Southeast
Regional
Office
9721
Executive
Center
Drive
N.
St.
Petersburg,
Florida
33702
February
23,
2004
Magalie
R.
Salas,
Secretary
Federal
Energy
Regulatory
Commission
888
First
Street,
N.
E.,
Room
1A
Washington,
D.
C.
20426
Dear
Secretary
Salas:

The
National
Marine
Fisheries
Service
(
NOAA
Fisheries)
has
reviewed
the
"
NOTICE
OF
ENVIRONMENTAL
REVIEW
AND
SCOPING
FOR
THE
GOLDEN
PASS
LNG
TERMINAL
AND
PIPELINE
PROJECT
AND
REQUEST
FOR
COMMENTS
ON
ENVIRONMENTAL
ISSUES"
(
Docket
No.
PF04­
1­
000)
dated
January
23,
2004.
Golden
Pass
LNG
Terminal
LP
and
Golden
Pass
Pipeline
LP,
both
affiliates
of
ExxonMobil
Corporation
(
ExxonMobil)
propose
to
construct
a
liquefied
natural
gas
(
LNG)
receiving
terminal,
regasification
facility,
and
associated
pipeline
near
Sabine
Pass,
Texas.
ExxonMobil
proposes
to
use
approximately
100
million
gallons
of
seawater
per
day
(
mgd)
as
a
heating
medium
in
an
open
rack
vaporizing
system
for
LNG
regasification.
The
seawater
intake
will
be
located
at
the
head
of
the
berth
area
for
the
LNG
tanker
ships.
An
aquatic
filter
barrier
system
engineered
by
Gunderboom
would
be
placed
as
a
curtain
in
front
of
the
intake
in
an
attempt
to
exclude
eggs
and
larval
fish
from
entrainment
in
the
heating
water
intake.

The
proposed
project
site
includes
and
is
adjacent
to
areas
identified
as
essential
fish
habitat
(
EFH)
for
postlarval,
juvenile,
and
adult
red
drum
(
Sciaenops
ocellatus),
adult
and
subadult
Spanish
mackerel
(
Scomberomorus
maculatus),
and
juvenile
and
subadult
white
(
Litopenaeus
setiferus)
and
brown
shrimp
(
Farfantepenaeus
aztecus).
The
estuarine
water
column,
unvegetated
benthic
habitats,
and
intertidal
wetlands
are
categories
of
EFH
that
could
be
impacted
by
the
proposed
project.
The
designations
by
the
Gulf
of
Mexico
Fishery
Management
Council
(
GMFMC)
in
its
EFH
amendment,
as
approved
by
NOAA
Fisheries,
were
specified
consistent
with
the
requirements
of
the
Magnuson­
Stevens
Fishery
Conservation
and
Management
Act
(
Magnuson­
Stevens
Act)
(
P.
L.
104­
297)
and
implementing
regulations.
As
the
proposed
facilities
would
have
an
adverse
impact
on
EFH
and
associated
managed
species,
Federal
Energy
Regulatory
Commission
(
FERC)
will
be
required
to
consult
with
NOAA
Fisheries
prior
to
any
final
federal
action
on
the
proposed
LNG
project.
The
GMFMC
also
is
provided
an
opportunity
for
comment
on
EFH­
related
issues
under
provisions
of
the
Magnuson­
Stevens
Act.

NOAA
Fisheries
is
very
concerned
that
ExxonMobil
proposes
to
construct
this
facility
in
an
estuarine
tidal
pass.
It
has
been
estimated
that
approximately
95
percent
of
all
Gulf
coast
fishery
landings
are
of
estuarine
dependent
species
(
U.
S.
EPA,
1999).
Natural
mortality
of
fish
eggs
and
larvae
is
already
high,
and
stock
success
can
depend
on
survival
and
transport
of
relatively
few
recruits
to
their
estuarine
nursery
habitats
(
Houde
1987,
1989).
NOAA
Fisheries
views
mortality
caused
by
the
proposed
LNG
facility
as
a
significant
additional
mortality
factor
to
the
natural
conditions
that
affect
the
sustainability
of
these
fisheries.
If
it
is
determined
that
the
proposed
LNG
facility
kills
the
few
recruits
destined
for
survival,
the
facility
may
have
a
dramatic
negative
effect
on
economically
important
fish
stocks.
Information
which
should
be
provided
to
complete
a
traditional
stock
assessment
to
determine
impacts
from
impingement
and
entrainment
includes:

a)
Numbers
of
eggs,
larvae,
and
juveniles
that
are
expected
to
be
entrained
or
impinged
(
and
killed)
by
species.

b)
Daily
natural
mortality
estimates
by
life
stage
during
the
first
year
of
life
by
species,
including
hatching
success.
This
allows
an
estimation
of
survival
from
viable
egg
to
age
of
entrainment.

c)
Age­
structured
population
model
(
e.
g.,
VPA
or
forward­
projection
model)
estimates
of
recruits
to
age­
1
and
population
fecundity
(
need
maturity
schedule
and
fecundity
relationship).
This
allows
stock­
level
estimates
of
egg
production
(
viable
eggs)
and
overall
survival
from
viable
egg
to
recruitment
at
age­
1.

In
addition
to
direct
fish
and
crustacean
impacts,
all
zooplankton
passing
through
the
proposed
LNG
facility
are
likely
to
be
killed.
Zooplankton
are
microscopic
drifting
animals
that
are
important
components
of
the
marine
and
estuarine
food
webs,
consuming
phytoplankton
and
smaller
zooplankton
and
providing
food
for
higher
level
predators,
such
as
larvae
of
fish
and
crustaceans.
A
rough
estimate
from
Minello
(
1980)
indicates
that
average
annual
densities
of
larger
zooplankton
(
mostly
copepods)
are
around
2000
per
m3
in
coastal
waters
off
Texas
and
Louisiana.
Therefore,
the
environmental
impact
statement
should
provide
and
evaluate
information
on
zooplankton
mortality
from
the
proposed
LNG
facility.

NOAA
Fisheries
also
questions
whether
the
Gunderboom
Marine
Life
Exclusion
System
©
will
adequately
address
the
potential
problem
of
impingement
and
entrainment
of
larval
fish
and
eggs.
From
internet
searches,
it
appears
that
this
technology
has
been
used
mainly
in
riverine
systems
and
is
unproven
in
eutrophic
and
often
turbid
estuarine
systems
such
as
those
found
on
the
Gulf
coast.
Studies
conducted
by
P.
A.
Henderson
et
al.
(
2001)
found
that
the
Gunderboom
systems
became
bio­
fouled
very
quickly
and
resulted
in
organisms
becoming
impinged
on
the
curtain.
The
air
jets
were
found
to
injure
impinged
organisms
and
actually
increased
the
amount
of
colonization
by
other
organisms
within
the
curtain's
mesh.
Seaby
et
al.
(
2002)
concluded
that
fouling
was
likely
to
cause
a
failure
of
the
system
and
result
in
entrainment
of
organisms.
Fouling
may
be
even
greater
in
the
Gulf
estuaries
such
as
Sabine
Lake.
Even
if
a
small
mesh
size
were
used
and
filtration
efficiency
could
be
maintained
(
i.
e.,
no
clogging),
planktonic
eggs
and
larvae
would
be
impinged
on
the
mesh
surface
and
likely
suffer
mortality
due
to
predation,
starvation,
or
physical
damage.
Aggregating
predators
are
likely
to
feed
upon
impinged
organisms,
and
air
burst
cleaning
may
damage
any
survivors.
Therefore,
to
allow
an
adequate
evaluation
of
alternative
screening
devices,
ExxonMobil
or
FERC
should
conduct
a
scientifically
based
demonstration
project
in
the
Sabine
Pass
area
to
test
the
efficacy
of
the
proposed
Gunderboom
system.
Any
such
demonstration
design
first
should
be
reviewed
and
approved
by
the
NOAA
Fisheries
Southeast
Science
Center.

We
also
are
concerned
that
the
proposed
LNG
facility
would
add
significantly
to
the
cumulative
loss
of
living
marine
resources
from
existing
once
through
seawater
cooling
systems.
For
example,
Palafox
and
Wolford
(
1993)
conducted
a
study
to
gauge
the
relative
importance
of
impingement
from
five
power
plants
in
Galveston
Bay,
Texas,
on
commercially
and
recreationally
important
species.
They
reported
that
from
1978­
1979,
the
time
period
with
the
most
extensive
data
set,
the
weight
of
impinged
shrimp
and
crabs
on
power
plant
intake
screens
was
nearly
11
and
17
percent
respectively
of
the
commercial
bay
landings.
Impingement
of
red
drum,
sand
seatrout
(
Cynoscion
arenarius)
and
spotted
seatrout
also
accounted
for
almost
three
percent
of
the
recreational
landings.
The
Environmental
Protection
Agency
(
EPA)
also
conducted
several
case
study
analyses
of
the
impact
of
cooling
water
intakes
for
power
plants
on
fisheries
as
part
of
their
proposed
Section
316(
b)
Phase
II
Existing
Facilities
rulemaking
process.
In
their
study
of
Tampa
Bay,
Florida,
the
only
Gulf
coast
estuary
studied,
EPA
found
that
the
economic
impacts
from
entrainment
and
impingement
ranged
between
$
20.39
million
to
$
21.75
million
dollars
annually
in
year
2000
dollars
(
EPA
2002).
To
adequately
address
such
issues,
the
FERC
should
undertake
a
detailed
cumulative
impacts
assessment
of
the
proposed
project
which
takes
into
account
project
impacts
in
conjunction
with
past,
present
and
reasonably
foreseeable
future
projects,
as
required
by
the
National
Environmental
Policy
Act
(
NEPA).

The
FERC
also
should
provide
a
detailed
alternatives
analysis,
as
required
by
NEPA,
of
regasification
systems.
Alternative
systems
are
proposed
for
use
at
other
LNG
facilities
which
we
believe
avoid
and
minimize
impacts
to
EFH
and
associated
managed
species.
It
is
noteworthy
that
a
closed
loop
system
utilizing
a
water/
glycol
solution
and
a
natural
gas
boiler
to
vaporize
LNG
is
proposed
for
use
at
the
Sabine
Pass
facility
during
the
late
fall
to
late
winter
months
when
seawater
temperatures
are
not
suitable
for
efficient
regasification.
Since
the
system
would
already
be
in
place,
one
alternative
would
be
to
run
the
closed
loop
system
year
round
and
not
construct
the
once
through
seawater
system.
We
believe
this
technology
should
be
considered
a
best
available
technology.

EPA
is
considering
revising
the
Clean
Water
Act
Section
316(
b)
regulations
concerning
entrainment
and
impingement
impacts
from
once­
through
water
systems.
Although
EPA
has
not
made
a
decision
whether
LNG
facilities
will
be
covered
under
the
proposed
Phase
III
Regulations,
we
believe
that
the
FERC
should
hold
new
LNG
facilities
to
the
same
standards
as
new
power
plants,
since
the
impacts
on
fisheries
from
the
once­
through
seawater
systems
with
similar
intake
volumes
would
be
the
same.
Therefore,
we
believe
that
the
Tract
I
standards
set
in
section
125.84
(
b)(
1)
of
the
Section
316(
b)
Phase
I
Regulations
for
new
electric
generation
facilities
that
withdraw
greater
than
10
mgd
should
be
the
required
standard
for
this
LNG
facility.
The
cited
standard
requires
that
intake
flows,
at
a
minimum,
be
reduced
to
a
level
commensurate
with
that
which
can
be
attained
by
a
closed
cycle
recirculating
cooling
water
system.

We
are
also
concerned
about
the
potential
impacts
of
the
proposed
pipeline
construction.
Installation
of
pipelines
and
other
transmission
lines
by
current
trenching
and
push/
pull
methods
historically
has
caused
significant
emergent
marsh
loss
in
coastal
environments.
Both
documented
and
undocumented
evidence
demonstrates
that
restoration
of
temporary
pipeline
work
corridors
to
pre­
project
conditions
is
often
unsuccessful,
that
restoration
requirements
are
not
being
enforced
and
that
permanent
wetlands
impacts
are
occurring.
A
review
of
aerial
photography
of
the
upper
Texas
Coast
along
pipeline
corridors
clearly
depicts
extensive
permanent
marsh
loss
for
permitted
pipelines,
although
the
amount
of
marsh
loss
is
largely
undocumented
and
unmitigated.

To
address
pipeline
impacts,
we
recommend
that
the
FERC
consider
the
following
issues
during
its
evaluation
of
mitigation
needs
for
the
proposed
pipeline
construction
in
EFH:

a)
The
need
for
pre­
construction
surveys
and
aerial
photography
of
pipeline
rights­
of­
way
in
wetlands
to
determine
pre­
project
contours,
elevations,
vegetation
types
and
vegetative
cover.

b)
The
need
for
post­
construction
pipeline
surveys
using
aerial
photography
and
other
techniques,
which
would
include
all
vehicle
tracks
both
inside
and
outside
the
identified
work
corridor.
The
surveys
should
be
designed
to
evaluate
restoration
success,
remedial
measures
and
mitigation
needs.

Finally,
the
project
area
may
be
within
the
known
distribution
limits
of
federally
listed
threatened
species
that
are
under
purview
of
NOAA
Fisheries.
In
accordance
with
the
Endangered
Species
Act
of
1973,
as
amended,
it
is
the
responsibility
of
FERC
to
identify
actions
that
may
affect
endangered
or
threatened
species
or
their
habitat.
Determinations
involving
species
under
NOAA
Fisheries'
jurisdiction
should
be
reported
to
our
Protected
Resources
Division
(
PRD)
at
the
letterhead
address.
If
it
is
determined
that
the
activities
may
adversely
affect
any
species
listed
as
endangered
or
threatened
and
under
PRD
purview,
then
formal
consultation
must
be
initiated.

Thank
you
for
the
opportunity
to
provide
comments
on
environmental
issues
concerning
the
proposed
permitting
of
the
Golden
Pass
LNG
Terminal
and
Pipeline.
While
we
strongly
urge
FERC
to
require
the
use
of
a
closed
loop
heating
system
on
a
year
round
basis,
we
are
including
a
list
of
scoping
information
needs,
in
addition
to
the
preceding,
to
allow
a
full
assessment
of
the
impacts
of
the
project
as
currently
proposed.
If
we
may
be
of
further
assistance,
please
contact
Mr.
Rusty
Swafford
in
our
Galveston,
Texas,
facility
at
(
409)
766­
3699.
For
information
concerning
threatened
and
endangered
species
please
contact
Mr.
David
Bernhart
of
our
PRD
at
(
727)
570­
5312.

Sincerely,

Miles
M.
Croom
Assistant
Regional
Administrator
Habitat
Conservation
Division
cc:
PRD
SER
42
SER
43
SER
44
SEFSC­
Minello
Enclosure
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b)
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Galveston
District.
Permit
20376
to
Liquid
Carbonics
monitoring
report.

U.
S.
Department
of
the
Army
Corps
of
Engineers,
Galveston
District.
Permit
20838
to
Air
Liquide
monitoring
report.
INFORMATION
REQUIREMENTS
FOR
NOAA
REVIEW
OF
GOLDEN
PASS
LNG
PROJECT,
DOCKET
NO.
PF­
04­
1­
000
General
project
details:

1.
Project
Location
a.
Associated
state,
county/
parish,
city
b.
Habitat
types
impacted
c.
Surrounding
features
(
natural,
created,
other
industry,
etc.)
d.
Alternate
sites
i.
Location
of
less­
damaging
sites
(
particularly
important
if
proposed
terminal
to
be
sited
in
a
wetland,
estuarine
pass,
or
shallow
water)
ii.
Justification
for
not
siting
terminal
in
less­
damaging
location
2.
Project
Features
a.
Type
of
terminal
structure
b.
Associated
pipelines
i.
Size
ii.
Location
iii.
Installation
procedures
iv.
Associated
wetlands
impacts
v.
Restoration/
monitoring
protocols
vi.
Wetlands
impact
mitigation
plan
vii.
Reporting
requirements
c.
Overall
project
footprint
d.
Construction
and/
or
installation
procedures
e.
Regasification
system
i.
Closed­
loop
or
other
Best
Available
Technology
(
BAT)
vs.
ii.
Open­
loop
(
1)
Justification
for
not
using
BAT
(
a)
Economic
(
i.
e.,
comparison
of
cost
associated
with
using
BAT
vs.
open­
loop;
open­
loop
cost
estimate
should
include
cost
of
additional
necessary
features
such
as
exclusion
systems,
cleaning,
monitoring,
mitigation,
fisheries
impacts,
etc.,)
(
b)
Safety
(
i.
e.,
combustion
hazard)
(
c)
Environmental
(
i.
e.,
air
emissions)
(
i)
Quantification
of
existing
air
quality
regime
in
the
project
area
(
ii)
Comparison
of
emissions
in
BAT
vs.
open­
loop
systems
(
2)
Impacts
(
see
next
section
for
greater
detail)
(
a)
Entrainment
(
b)
Impingement
(
c)
Anti­
biofouling
agents
(
d)
Thermal
discharge
(
e)
Cumulative
impacts
f.
Terminal
operation
schedule
(
i.
e.,
number
of
days
per
year
LNG
expected
to
be
regasified
at
terminal)

3.
Essential
fish
habitat
(
EFH)
a.
Description
of
EFH
to
be
impacted
b.
Description
of
life
stages
of
managed
species
to
be
impacted
c.
Proposed
measures
to
avoid
and
minimize
EFH
impact
d.
Proposed
EFH
mitigation
measures
Issues
associated
with
regasification
in
open­
loop
mode:

4.
Seawater
intakes
e.
Depth
of
intake
b.
Configuration
i.
Type
of
intake
ii.
Number
of
intakes
c.
Intake
volume
(
i.
e.,
number
of
gallons
of
seawater
utilized
per
day
and
year)
d.
Intake
velocity
i.
Maximum
allowed
velocity
ii.
Method
for
monitoring
velocity
iii.
Operational
protocol
if
intake
velocity
is
found
to
exceed
maximum
allowed
by
license
e.
Marine
life
exclusion
features
i.
Type
(
mesh
screens,
Gunderboom,
etc.)
1.
Provide
information
on
efficiency
of
exclusion
feature
(
e.
g.,
literature
review,
data
from
demonstration
projects,
etc.,)
ii.
Size
range
of
organisms
excluded
by
system
iii.
Operational
procedures
1.
Cleaning
procedures
2.
Frequency
of
cleaning
3.
Potential
effects
to
intake
velocity
as
exclusion
system
becomes
increasingly
fouled
4.
Quantify
impacts
to
organisms
that
will
be
impinged
on
screen
f.
Estimation
of
entrainment
i.
Species
present
ii.
Density
of
eggs
and
larvae
in
the
project
area
iii.
Vertical
distribution
of
organisms
iv.
Any
known
seasonality
of
organism
distribution
v.
Entrainment
mortality
1.
contact
with
structural
components
of
system
(
e.
g.,
impeller
blades)
2.
sudden
changes
in
ambient
pressure
3.
drop
in
water
temperature
4.
exposure
to
anti­
biofouling
agents
vi.
Impacts
to
managed
species
from
loss
of
food
source
(
e.
g.,
entrainment
of
zooplankton)
g.
Fisheries
stock
impact
assessment
i.
Describe
approach
and
provide
rationale
ii.
Provide
data
and
information
on
data
source
h.
Analysis
of
economic
impact
to
commercial
and
recreation
fishers
i.
Describe
approach
and
provide
rationale
ii.
Provide
data
and
information
on
data
source
5.
Seawater
discharge
a.
Depth
of
discharge
b.
Configuration
i.
Type
of
discharge
(
diffuser,
vertical,
angular,
etc.)
ii.
Number
of
discharge
points
c.
Discharge
velocity
d.
Anti­
biofouling
agents
i.
Type
of
agent
used
ii.
Concentration
of
agent
1.
In
system
2.
In
discharge
3.
Area
required
for
dilution
of
agent
4.
Potential
for
accumulation
in
the
project
area
iii.
Potential
impacts
to
organisms
exposed
to
anti­
biofouling
agent
1.
Tolerance
of
relevant
species
to
chronic
and
acute
levels
of
agent
(
in
egg,
larval,
juvenile,
and
adult
forms)
2.
Lethal
impacts
3.
Sublethal
impacts
4.
Potential
for
bioaccumulation
e.
Thermal
discharge
i.
Temperature
of
discharge
ii.
Difference
between
ambient
temperature
and
thermal
discharge
iii.
Area
required
for
dilution
of
thermal
discharge
back
to
ambient
temperature
(
given
that
)
iv.
Potential
impacts
to
organisms
exposed
to
thermal
discharge
1.
Tolerance
of
relevant
species
to
predicted
temperatures
(
in
egg,
larval,
juvenile,
and
adult
forms)
2.
Lethal
impacts
3.
Sublethal
impacts
6.
Cumulative
Impacts
(
past,
present
and
reasonably
foreseeable
future)
a.
Other
LNGs
b.
Other
industry
(
e.
g.,
petroleum,
fishing,
power
generation,
etc.)
c.
Natural
processes
i.
Environmental
conditions
ii.
Starvation
iii.
Predation
iv.
Transport
out
of
area
(
i.
e.,
currents)

7.
Monitoring
(
If
terminal
will
be
permitted
to
operate
in
open­
loop
mode,
NOAA
Fisheries
will
require
a
monitoring
plan;
it
would
be
helpful
if
license
applications/
NEPA
documents
indicated
the
applicant's
intent
to
implement
monitoring
and
indicate
the
general
components
of
the
plan)
a.
Baseline
(
pre­
project)
conditions
at
the
site
b.
Protocol
for
monitoring
impacts
of
terminal
i.
Entrainment
ii.
Impingement
iii.
Anti­
biofouling
agents
iv.
Thermal
discharge
c.
Timeline
i.
Coordination
of
monitoring
plan
with
NOAA
Fisheries
ii.
Implementation
of
monitoring
plan
prior
to
construction
and
operation
of
terminal
d.
Reporting
procedures
e.
Proposed
remedial
actions
for
marine
life
exclusion
system
failure
8.
Identify
mitigation
measures
for
impacts
and
direct
loss
to
fisheries
