hydrant, deluge system, hose, and sprinkler, as well as piping and instrumentation 

diagrams, of the firewater system shall be filed prior to initial site preparation (EIS 

section 4.12). 

66. A copy of the hazard design review and list of recommendations that are to be 

incorporated in the final facility design shall be filed prior to initial site preparation

(EIS section 4.12). 

67. Drawings of the storage tank piping support structure and support of horizontal piping at 

grade shall be filed prior to initial site preparation (EIS section 4.12). 

68. Procedures shall be developed for offsite contractors’ responsibilities, restrictions, and 

limitations and for supervision of these contractors by Jordan Cove staff, prior to initial 

site preparation (EIS section 4.12). 

69. Complete plan drawings of the security fencing and of facility access and egress shall be 

provided prior to initial site preparation (EIS section 4.12). 

70. Jordan Cove shall develop an ERP (including evacuation) and coordinate procedures with 

the Coast Guard; state, county, and local emergency planning groups; fire departments; 
5-43 5.0 – Conclusions and Recommendations 

state and local law enforcement; and appropriate federal agencies. This plan shall include 

at a minimum: 

a. designated contacts with state and local emergency response agencies; 

b. scalable procedures for the prompt notification of appropriate local officials and 

emergency response agencies based on the level and severity of potential incidents; 

c. procedures for notifying residents and recreational users within areas of potential 

hazard; 

d. evacuation routes/methods for residents and other public use areas that are within 

any transient hazard areas along the route of the LNG marine traffic; 

e. locations of permanent sirens and other warning devices; and 

f. an “emergency coordinator” on each LNG vessel to activate sirens and other 

warning devices. 

The ERP shall be filed with the Secretary for review and written approval by the Director 

of OEP prior to initial site preparation. Jordan Cove shall notify the FERC staff of all 

planning meetings in advance and shall report progress on the development of its ERP at 

3-month intervals (EIS section 4.12). 

71. The ERP shall include a Cost-Sharing Plan identifying the mechanisms for funding all 

project-specific security/emergency management costs that will be imposed on state and 

local agencies. In addition to the funding of direct transit-related security/emergency 

management costs, this comprehensive plan shall include funding mechanisms for the 

capital costs associated with any necessary security/emergency management equipment 

and personnel base. The Cost-Sharing Plan shall be filed with the Secretary for review 

and written approval by the Director of OEP prior to initial site preparation (EIS 

section 4.12). 

72. Jordan Cove shall provide information/revisions related to the 20 responses to the 

October 31, 2007 Engineering Information Request, which stated that corrections or 

modifications would be made to the design. The final design shall specifically address 

response numbers 3, 9, 10, 16, 17, 26, 31, 37, 38, 39, 43, 62, 63, 64, 65, 68, 69, 70, 71, 

and 74 using management of change procedures (EIS section 4.12). 

73. The final design shall include the modifications to the minimum flow recycle line, the 

outlet of the blowdown drum, and the manual bypass for each vaporizer as specified in 

Jordan Cove’s December 5, 2008 responses to the draft EIS (EIS section 4.12). 

74. The P&IDs in the final design shall show and number all valves including drain, vent, 

main, and car sealed (EIS section 4.12). 

75. The final design shall specify that piping and equipment that may be cooled with liquid 

nitrogen are designed for liquid nitrogen temperatures, with regard to allowable 

movement and stresses (EIS section 4.12). 

76. The final design shall include a hazard and operability review of the completed design. 

A copy of the review and a list of the recommendations shall be filed (EIS section 4.12). 
5-44 5.0 – Conclusions and Recommendations 

77. The final design shall specify that the LNG tank carbon steel piping support plates and 

connections to piping supports shall be designed to ensure that corrosion protection is 

adequately provided and provisions for corrosion monitoring and maintenance of carbon 

steel attachments are to be included in the design and maintenance procedures (EIS 

section 4.12). 

78. The final design of the tank foundation shall include an inclinometer, instrumented to 

record and display tank settlement, and a minimum of eight permanent reference points, 

equally spaced around the base for elevation survey measurement (EIS section 4.12). 

79. The final design shall include details of the LNG tank tilt settlement and differential 

settlement limits between each LNG tank and its piping, as well as the procedures to be 

implemented in the event that those limits are exceeded (EIS section 4.12). 

80. The final design shall include detailed drawings of the spill control system to be applied 

to the LNG tank roof (EIS section 4.12). 

81. The final design shall include details of the BOG temperature measurement for each tank 

(EIS section 4.12). 

82. The final design shall specify that the first isolation valve at the inlet to the sendout 

pumps shall be a weld end shutoff valve. In the case that flanged valves are specified, the 

sendout system shall be shutdown in the event of a leak (EIS section 4.12). 

83. The final design shall specify that the first isolation valve at the inlet to the deethanizer 

feed pumps shall be a weld end shutoff valve. In the case that flanged valves are 

specified, the deethanizer system shall be shutdown in the event of a leak (EIS section 

4.12). 

84. The final design shall specify that the first isolation valve at the inlet to the NGL product 

pumps shall be a weld end shutoff valve. In the case that flanged valves are specified, the 

NGL system shall be shutdown in the event of a leak (EIS section 4.12). 

85. The final design shall provide provisions to shutdown the sendout pumps in the event 

that the discharge flow falls below the minimum recommended flow specified by the 

manufacturer (EIS section 4.12). 

86. The final design shall specify that dual low low temperature elements and shutdown are 

to be provided at the discharge of the vaporizers (EIS section 4.12). 

87. The final design shall include a pilot relief valve or operated vent valve sized for thermal 

relief at the discharge of each vaporizer, upstream of the isolation valves (EIS section 

4.12). 

88. The final design shall include P&IDs and drawings of the natural gas meter station (EIS 

section 4.12). 

89. The final design shall include P&IDs and drawings of the NGL product meter station 

(EIS section 4.12). 

90. The final design of the vapor return system shall specify that the vapor inlet piping to the 

desuperheater knockout drum, shall be designed to ensure that LNG, from the 

desuperheater and LNG piping discharging to the drum, cannot back flow to the vapor 

return piping (EIS section 4.12). 
5-45 5.0 – Conclusions and Recommendations 

91. The final design shall specify that all drains from high-pressure LNG systems are to be 

equipped with double isolation and bleed valves (EIS section 4.12). 

92. The final design shall include piping specifications that include pressure ratings 

consistent with standard ratings of the flange classes proposed for the facility (EIS 

section 4.12). 

93. The piping specifications for the final design shall specify that the minimum temperature 

for all piping in cryogenic service shall be -325 °F (EIS section 4.12). 

94. The final design shall specify that for LNG and natural gas service, branch piping and 

piping nipples less than 50mm (2 inches), shall be no less than schedule 160 (EIS section 

4.12). 

95. The layout and elevation drawings of the process equipment that are appropriate for the 

proposed operation and maintenance of the facility shall be included in the final design

and filed with the FERC at the time that the EPC contractor issues the drawing for 

review. This milestone shall be included in the project schedule (EIS section 4.12). 

96. The final design shall include provisions for the future installation of an LNG pump for 

the desuperheater knockout drum (EIS section 4.12). 

97. The final design shall include provisions for the future installation of an LNG pump for 

the BOG compressor suction drum (EIS section 4.12). 

98. The final design shall specify that the vapor inlet piping to the BOG compressor suction 

drum shall be designed to ensure that LNG, from the desuperheater and LNG piping 

discharging to the drum, cannot back flow to the vapor return piping (EIS section 4.12). 

99. The final design shall ensure that the LNG spray control valve at the desuperheater, 

upstream of the BOG compressor suction drum and the associated controls are designed 

to prevent operation when boiloff vapor is not flowing through the drum (EIS section 

4.12). 

100. The final design shall include provisions to install temporary high pressure boiloff 

compression in the event that sendout operation is curtailed, or ceased for a period in 

excess of 30 days. Details shall include plans and drawings of the BOG recovery system 

and specifications of the equipment and compressors to be installed (EIS section 4.12). 

101. The final design shall specify that the design pressure of sendout equipment containing 

LNG in low pressure service shall not be less than the design pressure of the piping 

system (EIS section 4.12). 

102. The final design shall specify that LNG relief valves and LNG drains shall not discharge 

into the vapor system (EIS section 4.12). 

103. The final design shall include provisions to control venting of the deethanizer system to 

the flare vent (EIS section 4.12). 

104. The final design of the blow down drum shall include a fail closed shutoff valve in the 

drain line, actuated by low temperature in the drum (EIS section 4.12). 

105. The final design shall provide each LNG pump suction vessel with a pressure relief valve 

(EIS section 4.12). 
5-46 5.0 – Conclusions and Recommendations 

106. The final design shall specify that, in addition to meeting the electrical design and 

installation code requirements for the Class 1 Group D hazardous area classification of 

the LNG pump area, vaporizer LNG inlet and outlet piping areas, the operating and 

maintenance for these areas procedures shall be in accordance with Class 1 Group D, 

Division 1. (EIS section 4.12). 

107. The final design shall include details of the air gaps to be installed downstream of all 

seals or isolations installed at the interface between a flammable fluid system and an 

electrical conduit or wiring system. Each air gap shall vent to a safe location and be 

equipped with a leak detection device that shall continuously monitor for the presence of 

a flammable fluid; shall alarm the hazardous condition; and shall shut down the 

appropriate systems (EIS section 4.12). 

108. The final design of the hazard detection equipment shall identify manufacturer and 

model (EIS section 4.12). 

109. The final design shall specify that all hazard detection equipment shall include 

redundancy and fault detection as well as fault alarm monitoring in all potentially 

hazardous areas and enclosures (EIS section 4.12). 

110. The final design of the fixed and wheeled dry-chemical, fire extinguishing and high 

expansion foam hazard control equipment shall identify manufacturer and model. 

111. The final design shall include an updated fire protection evaluation carried out in 

accordance with the requirements of NFPA 59A 2001, chapter 9.1.2 (EIS section 4.12). 

112. The final design of the firewater system shall include provisions to measure and record 

the discharge flow and pressure from each of the firewater pumps (EIS section 4.12). 

113. The final design shall include emergency shutdown of equipment and systems activated 

by hazard detection devices for flammable gas, fire, and cryogenic spills, when 

applicable (EIS section 4.12). 

114. The final design shall include details of the shut down logic, including cause and effect 

matrices for alarms and shutdowns (EIS section 4.12). 

115. The final design shall specify that all ESD valves are to be equipped with open and 

closed position switches connected to the DCS/SIS (EIS section 4.12). 

116. The final design of the BOG compressor shelter/building shall provide permanent 

protection of the equipment and operating and maintenance personnel from adverse 

weather conditions. The design details and procedures to record and to prevent the tank 

fill rate from exceeding the maximum fill rate specified by the tank designer shall be filed 

prior to commissioning (EIS section 4.12). 

117. The maintenance procedures to be filed prior to commissioning shall state that a 

foundation elevation survey of all LNG tanks shall be made on an annual basis (EIS 

section 4.12). 

118. All valves including drain, vent, main, and car sealed, or locked valves shall be tagged in 

the field during construction and prior to commissioning (EIS section 4.12). 

119. A tabulated list of the proposed hand-held fire extinguishers shall be filed prior to 

commissioning. The information shall include a list with the equipment number, type, 
5-47 5.0 – Conclusions and Recommendations 

size, number, and location. Plan drawings shall include the type, size, and number of all 

hand-held fire extinguishers (EIS section 4.12). 

120. Operation and maintenance procedures and manuals, as well as safety procedure 

manuals, shall be filed prior to commissioning (EIS section 4.12). 

121. The contingency plan for failure of the LNG tank outer containment shall be filed prior 

to commissioning (EIS section 4.12). 

122. A copy of the criteria for horizontal and rotational movement of the inner LNG storage 

tank for use during and after cooldown shall be filed prior to commissioning (EIS 

section 4.12). 

123. The FERC staff shall be notified of any proposed revisions to the security plan and 

physical security of the facility prior to commencement of service (EIS section 4.12). 

124. Until commencement of service, Jordan Cove shall annually review its WSA relating to 

LNG marine traffic for the project; update the assessment to reflect changing conditions 

which may impact the suitability of the waterway for LNG marine traffic; provide the 

updated assessment to the cognizant COTP/FMSC for review and validation and if 

appropriate, further action by the COTP/FMSC relating to LNG marine traffic; and 

provide a copy to FERC staff (EIS section 4.12). 

125. Progress on construction of the project shall be filed in monthly reports. Details shall 

include a summary of activities, projected schedule for completion, problems 

encountered and remedial actions taken. Problems of significant magnitude shall be 

reported to the FERC within 24 hours (EIS section 4.12). 

In addition, we recommend that the following measures shall apply throughout the life of 

the LNG facility: 

126. The facility shall be subject to regular FERC staff technical reviews and site inspections 

on at least an annual basis or more frequently as circumstances indicate. Prior to each 

FERC staff technical review and site inspection, Jordan Cove shall respond to a specific 

data request including information relating to possible design and operating conditions 

that may have been imposed by other agencies or organizations. Up-to-date detailed 

piping and instrumentation diagrams reflecting facility modifications and provision of 

other pertinent information not included in the semi-annual reports described below, 

including facility events that have taken place since the previously submitted semi-annual 

report, shall be included (EIS section 4.12). 

127. Semi-annual operational reports shall be filed with the Secretary to identify changes in 

facility design and operating conditions, abnormal operating experiences, activities 

(including LNG carrier arrivals, quantity and composition of imported LNG, vaporization 

quantities, boil-off/flash gas, etc.), plant modifications including future plans and 

progress thereof. Abnormalities shall include, but not be limited to: unloading/carrier 

problems, potential hazardous conditions from offsite vessels, storage tank stratification 

or rollover, geysering, storage tank pressure excursions, cold spots on the storage tanks, 

storage tank vibrations and/or vibrations in associated cryogenic piping, storage tank 

settlement, significant equipment or instrumentation malfunctions or failures, nonscheduled maintenance or repair (and reasons therefore), relative movement of storage 
5-48 5.0 – Conclusions and Recommendations 

tank inner vessels, vapor or liquid releases, fires involving natural gas and/or from other 

sources, negative pressure (vacuum) within a storage tank, and higher than predicted 

boiloff rates. Adverse weather conditions and the effect on the facility shall also be 

reported. Reports shall be submitted within 45 days after each period ending June 30 

and December 31. In addition to the above items, a section entitled "Significant plant 

modifications proposed for the next 12 months (dates)" shall also be included in the semiannual operational reports. Such information will provide the FERC staff with early 

notice of anticipated future construction/maintenance projects at the LNG facility (EIS 

section 4.12). 

128. In the event the temperature of any region of any secondary containment becomes less 

than the minimum specified operating temperature for the material, the Commission shall 

be notified within 24 hours and procedures for corrective action shall be specified (EIS 

section 4.12). 

129. Significant non-scheduled events, including safety-related incidents (i.e., LNG or natural 

gas releases, fires, explosions, mechanical failures, unusual overpressurization, and major 

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

shall be reported to FERC staff. In the event an abnormality is of significant magnitude 

to threaten public or employee safety, cause significant property damage, or interrupt 

service, notification shall be made immediately, without unduly interfering with any 

necessary or appropriate emergency repair, alarm, or other emergency procedure. In all 

instances, notification shall be made to Commission staff within 24 hours. This 

notification practice shall be incorporated into the LNG facility's emergency plan. 

Examples of reportable LNG-related incidents include: 

a. fire; 

b. explosion; 

c. estimated property damage of $50,000 or more; 

d. death or personal injury necessitating in-patient hospitalization; 

e. free flow of LNG that results in pooling; 

f. unintended movement or abnormal loading by environmental causes, such as an 

earthquake, landslide, or flood, that impairs the serviceability, structural integrity, or 

reliability of an LNG facility that contains, controls, or processes gas or LNG; 

g. any crack or other material defect that impairs the structural integrity or reliability of 

an LNG facility that contains, controls, or processes gas or LNG; 

h. any malfunction or operating error that causes the pressure of a pipeline or LNG 

facility that contains or processes gas or LNG to rise above its maximum allowable 

operating pressure (or working pressure for LNG facilities) plus the buildup allowed 

for operation of pressure limiting or control devices; 

i. a leak in an LNG facility that contains or processes gas or LNG that constitutes an 

emergency; 

j. inner tank leakage, ineffective insulation, or frost heave that impairs the structural 

integrity of an LNG storage tank; 
5-49 5.0 – Conclusions and Recommendations 

k. any condition that could lead to a hazard and cause a 20 percent reduction in 

operating pressure or shutdown of operation of a pipeline or an LNG facility; 

l. safety-related incidents to LNG carriers at or en route to and from the LNG facility; 

or 

m. an event that is significant in the judgment of the operator and/or management even 

though it did not meet the above criteria or the guidelines set forth in an LNG 

facility’s incident management plan. 

In the event of an incident, the Director of OEP has delegated authority to take whatever 

steps are necessary to ensure operational reliability and to protect human life, health, 

property or the environment, including authority to direct the LNG facility to cease 

operations. Following the initial company notification, Commission staff will determine 

the need for an on-site inspection by Commission staff, and the timing of an initial 

incident report (normally within 10 days) and follow-up reports (EIS section 4.12). 

130. Throughout the life of the facility, Jordan Cove shall ensure that the facility and any 

LNG carrier transiting to and from the facility comply with all requirements set forth by 

the Coast Guard COTP Sector Portland, including all risk mitigation measures 

recommended in the WSR (EIS section 4.12).